Cookie Policy

Last Updated: March 2026

Introduction

This Cookie Policy explains how Mountain Top University (“MTU”, “the University”, “we”, “us”, or “our”) uses cookies and similar tracking technologies on our website, learning management systems, student portals, and other digital platforms (collectively, “our Platforms”).

This Policy is issued in compliance with the Nigeria Data Protection Act (NDPA) 2023, GDPR and the General Application and Implementation Directive (GAID) 2025 issued by the Nigeria Data Protection Commission (NDPC).

As a Data Controller of Major Importance (DCPMI) under Nigerian data protection law, we are committed to protecting your personal data and ensuring transparency in our data processing activities.

What are Cookies?

Cookies are small text files that are placed on your device (computer, tablet, smartphone) when you visit our Platforms. They allow us to recognise your device, remember your preferences, and understand how you interact with our services.

Cookies may collect personal data as defined under Section 3 of the NDPA 2023. We also use similar tracking technologies, such as:

• Web beacons
• Pixel tags
• Local storage objects
• Device fingerprinting technologies
• Session storage technologies

These technologies are treated as equivalent to cookies under Article 19(8) of the GAID and are subject to the same consent requirements.

Legal Basis for Cookies Use

Under Section 24 of the NDPA 2023 and Article 19 of the GAID 2025, we process personal data through cookies based on the following legal grounds:

Legitimate Interest (Necessary Cookies)

For cookies essential to the operation of our Platforms, we rely on legitimate interest as defined under Section 25(1)(f) of the NDPA. These cookies do not require your explicit consent under Article 19(5) of the GAID, provided they do not process sensitive personal data, financial data, or privately stored data.

Explicit Consent (Non-Essential Cookies)

For all other cookies, we rely on your explicit, freely given, specific, informed, and unambiguous consent as required by Section 25(1)(a) of the NDPA and Article 19(3) of the GAID.

Key characteristics of valid consent under Nigerian law:

• Explicit: You must take affirmative action (clicking “Accept” or “Yes”)
• Freely given: No coercion or pressure to accept
• Specific: Consent is requested for distinct purposes
• Informed: Clear information provided before consent
• Unambiguous: No pre-ticked boxes or implied consent through continued browsing

How We Obtain Your Consent

Cookie Banner Requirements

In compliance with Article 19(4) and Article 7(l) of the GAID, our cookie consent mechanism meets mandatory requirements:

• Conspicuous Display: Our banner is prominently placed to ensure visibility upon your first visit.
• Granular Control: You can accept or reject each category individually.
• No Pre-ticked Boxes: All non-essential categories are “off” by default.

Data Subject Rights Regarding Cookies

Children’s Privacy and Cookies

Under Section 38 of the NDPA 2023, we implement special protections for children (individuals under 18 years). We do not knowingly use marketing or tracking cookies for users under 18 without verifiable parental consent.

Contact Information

Data Protection Officer (DPO)

As a Data Controller of Major Importance, we have appointed a Data Protection Officer:
Email: [email protected]

Nigeria Data Protection Commission (NDPC)

Website: www.ndpc.gov.ng
Email: [email protected]

Compliance Certification

This Cookie Policy has been reviewed and approved to ensure compliance with:

• Nigeria Data Protection Act, 2023
• General Application and Implementation Directive (GAID), 2025
• Constitution of the Federal Republic of Nigeria, 1999 (Section 37)