Privacy Policy

1. Who We Are

FailFastNG is an educational technology platform owned and operated by Failfast Pioneer Systems Ltd (RC: 9433743), a company incorporated in Nigeria. Our registered address is 6, Rotimi Street, Yaba, Lagos, Nigeria. We run two products: FailFast Arena, a competitive knowledge and staking platform, and FailFast EDU, a school management and assessment tool for schools and tutorial centers.

The platform is accessible to users from any country. Real-money features in Arena (wallet, staking, and funded competitions) are restricted to Nigerian users who complete Nigerian identity verification. All other features are available to users worldwide.

This policy explains what personal data we collect from users of our website and applications, how we use it, and what rights you have. It applies to all user types: Challengers, Instructors, Sponsors, School Admins, Teachers, and Students.

We process personal data in line with the Nigeria Data Protection Act (NDPA) 2023 and are registered with the Nigeria Data Protection Commission (NDPC) as required under the Act. Users located outside Nigeria accept that their data is processed by a Nigerian entity under Nigerian law when they use the platform.

2. Data We Collect

2.1 Account and Identity Data

When you create an account, we collect:

Full name
Email address
Phone number
Date of birth (used to age-gate real-money features in Arena; users under 18 may register but cannot access wallet, staking, or real-money competitions until their 18th birthday)
Profile photo (optional)
Username or display name

2.2 Financial and Transaction Data

For users of FailFast Arena who fund a wallet or participate in staking challenges, we collect:

Wallet balance and transaction history
Stake amounts, winnings, and withdrawal records
Hosted competition funding and payout records
Gift card issuance, balance history, and expiry records. Gift cards are only available to Nigerian KYC-verified users aged 18 or older. We record which accounts sent and received gift cards, remaining balances, and usage against individual challenges.
Payment method details processed through our payment platform partner (we do not store full card numbers or bank account details on our servers)

For Instructor and Teacher accounts, content payout earnings are tracked in a receive-only wallet. For international Instructors outside Nigeria, these earnings accumulate in their wallet dashboard but cannot be withdrawn until the platform expands payment infrastructure to their region. The accumulated balance is retained and remains accessible to the Instructor when withdrawal becomes available.

2.3 Content and Activity Data

Questions answered, attempts made, and scores earned in FailFast Mine and competitive challenges
Content submitted by Instructors for review and payout calculation
Competition parameters set by Sponsors and Challengers who host competitions
Quizzes and assessments created by Teachers in FailFast EDU
For EDU students who link their school account to an Arena account: qualifying FailFast Mine session data (success points, grit points, and streak days earned from practice on platform-verified questions) is synced one-directionally from the EDU account to the linked Arena account. This sync is continuous after linking and does not require manual action from the student. The school admin is not notified when a student links accounts.

2.4 Device and Session Data

We automatically collect certain technical data when you use our platform:

Device type, operating system, and browser
IP address
Pages visited and features used
Session duration and time stamps
App focus events: how often the app loses focus during a session, how long each absence lasts, and whether the absence was triggered by a manual app switch, an incoming phone call, or a screen-lock event. This data is used for anti-cheat scoring integrity and is described further in Section 5.
Per-question response times, collected silently during every session to support anomaly detection

2.5 School and Institutional Data (EDU Only)

For FailFast EDU, School Admins provide:

School name, address, and contact details
Class structure and student enrollment lists
Student names and class levels (e.g., SS2, JSS3)

Student accounts in FailFast EDU are created and managed by School Admins. Parents or guardians of students under 18 should contact their school admin regarding how student data is managed within the school's account.

3. How We Use Your Data

3.1 To Operate the Platform

Create and manage your account
Process wallet transactions, staking payouts, and hosted competition payouts
Track scores, tier progression, streaks, and leaderboards
Generate and deliver questions matched to your subject preferences and difficulty tier
Calculate Instructor and Teacher content payouts based on question usage in staking sessions

3.2 To Protect Platform Integrity

FailFast uses behavioral data to detect and prevent cheating. This includes monitoring per-question response times, app focus events, and answer pattern anomalies. A full description of what is collected and how it is used is in Section 5.

3.3 To Communicate With You

Send account verification and transaction confirmation emails
Notify you of challenge results, tier changes, and streak updates
Respond to support requests
Send product updates (you can opt out of non-essential communications at any time)

3.4 To Comply With the Law

We may use or retain your data where required by Nigerian law, including for tax reporting, regulatory audits related to our gaming license, or responses to valid legal requests.

