Privacy Policy

An Overview of Data Protection

General information

This policy describes how we process your personal data when you visit the Inua Academy (“Our”) website. The term “personal data” comprises all data that can be used to personally identify you. For detailed information about data protection, please see our Data Protection Declaration, which we have included at the tail end of this document.

This Privacy Policy was last revised on: 24th March 2021.

Data processing on this website

Who is responsible for the processing of data on this website (i.e., the “controller”)?

The controller is the entity that determines how and why personal information relating to a natural person such as their name, physical address, email, and phone number etc. are processed. In this regard, Inua Academy (“We/Our/Us”) is the controller. As the operator of this website, Inua processes personal data. Our contact information is available under section “Information about the responsible party in this Privacy Policy.”

How do we collect your data?

We collect your data which you directly provide to us. This may, for instance be information you provide in our contact form. Some of the information we collect about you includes but is not limited to your name, phone number and email address. 

Other data shall be recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g. web browser, operating system, or time the site was accessed). This information is recorded automatically when you access this website.

What are the purposes we use your data for?

A portion of the information is generated to guarantee the error free provision of the website. Other data may be used to analyze your user patterns. To enable  performance of  the contract you sign with INUA Academy.

What rights do you have as far as your information is concerned?

1. You have the right to receive information about the source, recipients, and purposes of your personal data at any time without having to pay a fee. 
2. You also have the right to demand that your data are rectified or deleted as need maybe.
3. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing.
4. You have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to lodge a complaint with us.
5. The right to receive your data in a structured, commonly used, machine-readable format, to transmit this ported data to another data controller or processor, or to request the transfer to another data controller or processor where possible and practical.

Please note that revoking your consent to our processing of your data or requesting us to delete your data will affect our ability to deliver services to you.  Please do not hesitate to contact us at any time if you have questions about this or any other data protection related issues.

Analysis Tools and Tools Provided by Third Parties

There is a possibility that your browsing patterns will be statistically analyzed when your visit this website. Such analyses are performed primarily with what we refer to as analysis programs.

For detailed information about these analysis programs please consult our Data Protection Declaration below.

Hosting and Content Delivery Networks (CDN)

External Hosting

This website is hosted by an external service provider (host). Personal data collected on this website are stored on the servers of the host. Such information may include, but is not limited to, IP addresses, contact requests, metadata and communications, contract information, contact information, names, web page access, and other data generated through a web site.

The host is used for the purpose of fulfilling the contract with our potential and existing customers and in the interest of secure, fast, and efficient provision of our online services by a professional provider.

Our host will only process your data to the extent necessary to fulfil its performance obligations and to follow our instructions with respect to such data.

Execution of a contract data processing agreement

To guarantee effective processing, we have concluded an order processing contract with our host as described below.

Cloudflare

We use the “Cloudflare” service provided by Cloudflare Inc., 101 Townsend St., San Francisco, CA 94107, USA. (hereinafter referred to as “Cloudflare”).

Cloudflare offers a content delivery network with DNS that is available worldwide. As a result, the information transfer that occurs between your browser and our website is technically routed via Cloudflare’s network. This enables Cloudflare to analyze data transactions between your browser and our website and to work as a filter between our servers and potentially malicious data traffic from the Internet. In this context, Cloudflare may also use cookies or other technologies deployed to recognize Internet users, which shall, however, only be used for the herein described purpose.

The use of Cloudflare is based on our legitimate interest in a provision of our website offerings that is as error free and secure as possible.

For more information on Cloudflare’s security precautions and data privacy policies, please follow this link: https://www.cloudflare.com/privacypolicy/ .

General information on Processing of Personal Data

Data protection

The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with data protection statutes and regulations and this Data Protection Declaration.

Whenever you use this website, a variety of personal information will be collected. This Data Protection Declaration explains which data we collect, how we collect it, and the purposes we use the data for. 

