Statutory Cookie & Tracking Policy

1. What Are Cookies and Local Storage?

Cookies are small cryptographic text files placed on your computer, tablet, or smartphone when you access web pages. They serve critical technical functions, such as verifying secure sessions, defending against cross-site request forgery (CSRF), preserving accessibility settings, and remembering your privacy selections across visits.

In addition to standard HTTP cookies, modern web platforms utilize related client-side technologies:

• Local Storage (HTML5 Web Storage): Key-value data stored indefinitely on your device until intentionally cleared. We use this exclusively to persist your cookie consent choices (so you are not interrupted on every page visit) and UI preferences (such as dark/light display mode).
• Session Storage: Data stored exclusively for the duration of an active browser tab. This is used by our client-side educator calculation utilities to retain working numbers without ever sending them to a server.
• Service Worker Cache Storage: Browser-managed caching that enables the Harmony Digital Consults Progressive Web App (PWA) to operate offline during intermittent electrical power or internet connectivity disruptions across Nigerian schools.

2. Statutory Legal Basis under the Nigeria Data Protection Act (NDPA) 2023

Harmony Digital Consults Ltd is incorporated under Nigerian law (Corporate Affairs Commission RC 8949899) and operates under the direct regulatory jurisdiction of the Nigeria Data Protection Commission (NDPC).

Under Sections 24, 25, and 35 of the Nigeria Data Protection Act (NDPA) 2023:

• Principle of Data Minimization (Section 24(1)(c)): We do not deploy superfluous or invasive tracking scripts. Only technical tokens strictly necessary for secure platform operation and consented, anonymized diagnostic telemetry are utilized.
• Principle of Lawful Processing (Section 25): Non-essential performance and analytical cookies are placed strictly with your prior, freely given, specific, and unambiguous affirmative consent obtained via our interactive consent interface.
• Right to Withdraw Consent (Section 35(1)): You possess the absolute, unfettered right to revoke or amend your cookie preferences at any time. Withdrawal of consent operates seamlessly without penalty or restriction from core public services.

3. Strict Safeguards for Child and Student Data (Section 31 NDPA)

Recognizing that our primary domain is educational technology, school enterprise management (HavonTrack), and educator enablement, we enforce stringent compliance with Section 31 of the NDPA 2023 (Processing of Personal Data of a Child):

• No Behavioral Profiling of Minors: No cookies, pixels, or trackers deployed on this domain profile students, build advertising personas, or track underage pupils across websites.
• Zero Storage of Pupil Continuous Assessment (CA) Marks: When teachers utilize our Broadsheet Validator or Report Card Remark generators, grade computations run entirely in the browser's temporary heap memory. Nothing is written to permanent cookies or transferred to external analytics endpoints.
• Independent Institutional ERP Separation: Live school ERP databases under HavonTrack are hosted in sovereign, role-based, password-secured subdomains governed under bilateral institutional Data Processing Agreements (DPAs) completely isolated from public promotional cookies.

4. Complete Cookie & Storage Inventory

In fulfillment of statutory disclosure standards, the table below provides a comprehensive catalog of every cookie and persistent storage key utilized across the Harmony Digital Consults web domain:

5. Detailed Categories of Cookies in Use

Category 1: Strictly Necessary & Security Tokens (Always Active)

These technical items are indispensable for enabling navigation, safeguarding user input, and protecting against malicious cyber activities. Because the website cannot function reliably or securely without them, they cannot be deactivated via our preferences panel.

• Anti-Spam & Honeypot Verification: Validates contact form submissions to prevent automated bot flooding and denial-of-service disruptions against school communication channels.
• Consent State Management: Remembers whether you approved or denied optional cookies so we do not bother you on subsequent page loads.
• Accessibility & Display State: Retains your text size choices, high-contrast settings, and dark-mode preferences.

Category 2: Performance & Vercel Analytics (Optional — Consent Controlled)

We use privacy-preserving Vercel Web Analytics & Vercel Speed Insights to gauge aggregate visitor experiences, measuring page load speeds across Nigerian mobile networks and detecting broken links.

• Zero Tracking Cookies & Full Privacy: Vercel Web Analytics is cookieless and does not track users across different websites or build advertising profiles.
• Zero Student Profiling: We do not track student learning activity, exam scores, or personal records.
• Revocation at Any Time: If you accept analytics and later change your mind, clicking "Reject Non-Essential" immediately halts telemetry dispatch.

Category 3: Functional & Offline Diagnostics (Optional — Consent Controlled)

These storage mechanisms support high-utility interactive capabilities designed specifically for Nigerian educators and school administrators:

• Progressive Web App (PWA) Offline Storage: Pre-caches diagnostic scorecards, curriculum documents, and syllabus checklists so teachers can work uninterrupted during power outages or broadband dropouts.
• Local Draft Memory: Temporarily retains draft values in calculator forms on your personal computer so accidental page reloads do not erase your continuous assessment verification inputs.

6. Third-Party Integrations & Sub-processors

To deliver responsive enterprise support, we partner with reputable, security-audited technology providers. When interacting with specific features, technical tokens may be initialized under strict sub-processor constraints:

• Vercel Inc (Cloud Hosting & Web Analytics): Cloud hosting and privacy-first web performance metrics. Vercel adheres to ISO 27001, SOC 2 Type II, and strict GDPR/NDPA adequacy standards without advertising cookies.
• Meta Platforms Ireland Ltd (WhatsApp Quick-Routing): Initiates direct encrypted consultations with our technical advisory team. Clicking the floating WhatsApp button launches WhatsApp Web or the WhatsApp mobile application directly on your device under Meta's separate end-to-end encryption privacy policy.
• Google Cloud Platform: Enterprise European cloud hosting compute infrastructure with multi-layer encryption.

7. Your Rights: How to Control, Block, or Withdraw Consent

You hold total dominion over your data. Under NDPA 2023 regulations, you can adjust your cookie choices at any moment through three easy methods:

1. Direct Interactive Preference Panel: Click the Manage Cookie Preferences button at the top of this page or in the footer of any page to open the interactive preference manager and toggle analytics or functional storage.
2. Instant Reset: Click "Reset Preferences" in the status card above to erase all saved choices from your browser, triggering the initial consent banner on your next navigation.
3. Hard Browser Purge: Clear your browser cookies through your application settings (instructions provided in Section 8 below).

8. Browser-Specific Management Instructions

Most modern browsers permit you to reject all cookies, accept only first-party cookies, or delete stored files upon closing your window. Follow the direct navigation steps below for your operating system:

9. Policy Updates, Versioning & Annual Audits

As statutory guidelines issued by the Nigeria Data Protection Commission (NDPC) evolve and new digital tools are introduced, this Cookie Policy may be updated periodically. When material revisions occur, the revised version will be published here with an updated "Last Statutory Review" date and announced via our website banner.

We conduct formal, documented internal audits of all digital assets every twelve (12) months to verify that no unauthorized tracking scripts or unlisted sub-processors have been integrated into our public or institutional software suites.

10. Data Protection Desk & NDPC Regulatory Contact

If you have questions, require clarification regarding our use of cookies, or wish to submit an inquiry regarding institutional compliance for your school or tertiary institution, please contact our Data Governance Desk: