1. Introduction
Loho Learning Ltd ("we", "us", or "our") operates the Elimu Pepe mobile application (the "App"). This Privacy Policy explains how we collect, use, disclose, and protect information about users of our App, including parents, guardians, and children.
Elimu Pepe is an educational platform designed to support Kenya's Competency Based Curriculum (CBC). Our App is intended for use by learners of all ages, including children under the age of 13, under parental or guardian supervision.
By downloading or using the App, you agree to the collection and use of information as described in this Privacy Policy.
2. Information We Collect
We collect the following categories of information:
2.1 Information You Provide
- Full name and profile information (parent/guardian or learner)
- Profile photos and images (if you choose to upload a custom avatar)
- Phone number (used for Safaricom carrier billing / subscription authentication)
- School name and grade/class level
- Account credentials (username and password, if applicable)
2.2 Payment Information
When you subscribe to Elimu Pepe, payments are processed securely by our third-party payment providers Safaricom-PESA. Our application does not collect, access, or store any sensitive financial information, such as credit card numbers, bank details, or PINs. We only receive a confirmation of your subscription status to unlock your content.
2.3 Information Collected Automatically
- Device information: device type, operating system version, unique device identifiers
- Learning progress and quiz scores (used to personalise and track educational outcomes)
- App usage data: pages visited, features used, session duration
- Log data: IP address, timestamps, error logs
2.4 Information from Third Parties
- Subscription status and billing data from Safaricom (via Direct Carrier Billing). We do not store full payment details.
- Analytics data from Facebook Pixel on our web platform (not within the App itself)
We do NOT collect: precise GPS location, contacts, camera/microphone data, or financial account details.
3. How We Use Your Information
We use the information we collect to:
- Create and manage your account
- Process and verify your Safaricom subscription
- Personalise the learning experience based on grade level and progress
- Track and display learning achievements, badges, and leaderboard rankings
- Send important service notifications (e.g. subscription renewal, account alerts)
- Improve App performance, diagnose technical issues, and conduct internal analytics
- Ensure the safety and integrity of the platform
- Comply with applicable legal obligations
We do NOT sell your personal data to third parties or use it for targeted advertising within the App.
4. Children's Privacy (Under 13)
Elimu Pepe is used by learners including children under the age of 13. We are committed to protecting the privacy of children. The following safeguards apply:
Our application is designed to support learning and may be used by children. We are committed to protecting children's privacy in compliance with applicable laws and the Google Play Families Policy.
- Children's accounts are created and managed by a parent or guardian who accepts this Privacy Policy on their behalf.
- Parents or guardians have full control over the child's profile and can monitor progress or delete the account at any time through the web dashboard.
- We do not use children’s personal data for advertising or marketing purposes.
- Parents or guardians can request access to or deletion of their child’s personal data by contacting us at support@loholearning.co.ke.
- We take appropriate security measures to protect children's data.
- We do not allow children to publicly post personal information.
This section is intended to comply with the Google Play Families Policy, COPPA (U.S. Children's Online Privacy Protection Act), and relevant Kenyan data protection law.
5. Sharing Your Information
We may share your information with:
- Safaricom Limited to verify and process your subscription via Direct Carrier Billing.
- Cloud hosting and infrastructure providers to store and process data securely on our behalf.
- Analytics providers in aggregated, anonymised form to understand usage patterns.
- Legal authorities if required by law, court order, or to protect the rights and safety of our users.
We require all third-party service providers to handle your data securely and in accordance with applicable privacy laws.
6. Data Retention
We retain your personal data for as long as your account is active or as needed to provide services. Specifically:
- Account and profile data: retained while your account is active.
- Learning progress data: retained for the duration of the account and for up to 12 months after account deletion to enable re-enrolment.
- Subscription and billing records: retained for up to 7 years for legal and financial compliance.
You may request deletion of your account and associated data at any time (see Section 9).
7. Data Security
We take the security of your data seriously and implement appropriate technical and organisational measures, including:
- Encrypted data transmission (HTTPS/TLS)
- Access controls limiting who within our organisation can access personal data
- Regular security reviews of our infrastructure
While we strive to protect your personal data, no method of transmission over the internet is 100% secure. We encourage you to use a strong password and keep your account credentials confidential.
8. Cookies and Tracking
The Elimu Pepe App uses a WebView to display content from our website. Our website uses cookies for the following purposes:
- Strictly Necessary Cookies: required for the App and website to function correctly.
- Performance Cookies: help us understand which pages are most visited and how users navigate.
- Functional Cookies: enable personalisation and enhanced features.
Our website also uses Facebook Pixel for marketing analytics on the web platform. This tracking is limited to our website and is not used to target children within the App.
You can manage cookie preferences at any time through your browser or device settings.
9. Your Rights
Under the Kenya Data Protection Act, 2019, and applicable international standards, you have the right to:
- Access the personal data we hold about you
- Request correction of inaccurate data
- Request deletion of your data ("right to be forgotten")
- Object to or restrict certain types of processing
- Data portability: receive your data in a structured, commonly used format
- Withdraw consent at any time, without affecting the lawfulness of prior processing
To exercise any of these rights, please contact us at:
Email: support@loholearning.co.ke
Address: Loho Learning Ltd, Funzi Road, Industrial Area, Nairobi, Kenya
We will respond to requests within 30 days.
10. Third-Party Links and Services
The App may contain links to third-party websites or services. This Privacy Policy does not apply to those external sites. We encourage you to review the privacy policies of any third-party services you access.
11. Changes to This Policy
We may update this Privacy Policy from time to time. When we make significant changes, we will:
- Update the "Last Updated" date at the top of this document
- Notify users via in-app notification or email where required
Your continued use of the App after any changes constitutes acceptance of the updated Privacy Policy.
12. Contact Us
If you have any questions, concerns, or complaints about this Privacy Policy or our data practices, please contact us:
Loho Learning Ltd
Funzi Road, Industrial Area, Nairobi, Kenya
Email: support@loholearning.co.ke
Phone: +254 797 349 396
Website: https://elimupepe.loholearning.co.ke