Privacy Policy

1. Who We Are

Tenkobo is operated by Kronerland AS, a Norwegian company committed to transforming education through technology. Our registered address is Olsvikmarken 82, 5183 Olsvik, Bergen, Norway (Organization Number: 935 974 224).

While our primary user base is in Nigeria and West Africa, we operate under Norwegian and European Union data protection laws, including the General Data Protection Regulation (GDPR), which provides strong privacy protections for all our users worldwide.

2. Information We Collect

Account Information

• Email address (required for account creation)
• Username and profile information
• Educational institution details (optional)
• Academic year and course of study (optional)

Learning Data

• Study progress and flashcard interactions in Surpass
• Quiz scores and performance analytics
• CGPA calculations and academic goals in FirstClassAI
• Game scores and leaderboard positions in SurpassGames
• Price tracking preferences in PriceTracker

Technical Information

• Device type, operating system, and app version
• IP address and approximate location (country/city level)
• App usage patterns and feature interactions
• Error logs and performance data

Payment Information

• Android/iOS Apps: Payment processing handled by Google Play Store and Apple App Store respectively. We do not store your payment details.
• Web App: Payment processing handled by Stripe, with future support for PayStack and/or Flutterwave. We do not store full payment card details.
• Subscription status and transaction history

3. How We Use Your Information

• Provide Educational Services: Deliver personalized learning experiences, track study progress, and calculate academic metrics
• Improve Our Platform: Analyze usage patterns to enhance features and develop new educational tools
• Communicate with You: Send important updates about your account, new features, and educational tips
• Process Payments: Handle subscription billing and reward distributions for SurpassGames
• Ensure Security: Protect against fraud, abuse, and unauthorized access
• Comply with Laws: Meet legal obligations in Nigeria, Norway, and other applicable jurisdictions

4. Data Storage and Security

Your data is stored securely using industry-standard encryption and security practices. We use reputable cloud services with servers primarily located in Europe, ensuring GDPR compliance.

Local Data Storage: Some learning data (like flashcard progress) is stored locally on your device using secure, encrypted storage methods. This allows Tenkobo to work offline and provides faster access to your study materials.

We retain your personal data only as long as necessary to provide our services or as required by law.

5. Account Deletion

You can request deletion of your account and personal data at any time. For detailed instructions on the deletion process, including what data is removed and what may be retained for legal compliance, visit our Account Deletion page.

6. Your Rights

Under GDPR and Nigerian data protection laws, you have the following rights:

• Access: Request a copy of your personal data
• Rectification: Correct inaccurate or incomplete data
• Erasure: Request deletion of your personal data
• Portability: Export your data in a machine-readable format
• Restrict Processing: Limit how we process your data
• Object: Opt-out of certain data processing activities
• Withdraw Consent: Revoke permission for data processing where based on consent

To exercise these rights, contact us at privacy@kronerland.no.

7. Data Sharing and Third Parties

We do not sell your personal data. We may share your information with:

• Service Providers: Cloud hosting, analytics, and payment processing partners
• Payment Processors: Google Play, Apple App Store, Stripe, and potentially PayStack/Flutterwave
• Legal Authorities: When required by law or to protect our users and services

All third-party providers are contractually required to maintain appropriate data protection standards.

8. Children's Privacy

Minimum Age Requirements

• Ages 16-17: May create an account with verified parental or guardian consent
• Ages 18+: May create an account independently without parental consent
• Under 16: Not permitted to use Tenkobo services

Age Verification and Honesty

Users are required to provide accurate age information during registration. Providing false age information violates our Terms of Service and may result in account suspension or termination.

Parental Rights and Oversight

For users aged 16-17, parents and guardians have the right to:

• Review their child's account information and learning data
• Request modifications to their child's profile or privacy settings
• Request deletion of their child's account and associated data
• Receive copies of any personal information we hold about their child
• Withdraw consent for data processing at any time

Enhanced Privacy Protections

For users under 18, we implement additional privacy safeguards:

• Limited data collection - only information necessary for educational services
• No targeted advertising or marketing communications
• Enhanced security measures for account protection
• Regular review of data retention and processing practices
• Priority support for privacy-related requests

9. International Data Transfers

As a Norwegian company serving users globally, we may transfer your data internationally. We ensure appropriate safeguards are in place, including:

• European Commission adequacy decisions
• Standard Contractual Clauses (SCCs)
• Other legally recognized transfer mechanisms

10. Nigerian Users - Specific Provisions

For our users in Nigeria, we also comply with the Nigeria Data Protection Regulation (NDPR) 2019 and other applicable Nigerian laws. You have additional rights under Nigerian law, including the right to lodge complaints with the National Information Technology Development Agency (NITDA).

11. Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices or applicable laws. We will notify users of significant changes through the app or via email. Continued use of Tenkobo after such changes constitutes acceptance of the updated policy.

12. Contact Us