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KODRIS AFRICA PRIVACY POLICYS

Kodris Africa Consulting Limited (hereinafter "Kodris Africa") is a company that presents the “Kodris Africa Web 1.0” version platform, which made available to the public for use on 01.06.2022, that consists of 250 screens and provides the opportunity to learn computer science at primary, middle and high school level students within the specified time period. As a part of that mission, Kodris Africa operates the websites located at https://kodrisafrica.com, information, text, curricula, videos, graphics, photos, APIs, email notifications and other materials and related products and services (the “Services”).

Your privacy is important to us. Kodris Africa’s Privacy Policy explains on what personal data we collect, why we collect it, and what we do with it. Moreover, we want you to know your rights regarding this personal data. Please read the Privacy Policy carefully for information relating to Kodris Africa’s collection, use, and disclosure of your personal information as well as the administrative, technical and physical safeguards we maintain to protect against unauthorized use, disclosure of or access to personal information before accessing or using the Website. If you have any questions, you can contact us at https://kodrisafrica.com/contact.html or [email protected]

Kodris Africa Privacy Principles

Our Privacy Policy is fuelled by our commitment to the following Privacy Principles:

  1. We’re deeply committed to creating a safe and secure learning environment for our students and teachers. We take the protection of this information seriously.
  2. We do not require you to provide any Personal Information in order to try our courses (only your IP address is collected). However, learning progress won't be saved without creating an account.
  3. The only reason we collect any data from Students or Teachers is to better succeed at our mission of providing a great computer science education for every student in every school.
  4. We do not sell your Personal Information; we do not sell ads.
  5. Any Student academic data provided by us or by our school partners to third party evaluators for the purpose of evaluating our courses in meeting our mission will be de- identified (per standard industry practice).
  6. We strive to provide you with access to and control over the information you give us (as detailed below), and we take the protection of your information very seriously.
  7. When student Personal Information is provided to Kodris Africa by a school, Kodris Africa agrees to retain such information as directed by the school.
  8. We hold our partners to privacy and security practices no less stringent than our own.

Privacy Policy

We are committed to creating a safe and secure environment for learners of all ages on our website located at kodrisafrica.com (“Website”). Visitors and users of the Website and participants in our education programs are referred to individually as “User” and collectively as “Users”. Any User that creates a student account is referred to as “Student”. Similarly, any User that creates a teacher account is referred to as “Teacher.” We use the data we receive only insofar as it helps our mission of providing a great computer science education for every student in every school.

Our Privacy Policy describes what information we gather from our Users, how we use that information, and what we do to protect it. Your use of the Website and any information you provide on the Website are subject to the terms of this Privacy Policy, which is incorporated into and subject to our Terms of Service. Any capitalized terms used but not defined within this Privacy Policy have the meaning given to them in our Terms of Service. By visiting or using our Website, you expressly consent to the information handling practices described in this Privacy Policy.

Any version of these Term in a language other than English is provided for convenience and you understand and agree that the English language will control if there is any conflict.

These Terms (including any agreements and policies linked from these Terms) constitute the entire agreement between you and us.

Collection and Use of Your Information

The sections below describe the ways Kodris Africa collects and uses personal data, which refers to any information that identifies you as an individual (directly or indirectly). This includes things like the name, display name, email address, school name and address, telephone number, etc. from Users (“Personal Information”), persistent cookies or IP addresses (“Persistent Identifiers”), as well as some of the non-Personal Information and technical information (described below) we collect. We collectively refer to any of this data we collect from Students, along with any Student information, Student records, and Student-generated content as “Student Data.”

Our collection, use, and disclosure of your data are governed by our Privacy Policy and Terms of Use and also by Data Protection Act of Kenya (referred to under this information sheet as “DPA”), and any other applicable Legal Framework. Kodris Africa shall not use Student Data for any purposes other than those authorized pursuant to our Terms of Service and Privacy Policy.

Kodris Africa does not collect any Personal Information from students participating in the tutorials unless they choose to create Kodris Africa accounts. Tutorials do not require login to use.

Kodris Africa accounts: The following table describes the data that Kodris Africa collects from registered Users of Kodris Africa.com courses. You can also try Kodris Africa courses without creating an account, but your learning progress won't be saved and will be limited.