4. Legal Basis for Processing

Under the NDPA 2023, we process your data on the following grounds:

Contract performance: Processing your account and transaction data to deliver the services you signed up for.
Legitimate interest: Protecting the platform against fraud, cheating, and abuse.
Legal obligation: Retaining financial records and complying with regulatory requirements tied to our gaming license.
Consent: Where you have given consent, such as for optional communications or for EDU student data collected under school admin authorization.

For users located outside Nigeria: by registering for and using the platform, you accept that your data is processed by a Nigerian entity under the NDPA 2023. FailFastNG does not currently offer jurisdiction-specific processing arrangements for other countries' data protection laws. If this is a concern, you should not register for the platform.

5. Anti-Cheat Monitoring

Because FailFast Arena involves real-money staking, we take scoring integrity seriously. The following data is collected passively during sessions and used only for integrity purposes.

5.1 Per-Question Response Time

The platform records how long each question stays on screen before an answer is submitted. Users who consistently take an unusually long time on questions they get right on the first attempt are flagged for review, since that pattern can indicate using an external tool to look up answers.

5.2 App Focus Events

When you switch away from the app during an active session, the platform logs that a focus loss occurred, how long you were away, and the type of event. Manual app switches, incoming phone calls, and screen-lock events are each tracked and weighted differently in the anomaly scoring. Phone calls and screen-lock events are given less weight than deliberate app switches.

On return from a focus loss, a non-accusatory overlay is shown briefly before you can continue. In competition mode (group staking, sponsored competitions, hosted competitions), the overlay lasts 10 seconds and the session timer does not pause during your absence or during the overlay. In practice mode (FailFast Mine), the overlay lasts 5 seconds and the question timer pauses while you are away. In Adventurer mode, the overlay behavior matches practice mode by default, and users can disable it entirely since Adventurer sessions often involve consulting uploaded study materials.

The cumulative count of focus losses and total time away during a session contribute to an anomaly score. A single focus loss in a long session is treated as a normal interruption. A pattern of switching away on most questions is flagged for manual review.

5.3 Statistical Anomaly Detection

Accounts with sustained high first-try success rates combined with slow per-question response times are flagged automatically for manual review. This combination is the clearest behavioral signal of AI-assisted cheating.

5.4 How This Data Is Used

Anti-cheat data is used only for scoring integrity purposes. It is not sold or shared with third parties. Users can request a review if they believe a flag was applied to their account in error.

5.5 Automated Decision-Making

The anti-cheat system makes automated decisions based on behavioral data. These decisions can result in an account being flagged, winnings being withheld, or a competition result being voided. No account suspension or permanent termination is applied based on automated detection alone. A human review confirms any significant action taken against an account.

Under the NDPA 2023, you have the right not to be subject to decisions that significantly affect you based solely on automated processing. If you believe an automated flag or decision has been applied to your account incorrectly, you may request a human review by contacting us at privacy@failfastng.com. We will respond within 10 business days.

6. Who We Share Your Data With

We do not sell your personal data. We share it only in the following cases:

6.1 Payment Platform Partner

To process wallet top-ups, challenge stakes, hosted competition payouts, and withdrawals, we pass transaction data to our payment platform partner. That partner operates under their own privacy policy and is responsible for securing payment credentials.

6.2 Question Content Providers

We source questions from third-party APIs, including public exam question providers. We do not share your personal data with these providers.

6.3 Legal and Regulatory Bodies

We will share data with Nigerian regulatory authorities, law enforcement, or courts if required by a valid legal order.

6.4 Service Providers

We use third-party services for hosting, analytics, and communications. These providers are bound by data processing agreements and may only use your data to deliver services on our behalf.

6.5 Internal Cross-Product Data Sync (EDU to Arena)

When an EDU student links their school account to an Arena account, qualifying practice data flows internally from the EDU tenant to the Arena user record. This is a read from the student's own session records only. No other school data, no teacher notes, no admin settings, and no data from other students is accessed or transferred. Data never flows in the opposite direction: Arena activity, wallet history, and staking records are never visible in the school dashboard.

6.6 Cross-Border Data Transfers

FailFastNG uses third-party infrastructure providers to operate the platform. Some of these providers store or process data on servers located outside Nigeria. Where this occurs, we ensure that appropriate safeguards are in place as required by the NDPA 2023, including data processing agreements with those providers that bind them to data protection standards consistent with Nigerian law. The types of international providers we use include cloud storage and hosting services, analytics and monitoring tools, and communication platforms. We do not transfer data to a country whose laws do not provide adequate protection for personal data without first putting appropriate contractual safeguards in place.

