Privacy Policy

Introduction

MwalimuDocs ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains what information we collect when you use MwalimuDocs, why we collect it, who processes it on our behalf, where it is stored, and the rights you have over it.

By using MwalimuDocs, you agree to the collection and use of information in accordance with this policy. If you do not agree with it, please do not use our services.

This policy is written to meet the Kenya Data Protection Act 2019. The data controller is MwalimuDocs. You can reach us at support@mwalimudocs.com.

Information We Collect

Teachers and school staff

• Account information: Your name, email address, phone number and password. Your password is stored only in a scrambled (hashed) form that we cannot read
• Professional information: Your school, the grades, streams and subjects you teach, and your role at the school
• Content: Lesson plans, schemes of work, lesson notes, records of work, quizzes, rubrics and any other documents you create or customise
• Account history: Your balance, the documents you have generated, and whether you joined through a colleague's invitation or a field representative

If you try MwalimuDocs as a guest, we hold your name, email address, phone number and school.

Schools

When a school enquires or signs up, we hold the contact person's name, role, email address and phone number, the school's county, and the principal's name and contact details. A school may upload a staff list with each teacher's name, email address, phone number and subjects so that we can invite them.

Learners and their guardians

Where a school keeps its records on MwalimuDocs, we hold on its behalf:

• Learner details: Name, date of birth, gender, admission number, UPI and KNEC assessment number, grade, class, stream and, for Senior School, pathway
• Guardian details: Name, relationship to the learner, phone numbers, email address and National ID number
• School records: Attendance, assessment results, photos and videos of learners' work used as assessment evidence, and library loans
• Special needs education: For schools using the special-needs module, EARC assessment reports, disability categories, functional assessments, accommodations, and individualised education programmes with the goals and progress recorded against them

Field representatives

If you apply to represent MwalimuDocs, we collect your name, email address, phone number, county, and the CV and statement you send with your application. Once you are accepted we also collect your National ID number and KRA PIN, scans of both, and the M-Pesa number your commission is paid to. We need these to verify who is carrying our Letter of Introduction into a school, to pay you, and to meet our tax reporting obligations. Your identity documents are held for that and nothing else, and are never shown to schools or to other representatives.

We also keep a record of each agreement you accept, your training results, and your commission and withholding tax history. Our public verification page shows only your name, your agent code and the area you are authorised to work in.

When a representative records a teacher they have spoken to, we hold that teacher's phone number, school and subject, and the representative's notes, so that a later sign-up can be credited to the right representative.

Payments

When you pay, we record the phone number you pay from, the mobile network, the amount and the payment reference. The phone number is deleted automatically after 30 days; the amount and reference stay in your transaction history. We never see or store your mobile money PIN.

Automatically collected information

• Device information, such as your browser and operating system
• Log data, such as your IP address and the time of each request. We record the IP address and browser alongside each purchase and each document delivered, and use IP addresses to limit abuse
• Usage data, such as the pages you visit and the features you use

How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve our services
• Generate lesson plans, schemes of work and other documents for you
• Process payments and keep your balance and transaction history
• Send you emails about your account, your documents and your payments
• Respond to your questions and support requests
• Understand how the platform is used, so that we can improve it
• Detect, investigate, and prevent fraud and abuse
• Verify, train and pay field representatives

We do not send marketing email, and we do not use your information for advertising.

How We Use AI

Your documents are written by AI models. To write a document, the model receives what it needs: the curriculum details you choose and the instructions you give.

Some features send learner information to the model, because the feature cannot work without it:

• Individualised education programmes: the learner's name, grade, age, disability categories and assessment details
• EARC assessment reports: the report a teacher uploads, so that its details can be read into the learner's record
• AI marking: photos or scans of the learner's work

Information sent to the AI models is not used to train them, by us or by the provider that runs them, and we do not use learners' data to profile them.

Information Sharing

We do not sell, trade, or rent your personal information to anyone. We share it only in the following situations:

• A cloud hosting provider stores our data and uploaded files, sends our email, generates PDF documents, and runs our AI processing
• A website hosting provider hosts the website and measures its usage and performance without cookies
• Google provides Google Analytics, which tells us how the site is used; reCAPTCHA, which protects our sign-up and enquiry forms from automated abuse; and the fonts the site is displayed in. We run Google Analytics with IP anonymisation on and advertising features off, and we do not send it your name, email address or phone number
• Licensed payment processors process mobile money payments by M-Pesa and Airtel Money. They receive the phone number you pay from, and may also receive your email address. They also pay field representatives' commission to their M-Pesa number
• Your school: If you are part of a school account, your school's administrators can see the documents you create and how you use the platform
• Legal requirements: We may disclose information if required by law or in response to valid requests by public authorities
• Business transfers: In connection with any merger, sale of company assets, or acquisition

Each of these service providers acts on our instructions only. When we search for images to illustrate a document, the image services receive only the search terms, never information about you.

You can ask us for the current list of our service providers, and we will tell you who they are. Write to support@mwalimudocs.com.

Data Security

We use appropriate technical and organisational measures to protect your personal information, including:

• Encryption of data in transit and at rest
• Access controls, so that people see only the records their role requires

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

Where Your Data Is Stored

Your data is stored in Canada, by our cloud hosting provider. When an AI model writes a document, the request may be processed in other regions around the world, and the website itself is delivered through our website hosting provider's global network. That means your personal data is stored and processed outside Kenya, and this is a cross-border transfer within the meaning of the Data Protection Act 2019.

We rely on the safeguards in our agreements with these providers, which bind them to process the data only on our instructions and to protect it to standards appropriate to the Act. Data is encrypted in transit and at rest. If you would rather your data did not leave Kenya, we cannot offer that, and you should tell us before you sign up.

Data Retention

We keep your personal information for as long as your account is active or as needed to provide you services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. The phone number you pay from is deleted after 30 days.

You may ask us to delete your account and the data associated with it at any time by writing to support@mwalimudocs.com. A school decides how long its learners' records are kept. Where you are a field representative, we keep your identity records for as long as the law requires us to hold tax records, and no longer.

Your Rights

You have the right to:

• Be informed: Know how your personal information is used, which is what this policy is for
• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete data
• Deletion: Request deletion of your personal information
• Objection: Object to our processing of all or part of your personal information
• Data portability: Request a copy of your data in a portable format

To exercise any of these rights, write to support@mwalimudocs.com. We will respond within the period the Data Protection Act 2019 allows, and we will not charge you for it.

If you are not satisfied with how we have handled your data or your request, you have the right to complain to the Office of the Data Protection Commissioner. You do not need our permission and you do not need to come to us first.

Children's Data

Many of the learners whose records schools keep on MwalimuDocs are children. If a school enables student or parent accounts, learners and their parents or guardians may also sign in themselves.

We handle learners' data on the school's instructions. The school decides what is entered, who at the school may see it, and how long it is kept. We do not use children's data to train AI models, we do not profile learners, and we never use it for marketing of any kind. Before a school enters a learner, it confirms under our Data Processing Terms that it has a parent's or guardian's consent, and it obtains separate, explicit consent before using the special-needs module for that learner.

A parent or guardian who wants to see, correct or have removed what we hold about their child should ask their school first, since the school controls that record. If the school cannot help, write to support@mwalimudocs.com and we will act on it.

Cookies and Browser Storage

MwalimuDocs stores a small amount of information in your browser to keep you signed in, to remember your preferences, and to keep copies of your work available when your connection drops. Clearing your browser's site data signs you out and removes these copies.

Google Analytics and reCAPTCHA set their own cookies. You can block cookies in your browser; blocking Google Analytics does not affect how MwalimuDocs works, but reCAPTCHA is needed to sign up and to send a school enquiry.

Links to Other Websites

Our platform may contain links to other websites or services. We are not responsible for their privacy practices, and we encourage you to read the privacy policies of any website you visit.

Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will post the updated policy on this page and change the "Last updated" date. Changes take effect when they are posted.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

• Anything about your data: support@mwalimudocs.com
• Anything about a field representative who visited your school: admin@mwalimudocs.com
• Other ways to reach us: Support