Last updated: 7 January 2025
Edumetrics Zambia (“Edumetrics”, “the App”, “we”, “our”, “us”) is an education results analytics platform used by schools, teachers and authorised education officers in Zambia. This Privacy Policy explains what personal data we collect, why we collect it, how we use it, how we protect it, and your rights under applicable law including the Zambian Data Protection Act No. 3 of 2021 and, where applicable, the EU General Data Protection Regulation (GDPR).
1. Controller
Edumetrics is the data controller for personal data collected through this App. For questions or requests about personal data, you can contact us at support@edumetrics.icu.
2. Scope — Who this Policy Applies To
This policy applies to users of the Edumetrics mobile and web applications, schools and school staff who upload learner data, and any education officers who use the system. It covers personal data we collect directly and data that your school uploads on behalf of learners and parents/guardians.
3. Data We Collect
Account & user data: name, email, phone number, role (e.g. school_admin, class_teacher, deso, peso, neso), school affiliation.
Learner data (uploaded by schools): learner name, gender, date of birth (if provided), parent/guardian name, class/grade, school, assessment and exam results, subjects taken, and any analytics summaries derived from those results.
Device & technical data: app version, basic device information, crash logs and non-identifying analytics collected via Firebase or similar services to improve app stability and performance.
Sharing & communications data: phone numbers and emails that schools include for sending results via the device’s SMS, email or WhatsApp apps. (Edumetrics does not store copies of messages sent from the device.)
4. How We Use Your Data (Purposes & Lawful Bases)
We process personal data for the following purposes:
• To provide the Edumetrics service, including class/teacher access control and school-level dashboards (legal basis: contract / legitimate interest).
• To generate reports (PDFs) and share results through the device’s SMS/email/WhatsApp apps (legal basis: contract / consent when required).
• To run analytics and improve product quality (legal basis: legitimate interest / consent for analytics where required by law).
• To respond to support requests and manage accounts (legal basis: contract / legitimate interest).
• To comply with legal obligations or bona fide requests from education authorities where the school or local law requires sharing (legal basis: legal obligation).
For EU users covered by GDPR, we will rely on one or more lawful bases listed above and will inform you if we rely on consent where required.
5. Data Sharing & Third Parties
We do not sell personal data to advertisers. We share data only with:
• The school and its authorised staff (taught/assigned teachers and administrators).
• Education authorities (DESO/PESO/NESO) only where the school opts in or where required by law or policy.
• Third-party service providers that help operate the App, such as Google Firebase (Firestore & Cloud Storage) for data storage and analytics, email/SMS gateway services if used by the school, and crash/analytics providers. These providers are contractually bound to protect the data and process it only on our instructions.
We may also share aggregated, anonymised statistics that cannot reasonably be used to identify an individual for research or reporting purposes.
6. Data Transfers
Some third-party services we use (e.g., Google Cloud / Firebase) may store or process data outside of Zambia. Where transfers occur, we put in place appropriate safeguards such as standard contractual clauses or rely on providers’ compliance frameworks to ensure an adequate level of protection.
7. Data Retention
We retain personal data for as long as the school maintains an active account or as necessary to provide the service, comply with legal obligations, resolve disputes, and enforce agreements. Schools may request deletion of learner data; we will delete such data subject to any legal or regulatory retention requirements and reasonable processing time.
8. Learner Data & Children
Learner data is uploaded and managed by schools. The App is intended for school administrators and teachers to manage learners’ academic records — it is not intended for direct use by children without authorisation. Schools remain responsible for obtaining any required parental or guardian consents under applicable law before uploading children’s personal data.
9. Security
We take the security of your personal data seriously. We use Google Firebase (Firestore & Cloud Storage) and enforce TLS/HTTPS for data in transit. We implement role-based access controls, Firestore security rules, and standard operational safeguards such as least privilege, regular patching, and encrypted backups. However, no system is 100% secure; if a security incident affects your personal data we will notify affected parties and authorities as required by law.
10. Your Rights
Depending on your jurisdiction, you may have rights including:
• Access to the personal data we hold about you; • Correction of incorrect data; • Deletion of your personal data (subject to legal/contractual limits); • Restriction or objection to certain processing; • Data portability where applicable; • Withdraw consent where processing is based on consent.
To exercise rights, contact support@edumetrics.icu. We will respond within the timeframes required by applicable law.
11. Messaging (SMS / Email / WhatsApp)
When sharing results via SMS, email or WhatsApp, the App uses the device’s native apps — message content is created and sent by the device owner. Edumetrics does not store message bodies in any external service as part of normal operation.
12. School Admin Controls
Schools control what learner data they upload, which staff have access, and whether to share data with education authorities. Edumetrics provides role-based access controls so schools can limit who sees sensitive data.
13. Grievances and Supervisory Authority
If you believe your data protection rights have been violated, you may contact us at support@edumetrics.icu. You may also lodge a complaint with the Zambian Data Protection Commissioner or other relevant supervisory authority in your jurisdiction.
14. Changes to This Privacy Policy
We may update this Privacy Policy to reflect changes in our practices or legal requirements. When we make material changes, we will post the revised date at the top of the policy and, where appropriate, notify users.
15. Contact
For privacy enquiries, data access requests, or other questions, contact: support@edumetrics.icu.