The website www.cloudtopg.com is provided by Cloud Top G (“Cloud Top G,” “we,” “our,” or “us”).
At Cloud Top G, we value your privacy and are committed to protecting your personal data. All personal information you share with us will be safeguarded and kept confidential within Cloud Top G, its affiliates, representatives, and authorized partners.
This Privacy Policy explains how we collect, use, share, and protect your personal data in connection with your relationship with Cloud Top G as a learner, applicant, potential learner, partner, or any other person whose information we may process. It also outlines your rights and who you may contact for further information.
By visiting our website, applying to our programs, using our services, or registering for a course, you agree to this Privacy Policy. Your use of our services, and any dispute regarding privacy, is subject to this Policy and our Terms and Conditions, which are incorporated by reference.
Our website and services are not directed to, and may not be used by, any person in a jurisdiction where providing or accessing such services would be contrary to local law or regulation.
For the purposes of this Privacy Policy, unless the context otherwise requires:
(a) “Consent” – means the freely given, specific, informed, and unambiguous indication of a data subject’s wishes by which they, through a statement or clear affirmative action, signify their agreement to the processing of their personal data.
(b) “Data Controller” – means the natural or legal person or organization which, alone or jointly with others, determines the purposes and means of processing personal data. For the purposes of this Policy, Cloud Top G is the Data Controller of all personal data relating to data subjects.
(c) “Data Processor” – means any person or organization which processes personal data on behalf of a Data Controller. This includes Cloud Top G employees, affiliates, and authorized third-party service providers.
(d) “Data Protection Legislation” – means all applicable data protection and privacy laws, including but not limited to the Nigerian Data Protection Act 2023, the Nigeria Data Protection Regulation 2019 (NDPR), the General Data Protection Regulation 2018 (GDPR), and any successor legislation.
(e) “Data Protection Officer (DPO)” – means the officer appointed by Cloud Top G who is responsible for ensuring compliance with all Data Protection Legislation.
(f) “Data Subject” – means a living, identified, or identifiable individual whose personal data is collected or processed by Cloud Top G.
(g) “Personal Data” – means any information relating to a Data Subject who can be identified, directly or indirectly, by reference to an identifier such as a name, identification number, location data, online identifier, or one or more factors specific to their identity.
(h) “Personal Data Breach” – means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed.
(i) “Processing” – means any operation performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation, retrieval, consultation, use, disclosure, dissemination, alignment, restriction, erasure, or destruction.
(j) “Learner/Applicant” – means any individual who has applied for admission to a program offered by Cloud Top G, or who has been successfully enrolled as a participant in Cloud Top G’s educational services. This includes prospective learners, admitted learners, and active participants.
(k) “Learning Ecosystem” – means the full range of Cloud Top G’s digital and physical platforms, including but not limited to the official website, dashboards, Slack community, learning portals, and any other platform introduced by Cloud Top G for program delivery.
3.1. The designated Data Protection Officer (DPO) for Cloud Top G can be contacted at datacompliance@cloudtopg.com. The DPO is responsible for administering this Privacy Policy, ensuring Cloud Top G’s compliance with all applicable Data Protection Legislation, and working with relevant departments to implement appropriate procedures, controls, and safeguards.
3.2. This Privacy Policy applies to all employees, contractors, affiliates, agents, and third-party service providers who process personal data on behalf of Cloud Top G. All such parties are required to comply with this Policy and must implement practices that ensure the secure and lawful handling of personal data.
3.3. Any questions, requests, or concerns relating to this Policy or Cloud Top G’s collection, processing, or use of personal data should be directed to the Data Protection Officer.
4.1. By accessing the Cloud Top G website, registering for a program, submitting an application, or using any part of the Learning Ecosystem, you provide your consent for Cloud Top G to collect, process, and use your personal data in accordance with this Privacy Policy and applicable Data Protection Legislation.
4.2. Learners have the right to withdraw their consent at any time. Such withdrawal shall not affect the lawfulness of data processing carried out prior to the withdrawal of consent.
