Privacy & Child Protection

Your trust is our priority. We protect children's privacy with the highest care.

Last updated: 11 February 2026

Secure by Design

We collect only essential data and protect it with industry-leading security measures.

Your Rights Protected

Access, correct, or delete your data anytime. Full transparency guaranteed.

Child-First Approach

Every decision prioritizes the safety, privacy, and best interests of children.

Section 1

Who We Are

KyriosLearn provides coding, robotics and digital skills programmes for children. In this notice, "KyriosLearn", "we", "us" and "our" refer to KyriosLearn and its authorised staff and contractors.

We act as a data controller for most personal data collected during our programmes. Where we process data on behalf of a school or partner organisation, we may act as a data processor and follow the partner's instructions.

Section 2

Our Commitment to Children's Privacy and Safety

  • ●We process children's personal data in a manner that protects and advances the rights and best interests of the child.
  • ●We use child-friendly language where we communicate directly with learners.
  • ●We collect the minimum data we need, keep it secure, and retain it only for as long as necessary.
  • ●We do not publish a child's full name together with an identifiable image or video in public marketing materials unless a parent/guardian has given specific, informed consent.
  • ●We have safeguarding practices, staff conduct expectations and reporting pathways to help prevent and respond to harm.
Section 3

What Information We Collect

A. Learner (Student) Information

  • Identification and enrolment details: learner's name, age/date of birth (or age bracket), school and class.
  • Contact details (where applicable): learner phone/email for older learners, or school contact details for coordination.
  • Programme data: attendance, progress, assessment results, certificates, badges/awards, and learning support needs shared by a parent/guardian or school.

B. Parent/Guardian Information

  • Name and contact details (phone, email, and/or WhatsApp number).
  • Relationship to the learner and emergency contact information.

C. Payment Information

We collect the minimum payment information needed to confirm payment and manage accounts, such as payer name, payment reference, transaction messages/receipts (e.g., M-PESA confirmation), invoicing details, and programme fees paid. Where card payments are used via a payment provider, card details are processed by the provider and are not stored by KyriosLearn.

D. Communications, Feedback and Surveys

  • Messages you send to us (email, WhatsApp, SMS), support requests and feedback.
  • Survey responses and programme evaluations.

E. Photos, Audio and Video

  • Photos/videos from classes, events and competitions (online or in-person).
  • For online sessions, limited recordings may be used for learning review, safeguarding, quality assurance, or as required by a partner/school.
Section 4

Why We Collect and Use Your Information

We use personal data for the following purposes:

  • ●Enrolment and programme delivery (registration, class lists, lesson delivery, assessments, certification).
  • ●Communication with parents/guardians and partner schools (schedules, safety updates, programme changes).
  • ●Safeguarding and child protection (responding to safety concerns, incident management, duty of care).
  • ●Billing and accounting (invoicing, payment confirmation, refunds where applicable).
  • ●Quality improvement (feedback analysis, programme evaluation and training).
  • ●Marketing and storytelling (only where appropriate consent has been obtained for child images or recordings).

Lawful basis: Our processing is based on one or more lawful grounds under Kenyan data protection law, including consent, performance of a contract, compliance with legal obligations, and legitimate interests, applied with special care for children.

Section 5

Children's Data and Parental/Guardian Consent

  • ●We obtain explicit consent from a parent/guardian before collecting or processing a child's personal data where required, and especially for photos/videos used for marketing.
  • ●Consent requests are specific and separate (e.g., programme delivery consent is separate from marketing consent).
  • ●Parents/guardians may withdraw consent at any time. Withdrawal does not affect processing already done before withdrawal, but we will stop the activity going forward.
  • ●If consent is withdrawn for marketing images/videos, we will stop using the content in future posts/prints and will take reasonable steps to remove it from platforms we control (noting that third-party re-shares may be outside our control).
Section 6

How We Share Information

We may share personal data only when necessary and with appropriate safeguards, for example:

  • • With partner schools for programme administration and learner support.
  • • With vetted service providers who help us operate (e.g., email/communications tools, learning platforms, cloud hosting, payment processors), under confidentiality and data protection obligations.
  • • With regulators, law enforcement or child protection authorities where required by law or to protect a child.

We do not sell children's or parents' personal data.

Section 7

International Transfers

If we use cloud services that store or process data outside Kenya, we put in place appropriate safeguards as required by Kenyan law. Where required, we will seek consent or ensure adequate protection measures are in place.

Section 8

Data Retention

  • • We keep enrolment and programme records only for as long as needed for programme delivery, certification, and legitimate operational needs.
  • • Financial records are retained for the period required by applicable tax and accounting laws.
  • • Photos/videos used for marketing are retained only while the marketing purpose remains valid and consent remains in place; we periodically review and delete/archive content appropriately.
Section 9

Data Security

  • ●Access controls: only authorised staff/contractors access personal data based on their role.
  • ●Secure storage: use of password protection, encryption where appropriate, and reputable cloud services.
  • ●Device and account security: strong passwords, 2-factor authentication where available, and secure device practices.
  • ●Staff training: privacy and safeguarding training and confidentiality obligations.
  • ●Incident response: procedures to manage and report data breaches and safeguarding incidents.
Section 10

Your Rights

Under Kenyan data protection law, you have rights that may include:

  • • Right to be informed about how your data is used.
  • • Right of access to your personal data.
  • • Right to correction of inaccurate or incomplete data.
  • • Right to deletion/erasure in certain situations.
  • • Right to object to processing in certain situations, including direct marketing.
  • • Right to restrict processing in certain situations.
  • • Right to data portability where applicable.

To exercise these rights, contact us using the details in section 13. We may need to verify your identity before responding.

Section 11

Cookies and Online Platforms

If you use our website or online learning tools, we may collect limited technical information (e.g., device type, browser, and usage logs) to maintain security and improve performance. Where cookies are used, we will provide a cookie notice and options where appropriate.

Section 12

Safeguarding and Child Protection

  • • We maintain a child safeguarding approach aligned to the best interests of the child and applicable Kenyan child protection frameworks.
  • • We expect staff and volunteers to follow a code of conduct when interacting with children.
  • • We take concerns seriously and may escalate safeguarding issues to the relevant school leadership and/or child protection authorities as required.
  • • In online sessions, we apply safety measures such as moderated sessions, controlled access links, and appropriate communication channels.
Section 13

Contact Us

KyriosLearn Privacy Contact

Email: kyrioslearn@gmail.com

Phone/WhatsApp: +254 723935998

For any questions about this privacy policy or how we handle your data, please don't hesitate to reach out.

Section 14

Complaints

If you are not satisfied with how we handle your personal data, you may contact us first. You also have the right to lodge a complaint with the Office of the Data Protection Commissioner (ODPC) of Kenya.

Section 15

Changes to This Notice

We may update this notice from time to time to reflect legal, operational or programme changes. We will post the updated version on our website and indicate the new 'Last updated' date.

Legal and Regulatory Basis (Kenya)

  • ●Constitution of Kenya (Right to Privacy - Article 31)
  • ●Data Protection Act, 2019
  • ●Data Protection (General) Regulations, 2021 and related regulations/guidance issued by the ODPC
  • ●Children Act, 2022 and applicable child protection frameworks