Privacy Policy

1. Introduction

Telvorn ("we," "our," or "us") is committed to protecting your privacy. This Policy explains how we collect, use, disclose, and safeguard personal data in compliance with the Nigeria Data Protection Act, 2023 (NDPA) and applicable law.

Telvorn is a clinical case-based learning platform built for pharmacotherapeutics education in Nigerian universities, supporting an AI-assisted case simulation and reasoning-portrait system (Ekere). This Policy applies to everyone who uses Telvorn, including students, tutors, and course administrators.

2. Data We Collect

• Account information: name, email address, role (student, tutor, or admin), and small-group assignment.
• Case work: your responses to simulated cases, questions you ask the AI case agent, structured management-plan decisions, drug-therapy-problem classifications, written justifications, confidence ratings, and reflections submitted after your tutor releases correct answers.
• Group work: consensus statements and disagreement notes your small group submits, visible to your group and your tutor.
• Reasoning-portrait data: an AI-generated reading of your case responses used to produce a formative reasoning profile (Ekere), visible to you and your course tutor.
• Usage data: device information, IP address, and access logs, for security and diagnostic purposes.

3. How We Use Your Data

• To operate the Services and generate responses from the AI case agent and Ekere's reasoning portrait.
• To support the individual attempt, small-group comparison, and cohort debrief phases of the course, and to build an anonymised, aggregated briefing for your tutor.
• To maintain platform security and prevent misuse.
• To respond to your enquiries and provide support.

We do not use your case responses to train a shared or public AI model. If this changes in future — for example, for de-identified aggregate research — we will seek your fresh, explicit, opt-in consent before doing so, separate from this Policy.

4. Legal Basis for Processing

We process your data on the basis of your consent when you register for the platform, and as necessary to deliver the course activity you have been enrolled in. Where required, we process data to comply with legal obligations.

5. Third-Party AI Processing

Telvorn's case agent and reasoning portrait (Ekere) are powered by third-party AI service providers. When you interact with a case or submit an attempt, relevant text is sent to these providers to generate a response or analysis. We work with providers under terms consistent with the protections described in this Policy.

6. Sharing and Disclosure

We do not sell your data. We may share it with:

• Third-party AI and infrastructure providers that host the platform and power the case agent and reasoning portrait.
• Your assigned small group, who can see your individual case answers during the group-comparison phase, and your group's consensus submission.
• Your course tutor and course administrators, who can see your individual reasoning profile, attempt history, and cohort-level aggregated patterns.
• Regulatory authorities, where required by law.

7. Data Security

We apply access controls, encrypted storage, and authenticated access to protect your data, and review our security practices on an ongoing basis.

8. Data Breach Notification

If we become aware of a personal data breach likely to result in a risk to your rights, we will assess the risk and, where required, notify the Nigeria Data Protection Commission (NDPC) within seventy-two (72) hours of becoming aware, and notify affected individuals directly where the breach is likely to result in a high risk to their rights.

9. International Data Transfers

Some of our infrastructure and AI providers may process data outside Nigeria. Where this occurs, we rely on contractual safeguards or your consent, consistent with the NDPA. You may request details of the specific safeguard relied on for a given transfer.

10. Your Rights

Under the NDPA, you have the right to:

• Access the personal data we hold about you.
• Correct inaccurate or incomplete data.
• Withdraw consent at any time.
• Request deletion of your data, by contacting your course tutor or the platform administrator, who can process this on your behalf.
• Object to how your data is used.
• Lodge a complaint with us, or with the Nigeria Data Protection Commission (NDPC) if you are not satisfied with our response.

To exercise any of these rights, contact us using the details in Section 13. We may need to verify your identity before acting on a request.

11. Data Retention

We retain your data for as long as your account is active, or as needed to support the course. If your account is removed, we delete your associated data, except where we are required to retain limited records by law.

12. Children

Telvorn is intended for enrolled pharmacy students and is not directed at children. We do not knowingly collect data from anyone under 18.

13. Contact Us

For questions about this Policy or to exercise your rights, contact us at enquiries@telvorn.com. You may also lodge a complaint directly with the Nigeria Data Protection Commission (NDPC).

14. Changes to This Policy

We may update this Policy periodically. Material changes will be indicated by an updated "Last updated" date. Continued use of Telvorn after changes take effect constitutes acceptance of the revised Policy.