4.3. Where Cloud Top G intends to process personal data for a new or different purpose that is incompatible with the purpose for which the data was originally collected, Cloud Top G will obtain your consent before such processing occurs.
4.4. Consent may be given explicitly (such as signing up or ticking an acceptance box) or implied through affirmative actions such as submitting an application, continuing to use the Learning Ecosystem, or engaging with Cloud Top G services.
5.1. Cloud Top G programs and services are designed primarily for individuals who are 18 years of age or older at the time of registration.
5.2. Individuals under the age of 18 may only apply and participate where a parent or legal guardian provides verifiable consent and assumes responsibility for the Learner’s enrollment and participation.
5.3. By creating a Learner Account or applying to Cloud Top G, you affirm that you are either:
a. 18 years or older and have the legal capacity to contract in your own name, or
b. Under 18 but have obtained the express consent of a parent or legal guardian to contract on your behalf.
5.4. Cloud Top G reserves the right to request proof of age or guardian consent at any stage of the enrollment process. If it is discovered that a Learner has misrepresented their age or provided false consent documentation, Cloud Top G may immediately terminate the Learner Account and remove any associated data from its records.
Cloud Top G is committed to processing all personal data in accordance with applicable Data Protection Legislation, including the Nigerian Data Protection Act (NDPA), the Nigeria Data Protection Regulation (NDPR), and where applicable, the General Data Protection Regulation (GDPR).
In handling personal data, Cloud Top G, its employees, contractors, affiliates, and authorized third-party service providers shall comply with the following principles:
6.1. Lawfulness, Fairness, and Transparency – Personal data shall be processed lawfully, fairly, and in a transparent manner in relation to the Data Subject.
6.2. Purpose Limitation – Personal data shall only be collected for specific, explicit, and legitimate purposes, and shall not be further processed in a way that is incompatible with those purposes.
6.3. Data Minimization – Personal data collected shall be adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.
6.4. Accuracy – Personal data shall be kept accurate and up to date. Reasonable steps will be taken to correct or erase inaccurate data without delay.
6.5. Storage Limitation – Personal data shall not be kept for longer than is necessary for the purposes for which it is processed, except where required for legal, research, or historical purposes with appropriate safeguards.
6.6. Integrity and Confidentiality – Personal data shall be processed in a manner that ensures appropriate security and confidentiality, including protection against unauthorized or unlawful processing, accidental loss, destruction, or damage, using technical and organizational measures.
7.1. Personal Data Provided by You – At the point of registration or during program participation, we may collect:
(a) Full legal name;
(b) Email address;
(c) Phone number;
(d) Date of birth;
(e) Passwords and other account login credentials;
(f) Financial and billing information necessary for payment processing of tuition and related fees.
7.2. Educational and Professional Data – While not required at the moment, Cloud Top G may, in the future, request academic or professional information such as educational history, CV/resume details, or employment status.
7.3. Participation Data – We collect data relating to your participation and progress in the program, including but not limited to class attendance, assignment submissions, assessments, and project completions.
7.4. Technical Data Collected Automatically – Whenever you access the Learning Ecosystem, certain non-personal technical data is automatically collected, such as:
(a) Internet Protocol (IP) address;
(b) Browser type and version;
(c) Device type and operating system;
(d) Geographical location;
(e) Website usage statistics (pages visited, time spent, search queries, etc.).
7.5. Restrictions on Changes – Certain key details provided during registration — including your full legal name, date of birth, and email address — are treated as permanent identifiers and cannot be changed except with valid documentation.
Cloud Top G collects and processes personal data only for legitimate educational, administrative, and operational purposes in line with applicable Data Protection Legislation. Your information may be used and disclosed for the following purposes:
8.1. Core Educational Purposes
(a) To verify your identity during application, registration, and participation;
(b) To deliver course content, assignments, and assessments;
(c) To manage Learner Accounts within the Learning Ecosystem;
(d) To track attendance, monitor academic progress, and record performance outcomes.
8.2. Administrative Purposes
(a) To process applications, payments, and billing transactions;
(b) To communicate important updates, program announcements, and deadlines;
(c) To provide customer support and respond to inquiries.
