MwalimuPLUS will ensure, to the extent possible and reasonable and as required by any applicable laws, the protection of the privacy and personal information of all users who access and use this Platform for the purposes for which such access and use is intended. In the event that you are required to provide certain information for purposes of identification and in order to facilitate your use of the Platform, we confirm that such information shall only be used in accordance with this privacy statement.1. Information We Collect
How we collect and store information depends on how you access and use the Platform. We collect information in multiple ways including when you provide information directly to us, when you permit third parties to provide information to us, and when we passively collect information from you, such as information collected from your browser or device.a. Types of information collected
MwalimuPLUS collects Personal Information (i.e. data that allows someone to identify or contact you such as your name, address, geographic location of your computer or mobile device, telephone number, email address and bank account and other Financial Information) only if you voluntarily choose to share such information with MwalimuPLUS . However, in order for you to take advantage of particular opportunities provided through the MwalimuPLUS Platform, we may require that you furnish Personal Information. When you register your account, sign up for newsletters, complete forms for optional programs, surveys, contests and other entries, and through communications transmitted through MwalimuPLUS , applications and your use of the MwalimuPLUS mobile application, we collect information including your name, address, phone number and email address.
Information about Schools: We ask for certain information when a Head Teacher registers a School with MwalimuPLUS , including a name, school name, school email address and/or account name and password, phone number, message content, and information relating to the School’s information systems. We may also retain information provided by a school if the school sends us a message, posts content to our Platform or through our Service, or responds to emails or surveys. Once a school begins using MwalimuPLUS , we will collect content and information provided by the school through the School’s use of the Service and we will keep records of activities related to the Service. We use this information to operate, maintain, and provide to the features and functionality of the Service, to analyse and improve our Service offerings and functionality, and to communicate with our Schools and Platform visitors.
Student Data: Through the course of providing its Service to a School, MwalimuPLUS may have access to personally identifiable information about students (“Student Data”) that is provided by the School, by the parent or guardian, or by the Student. In order to use MwalimuPLUS, the School provides each student with login credentials and confirms that it has obtained appropriate parental consents, as needed, before the student is permitted to access the Service.
The information you provide directly to us may concern you or others and may include, but is not limited to: (a) name; (b) zip code; (c) email address; (d) home or business telephone number; (e) home, business or mailing address; (f) demographic information (e.g., gender, age, political preference, education, race or ethnic origin, and other information relevant to user surveys and/or offers); (g) date of birth; (h) insurance information; (i) photographs; (j) video or audio files; (k) in certain circumstances, payment and/or identity verification information. and/or (l) any other content you include in private communications with other users through the Platform or communications with us. You are not required to provide us with such information, but certain features of the Platform may not be accessible or available, absent the provision of the requested information.b. Information from Affiliates, Non-affiliated Third Parties
We may also collect information about you or others through non-affiliated third parties. For example, to the extent permitted by law, we may, in our sole discretion, ask for and collect supplemental information from third parties, such as information about your credit from a credit reference bureau, or information to verify your identity or trustworthiness, or for other fraud or safety protection purposes. We may combine information that we collect from you through the Platform with information that we obtain from such third parties and information derived from any other products or services we provide.c. Information that is passively or Automatically Collected Device/Usage Information
When you use the Platform, we may collect general location information (such as IP address). If you install our mobile app, we may ask you to grant us access to your mobile device’s geolocation data. If you grant such permission, we may collect information about your precise geolocation, and we may use that information to improve the Platform, including providing you with location-based features (e.g. for identification of Pro Services available near you). To deliver customized content and advertising, we may share your location information with our agents, vendors, or advertisers. If you access the Platform through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details. If you disable certain functions, you may be unable to use certain parts of the Platform.Cookies and Other Electronic Technologies.
