Privacy Policy

1. Introduction

CAOSCE NETWORK LTD (RC 9839990) ("we", "our", "us") operates the CAOSCE (Computer Aided Objective Structured Clinical Examination) and Computer-Based Test (CBT) examination platform accessible at caosce.net (the "Platform"). This Privacy Policy explains how we collect, use, store, share, and protect personal data in compliance with the Nigeria Data Protection Act (NDPA) 2023.

By using the Platform, you ("User", "Student", "Agent", "Lecturer", "School") agree to the practices described in this Policy.

2. Who We Are

• Company: CAOSCE NETWORK LTD (RC 9839990)
• Data Controller: CAOSCE NETWORK LTD (RC 9839990)
• Data Protection Officer (DPO): EBIZIMO TONBRA, Director
• DPO Contact: dpo@caosce.net
• Address: No. 69 Azikoro Road, Yenagoa, Bayelsa State

3. Personal Data We Collect

We collect only the minimum data required to conduct examinations, process payments, pay agents and pay lecturers.

a. From Students

• Full name
• Exam number / Matric number
• Student profile picture
• Live camera footage for proctoring (processed in real time, not stored)
• Payment reference for any bank transfer made to take an exam

b. From Schools / Exam Administrators

• Administrator email and password
• Name, rank, school name, department
• Profile picture (optional)
• Bank account name, bank name, and account number (for revenue payouts only)

c. From Agents

• Agent email and password
• Name, school name
• Profile picture (optional)
• Bank account name, bank name, and account number (for revenue payouts only)

d. From Lecturers (where applicable)

• Name, rank, school name, department
• Bank name, account name, and account number (for revenue sharing only)

4. What We Do NOT Collect

• We do not collect or store student bank account details.
• We do not process or store card payments, card numbers, CVVs, or card PINs.
• We do not sell personal data to third parties.

5. Lawful Basis for Processing

We process personal data based on:

• Contractual necessity — to register students, conduct exams, and issue results.
• Legal obligation — to retain payment transaction records for financial and dispute purposes.
• Legitimate interest — to prevent exam fraud through proctoring on the CBT platform.
• Consent — for optional fields such as profile picture and name.

6. How We Use Personal Data

We use collected data to:

• Register students and verify identity for the exam.
• Conduct the CAOSCE or CBT examination.
• Score results and make them available to the examining school.
• Process and verify bank transfer payments.
• Pay schools, agents and lecturers their agreed revenue share.
• Maintain transaction records for dispute resolution and regulatory compliance.
• Detect and prevent cheating during exams.

7. Student Results — Retention

Student results are made available only to the examining school that initiated the exam.

8. Lecturer, Agent and School Bank Details

Bank account details provided by schools, agents and lecturers are stored solely for the purpose of paying out revenue share. They are:

• Encrypted at rest.
• Accessible only to the CEO/DPO and authorized finance personnel.
• Never shared with students or any third party.

9. Payment Information

• We accept bank transfers only.
• We do not store student bank accounts.
• We do not receive or process card payments.
• For each student payment, we retain the following for financial and dispute purposes only: transaction reference, amount, date, and student exam number.

10. Sharing of Data

We share personal data only with:

• The examining school — to deliver results.
• VPay (our payment processor) — to reconcile bank transfer payments. VPay does not receive student card details, as we do not accept card payments.
• Law enforcement or regulatory bodies — when legally required.

We do not sell or rent personal data.

11. Data Security

We implement the following safeguards:

• Encrypted connections (HTTPS) across the Platform.
• Password-protected access for all administrators.
• Role-based access control.
• Regular backups.
• Monitoring for suspicious activity and exam fraud.

12. Your Rights Under NDPA

You have the right to:

• Access the personal data we hold about you.
• Correct inaccurate data.
• Request deletion (subject to our legal retention obligations for transaction records).
• Object to certain processing activities.
• Lodge a complaint with the Nigeria Data Protection Commission (NDPC).

To exercise any of these rights, contact dpo@caosce.net.

13. Data Breach Notification

If a data breach occurs that affects your personal data, we will notify the NDPC within 72 hours and affected Users without undue delay.

14. Changes to This Policy

We may update this Policy from time to time. Changes will be posted on this page with an updated "Last updated" date.

15. Contact Us