8.3. Improvement and Analytics
(a) To monitor and analyze usage of the Learning Ecosystem;
(b) To enhance service delivery, platform features, and learner experience;
(c) To conduct internal research, reporting, and statistical analysis.
8.4. Marketing and Communication
(a) To send program-related recommendations, upcoming opportunities, newsletters, or promotional offers, unless you have opted out of such communications;
(b) To keep you informed of new features, services, or learning pathways offered by Cloud Top G.
8.5. Fraud Prevention and Compliance
(a) To detect, investigate, and prevent fraudulent or unauthorized activities within the Learning Ecosystem;
(b) To comply with applicable legal, statutory, and regulatory obligations.
Cloud Top G does not sell, rent, or trade personal data. However, in the course of delivering our programs and services, we may share your personal data with trusted third parties under the following circumstances:
9.1. Service Providers
We may share data with vendors, contractors, or agents working on our behalf to deliver essential services, including IT support, cloud hosting, communication tools, and other learning management platforms. Such third parties process personal data only as necessary and in compliance with this Policy.
9.2. Payment Processing
When you provide payment information for tuition or other fees, we may share necessary details with banks, payment processors, and financial institutions for processing transactions, preventing fraud, and verifying payments.
9.3. Affiliates
We may enable access to personal data across our subsidiaries, affiliates, or related companies where such access is required to provide services, operate our business, or improve the Learning Ecosystem.
9.4. Partners
With your consent, we may share limited personal data with partner organizations (such as career networks, event hosts, or internship collaborators) to provide additional learning and professional opportunities.
9.5. Corporate Transactions
In the event of a merger, acquisition, restructuring, or sale of assets, your personal data may be transferred as part of the transaction, provided appropriate safeguards remain in place.
9.6. Legal and Regulatory Compliance
We may disclose personal data where required to comply with laws, court orders, or regulatory directives, including lawful requests from law enforcement agencies.
9.7. Security and Safety
We may disclose personal data where necessary to:
9.8. Third-Party Responsibility
Any third party with whom we share personal data operates under their own privacy policies. Cloud Top G shall not be responsible for their independent data protection practices once data has been lawfully shared.
10.1. Learners are responsible for ensuring that all personal data provided to Cloud Top G is true, complete, and up to date at the time of submission. Learners must promptly notify Cloud Top G of any changes to their personal details, such as contact information.
10.2. Cloud Top G will take reasonable steps to verify the accuracy of personal data in its possession and to ensure that learner records remain current and reliable.
10.3. The provision of false, misleading, or outdated information constitutes a material breach of this Privacy Policy and may result in the suspension or termination of the Learner’s Account and access to the Learning Ecosystem.
10.4. Learners have the right to request corrections or updates to their personal data where they believe the information held by Cloud Top G is inaccurate or incomplete. Such requests will be processed in line with applicable Data Protection Legislation.
11.1. Cloud Top G will retain personal data for the duration of a learner’s engagement with the Learning Ecosystem and for a reasonable period following the completion or withdrawal from a program. This ensures continuity of service, compliance with legal obligations, and the ability to provide alumni-related support.
11.2. Academic Records — Cloud Top G retains academic records, including participation data, attendance, assignments, assessments, and certifications, on a permanent basis as part of the official learner history maintained by the institution.
11.3. Financial and Transactional Data — All financial and payment-related records will be retained for a minimum period required by applicable accounting, audit, and tax laws (typically five to seven years), after which they may be securely archived or deleted.
11.4. Right to Deletion — Learners may request the deletion of their personal data after completing or withdrawing from the program. Such requests will be honored, except where retention is required by law, regulatory obligations, or for the protection of Cloud Top G’s legitimate interests.
11.5. Cloud Top G does not retain personal data longer than necessary, except where such retention is required for legal, research, or historical purposes with appropriate safeguards.
