Privacy Policy

1. Who We Are

IELTS by Mercy provides IELTS preparation and learning services through the Website and the Learning Management System.

Our services include IELTS preparation courses, structured video lessons, practice materials, mock tests, band descriptors, writing samples, vocabulary resources, instructor support, learning progress features, student account management, and related educational resources.

2. What This Policy Covers

The Website and the Learning Management System, including Student, Instructor and Admin areas.

If a third-party website or service is opened from our sites, that service has its own privacy practices and terms.

3. What Personal Information We Collect

3.1 Public website

Name and email address submitted through the contact form.
Any message, enquiry or other information you choose to include.
Phone number or other contact information if the relevant form asks for it or you voluntarily provide it.
Basic technical information such as IP address, browser type, device type and security-related information.
Information made available through embedded services such as Google Maps when the service loads.

3.2 Learning platform

Full name and email address.
Username and account credentials. Passwords are stored in a protected, non-readable form.
Phone number if provided.
Course, module and lesson enrolment information.
Progress through courses and lessons.
Messages sent to an instructor or administrator.
Parent/guardian information where it is required for a student who is a child.
IP address and login/session information used for security and account management.
Browser storage and cookie information described in the Cookie Policy.

4. Why We Use Personal Information

We use personal information only for clear and legitimate purposes connected with providing, supporting, securing and improving our services.

To respond to enquiries, questions and requests submitted through the Website.
To create, manage and maintain student accounts on the Learning Management System.
To provide students with access to the courses, lessons, resources and other learning services they have enrolled for.
To record and display course, module and lesson progress so students and authorised instructors can monitor learning.
To communicate with students about their accounts, courses, access, important service notices and support requests.
To provide instructor and administrator support and respond to messages submitted through the Learning Management System.
To protect the Website and Learning Management System against unauthorised access, fraud, misuse and security threats.
To maintain appropriate records, resolve disputes, investigate complaints and enforce our Terms of Service.
To comply with applicable legal, regulatory and lawful authority requirements.
To manage cookies and similar technologies in accordance with our Cookie Policy and your choices where consent is required.

5. Lawful Bases

Depending on the circumstances, we rely on one or more lawful bases recognised under Nigerian data-protection law: taking steps at your request or performing a contract; your consent where consent is required; our legitimate interests where those interests are balanced against your rights; and compliance with a legal obligation.

We do not treat consent as a substitute for a different lawful basis where the law requires another basis. Where consent is the lawful basis, you can withdraw it at any time.

6. Direct Marketing

We will not use your personal information for direct marketing where consent is required unless you have provided the required consent. Marketing messages will include an appropriate way to stop receiving them. Withdrawing marketing consent does not affect the processing needed to provide services or comply with the law.

7. Who We Share Information With

Where a service provider processes personal information for us, we require appropriate contractual and organisational safeguards for that processing.
Authorised instructors and administrators, where access is necessary to teach, support students, administer accounts or protect the platform.
Website and hosting providers that store or support our systems on our behalf.
Google, when Google Maps or Google Drive video streaming is used. Your browser may connect directly to Google when these services load or are used.
Professional advisers, regulators, law-enforcement bodies or courts where disclosure is required or permitted by law.
A successor organisation in a merger, restructuring or sale, subject to applicable data-protection requirements.
We do not sell or rent personal information.

8. International Transfers

Some service providers used by the sites may process information outside Nigeria. For example, course-video playback through Google Drive can cause your device to communicate with Google’s systems outside Nigeria. Where personal information is transferred internationally, we will use a transfer mechanism permitted by applicable Nigerian data-protection law, such as an adequacy decision, an appropriate contractual or other safeguard, or consent where consent is legally required. We will not rely on a generic statement that a provider is secure as a substitute for the legally required transfer safeguard.

9. Data Retention

We periodically review retained information and delete or anonymise it when there is no longer a legitimate reason to keep it, subject to legal exceptions.

10. How We Protect Information

Passwords are protected using encryption and are not stored as readable passwords.
The Learning Management System uses HTTPS for communications.
Access to student information is restricted according to staff roles and business need.
Limit access to student information according to role and business need.
Use contractual and organisational safeguards for service providers where required.
No online system can be guaranteed to be completely secure. If a personal-data breach occurs, we will assess it promptly and make notifications to the NDPC and affected individuals where required by law.

11. Your Data-Protection Rights

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Following this, you have the right to;

Ask whether we hold personal information about you and request access to it.
Ask us to correct inaccurate or incomplete information.
Ask for deletion of your information where the legal conditions for erasure are met.
Ask us to restrict certain processing where the legal conditions are met.
Object to processing in circumstances where the law gives you an objection right.
Request portability of eligible information where applicable.
Withdraw consent where processing is based on consent.
Object to direct marketing where applicable.
Ask for information about international transfers and safeguards where applicable.
Lodge a complaint with the Nigeria Data Protection Commission (NDPC).
To exercise a right, email info@ieltsbymercy.com. We may need enough information to verify your identity before releasing or changing personal information. We will respond within the period required by applicable law.

12. Children and Young Students

For students under 18, we may collect the parent or legal guardian’s name and contact details where needed to obtain or verify the required consent.

The learning service may be used by younger students. Where processing relies on consent for a child or a person who lacks legal capacity, we will obtain and verify the consent of a parent or legal guardian as required by Nigerian law. We will not knowingly use a child’s personal information for unrelated advertising or profiling.

Parents or guardians may contact us about a child’s information using the privacy contact above. If we discover that information was collected in circumstances where required consent was not obtained, we will take appropriate steps, which may include deleting the information, subject to legal requirements.

13. Automated Decisions and Profiling

We do not currently use personal information for advertising or behavioural profiling, and we do not make decisions about students solely through automated processing where those decisions have legal or similarly significant effects.

We do not currently make decisions about students solely by automated processing where the decision produces legal or similarly significant effects. Course progress is used to provide and support the learning service, not to make an automated decision about a student’s legal rights.

14. Third-Party Links and Services

Our sites may link to social media, Google Maps, Google Drive or other third-party services. Once you interact with those services, their own policies apply. We do not control their independent processing.

15. Cookies

The Cookie Policy explains the cookies and browser-storage technologies used on the two sites and how you can manage them.

16. Changes to This Policy

We may update this Policy when our services, technology, legal obligations or data practices change. Where a change is material and notice is required, we will provide an appropriate notice before or when the change takes effect. The latest version will show its effective and update dates.

17. Complaints and Regulatory Contact

If you have a privacy concern, contact us first at info@ieltsbymercy.com. You may also contact the Nigeria Data Protection Commission (NDPC), the Nigerian regulator responsible for data protection, or the relevant data-protection authority in your country where applicable.

Version 1.0 | Updated 13th August, 2026