Data stored by Kodris Africa if you create a Kodris Africa Student account How and when is the data collected How this data is used
Display Name (e.g., “CoderNairobi” or “Mugumo””) and username (eg "codernairobi400") Required by User (or their Teacher) on account creation Display name is used to provide Students a welcoming login and to identify the Student in the Teacher’s view of student progress.
Student email address Email address is required on account creation if Student signs up directly. A Student's email address is only used for the purposes of login. See section on "Student Email Addresses" below for more details.
Parent or guardian email address Can be optionally provided by parent to create a login for their child at home. A Student may want to create a personal login to access their account independently of their Teacher or school, especially if the Teacher decides to delete the classroom section that the Student belonged to or the Student signs in with an account like Google, Twitter, Github or Facebook.
If the Student is under 13, we require a parent email address for password recovery. The Student will then be able to sign in at home with a username and password.
Login time, IP address, and other technical data Automatically collected as the site is used. This data helps Kodris Africa troubleshoot any problems Users experience. It also helps Kodris Africa understand usage patterns, ensure the service can support all Users, and enable site updates with minimal service disruption. See section below on “technical information” for additional details.
Progress in the course
1.Date/Time each lesson is tried
2.Number of tries to solve a level, and whether it was solved successfully or optimally
3.Information on how the Student solved the level including time to completion and whether they used hints
4.The code that the Student submitted		 Collected as Students work through a tutorial or course progression. This information is displayed to Students and their Teachers to see their progress in a course, to see the code they’ve created, and to identify topics they need help with. It also lets Students pick up where they left off if they sign out and sign in later.
This data, in de-identified form, also helps Kodris Africa improve course effectiveness. For example, if a level is too hard, Kodris Africa may take action (like providing better hints) to improve the learning process.
Data stored by Kodris Africa if you create a Kodris Africa Teacher account How and when is the data collected? How this data is used
Email address Email address is required on account creation A teacher’s email address is only used for the purposes of login.
All non-transactional emails sent by Kodris Africa contain an unsubscribe link and do not require typing a password to unsubscribe.
School name and/or school type (private, public, after school, or other) and/or school address Provided by the Teacher on account creation. At the Teacher's option and under their control, we would list their school in the Kodris Africa map and database of schools that teach computer science courses.
Kodris Africa may also use this information to reach out to the Teacher's school to discuss broader education partnerships or participation in special events.
Student section data Collected if Teacher decides to create a section on Kodris Africa to manage their Students. The Teacher may create accounts for their students (and provide each Student’s display name and optionally their age), and organize these Students into sections. The Teacher may assign each section a display name, a course assignment, and grade level. Th e section grouping data is used to simplify their view of Students across multiple sections
Teachers are encouraged to share a document with Students and parents informing them about the Kodris Africa course, including the privacy implications.

Students and Teachers may update, correct, or delete Personal Information in their Kodris Africa accounts at any time via the account settings page. Teachers also have the ability to reset the password of any Student in their section. A parent or legal guardian of a Student under the age of 18 may also review Personal Information and correct erroneous information, if any, by asking the Student or Teacher to access the Student account.

Teachers can create accounts on behalf of Students. When registering an account for a Student who is under the age of 16 (a “Child”), the Teacher represents and warrants that they or the educational organization they work for has proper permission to register the Child for Kodris Africa, and that they or the educational organization has obtained the necessary parental consent for collection of some of the Child’s Personal Information for the use and benefit of the school and for no other commercial purpose. In addition, they agree to be bound by this Privacy Policy on behalf of the educational organization they work for, and are authorized to do so.

Student Data of any Student that is in a Teacher's section will continue to be under the control of the Teacher. Teachers can get access to the User's course progress, display name, and their email address If the user's account is associated with the Teacher’s section.

In order to allow Users to recover deleted accounts, we will save progress, code creations and data for a period of time. A User can email [email protected] to request permanent deletion of their account and all the associated data. A Teacher may also request the deletion of Student accounts or particular Student projects or Student Data the same way.

Information from Third Party Authentication Services

If you decide to register for a Kodris Africa account through an Authentication Service (such as Google Accounts, Microsoft Accounts or Facebook Connect), you give Kodris Africa the permission to store and use information already associated with your Authentication Service consistent with this Privacy Policy and the table above.

You may revoke Kodris Africa’s access to your account on any Authentication Service at any time by updating the appropriate settings in the account preferences of the respective Authentication Service. You should check your privacy settings on each Authentication Service to understand and change the information sent to us through each Authentication Service. Please review each Authentication Service’s terms of use and privacy policies carefully before using their services and connecting to our Website.