In addition to the personal data described in Section 7, Cloud Top G may also collect other categories of information in the course of delivering services and maintaining the Learning Ecosystem:
12.1. Website and Platform Usage Data – Information about your interactions with our website and portals, including IP address, browsing activity, click patterns, referral sources, time spent on pages, and engagement with platform features.
12.2. Device and Technical Data – Information relating to the device and technology you use to access our services, including device type, operating system, browser type, application version, and network provider.
12.3. Location Data – General geolocation information such as the country, city, or region from which you access our services. This may be used for analytics, fraud prevention, and improving program delivery.
12.4. Communications Data – Records of communications between you and Cloud Top G, including but not limited to email exchanges, Slack messages, WhatsApp support interactions, or helpdesk tickets, for purposes of accountability, service improvement, and learner support.
12.5. Research and Feedback Data – Information you provide voluntarily through surveys, feedback forms, research participation, or program evaluations.
12.6. Cookies and Tracking Tools – Data collected through cookies, tracking pixels, and analytics tools to monitor engagement and improve user experience, as further described in Section 19 of this Policy.
13.1. Cloud Top G treats all personal data as strictly confidential and processes it only in accordance with applicable Data Protection Legislation.
13.2. Access to personal data is restricted to authorized employees, contractors, affiliates, and service providers who require such access to perform their official duties. All such individuals and entities are bound by confidentiality obligations.
13.3. Cloud Top G may disclose personal data in limited circumstances, including where:
(a) Required to comply with applicable laws, court orders, or regulatory directives;
(b) Necessary to protect the rights, property, or safety of Cloud Top G, its learners, or the public;
(c) Necessary to address emergencies or enforce Cloud Top G’s policies.
13.4. Learners are also responsible for maintaining the confidentiality of their personal data by ensuring that their account credentials (username, password, and access codes) are secure and not shared with third parties. Cloud Top G shall not be liable for any unauthorized access arising from a Learner’s failure to safeguard their login details.
14.1. Cloud Top G may disclose personal data where required to comply with applicable laws, regulatory directives, or lawful requests from law enforcement agencies, courts, or government authorities.
14.2. We may disclose personal data where necessary to protect the rights, property, or safety of Cloud Top G, its learners, employees, contractors, partners, or the general public.
14.3. Personal data may be shared with contractors, affiliates, vendors, and service providers who require such information to deliver services on behalf of Cloud Top G, provided such parties are bound by confidentiality and data protection obligations.
14.4. In cases of emergency, Cloud Top G may disclose personal data if urgent action is required to protect life, health, or the security of any person.
14.5. With the Learner’s explicit consent, Cloud Top G may disclose personal data to third parties such as partner organizations, internship providers, or event collaborators in order to facilitate additional opportunities and services.
15.1. Cloud Top G may transfer personal data outside the Federal Republic of Nigeria where such transfer is necessary for the operation of its Learning Ecosystem, including but not limited to the use of secure third-party platforms such as cloud hosting providers, communication tools, and learning management systems.
15.2. Where personal data is transferred internationally, Cloud Top G shall ensure that appropriate contractual safeguards are in place to protect such data in accordance with applicable Data Protection Legislation.
15.3. This Privacy Policy shall serve as advance notice to all Learners that international transfers of data may occur in the course of delivering Cloud Top G’s programs and services.
15.4. All cross-border data transfers will be conducted in compliance with the Nigerian Data Protection Act (NDPA), Nigeria Data Protection Regulation (NDPR), and, where applicable, the General Data Protection Regulation (GDPR) or equivalent legislation.
As a Data Subject, you have specific rights under applicable Data Protection Legislation regarding the personal data Cloud Top G collects and processes about you. These rights include:
16.1. Right of Access – You may request access to the personal data Cloud Top G holds about you, including information about how and why it is being processed.
16.2. Right to Correction (Rectification) – You may request that Cloud Top G correct or update any personal data that is inaccurate, incomplete, or outdated.
16.3. Right to Erasure (“Right to be Forgotten”) – You may request the deletion of your personal data, except where Cloud Top G is legally required to retain it (e.g., financial records, permanent academic records) or where retention is necessary to protect Cloud Top G’s legitimate interests.
