Privacy Policy
PRIVACY NOTICE FOR PROCESSING PERSONAL DATA BY KOOD/JÕHVI
Valid from 01.01.2024
This Privacy Notice describes the purpose and extent of processing personal data by kood/Nairobi (Kenyatta University), referred to as kood/Nairobi.
General Provisions
kood/Nairobi ensures that the processing of personal data is carried out in compliance with the Kenya Data Protection Act, 2019 and other applicable Kenyan laws and regulations. The organisation also follows best practices for data protection and information security.
kood/Nairobi respects individuals’ right to privacy and takes all reasonable measures to protect personal data and maintain the security of its information systems.
Definitions
- Platform
- The online learning platform provided by kood/Nairobi and/or its authorised data processors, used by Students.
- Processing of personal data
- Any action or set of actions such as collecting, registering, accumulating, storing, adapting, altering, updating, using, distributing, depersonalising, or destroying personal data.
- Student
- A person enrolled in the educational programme of kood/Nairobi and using the Platform.
Purpose of Processing Personal Data and Its Legal Basis
kood/Nairobi processes personal data for the purposes of enrolling students in educational programmes, monitoring their academic progress and achievements, providing educational tasks, resources, and communication tools, facilitating interaction between students, staff, and educators, maintaining necessary academic and administrative records, and collecting gender-related data for statistical purposes to promote diversity and inclusion in the technology sector.
The legal basis for processing personal data is primarily the consent of the data subject, in accordance with the Kenya Data Protection Act, 2019. In cases where data processing is necessary to fulfil the terms of education-related agreements, such processing is carried out without additional consent as permitted by Kenyan law. In certain situations, kood/Nairobi may also rely on legitimate interest as a legal basis for processing, provided such interests do not override the fundamental rights and freedoms of the data subjects.
How kood/Nairobi Collects Personal Data
kood/Nairobi collects personal information on the Platform directly when the Student:
- —registers an account, providing name, email address, date of birth, and enrolment details;
- —participates in educational activities including forum discussions, assignment submission, and assessments;
- —customises their user profile by entering preferences, learning styles, and feedback;
- —engages with communication tools such as messages, discussions, or support requests.
kood/Nairobi collects personal information indirectly when:
- —the administrative system integrates with the platform, transferring student information such as accounts, enrolment status, and academic history;
- —data is collected via cookies and similar technologies including login data, IP addresses, browser types, and access times;
- —the Platform automatically generates records of student interactions such as time spent on materials, progress tracking, and resource access patterns.
Transmission of Personal Data
kood/Nairobi processes personal data within Kenya or within countries recognised by Kenyan law as providing an adequate level of personal data protection. All data is received, transmitted, and processed digitally, in accordance with applicable Kenyan data protection legislation.
Disclosure of Personal Data
kood/Nairobi engages third-party service providers to operate and maintain the Platform. These providers have access to personal data only to the extent necessary to perform their services and are contractually obligated to ensure confidentiality and security in accordance with Kenyan data protection laws.
Retention and Deletion of Personal Data
Retained for the duration of enrolment, and for 3 years after the expiry of the student agreement. Accounting data retained for 7 years.
Retained for as long as the processor conducting identity verification retains the data.
Retained for the duration of enrolment, and for 3 years after the expiry of the student agreement.
Retained for the duration of enrolment, and for 3 years after expiry, then securely deleted or anonymised.
Rights of the Student (Data Subject)
The Student has the right at any time to request:
- —access to personal data (accessed via the Platform);
- —correction of inaccurate personal data;
- —deletion of personal data;
- —restriction of processing of personal data;
- —withdrawal of data-processing consent (if applicable).
To exercise these rights, submit a request to nairobi@kood.tech. Requests will be responded to within 30 calendar days. The Student also has the right to lodge a complaint with the supervisory authority.
Changes and Validity
kood/Nairobi reserves the right to amend the conditions for personal data processing in accordance with applicable Kenyan data protection laws. In the event of substantial changes, users will be notified at least 1 month in advance through the Platform. Continued use of the Platform after changes take effect constitutes acceptance of the updated terms. The current conditions are valid from 01.01.2024.