TALKTRUE — PRIVACY POLICYFor uullc.info — effective date: 2 April 2026

1. About TalkTrue and This Policy

TalkTrue — The Free English Tutor is an English language learning service delivered through WhatsApp, operated by U&U LLC. This Privacy Policy explains what personal information we collect, why we collect it, how we use and protect it, and your rights under the Nigeria Data Protection Act 2023 (NDPA).

By using TalkTrue, you agree to the collection and use of information as described in this policy. If you do not agree, you may withdraw your consent at any time by sending the word STOP to TalkTrue on WhatsApp.

2. Who We Are

Data Controller: U&U LLC Website:uullc.infoContact:kodeet@uullc.infoData Protection enquiries: kodeet@uullc.info

U&U LLC is registered as a Data Controller under the Nigeria Data Protection Act 2023 with the Nigeria Data Protection Commission (NDPC).

3. What Information We Collect

When you use TalkTrue, we collect the following information:

Information you provide:

  • Your WhatsApp display name (collected at registration)

  • Your language preference (selected during onboarding)

  • Your English level (Beginner or Intermediate, selected by you)

  • Your answers to English lesson exercises and vocabulary challenges

Information collected automatically:

  • Your WhatsApp phone number (used to identify your account — stored in hashed form)

  • Your country, inferred from your phone number prefix

  • The time and date of your lesson activity

  • Your lesson progress, streak, and experience points (XP)

  • Whether and when you gave or withdrew consent

Information we do not collect:

  • Your full name beyond your WhatsApp display name

  • Your address, email address, or any government ID

  • Payment or financial information

  • Any information from your WhatsApp conversations outside of TalkTrue lesson interactions

4. Why We Collect This Information

We collect and process your information for the following purposes, each with a lawful basis under the NDPA 2023:

To deliver the TalkTrue service(Lawful basis: Contract) We use your phone number, language preference, level, and lesson progress to deliver personalised English lessons, track your progress, and send you lesson content through WhatsApp.

To improve our lessons(Lawful basis: Legitimate interest) We analyse lesson interaction data — which questions students answer correctly or incorrectly, how many attempts are needed, and which lesson topics are most challenging — to improve our curriculum and lesson quality.

To send you re-engagement reminders(Lawful basis: Legitimate interest) If you have not completed a lesson in approximately 23 hours, we may send you a reminder message through WhatsApp to encourage you to continue learning.

To share anonymised research data with educational partners(Lawful basis: Consent) With your explicit consent, we create anonymised versions of your learning interaction data — with your name and phone number permanently removed and replaced with an untraceable identifier — and share this data with educational research organisations, publishers, and learning technology companies to help improve English language learning tools worldwide. This anonymised data cannot be used to identify you. You give this consent during onboarding and may withdraw it at any time.

5. Anonymisation and Research Data

A core part of TalkTrue’s model is contributing to English language learning research. When you consent, your learning data is anonymised as follows:

  • Your phone number is replaced with a random unique identifier that cannot be traced back to you

  • Your WhatsApp display name is removed entirely

  • All timestamps are rounded to the nearest day — exact times are not included

  • Only your country (Nigeria) is retained, not your specific location

Once anonymised, this data may be shared with or sold to educational research organisations, university researchers, curriculum developers, and English language publishers. The data shared includes: the English words and sentences you practised, whether your answers were correct, how many attempts you made, your CEFR level (A1/A2/B1/B2), and the language you chose for instruction.

If you withdraw consent, your personal data is deleted. Your anonymised research data is retained — because it cannot identify you, it is no longer personal data under the NDPA — but it is flagged so it can be excluded from future exports if you request this.

6. How We Store and Protect Your Data

Your personal data is stored in a secure PostgreSQL database hosted on Render (render.com), a cloud infrastructure provider with servers located outside Nigeria. This transfer is made under appropriate safeguards consistent with the NDPA 2023, including contractual protections with our service provider.

We protect your data by:

  • Storing your phone number in hashed form — the original number is not stored in plain text in our interaction records

  • Restricting database access to authorised systems only

  • Maintaining separate, access-restricted tables for identity mapping and anonymised data

  • Logging all data access and processing events for audit purposes

We retain your personal data for as long as you are an active TalkTrue user. If you request deletion (by sending STOP), your personal data is deleted within 30 days.

7. Who We Share Your Data With

We do not sell your personal data. We share data only as follows:

Service providers: We use Render (cloud hosting), Meta/WhatsApp (message delivery), and AI model providers (lesson generation). These providers process data on our behalf under appropriate data processing agreements and are not permitted to use your data for their own purposes.

Research and educational partners: With your consent, we share anonymised (non-personal) learning data as described in Section 5. Recipients may include educational publishers, university research departments, and corporate training platforms. All recipients receive anonymised data only — your identity is never disclosed.

Legal requirements: We may disclose your data if required to do so by Nigerian law or a lawful order from a competent authority.

We do not share your data with advertisers. TalkTrue does not display advertising and your data is not used for advertising targeting.

8. Your Rights Under the NDPA 2023

As a data subject under the Nigeria Data Protection Act 2023, you have the following rights:

Right to access: You may request a copy of the personal data we hold about you.

Right to correction: You may request that we correct inaccurate personal data.

Right to deletion: You may request that we delete your personal data. Send STOP to TalkTrue on WhatsApp at any time to request deletion. We will process your request within 30 days.

Right to withdraw consent: You may withdraw your consent to data processing at any time without affecting the lawfulness of processing carried out before withdrawal. Send STOP to TalkTrue on WhatsApp.

Right to object: You may object to processing of your personal data for research or commercial purposes at any time.

Right to data portability: You may request a copy of your data in a structured, machine-readable format.

To exercise any of these rights, send STOP to TalkTrue on WhatsApp, or contact us at kodeet@uullc.info. We will respond within 30 days.

If you are not satisfied with our response, you may lodge a complaint with the Nigeria Data Protection Commission (NDPC) at ndpc.gov.ng.

9. Children

TalkTrue is intended for adult learners aged 18 and over. We do not knowingly collect personal data from anyone under 18. If you believe a person under 18 has registered with TalkTrue, please contact us at [CONTACT EMAIL] and we will delete their account promptly.

10. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will notify active TalkTrue users through WhatsApp and update the effective date at the top of this page. Continued use of TalkTrue after notification constitutes acceptance of the updated policy. If changes affect how we use your data for research purposes, we will seek fresh consent.

11. Contact Us

For any privacy-related questions, data subject requests, or complaints:

Email: kodeet@uullc.info Website:uullc.infoWhatsApp: Send STOP or HELP to TalkTrue

Nigeria Data Protection Commission (NDPC) For complaints: ndpc.gov.ng

This policy is effective as of 2 April 2026 and was last reviewed on 2 April 2026Version: v1.0-NDPA