16.4. Right to Restrict Processing – You may request that Cloud Top G temporarily suspend or restrict the processing of your personal data, for example, while a complaint or correction request is under review.
16.5. Right to Data Portability – You may request a copy of your personal data in a structured, commonly used, and machine-readable format and may also request that Cloud Top G transfer such data to another controller where technically feasible.
16.6. Right to Object – You may object to the processing of your personal data for specific purposes, including direct marketing, and Cloud Top G will respect your objection unless there are overriding legitimate grounds to continue processing.
16.7. Exercising Your Rights – To exercise any of these rights, you must submit a written request to the Data Protection Officer (datacompliance@cloudtopg.com). Cloud Top G may request reasonable verification of your identity before fulfilling such requests.
17. Website Security
17.1. Cloud Top G implements appropriate technical and organizational measures to protect personal data from unauthorized access, misuse, alteration, or destruction. These measures include but are not limited to:
(a) Secure Socket Layer (SSL) encryption;
(b) Firewalls and intrusion detection systems;
(c) Secure servers and restricted access protocols;
(d) Password protection and access controls; and
(e) Regular system monitoring, testing, and updates.
17.2. Where Cloud Top G engages trusted third-party service providers (including cloud hosting platforms, communication tools, and learning management systems), such providers are responsible for maintaining security on their own platforms. Cloud Top G ensures that appropriate contractual safeguards are in place with these providers.
17.3. Learners are responsible for safeguarding their account credentials, regularly updating their passwords, and ensuring that unauthorized individuals do not gain access to their accounts.
17.4. While Cloud Top G applies industry best practices to protect personal data, no method of transmission over the internet or electronic storage is completely secure. Accordingly, Cloud Top G cannot guarantee absolute security of personal data, but commits to taking all reasonable steps to mitigate risks.
18.1. Cloud Top G requires that all personnel who are privileged to access personal data undergo mandatory training on data protection and privacy obligations as part of their onboarding process. Additional training will be provided where material updates to data protection laws or Cloud Top G policies occur.
18.2. Cloud Top G also requires its third-party vendors, contractors, and service providers who process personal data on its behalf to demonstrate compliance with applicable data protection obligations.
18.3. Compliance with these training requirements and privacy obligations shall be periodically reviewed and monitored by Cloud Top G to ensure ongoing adherence to industry standards and applicable Data Protection Legislation.
19.1. The Cloud Top G website and Learning Ecosystem use cookies and similar tracking technologies to improve functionality, enhance user experience, and ensure the security of our services.
19.2. Cookies may be used for purposes including but not limited to:
(a) Facilitating login and authentication processes;
(b) Remembering user preferences and settings;
(c) Monitoring website performance and analytics;
(d) Preventing fraud and enhancing platform security.
19.3. Cloud Top G may also engage third-party analytics providers (such as Google Analytics or similar services) who may set cookies on our behalf to help analyze usage patterns and improve service delivery.
19.4. Learners may choose to disable or restrict cookies through their browser settings; however, doing so may affect the functionality of certain features within the Learning Ecosystem.
19.5. By continuing to use the Cloud Top G website or platform, you consent to the use of cookies in accordance with this Privacy Policy.
20.1. Cloud Top G retains certain categories of personal and non-personal data for defined periods in order to meet educational, administrative, and legal obligations.
20.2. Core Personal Data – Basic learner information such as full name, email address, phone number, and date of birth may be retained following completion or withdrawal from a program for administrative, alumni, or verification purposes.
20.3. Academic Data – Records of academic participation, including assignments, assessments, attendance, grades, certifications, and overall participation history, are retained on a permanent basis as part of the official learner history maintained by Cloud Top G.
20.4. Financial and Transaction Data – All payment and transaction records are retained for the legally required minimum period (typically five to seven years) in compliance with accounting and tax regulations, after which they may be securely archived or deleted.
20.5. Technical and Analytics Data – Information such as IP addresses, device details, and analytics logs may be retained for a limited period and will either be anonymized or securely deleted once no longer required for monitoring, security, or performance analysis.