If we suspect or become aware of any unauthorized access to your data by any unauthorized actors or third parties, or become aware of any other security breach relating to personal data held by us under this policy, we shall immediately notify you in writing and shall fully cooperate with you to prevent or stop such data breach.  In the event of such data breach, we shall fully and immediately comply with applicable laws, and shall take the appropriate steps to remedy such data breach.

Contact Information

The data controller on this website is:

INUA Digital Academy Ltd P.O.Box 64717-06200 Nairobi
Phone: +254 774 115 822
E-mail: hello@inua.academy

Storage duration

Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for which it was collected no longer applies upon which we will either anonymize or delete it. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g. tax or commercial law retention periods). In the latter case, the deletion will take place after these reasons cease to apply. A data deletion request sent to us will be responded to and actioned within 60 days. 

Data Location

Data generated from users and personal information is stored and processed within Kenya. However, where we may need to transfer or process your personal information outside our legal jurisdiction to other countries such as the United States of America, we undertake to ensure that your personal information is processed or transferred in accordance with the Kenya Data Protection Act 2019. By using this website, you acknowledge, agree and consent that we may transfer and store your data outside the jurisdiction.  

Revocation of your consent to the processing of data

We only process your data with your consent. You can also revoke this consent at any time any. This shall be without prejudice to the lawfulness of any data processing that occurred prior to your revocation.

Right to data portability

You have the right to demand that we hand over any data we automatically process on the basis of your consent or in order to fulfil a contract be handed over to you or a third party in a commonly used, machine readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.

Encrypted payment transactions on this website

Payment transactions using common modes of paying (M-PESA, Visa/MasterCard, debit to your bank account) are processed exclusively via encrypted SSL or TLS connections. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and, also by the appearance of the lock icon in the browser line.

Right to demand processing restrictions

You have the right to request that we stop processing your personal data. The right to demand restriction of processing applies in the following cases:

• If you dispute the correctness of your data held by us. We will usually need some time to verify this claim. During the time that this investigation is   ongoing, you have the right to demand that we restrict the processing of your personal data.
• If the processing of your personal data was/is conducted in an unlawful manner. 
• If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements.
• If you have raised an objection, your rights and our rights will have to be weighed against each other. If it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.
• If you have restricted the processing of your personal data, such data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons.

Rejection of unsolicited e-mails

We herewith object to the use of contact information published in conjunction with the mandatory information to be provided in our Site Notice to send us promotional and information material that we have not expressly requested. The operators of this website and its pages reserve the express right to take legal action in the event of the unsolicited sending of promotional information, for instance via SPAM messages.

Recording of data on this website

Cookies

Our websites and pages use what the industry refers to as “cookies.” Cookies are small text files that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies).

Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them, or they are automatically deleted by your web browser.

In some cases, it is possible that third-party cookies are stored on your device once you enter our site (third-party cookies).

These cookies enable you or us to take advantage of certain services offered by the third party (e.g. cookies for the processing of payment services).

Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of the cookies (e.g. the shopping cart function or the display of videos). The purpose of other cookies may be the analysis of user patterns or the display of promotional messages.

Cookies, which are required for the performance of electronic communication transactions (required cookies) or for the provision of certain functions you want to use (functional cookies, e.g. for the shopping cart function) or those that are necessary for the optimization of the website (e.g. cookies that pride measurable insights into the web audience), shall be stored. The operator of the website has a legitimate interest in the storage of cookies to ensure the technically error free and optimized provision of the operator’s services. If your consent to the storage of the cookies has been requested, the respective cookies are stored exclusively on the basis of the consent; this consent may be revoked at any time.

You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited.

If third-party cookies are used or if cookies are used for analytical purposes, we will separately notify you in conjunction with this Data Protection Policy and, if applicable, ask for your consent.

Server log files

The provider of this website and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises:

• The type and version of browser used; 
• The used operating system;
• Referrer URL;
• The hostname of the accessing computer; 
• The time of the server inquiry; and
• The IP addresses

This data is not merged with other data sources.

