Privacy Policy

Your privacy is important to us. Learn how we protect and manage your personal information.

1

Introduction

ShuleGram ("we," "our," or "us") is committed to protecting the privacy and security of all users of our educational social platform. This Data Protection Policy outlines how we collect, use, store, and safeguard the personal information of Learners (students), Parents, and Teachers ("you" or "your") in compliance with the Kenya Data Protection Act, 2019, and other applicable regulations.

Your Agreement

By using ShuleGram, you agree to the practices described in this policy. We encourage you to read this policy carefully to understand how we protect your information.

2

Definitions

Key terms used throughout this policy:

Learner: A child under the age of 18 whose educational data is shared on the platform.
Parent/Guardian: The legal guardian of a Learner, responsible for providing consent for the Learner's data processing.
Teacher/Educator: An authorized school staff member who uses the platform to share educational content.
Personal Data: Any information relating to an identified or identifiable natural person.
Sensitive Personal Data: As defined by the Data Protection Act, including data on a child's health, biometric data, and well-being.
3

Data We Collect

Account Information
Teachers
  • Name, email, phone number
  • School affiliation
  • TSC number for verification
Parents
  • Name, email, phone number
  • Relationship to the Learner
Learner Profile Information

Provided by the school or Parent:

  • Name, age, grade, class
  • Profile picture

Important: Explicit parental consent is required before any Learner profile is created or data is processed.

User-Generated Content
  • Photos, videos (including live streams), captions, and comments
  • Learning materials uploaded by Teachers or Parents
  • Work showcased by Learners (e.g., poetry, art) with Teacher and Parent approval
Technical and Usage Data
  • Device information and IP address
  • App crashes and performance logs
  • Analytics on feature usage to improve our services
Marketplace Data

For Tutors/Counselors:

  • Service descriptions
  • Qualifications and verification documents

For Transactions:

  • Booking requests
  • Transaction records (via secure third-party processors)
4

How We Use Your Data

We process your data based on lawful grounds and for specific purposes:

Purpose of Processing Lawful Basis
To provide core app functionality (e.g., sharing updates, live streams) Performance of a Contract & Consent (explicit consent for Learners)
To facilitate the services marketplace and process payments Performance of a Contract & Legitimate Interests
To utilize AI features (translation, behavior analytics) Explicit Consent (opt-in required for analytics)
To send notifications about a Learner's activities (e.g., live stream alerts) Legitimate Interests (vital interest of the Parent)
To ensure platform security and prevent misuse Legitimate Interests & Legal Obligation
For product development and troubleshooting Legitimate Interests
5

Data Sharing and Disclosure

We Do Not Sell Your Data

Your personal data is never sold to third parties. We share data only under strict, transparent conditions.

Within the Educational Circle

A Learner's data (photos, videos, updates) is shared only with:

  • Their verified Parents
  • Authorized Teachers at their school
With Service Providers

We use trusted third-party providers for:

  • Cloud Hosting: AWS
  • Live Streaming: AWS IVS
  • Payment Processing: M-Pesa, Stripe
  • Analytics & Translation: APIs

These partners are bound by strict data processing agreements.

For Legal Reasons

We may disclose data if required by Kenyan law or to protect the vital interests of a user.

6

Special Provisions for Children's Data

Our Highest Priority

The protection of Learner data is our highest priority. We implement multiple safeguards to ensure children's safety.

Verifiable Parental Consent

We require school-verified or digitally verified consent from a Parent before a Learner's profile is activated.

Limited Profile Access (Ages 10+)

Learner profiles for children over 10 that allow them to showcase work are subject to a "double-approval" system, requiring both Teacher and Parent consent before any content is made visible.

Privacy Safeguards in Media
Facial Blurring

Automatic blurring in group photos for children without consent

View-Once Mode

Sensitive content viewable only once, not saved to device

Digital Watermarking

All media watermarked to deter unauthorized redistribution

7

Data Security

We implement robust technical and organizational measures to protect your data:

Encryption
  • Data in transit (TLS)
  • Data at rest
Access Controls
  • Secure authentication
  • Role-based permissions
Security Testing
  • Regular assessments
  • Penetration testing
Staff Training
  • Data protection training
  • Security best practices
8

Data Retention

We retain personal data only for as long as necessary to fulfill the purposes outlined in this policy, or as required by law.

Live Stream Recordings & Media

Retained for a period defined by the school and Parent agreement (e.g., 1 academic year), after which it is automatically anonymized or deleted.

Account Data

Deleted upon user request or after a period of account inactivity.

9

Your Data Rights

Under the Kenya Data Protection Act, you have the following rights:

Right to Access

Access and receive a copy of your personal data

Right to Rectification

Rectify inaccurate or incomplete data

Right to Object

Object to or restrict the processing of your data

Right to Erasure

Request deletion of your data ("Right to be Forgotten")

Data Portability

Receive your data in a portable format

Withdraw Consent

Withdraw consent at any time

Exercise Your Rights

To exercise these rights, please contact us at dpo@shulegram.co.ke

10

International Data Transfers

Data is primarily processed within Kenya or the East African Community.

Safeguards

If any data transfer outside this region occurs, we will ensure it is protected by adequate safeguards as required by Kenyan law.

11

Policy Updates

We may update this policy periodically. We will notify users of any material changes via the app or email and will require renewed consent where necessary.

12

Contact Information

Data Protection Officer

For any questions, concerns, or requests regarding this policy or your data

dpo@shulegram.co.ke
Lodge a Complaint

You also have the right to lodge a complaint with the Office of the Data Protection Commissioner (ODPC) of Kenya.