Information from Other Sources

In certain situations, we may obtain information, including Personal Information, from third parties or sources other than the Website. For example, if you make your payments to Kodris Africa via M-PESA, PayU or credit card, we may obtain your name and mailing address to send a thank you note. If we combine or associate information from other sources with Personal Information that we collect through the Website, we will treat the combined information as Personal Information in accordance with this Privacy Policy.

Technical Information

To provide a personalized learning and high-quality experience for our Users, we may use various technologies that automatically record certain technical information from your browser or device, including browser language settings, standard log files, web beacons, or pixel tags. This technical information may include your Internet Protocol (IP) address, browser type, internet service provider (ISP), referring or exit pages, click stream data, operating system, and the dates and times that you visit the Website. This information assists us in understanding how our Users are using our Website.

To track information about use of our Sites, we use various technological tools. For example: Like most websites, whether or not you are a registered member, we may send one or more cookies – small text files containing a string of alphanumeric characters that save to your computer or mobile device when you visit our Website. Cookies are small data files set up in your computer by a web server, via your browser. Web sites use cookies to recognize you when a connection is established between your browser and the server. Cookies are designed to make a web site more convenient to use for its visitors. There are four types of cookies classified according to their purpose of use: Essential Cookies, Performance Cookies, Functional Cookies, and Analytical Cookies.

Generally, Internet browsers are predefined to accept cookies automatically. Browsers can be adjusted to block cookies or to warn the user when cookies are sent to the device. As the management of cookies may vary from browser to browser, please refer to the help menu of Your browser for further information.

You can visit www.allaboutcookies.org for detailed information about deleting and blocking cookies and for more general information on cookies.

Third Party Service Providers

Kodris Africa may use a variety of third-party service providers, such as email services to send email, analytics companies to understand our Website usage, and social networking platforms to host our videos. We may allow third-party service providers to place and read their own cookies, web beacons, and similar technologies to collect information through the Website. This technical information is collected directly and automatically by these third parties.

We use third party services to implement our Website and all of its associated services and features, including (but not limited to) Yandex (for website hosting and data storage), [email protected] (for sending email), [email protected] for customer support), Roamtech Solutions Limited (for sending User code-creations and/or tokens to phones), PayU for payments), and Google Analytics (for understanding how our Website is being used). Personal data will be used and stored by these third parties solely in context as an implementation services provider to Kodris Africa, but these third parties will not receive any ownership or have any other rights to access or use this personal data. In particular, when we use Roamtech Solutions Limited to send text messages to deliver User code-creations to phones, Kodris Africa store the phone number, and it is possible that underlying phone-service providers may retain this information.

Kodris Africa does not allow advertising on our Website, and we do not have the ability to collect your web search history across third-party Internet websites or search engines. However, if you navigate to the Kodris Africa Website via a web search, your web browser may automatically provide to us the web search term you used in order to find Kodris Africa. Using an account third party social networking services, such as Facebook and Twitter, is entirely at your option and under your control.

Certain capabilities linked from the Kodris Africa Website may be implemented by third parties who collect data. For example, purchase to Kodris Africa are processed via a third party who collects and may store the payment instrument.

Other third-party websites, such as the Kodris Africa Facebook page and Twitter page, may be co-branded with our name or logo. Use of these third-party services are completely optional to Users, typically meant only for adults, and governed by the privacy policy of these third parties. We encourage you to review the privacy policy at the third parties for details about how they may collect, store, and use your Personal Information.

Uploading Custom Content

Student and Teacher profiles can NOT be customized with a photo.

Information We Do NOT Collect

Kodris Africa does not directly collect or store payment instruments. We only receive payment fail information (such as ‘3D secure failed’) by the bank.

Student Email Addresses

When User accounts use a Student email address for login, Kodris Africa store the email address provided by those Users. We store the e-email address, and use it only for the purposes of login, account management, and password recovery. The main circumstance when Kodris Africa's servers receive a Student's Kodris Africa email address is if the Student forgets their password and asks to reset it. At that point, the Student is prompted to enter their email, which is used to send them a password reset link.

If a User contacts us via our customer support pages, we will also store and use their email address in order to respond to them.

Children Under Age 16

We recognize the privacy interests of children and encourage parents and guardians to take an active role in their children’s online activities and interests. Children under the age of majority should review this agreement with their parent or guardian to ensure that the child and parent or legal guardian understand it.