This data is recorded on the basis of Art. 6 Sect. 1(f) GDPR. The operator of the website has a legitimate interest in the technically error free depiction and the optimization of the operator’s website. In order to achieve this, server log files must be recorded.

Contact Form

If you submit inquiries to us via our contact form, the information provided in the contact form as well as any contact information provided therein will be stored by us in order to handle your inquiry and in the event that we have further questions. We will not share this information without your consent.

The processing is based on our legitimate interest in the effective processing of the requests addressed to us or on your agreement if this has been requested.

The information you have entered into the contact form shall remain with us until you ask us to delete the data, revoke your consent to the archiving of data or if the purpose for which the information is being archived no longer exists (e.g. after we have concluded our response to your inquiry). This shall be without prejudice to any mandatory legal provisions – in   particular, the retention periods.

Request by e-mail, telephone, or fax

If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not share this data on without your consent.

The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

Communication via WhatsApp

For communication with our customers and other third parties, one of the services we use is the instant messaging service WhatsApp. The provider is WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

The use of WhatsApp is based on our legitimate interest in communicating as quickly and effectively as possible with customers, interested parties and other business and contractual partners (Art. 6(1)(f) GDPR). If a corresponding consent has been requested, data processing is carried out exclusively on the basis of the consent. This consent may be revoked at any time with effect for the future.

The communication content exchanged between and on WhatsApp remains with us until you request us to delete it, revoke your consent to storage or the purpose for which the data is stored ceases to apply (e.g. after your request has been processed). Mandatory legal provisions – in particular retention periods – remain unaffected.

We have set up our WhatsApp accounts in such a way that there is no automatic synchronization of data with the address book on the smartphones in use.

We have concluded a contract for order processing with WhatsApp.

Further details on data processing can be found in the WhatsApp privacy policy at: https://www.whatsapp.com/legal/#privacy-policy.

Registration on this website

You have the option to register on this website to be able to use additional website functions. We shall use the data you provide only to offer the service you have registered for. The information we  request for at required information we request at the time of registration must be provided in full. Otherwise, we shall reject the registration.

To notify you of any important changes to the scope of our portfolio or in the event of technical modifications, we shall use the e-mail address provided during the registration process.

The data recorded during the registration process shall be stored by us as long as you are registered on this website. Subsequently, such data shall only be deleted upon your request or if it is no longer needed to offer our services to you. This shall be without prejudice to mandatory statutory retention obligations.

Analysis tools and advertising

Matomo (formerly called Piwik)

This website uses the open-source web analysis service Matomo. Matomo uses technologies that make it possible to recognize the user across multiple pages with the aim of analyzing the user patterns (e.g. cookies or device fingerprinting). The information recorded by Matomo about the use of this website will be stored on our server. Prior to archiving, the IP address will first be anonymized.

Through Matomo, we are able to collect and analyze data on the use of our website by website visitors. This enables us to find out, for instance, when which page views occurred and from which region they came. In addition, we collect various log files (e.g. IP address, referrer, browser, and operating system used) and can measure whether our website visitors perform certain actions (e.g. clicks, purchases, etc.).

The use of this analysis tool is based on a legitimate interest in  the analysis of user patterns, in order to optimize the operator’s web offerings and advertising.

Hosting

We host Matomo exclusively on our own servers so that all analysis data remains with us and is not passed on.

Newsletter

Newsletter data

If you would like to subscribe to the newsletter offered on this website, we will need you to opt in to our marketing offer and signing up for the same by providing  an e-mail address which shall indicate your consent to the receipt of the newsletter. No further data shall be collected or shall be collected only on a voluntary basis. We shall use such data only for the sending of the requested information and shall not share such data with any third parties.

The processing of the information entered into the newsletter subscription form shall occur exclusively on the basis of your consent. You may revoke the consent you have given to the archiving of data, the e-mail address and the use of this information for the sending of the newsletter at any time, for instance by clicking on the “Unsubscribe” link in the newsletter. 