We may also use local shared objects (also known as “Flash cookies”) to assist in delivering special content, such as video clips or animation. Flash cookies are stored on your device, but they are not managed through your web browser. To learn more about how to manage Flash cookies, you can visit the Adobe website and make changes at the Global Privacy Settings Panel.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but your browser may allow you to modify your browser settings to decline cookies if you prefer. If you disable cookies, you may be prevented from taking full advantage of the Platform, because it may not function properly. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser may not affect flash cookies. As we adopt additional technologies, we may also gather additional information through other methods.2. Use of information collected
We may use your information for any of the following reasons:
- For the purposes for which you provided it;
- To enable you to use the services available through the Platform, including registering you for our services and verifying your identity and authority to use our services;
- For customer support and to respond to your inquiries;
- For internal record-keeping purposes;
- To administer surveys, sweepstakes, promotions, or contests;
- To process billing and payment including sharing with third-party payment gateways and payment service providers in connection with the Platform;
- To improve and maintain the Platform and for product development;
- To address fraud or safety concerns, or to investigate complaints or suspected fraud or wrongdoing;
- To periodically send promotional emails regarding new products from MwalimuPLUS ` Ltd, special offers from MwalimuPLUS , or other information that may interest you;
- With your consent, to contact you by text message regarding certain services or information you have requested;
- With your consent, to contact you by telephone or text message regarding Platform features, improvements, or other products and services that may interest you;
- For MwalimuPLUS’ market research purposes, including, but not limited to, the customization of the Platform according to your interests;
- To contact you about goods and services that may interest you or with information about your use of the Platform;
- For other research and analytical purposes; and
- To resolve disputes, to protect ourselves and other users of the Platform, and to enforce any legal terms that govern your use of the Platform.
We may combine information that we collect from you through the Platform with information that we obtain from affiliated and non-affiliated third parties, and information derived from any other products or services we provide.
We may aggregate and/or de-identify information collected through the Platform. We may use de-identified or aggregated data for any purpose, including without limitation for research and marketing purposes and may also share such data with any third parties, including without limitation, advertisers, promotional partners, sponsors, event promoters, and/or others.
We may, either directly or through third parties we engage to provide services to us, review, scan, or analyse your communications with other users exchanged via the Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research and customer support purposes. For example, as part of our fraud prevention efforts, we may scan and analyse messages to prevent fraud or improper actions. We may also scan, review or analyse messages for research and product development purposes, as well as to debug, improve and expand product offerings. By using the Platform, you consent that MwalimuPLUS, in its sole discretion, may, either directly or through third parties we engage to provide services to us, review, scan, analyse, and store your communications, whether done manually or through automated means.
Cell Phone Numbers. MwalimuPLUS may use your cell phone number to call or text you in order to provide you notifications about tasks, for marketing purposes and to administer the Platform. You may be liable for standard SMS and per-minute charges by your mobile carrier. MwalimuPLUS may also message you via “Push” messaging, which you can opt-out of on your mobile device. Data rates may apply.
You can opt out of receiving certain promotional communications from MwalimuPLUS sent via text message at any time by following the instructions provided in text messages from MwalimuPLUS to text the word, “STOP”. Please note that your opt-out is limited to the phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt-out of receiving promotional communications, MwalimuPLUS may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or MwalimuPLUS ’ ongoing business relations.
Unless otherwise described in this Policy, we may also share the information that we collect from you through the Platform as follows:
- Affiliates. We may share your information with any MwalimuPLUS affiliates.
- Service Providers. We may provide access to your information to select third parties who perform services on our behalf. These third parties provide a variety of services to us including without limitation billing, sales, marketing, advertising, market research, fulfilment, data storage, analysis and processing, identity verification, fraud and safety protection and legal services. As we retain new service providers, we generally seek contractual assurances from these service providers that they will not use your information in any manner other than to help us provide you with the services and products available from MwalimuPLUS .
- Legal Requirements. We may disclose your information when required by law or when we believe in good faith that such disclosure is necessary to: (a) comply with court orders, or other legal process we receive; (b) establish or exercise our legal rights including enforcing and administering agreements with users; or (c) defend MwalimuPLUS against legal claims. If we are required by law to disclose your information, we will use commercially reasonable efforts to notify you unless (a) we believe in our sole discretion that providing notice could create a risk of injury or death, or that harm or fraud could be directed to MwalimuPLUS or users; or (b) we are precluded from providing notice by law. We will attempt to provide the notice by email if you have given us an email address. If you do not challenge the disclosure request, we may be legally required to turn over your information.
- Business Transfers. As we continue to develop our business, we may sell, buy, merge or partner with other companies or businesses, or sell some or all of our assets. In such transactions or where there is any change of control of MwalimuPLUS, user information may be among the transferred assets.
- App Store Providers. We may provide your identity and mobile device identifier to third-party app store providers (for example, the Apple App Store) to allow you to download our mobile apps.
- Academics and Research. We may provide information about users to third parties for academic and research purposes, in anonymized or aggregated form.