We take steps to minimize the collection of personal data from Users under the age of 16, as explained in the Kodris Africa privacy policy. Users under the age of 16 are required to get the approval of a parent or legal guardian before creating an account on Kodris Africa. Kodris Africa allows certain representatives of schools, such as teachers, administrators, counselors, and other educators (an “Educator”) to connect with their students through the Services in order to provide tutorial, educational and similar services. If you are an Educator, you may register accounts on the Services for one or more of your students.

If you are an Educator and you register an account for a student who is under the age of 16 (a “Child”), you represent and warrant that you or the educational organization you work for has proper permission to register the Child for Kodris Africa, and that you have obtained the necessary parental consent for Kodris Africa’s collection of the Child’s personal information for the use and benefit of the school and for no other commercial purpose. In addition, you agree to be bound by these Terms on behalf of the educational organization you work for.

Personal Information or Persistent Identifiers, and request that we no longer allow the Student to submit their information to Kodris Africa. To make such a request, please contact us at https://kodrisafrica.com/contact.html Before processing your request, we may verify your identity and your relationship with the Student.

Limitations on Access to your Personal Information by Employees and Authorized Parties

Kodris Africa’s officers, directors, employees, agents and contractors must have a legitimate business reason to access Personal Information you provide to Kodris Africa, for example to assist in product support. Kodris Africa will require our officers, directors, employees, agents, and contractors to comply with this Privacy Policy, and to treat any Personal Information of Kodris Africa Users as confidential information.

How We Share or Transfer Data

We do not rent or sell Personal Information, Persistent Identifiers, or any other information that we collect from Users, or exploit it for financial gain in any other way. Kodris Africa will never share or grant rights to Personal Information with other third-party organizations to use without your consent, except as part of a specific program or feature for which you will have the explicit ability and choice to opt-in.

Whenever we share Student personal data, we hold our partners to privacy and security practices no less stringent than our own.

We may share Student data with your Teacher and limited Teacher information with the Student

If a Student belongs to a Teacher’s section, we will share Student account information, course progress, and standalone projects with that Teacher so the Teacher can help manage the Student’s progress. The Student will also see limited information about their Teacher including their Teacher’s display name and section information.

We may share Classroom usage and Student achievement data with your school

In order to support school needs to oversee Kodris Africa usage in their classrooms, we may allow your school to access reporting data on student progress and achievement, presented on a student-level, classroom-level, teacher-level, grade-level or school-level basis for Students enrolled.

We may share limited information when you contact us for support

When you contact us with a support request, you may provide Personal Information, which is shared with a Kodris Africa support representative in order to process your request. Kodris Africa support representatives are either employees or independent contractors of Kodris Africa, and will always have signed a contract requiring them to protect and not disclose confidential information including Personal Information of Users, and to use it only in the context of resolving your product support requests.

We may share de-identified data to improve our services and learn more about our Users

In certain occasions, Kodris Africa may work with third parties (such as universities and education research organizations) to improve our services or offerings. We may disclose automatically collected and other aggregated and de-identified non-Personal Information to authorized partners to conduct research on online education or assist in understanding the usage, viewing, and demographic patterns for certain programs, content, services, promotions, and/or functionality on the Website. We require any research partner that receives de-identified data from us to agree in advance that they will not attempt to use this data to identify our Users.

We will share data when required by law

Kodris Africa may also disclose User data including Personal Information or Persistent Identifiers if required to do so by law, or if we have a good-faith belief that such action is necessary to comply with local, state, federal, international, or other applicable laws or respond to a court order, judicial or other government order, subpoena, or warrant, or administrative request. In some cases, we may make such disclosures without first providing notice to Users, Teachers, schools, parents or legal guardians.

We may share data when necessary or appropriate to protect Kodris Africa or others

Kodris Africa may disclose User data including Personal Information or Persistent Identifiers that we believe, in good faith, is appropriate or necessary to: take precautions against liability; protect Kodris Africa from fraudulent, abusive, or unlawful uses; investigate and defend ourselves against any third-party claims or allegations; assist government enforcement agencies; protect the security or integrity of the Website; or protect the rights, property, or personal safety of Kodris Africa, our Users, or others.