This shall be without prejudice to the lawfulness of any data processing transactions that have taken place to date.

The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter or after the purpose has ceased to apply. We reserve the right to delete or block e-mail addresses from our newsletter distribution list at our own discretion within the scope of our legitimate interest.

After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist to prevent future mailings. The data from the blacklist is used only for this purpose and not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest). The storage in the blacklist is indefinite. You may object to the storage if your interests outweigh our legitimate interest.

eCommerce and payment service providers

Processing of data (customer and contract data)

We collect, process, and use personal data only to the extent necessary for the establishment, content organization or change of the legal relationship (data inventory). These actions are taken for the processing of data for the fulfilment of a contract or pre- contractual actions. We collect, process and use personal data concerning the use of this website (usage data) only to the extent that this is necessary to make it possible for users to utilize the services and to bill for them. By using this website, you consent to our collection and processing of your data and acknowledge that we may share your information with third parties, related entities and partners for the purpose described above. 

Payment services

We integrate payment services of third-party companies on our website. When you make a purchase from us, your payment  data (e.g. name, payment amount, bank account details, credit card number, phone number) are processed by the payment service provider for the purpose of payment processing.  For these transactions, the respective contractual and data protection provisions of the respective providers apply. The use of the payment service providers is based on contract processing and in the interest of a smooth, convenient, and secure payment transaction. Insofar as your consent is requested for certain actions, consent may be revoked at any time for the future.

We use the following payment services / payment service providers within the scope of this website:

M-PESA

The provider of this payment service is Safaricom Limited of P.O. Box 66827 Westlands, Nairobi – 00800 (hereinafter “Safaricom”)
Details can be found in Safaricom’s privacy policy: https://www.safaricom.co.ke/dataprivacystatement/>.

PayPal

The provider of this payment service is PayPal Inc., 2211 North First StreetSan Jose, California 95131 (hereinafter “PayPal”).
Details can be found in PayPal’s privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full/>.

Online-based Audio and Video Conferences (Conference tools)

Data processing

We use online conference tools, among other things, for communication with our customers. If you communicate with us by video or audio conference using the Internet, your personal data will be collected and processed by the provider of the respective conference tool and by us. 

Should content be exchanged, uploaded, or otherwise made available within the tool, it is also stored on the servers of the tool provider. Such content includes, but is not limited to, cloud recordings, chat/ instant messages, voicemail uploaded photos and videos, files, whiteboards, and other information shared while using the service.

Please note that we do not have complete influence on the data processing procedures of the tools used. Our possibilities are largely determined by the corporate policy of the respective provider. Further information on data processing by the conference tools can be found in the data protection declarations of the tools used, and which we have listed below this text.

Duration of storage

Data collected directly by us via the video and conference tools will be deleted from our systems immediately after you request us to delete it, revoke your consent to storage, or the reason for storing the data no longer applies. Stored cookies remain on your end device until you delete them. Mandatory legal retention periods remain unaffected.

We have no influence on the duration of storage of your data that is stored by the operators of the conference tools for their own purposes. For details, please directly contact the operators of the conference tools.

Conference tools used

We employ the following conference tools:

Zoom

We use Zoom. We have entered into a contract data processing agreement with the provider of Zoom.

The provider of this service is Zoom Communications Inc, San Jose, 55 Almaden Boulevard, 6th Floor, San Jose, CA 95113, USA. For details on data processing, please refer to Zoom’s privacy policy: https://zoom.us/en-us/privacy.html.

Policy Update

We reserve the right to change the provisions of this privacy policy at any time. We will alert you that changes have been made by indicating on the privacy policy the date it was last revised. Your use of the Website following the posting of such revised policy shall constitute your acceptance of any such changes. We encourage you to review this policy whenever you visit the Website to guarantee your understanding of how your information may be collected and used.