20.6. Legal and Compliance Data – Cloud Top G may retain certain data for as long as necessary to comply with applicable laws, resolve disputes, enforce agreements, or protect its legitimate interests.
20.7. Cloud Top G will not retain personal data longer than is necessary for the purposes for which it was collected. Where possible, data will be anonymized rather than deleted to preserve its value for research and analytical purposes without compromising individual privacy.
21.1. In the event of a personal data breach, Cloud Top G shall promptly investigate the incident, contain its impact, and implement corrective measures to prevent recurrence.
21.2. Affected Learners will be notified without undue delay, and in any case within seventy-two (72) hours of Cloud Top G becoming aware of the breach, where the breach is likely to result in a risk to their rights and freedoms.
21.3. Where required by applicable law, Cloud Top G shall also notify the Nigerian Data Protection Commission (NDPC) or any other relevant regulatory authority in accordance with the Nigerian Data Protection Act (NDPA), the Nigeria Data Protection Regulation (NDPR), or any successor legislation.
21.4. Learners affected by a breach will be provided with appropriate guidance and recommended mitigation steps, which may include updating login credentials, monitoring financial accounts, or taking additional protective actions.
21.5. While Cloud Top G applies industry best practices and technical safeguards to protect personal data, no system is entirely immune to cyber threats. Accordingly, Cloud Top G cannot guarantee absolute security and shall not be held liable for breaches that occur despite the application of reasonable and appropriate protective measures.
22.1. The Cloud Top G website and Learning Ecosystem may contain links to third-party websites, platforms, or services — including but not limited to Slack, payment processors, cloud service providers, and other educational tools — that are not operated or controlled by Cloud Top G.
22.2. Cloud Top G is not responsible for the privacy practices, security standards, or content of such third-party websites or embedded tools. Your use of these services is subject to the separate privacy policies and terms provided by the respective third parties.
22.3. Learners are encouraged to review the privacy policies of all third-party websites and services before providing personal data to them, as Cloud Top G cannot guarantee how such third parties will process, store, or use that data.
22.4. This provision applies to all external links as well as any embedded third-party tools or integrations accessed through the Cloud Top G Learning Ecosystem.
23.1. To the fullest extent permitted by law, Cloud Top G shall not be liable for any indirect, incidental, special, or consequential damages, including but not limited to loss of income, business opportunities, reputation, goodwill, or data, arising from or in connection with the collection, use, disclosure, or storage of personal data.
23.2. Cloud Top G shall only be liable for damages resulting directly from its own gross negligence or willful misconduct. In such cases, Cloud Top G’s total liability shall in all circumstances be limited to the aggregate amount of Program Fees paid by the affected Learner.
23.3. Cloud Top G disclaims liability for failures, breaches, or losses caused by third-party service providers (including but not limited to cloud hosting providers, payment processors, communication platforms, or other external tools) that are beyond its reasonable control.
23.4. Learners acknowledge and agree that they are responsible for maintaining the security of their devices, internet access, and account credentials. Cloud Top G shall not be liable for any unauthorized access or loss of data resulting from the Learner’s negligence or failure to implement reasonable safeguards.
24.1. Cloud Top G reserves the right, at its sole discretion, to revise, amend, or replace this Privacy Policy at any time.
24.2. All updates to this Policy shall be communicated solely by publication on the official Cloud Top G website, and such publication shall constitute sufficient notice to all Learners.
24.3. The revised Policy shall become effective immediately upon publication on the website.
24.4. Learners are responsible for periodically reviewing this Privacy Policy to remain informed of the most current version. Continued use of the Learning Ecosystem following the publication of updates shall constitute acknowledgment of the changes and agreement to be bound by the updated Policy.
25.1. If you have any questions, concerns, or requests regarding this Privacy Policy or Cloud Top G’s data protection practices, you may contact us at our dedicated compliance email:
25.2. All privacy-related inquiries must be directed to the above email address. Cloud Top G does not process such requests through phone, physical mail, or informal communication channels.
Cloud Top G
09079778199
hello@cloudtopg.com