We may share data in the context of a change of business, including a merger or acquisition

In the event that Kodris Africa is acquired by, combined or merged with another entity, we may transfer or assign the Personal Information and Persistent Identifiers that we have collected from Users as part of such merger, acquisition, sale, or other change of control. Our promise to you is that any Personal Information and Persistent Identifiers we have collected from Users would be safeguarded by the acquiring organization under the same level of safety and privacy as afforded by this Privacy Policy.

Our Approach to Data Security

Website security is important to you, and to us

TTo protect your privacy and security, we take reasonable steps to verify your identity before granting you account access or making corrections to your Personal Information. If you have any questions about how we handle or protect your personal data, please contact us.

We try to ensure that our Website and information sent to us are safe, but no security measures are perfect

Kodris Africa uses certain physical, administrative, and technical safeguards designed to reasonably protect the confidentiality, availability, integrity and security of your Personal Information, Student Data, and other information we maintain in connection with the Website in such a manner that processing will meet the requirements of national, international or other applicable laws and ensure the protection of your rights. These safeguards include restrictions on physical access to the data center, hardened system configuration, two-factor authentication, patch management, disaster recovery process, employee security and privacy training, and employee background checks. We cannot, however, ensure or warrant the security of any or all of the Personal Information and other information you transmit to Kodris Africa, and you do so at your own risk. Once we receive your transmission of information, Kodris Africa maintains and enforces commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such Personal Information and other information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

If we learn of a data security incident that compromises or appears to compromise your Personal Information or that of your Students, then we will attempt to notify you electronically so that you can take appropriate protective steps.


Conditions of Use and Notices

If you choose to visit our Website, your visit and any dispute over privacy is subject to this Privacy Policy and our Terms of Service, including limitations on damages, arbitration of disputes, application of the law of Republic of Kenya and venue for all disputes in Nairobi.

If any provision of this Privacy Policy or our Terms of Service is held invalid by a court of competent jurisdiction, the remainder of this Privacy Policy and our Terms of Service will remain in full force and effect.

No Commercial Use of Student Data

Kodris Africa shall not use, disclose, or compile any student Personal Information for the purpose of advertising commercial products or services. We do not disclose any student Personal Information to third parties for marketing purposes.

You can review or delete your Personal Information at any time

We keep your personal data only as long as necessary or for the purposes for which it was collected or as required under any contract or by applicable law.

If, at any point, you wish to access, amend, export (i.e., data portability), or object to or restrict the processing of Personal Information collected via our Website, send us a request at https://kodrisafrica.com/contact.html We will promptly review all such requests in accordance with applicable laws.

Furthermore, there is a buffer period before permanent deletion of your account (to allow for account recovery in case a teacher or student accidentally deleted an account.) You can contact us to have any account permanently deleted sooner.

We also automatically delete any Personal Information associated with inactive Student or Teacher accounts per our data retention policy.

sociated with inactive Student or Teacher accounts per our data retention policy.

How to delete your Kodris Africa Account

If you would like to delete your Kodris Africa account or any content submitted to Kodris Africa, please send an email to [email protected].

Storing and protection of personal data

Your personal data will be stored in Kodris Africa’s data base and systems as a confidential data in accordance with the Article 12 of DPA, and your personal data will not share except with any methods above mentioned.

Updates to our Privacy Policy

From time to time our Privacy Policy will change. Kodris Africa will notify Users of any change to our Privacy Policy by posting the revised Privacy Policy with an updated date of revision on our Website. If we make any significant changes to the policy these will be called out with a short notice of the revision conspicuously posted on the Website homepage. We may also contact Users and notify them of the changes if required by law. We stand behind the promises we make, and will not change how we use any Personal Information we have already collected from Users in any material way without also providing notice of the change via email, through this Website, or through other means, and obtaining consent via your continued use to any new policies. We take the protection of the personal data you provide to us very seriously, and we strive to put you in control of decisions around your personal data.

Contacting Kodris Africa

Please contact Kodris Africa with any questions or comments about this Privacy Policy, your Personal Information, our third-party disclosure practices, or your consent choices by writing us at;

Title:Kodris Africa Consulting Limited

Address: Kenrail Towers Westlands, Ring Road Mkungu Close, 7th Floor, Northern Wing P.O Box 60447-00400 Nairobi, Kenya

Telephone: 0795 555 999

Website: https://kodrisafrica.com

E-mail: [email protected]

Kodris Africa

+254 795 555 999

+254 111 133 200

[email protected]

[email protected]

www.kodrisafrica.com

Kodris Africa - Kenrail Towers, Nairobi

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