7. How Long We Keep Your Data

Active account data: Retained for as long as your account is open.
Transaction and wallet records: Retained for 7 years in line with Nigerian financial record-keeping requirements.
Anti-cheat session logs: Retained for 90 days after a session, unless an investigation is in progress.
EDU student data: Retained for the duration of the school's active subscription. On subscription termination, student data is deleted within 60 days unless the school requests an earlier deletion.
Inactive accounts: Accounts with no activity for 24 consecutive months will be flagged for archiving. We will send a notice to the registered email address giving the user 30 days to log in and reactivate the account. If no response is received within that 30-day period, the account will be archived and personal data deleted, except for any data we are required to retain under Nigerian law.

8. Your Rights

Under the NDPA 2023, you have the right to:

Access: Request a copy of the personal data we hold about you.
Correction: Ask us to correct inaccurate or incomplete data.
Deletion: Request that we delete your data, subject to legal retention requirements.
Restriction: Ask us to stop certain types of processing.
Objection: Object to processing based on legitimate interest.
Portability: Receive your data in a structured, machine-readable format.

To exercise any of these rights, contact us at the address in Section 12. We will respond within 30 days.

EDU students, or their parents and guardians, should direct requests through the School Admin, who manages data within the school's tenant environment.

9. Cookies

Our website uses cookies to keep you logged in, remember your preferences, and measure how the platform is used. You can control cookie settings through your browser.

We do not use cookies to serve third-party advertising.

10. Minors and Children

Users under 18 may register for FailFast Arena and use the platform's free features: FailFast Mine, tier progression, leaderboards, streaks, and free challenges. All real-money features, including the wallet, deposits, group staking, hosted competitions, and sponsored competitions with real-money payouts, are hidden from accounts where the verified date of birth shows the user is under 18.

Real-money access is protected by two independent layers. The first is the platform's own age gate, which hides wallet features until the user's 18th birthday. The second is CBN regulation: BVN (Bank Verification Number) is only issued by Nigerian banks to individuals aged 18 and above. Since Nigerian KYC verification requires BVN, a user under 18 is physically unable to complete wallet activation regardless of what date of birth was entered at registration. These two layers together mean underage access to real-money features is structurally blocked by both platform controls and statutory banking regulation.

The NDPA 2023 requires parental or guardian consent before processing the personal data of a child. FailFast Arena collects date of birth and basic account information at registration from all users, including users under 18. By registering, a user under 18 confirms that they have obtained the consent of a parent or guardian before providing their personal data to the platform. FailFastNG relies on this confirmation at the point of registration. If a parent or guardian wishes to withdraw consent or request deletion of their child's data, they may contact us at privacy@failfastng.com. We will process such requests within 30 days.

FailFast EDU is designed for use in school environments and holds data belonging to students, many of whom are under 18. In those cases, the School Admin acts as the data controller for their institution and is responsible for ensuring appropriate parental or guardian consent is obtained before creating student accounts. Parents or guardians of students under 18 should direct privacy queries to the school. EDU student data is never used for real-money purposes and is completely separate from Arena.

If we become aware that an under-18 Arena user has somehow activated real-money features before their 18th birthday, we will immediately suspend wallet access and investigate. Confirmed underage wallet access will result in account suspension and return of any funds.

11. Security

We apply technical and organizational measures to protect your data, including encrypted connections, access controls, and regular security reviews. No system is fully secure, and we cannot guarantee that data will never be compromised, but we take reasonable steps to reduce that risk.

If a data breach occurs that is likely to affect your rights or freedoms, we will notify the Nigeria Data Protection Commission (NDPC) within 72 hours of becoming aware of the breach, as required by the NDPA 2023. We will also notify affected users without undue delay once the nature and scope of the breach has been confirmed and notification would not compromise any ongoing investigation.

12. Contact Us

If you have questions about this policy or want to exercise your rights, contact our Data Protection Officer at:

Email: privacy@failfastng.com

Mailing address: 6, Rotimi Street, Yaba, Lagos, Nigeria

We aim to respond to all privacy requests within 30 days.

13. Changes to This Policy

We may update this policy when the platform changes or when legal requirements shift. We will post the updated version on our website and notify registered users by email at least 14 days before the changes take effect. Continued use of the platform after that date means you accept the revised policy.

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