AHERIAHERI
NDPA 2023 Compliant

AHERI Hub Privacy Policy

How AHERI Hub keeps what you share private, secure, and safe. We put your confidentiality and dignity first.

Version: 1.0 (Draft for Legal Review)Date: 28 September 2026DPO: Ms Ogechukwu Holly Mohanye

This Policy in Simple Words

  • You can get help on AHERI Hub without telling us your name. AHERI does not know who you are unless you choose to tell us.
  • Your teachers, your school, and your parents cannot read your chats, check-ins, or reports. Schools only see general numbers, never your words.
  • The only time we share without your permission is when someone’s life or safety is in serious danger, or when the law says we must.
  • We never sell your information and we never show you adverts.
  • You can ask to see or delete your information at any time, free of charge.
1. Data Controller

Who We Are

AHERI Hub is run by the Advocacy for Healing, Empowerment and Resilience Initiative (AHERI), a non-profit organisation registered in Nigeria with the Corporate Affairs Commission as an incorporated trustee (Registration Number 9052560).

AHERI, not your school, is in charge of AHERI Hub and is the data controller for everything you share on it. We protect your information under the Nigeria Data Protection Act 2023 and the General Application and Implementation Directive 2025 issued by the Nigeria Data Protection Commission (NDPC).

Contact Point & DPO Details

Organisation

Advocacy for Healing, Empowerment and Resilience Initiative

Office Address

26F, Sabondele Shopping Complex, Jabi, Abuja, Nigeria

Data Protection Officer

Ms Ogechukwu Holly Mohanye

Email

info@aherinitiative.org (Subject: "AHERI Hub privacy")

Telephone

+234 701 020 2280

Inside AHERI Hub

Use the "My privacy" option in the main menu

Scope & Access

Coverage and Support Paths

What This Policy Covers

  • AHERI Hub web pages (www.aherinitiative.org/aheri-hub)
  • The AHERI Hub web app and mobile app
  • The AHERI Hub WhatsApp chat service
  • The School Dashboard used by partner schools

Note: The main AHERI website has its own separate Privacy Policy.

Who AHERI Hub Is For

Students: Learners at partner schools (including under 18). Joined via a school sign-in slip with a code and Care ID.
Youths: Young people aged 18 to 25. Joined by confirming age and creating a PIN.
Women: Women aged 18 and older. Joined by selecting "Woman" and creating a PIN.
Anyone, of any age, can see emergency numbers and helplines on AHERI Hub without signing in.
4. Data Collection

What We Collect vs. What We Do Not

We strictly limit data collection to what is necessary to support you safely while maintaining standard anonymity.

PathWhat We CollectWhat We Do NOT Collect
StudentSchool code, Care ID, class level, scrambled PIN/secret word, chats, check-ins, and reports.Your name, home address, photograph, or record of which slip belongs to whom.
YouthAge confirmation (18–25), state, scrambled PIN/secret word, chats, check-ins, and reports.Your name, unless you choose to share it for follow-up.
WomanState, scrambled PIN/secret word, chats, check-ins, reports, safe contact method (if requested).Your name, unless you choose to share it.

How Sign-In Slips Protect You

  • Schools hand out slips at random and keep no list matching students to slips.
  • Only you know your PIN and secret word. AHERI staff cannot see them.
  • If forgotten, AHERI resets your PIN using your secret word—your school never resets it.
  • 5 wrong attempts lock the account for 30 minutes. Automatic sign-out occurs after 30 minutes of inactivity.
  • A emergency "Leave quickly" button on every screen closes AHERI Hub at once.

A Note About WhatsApp

When you chat on WhatsApp, Meta shares your phone number. We store your number in a protected, scrambled form to reply to you. We never pass it to your school or parents. Never type your PIN in a WhatsApp chat; setting PINs uses a secure link.

For full anonymity, please use the AHERI Hub web app instead of WhatsApp.

5. Sensitive Information

Information like mental health, physical wellbeing, or experiences of abuse is classified as sensitive under Section 30 of the NDPA 2023. We process it only with your explicit consent, when needed to protect life, or when required by law. It is kept with enhanced encryption and visible only to small teams of trained staff.

6. Students Under 18

Under Section 31 of NDPA 2023, children under 18 require parental/guardian consent. Partner schools collect consent via AHERI forms before distributing slips. Because we collect no names, we store minimal personal data. Under-18s outside partner schools can access all emergency helplines without signing in.

7 & 8. AI & Safety Frameworks

AI Chat Companion & Safety Disclosure

7. The Artificial Intelligence Chat Companion

  • The chat companion is a computer programme, not a doctor, counsellor, or lawyer.
  • It screens for crisis risk keywords. When detected, trained human staff step in to review and respond.
  • No automated decision is made without human oversight. Under Section 37 of NDPA 2023, you may request human review of automated decisions.
  • Third-party tech providers operate under contract and cannot use your messages to train public AI models.

8. When We Must Share Information to Keep People Safe

Confidentiality is paramount, but we will share the minimal necessary information without prior permission strictly when:

  • Someone's life is in immediate danger (including self-harm or harm to others).
  • A child is at serious risk of abuse or harm.
  • A court order or legal mandate in Nigeria requires disclosure.

This complies with the Child Rights Act 2003, Violence Against Persons (Prohibition) Act 2015, and National Mental Health Act 2021.

Data Sharing & Retention

Who Receives Data & How Long It Is Kept

9. Third-Party Sharing

Partner Schools: Only generalized numbers on the school dashboard (e.g., "12 students used AHERI Hub for exam stress"). Never groups smaller than 10.
School Care Contact: Receives no individual data, names, or chat logs.
Referral Partners: Only details you explicitly consent to share for medical, legal, or shelter aid.
No Commercial Selling: We NEVER sell, rent, or trade your personal information. Zero adverts.

11. Data Retention Schedule

Chats & Check-ins12 months after last use
Safety Reports6 yrs post-case (or until age 25)
WhatsApp Numbers12 months after last chat
Technical Logs90 days
Unused SlipsDeleted end of school year
13. Your Legal Rights

Exercise Your Rights Under NDPA 2023

You hold total control over your personal data under Sections 34–38 of the NDPA 2023:

Right to Access

Ask for a copy of data you shared.

Right to Deletion

Request account & chat deletion.

Right to Correct

Fix incorrect or outdated details.

Right to Restrict

Pause data processing during reviews.

Right to Object

Opt out of anonymous research data.

Human Review

Request human oversight on AI decisions.

How to exercise your rights:

Select "My privacy" in AHERI Hub or email info@aherinitiative.org. No real name required—your Care ID or report code is enough. We respond within 30 days, free of charge.

NDPC Regulator Portal

Questions about your privacy?

Our Data Protection Officer is available to address any privacy or security queries.