Please be advised that some information you provide will be publicly accessible. For instance, registration for an Account requires that you provide us with your name. Your name (full name, or in some instances, your first name and last initial) may be visible to other users. Depending on the circumstances, your name may be attached to your Content or information, Certain other people, including other users with whom you have interacted via the Platform, will see information about you that is attached to your name. For example (but without limitation), if you are registered in a class, your name will be shown to other members of the class. Thus, other users may be able to personally identify you based on Content you provide.
MwalimuPLUS collects limited personal information from minor students only where that student’s school, district, or teacher has contracted with MwalimuPLUS to collect personal information for the use and benefit of the learning environment. This information is not shared outside of the school or with any third parties except those needed for the provision of the service as outlined in this policy. Students of any age cannot share their profiles publicly outside of their classroom or school.
We invite you to post Content on or through our Platform, including, but not limited to, your comments, pictures, and any other information. However, please be careful and responsible whenever you are online. If you choose to post User Content on or through the Platform, such as through our review boards, forums, blogs, or other postings, that information: (a) may be or may become publicly available; (b) may be collected and used by third parties without our knowledge; and (c) may be used in a manner that may violate this Policy, the law, or your personal privacy.4. Analytics and Advertising Analytics
We may use third-party web analytics services on the Platform, such as but not exclusively, those of Google Analytics. These service providers use the sort of technology described in the ‘Information That Is Passively or Automatically Collected’ section above to help us analyse how users use the Platform, including by noting the third-party website from which you arrive. The information collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Platform. We also use such analytic services for certain purposes related to advertising, as described in the following section. To prevent these third party service providers from using your information for analytics, you may install the Google Analytics Opt-Out Browser Add-on or any other similar program or widget that would convey a similar effect.Tailored Advertising
When using a mobile application, you may also receive tailored in-application advertising content. Each operating system-iOS for Apple devices, Android for Android devices, and Windows for Microsoft devices-provides its own instructions on how to prevent the delivery of tailored in-application marketing content. You may review the support materials and/or the privacy settings for the respective operating systems in order to opt-out of tailored in-application advertising. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact the applicable platform operator.5. Privacy of Minors
Our services are essentially designed for minors, however only persons 18 years of age or older may register on the Platform. If we discover that an individual under 18 has registered on the Platform, we will close the account and delete the personal information to the extent required by the Laws of Kenya. We may, where permitted by law, retain certain information internally for purposes described in this Policy.6. Security
We employ appropriate physical, procedural and technological security measures, which are reasonably designed to help protect your personal information from unauthorized access or disclosure. MwalimuPLUS may use encryption, passwords, and physical security measures to help protect your personal information against unauthorized access and disclosure. No security measures, however, are 100% failsafe. Therefore, we do not promise and cannot guarantee, and thus you should not expect, that your personal information or private communications will not be collected, disclosed and/or used by others. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, logging off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, keeping your log-in and password private, and not recycling passwords from other websites or accounts. MwalimuPLUS is not responsible for the unauthorized use of your information nor for any lost, stolen, or compromised passwords, or for any activity on your Account via unauthorized password activity.
MwalimuPLUS is committed to the personal information of the customer. We will never ask for any password information from users and you are advised, in order to protect access to accounts and other channels, not to disclose passwords to any person. The MwalimuPLUS Platform may generate a default password which you will be required to change after your initial access. Please choose passwords that are sufficiently complex to mitigate the risk of unauthorised access by any third parties. Please use alpha numeric passwords with combination of upper case alphabets and numbers and special characters.
The password is private information and must be kept confidential.
MwalimuPLUS undertakes not to disclose the information provided by the customer to any person unless such action is necessary to the extent required by law and for regulatory purposes.
If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.7. Links to Other External Platforms
This policy is current as of the effective date set forth above. MwalimuPLUS may, in its sole and absolute discretion, change this policy at any time. MwalimuPLUS will post its updated policy on the platform, send you a message or otherwise notify you when you are logged into your account in advance of the new effective date. MwalimuPLUS encourages you to review this policy regularly for any changes. Your continued access to or use of the platform will be subject to the terms of the then-current policy.11. Consent Transfer
Our computer systems are currently based in Kenya, so your personal data will be processed by us in Kenya, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world, such as the European Union. If you create an Account with the Platform as a visitor from outside Kenya, by using the Platform, you agree to this Policy and you consent to the transfer of all such information to Kenya, which may not offer a level of protection equivalent to that required in the European Union or certain other countries, and to the processing of that information as described in this Policy.12. Contact Us