1. Introduction

Hilanaw (“we”, “our”, “us”) is committed to protecting the privacy of our users. This Privacy Policy explains how we collect, use, store, and share your personal data when you use the Hilanaw platform at hilanaw.com (“Platform”).

This Policy is prepared in compliance with the Nigeria Data Protection Act 2023 (“NDPA”) and other applicable data protection regulations. By using our Platform, you consent to the practices described in this Policy.

2. Data We Collect

2.1 Information You Provide

When you register and use Hilanaw, we collect:

1. Account information: name, email address, age, and location
2. Onboarding responses: your business goals, challenges, background, and entrepreneurship intentions
3. Conversation content: all messages you send to and receive from the AI mentor
4. Voice recordings: audio captured when you use the voice input feature (transcribed and processed by OpenAI Whisper)
5. File attachments: documents and images you upload during your sessions
6. Assessment responses: ratings, scores, and answers provided during module phases

2.2 Automatically Collected Data

We automatically collect certain technical information when you use the Platform:

1. Device type, browser type, and operating system
2. IP address and approximate location
3. Usage data including pages visited, features used, and time spent
4. Session identifiers and cookies

2.3 AI-Generated Data

As you interact with Hilanaw, our system builds a learning profile that includes:

1. Psychological trait assessments derived from your conversations
2. Business context data including your industry, goals, and progress
3. Module completion records, phase outcomes, and certificates earned
4. Semantic memories extracted by AI from your conversations to personalise future interactions

3. How We Use Your Data

We use your data for the following purposes:

1. To provide and personalise the AI mentorship experience
2. To track your learning progress through the curriculum
3. To generate certificates upon module completion
4. To assess eligibility for the Business Grant Programme
5. To improve our AI models and platform features
6. To communicate with you about your account and the platform
7. To detect and prevent fraud, abuse, and security incidents
8. To comply with legal obligations

4. AI Processing and Third-Party Providers

Hilanaw uses third-party AI providers to process and respond to your messages. Your conversation data is transmitted to these providers solely for the purpose of generating AI responses:

1. OpenRouter: Routes AI model requests during the platform launch phase
2. Google Gemini: Primary AI model powering the Hilanaw mentor (Google LLC, USA)
3. OpenAI Whisper: Transcribes voice messages into text (OpenAI, Inc., USA)

These providers process your data in accordance with their own privacy policies and applicable data protection laws. Where data is transferred outside Nigeria, we take appropriate steps to ensure adequate protection is in place, including reliance on providers who comply with internationally recognised data protection standards.

Hilanaw does not permit any third-party AI provider to use your personal data for their own training purposes without your explicit consent.

5. Data Retention

We retain your personal data for as long as your account is active and as necessary to provide our services. Specifically:

Account information: retained for the duration of your account

Conversation history and AI memories: retained to provide personalised mentorship continuity

Voice recordings: processed for transcription and not retained beyond the transcription session

File attachments: retained as part of your session history

Certificates and module completion records: retained indefinitely as proof of achievement

Upon account deletion, we will delete your personal data within 30 days, except where retention is required by law or for the purpose of resolving disputes.

6. Your Rights Under the NDPA

Under the Nigeria Data Protection Act 2023, you have the following rights with respect to your personal data:

1. Right to access: request a copy of the personal data we hold about you
2. Right to rectification: request correction of inaccurate or incomplete data
3. Right to erasure: request deletion of your personal data, subject to legal exceptions
4. Right to data portability: request your data in a structured, machine-readable format
5. Right to object: object to processing of your data in certain circumstances
6. Right to withdraw consent: where processing is based on consent, withdraw it at any time

To exercise any of these rights, contact our Data Protection Officer at privacy@hilanaw.com. We will respond to your request within 30 days.

7. Children’s Privacy

Hilanaw does not knowingly collect personal data from users under the age of 16. If you are under 16, you may not use this platform. If we become aware that we have collected data from a user under 16 without appropriate consent, we will delete such data promptly.

If you believe a minor under 16 has created an account, please contact us at privacy@hilanaw.com.

8. Cookies

Hilanaw uses cookies and similar tracking technologies to operate and improve the platform. Cookies help us remember your preferences, maintain your session, and understand how users interact with our platform.

You may configure your browser to refuse cookies, but doing so may affect the functionality of certain features. By continuing to use the platform, you consent to our use of cookies as described in this Policy.

9. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include encryption of data in transit, access controls, and regular security reviews.

While we take security seriously, no method of transmission over the internet is 100% secure. You use the platform at your own risk and should take appropriate measures to protect your own credentials and device.

10. Third-Party Links

The Hilanaw platform may contain links to third-party websites or services. We are not responsible for the privacy practices of those third parties and encourage you to review their privacy policies before providing any personal data.

11. Grant Programme Data

When the Business Grant Programme launches, we may collect additional information from applicants including business documentation, proof of activities, and financial details necessary to process grant applications. Such data will be used solely for the purpose of assessing grant eligibility and administering the programme. Specific data handling terms will be provided at the time of the Grant Programme launch.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal obligations. We will notify you of material changes by posting an update on the platform or by emailing your registered address. Continued use of the platform after changes take effect constitutes acceptance of the updated Policy.

13. Contact and Data Protection Officer

For any privacy-related enquiries, data requests, or complaints, please contact our Data Protection Officer:

Email: privacy@hilanaw.com

General support: help@hilanaw.com

Website: hilanaw.com

If you are not satisfied with our response, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC).