Privacy Policy
Last updated: 2026-10-16
This is a starting draft covering ElimuNexus's actual data flows as
implemented in the platform. It has not been reviewed by a lawyer and
should be reviewed against Kenya's Data Protection Act, 2019 (and any
other applicable law) — and against your Data Protection Officer
registration with the ODPC — before being relied on as your final
published policy.
1. Who this policy covers
This policy applies to students, parents/guardians, teachers, school
administrators, and finance/transport staff who use ElimuNexus, a school
management and digital learning platform used by schools in Kenya.
2. What we collect
- Account information: name, username, role, and school affiliation.
- Academic records: exam results, attendance, assignments, and timetable data entered by teachers and administrators.
- Financial records: fee statements and payment history, for schools using the finance module.
- Transport records: routes, vehicle assignments, and related logistics, for schools using the transport module.
- Communication data: SMS messages sent to parents/guardians regarding results, fees, or announcements.
- Uploaded files: curriculum documents and other files uploaded by teachers/administrators.
- Technical data: IP address and basic request logs, collected automatically for security (e.g. login rate-limiting) and reliability purposes.
3. How we use it
- To operate the platform's core functions: results, attendance, fees, transport, and communication between school, parents, and students.
- To send SMS notifications to parents/guardians (e.g. exam results, fee reminders) via our SMS provider.
- To secure accounts and prevent abuse (e.g. detecting repeated failed login attempts).
- To generate PDF reports, statements, and receipts requested by school staff.
4. Who we share it with
We do not sell personal data. Data is shared only as needed to operate
the platform:
- Your school's own staff, according to their role (e.g. a teacher sees only their assigned students/subjects).
- Our SMS delivery provider, to send the messages a school's staff request.
- Our cloud infrastructure providers (database hosting and file storage), who process data on our behalf under their own security safeguards.
5. Data retention
[PLACEHOLDER — state your actual retention period per data type, e.g.
"academic records are retained for the duration of enrollment plus N
years" — this must reflect a real policy decision, not a default we can
infer from the code.]
6. Your rights
Under Kenya's Data Protection Act, 2019, you may have the right to
access, correct, or request deletion of your personal data, and to
object to certain processing. To exercise these rights, contact us at
[PLACEHOLDER — support/contact email].
7. Security
We use industry-standard measures including encrypted connections
(HTTPS), secure session cookies, password hashing, and role-based access
control to protect your data. No system is perfectly secure, and we
encourage users to use strong, unique passwords.
8. Children's data
ElimuNexus necessarily processes data about students who are minors, on
behalf of and at the direction of their school. Parents/guardians and
schools should ensure they have the appropriate basis (e.g. school
enrollment agreements) for this processing under applicable law.
9. Changes to this policy
We may update this policy from time to time. Material changes will be
reflected by updating the "Last updated" date above.
10. Contact us
Questions about this policy can be sent to [PLACEHOLDER — contact
email / address].