Privacy Policy

1. Introduction

SUNOSPEAK TECHNOLOGIES LIMITED, trading as Hollen (“Hollen”, “we”, “our” or “us”), respects your privacy and is committed to protecting it. This Privacy Policy (“Policy”) describes how we collect, use, share, store and protect your personal information when you use the Hollen mobile applications (the “Apps”), our website at hollen.app (the “Website”), and any related services (together, the “Services”).

Please read this Policy together with our Terms of Service. By using the Services, you acknowledge that you have read and understood this Policy.

2. Who we are

SUNOSPEAK TECHNOLOGIES LIMITED is a company registered in Nigeria and is the data controller of the personal information described in this Policy. This means we decide how and why your personal information is processed. Our contact details are set out in Section 16.

3. Information we collect

3.1 Information you provide to us. When you use the Services, you provide:

• Account information: your name and email address.
• Study profile: your country, institution, app language, study days, reminder time and time zone.
• Study content: the courses you create; the files you upload, including documents, slides, photos, audio and video; the text we extract from those files; your messages to Tutor and its responses; and the quizzes, flashcards and mock exams you create, together with your answers and scores (“Study Content”).
• Communications: messages you send to us, and any reason you give when you delete your account.

3.2 Information collected automatically. When you use the Services, we automatically collect:

• Usage information: your study activity, progress and streaks.
• Device information: a push notification token for your device, and the IP address, device type and browser details associated with each signed-in session.

3.3 Information from third parties. If you sign in with Google, we receive your name, email address and profile photo from Google. Our payment providers tell us whether your payments succeeded and the status of your subscription. We do not receive or store your full card or bank account details.

3.4 Sensitive information. The Services are not designed to process sensitive personal information, such as health, financial or biometric data. Please do not upload such information unless it is necessary for your studies.

4. How we use your information

We use your personal information to:

1. create and maintain your account and sign you in;
2. provide the Services, including reading your materials, answering your questions and generating study and practice content;
3. process payments and manage your subscription;
4. send you sign-in codes, receipts and messages about your account and the Services;
5. send you study reminders and push notifications, where you have enabled them;
6. respond to your requests and provide support;
7. keep the Services secure, and prevent fraud, abuse and repeated sign-ups after account deletion;
8. understand how the Services are used, using aggregated information, so that we can improve them; and
9. comply with our legal obligations and enforce our terms.

We do not sell your personal information, and we do not use it for advertising.

5. Legal bases for processing

Under the Nigeria Data Protection Act 2023 (the “NDPA”), we rely on the following legal bases:

1. Contract: to provide the Services you have asked for, including your account, study features and paid plans (purposes 1 to 4 and 6 in Section 4).
2. Consent: to send study reminders and push notifications (purpose 5). You may withdraw your consent at any time in the App or your device settings.
3. Legitimate interests: to keep the Services secure, prevent abuse and improve the Services (purposes 7 and 8), where these interests are not overridden by your rights.
4. Legal obligation: to keep payment and tax records and respond to lawful requests (purpose 9).

6. Artificial intelligence

6.1 The Services use artificial intelligence models to generate Tutor responses, summaries and practice content. To do this, relevant parts of your Study Content are sent to the AI and document processing providers described in Section 7.

6.2 We do not use your Study Content to train AI models. Our providers may retain inputs for a limited period to operate their services and detect abuse, in accordance with their own terms.

6.3 Our staff do not access your Study Content unless you ask us to, for example in a support request, or where this is necessary for security or legal reasons.

6.4 We do not make decisions about you based solely on automated processing that produce legal or similarly significant effects.

7. How we share your information

7.1 Service providers. We share personal information with service providers that process it on our behalf and only in accordance with our instructions. These include:

• Google: Google sign-in, and reading text from documents through Document AI;
• Reducto: reading text and layout from documents;
• DeepInfra: running the AI models behind Tutor, practice content and search;
• Portabyte: storing your uploaded files;
• Google Firebase: delivering push notifications; and
• our email delivery and hosting providers, which send account emails and run our servers and databases.

7.2 Payment providers. Payments are processed by Bachs and Paystack, which collect and process your payment details under their own privacy policies.

7.3 Legal requirements. We may disclose personal information where required by law, court order or a lawful request from a public authority, or where necessary to protect the rights, property or safety of Hollen, our users or others.

7.4 Business transfers. If we are involved in a merger, acquisition or sale of all or part of our business, personal information may be transferred as part of that transaction. This Policy will continue to apply to your information.

8. International transfers

Some of our service providers process personal information outside Nigeria, including in the United States. Where we transfer personal information outside Nigeria, we do so in accordance with the NDPA, relying on contractual safeguards with our providers or on the transfer being necessary to provide the Services you have requested. You may contact us for more information about these safeguards.

9. Data retention

We keep personal information only for as long as necessary for the purposes described in this Policy:

• account information, study profile and Study Content are kept until you delete them or your account;
• signed-in sessions are kept for up to one year, or until you sign out;
• push notification tokens are kept until you sign out or the token is replaced;
• payment records are kept for as long as tax and accounting laws require; and
• after you delete your account, we keep a one-way hash of your email address, the reason you gave for leaving, and the dates you joined and left, to prevent abuse and repeated sign-ups. A one-way hash cannot be converted back into your email address.

10. Account deletion

10.1 In the App. You may delete your account at any time by going to Profile, then Delete account, in the App.

10.2 By email. If you cannot access the App, you may request deletion by emailing [email protected] from the email address associated with your account. We will verify and complete your request within 30 days.

10.3 Effect of deletion. Deleting your account permanently deletes your account information, study profile and Study Content, and stops future renewals of any paid plan. Deletion cannot be undone. We keep only the information described in the last two points of Section 9.

11. Your rights

11.1 Subject to the NDPA, you have the right to:

1. be informed about how we process your personal information;
2. access a copy of your personal information;
3. have inaccurate or incomplete information corrected;
4. have your personal information deleted;
5. restrict or object to our processing;
6. receive your personal information in a portable format;
7. withdraw your consent at any time, without affecting processing that took place before you withdrew it; and
8. not be subject to decisions based solely on automated processing.

11.2 To exercise these rights, email [email protected] from the email address associated with your account. We may need to verify your identity and will respond within 30 days.

11.3 If you are not satisfied with how we have handled your personal information, you have the right to lodge a complaint with the Nigeria Data Protection Commission.

12. Age requirements

The Services are intended for users aged 16 and over. Users under 18 may only use the Services with the consent of a parent or guardian. We do not knowingly collect personal information from anyone under 16. If we learn that we have done so, or that a user under 18 does not have the required consent, we will delete the account. Parents and guardians may contact us at [email protected].

13. Security

We use appropriate technical and organisational measures to protect your personal information, including encryption in transit, encrypted storage of third-party sign-in tokens, limits on repeated sign-in attempts and access controls. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If a personal data breach is likely to result in a high risk to your rights, we will notify you and the Nigeria Data Protection Commission as required by law.

14. Cookies and similar technologies

The App stores a sign-in token on your device to keep you signed in. The Website does not use advertising or analytics cookies, and we do not allow third parties to track you on the Website.

15. Changes to this Policy

We may update this Policy from time to time. When we do, we will change the “Updated” date at the top of this page. If we make material changes, we will notify you in the App or by email before they take effect.

16. Contact us

If you have any questions about this Policy or our privacy practices, please contact us at: