Data Protection Notice — How we collect, use, and protect your personal data
ElimuAI is an AI-powered personalised learning platform operated by Venus Unzag Limited, a company incorporated under the laws of Kenya (“we”, “us”, “our”). We are committed to protecting the privacy and personal data of all users of the ElimuAI platform, website, and mobile application (collectively, “the Platform”).
This Privacy Policy explains how we collect, use, store, share, and protect your personal data. It applies to all users across Kenya, Uganda, and Tanzania, and has been prepared in compliance with:
ElimuAI collects and processes data relating to children. We take this responsibility extremely seriously. We only collect the minimum data necessary, we never sell children’s data, and we require verified parental or guardian consent before processing any data relating to a child under the age of 18.
| Field | Details |
|---|---|
| Data Controller | Venus Unzag Limited |
| Trading Name | ElimuAI |
| Country of Incorporation | Kenya |
| Physical Address | Nairobi, Kenya |
| support@elimuai.africa | |
| Phone | +254 725 647 575 |
| Website | https://elimuai.africa |
| Data Protection Officer | Julius — support@elimuai.africa |
3.1 Data We Collect from Parents and Guardians
3.2 Data We Collect from Students / Learners
We do not collect a child’s surname, photograph, location, or contact details. All child accounts are created and managed by a verified parent or guardian.
3.3 Data We Collect from Teachers and School Administrators
3.4 Data We Collect Automatically
| Purpose | Data Used | Legal Basis |
|---|---|---|
| Providing and personalising the learning experience | Learner activity, AI interaction logs, progress data | Performance of contract |
| Account creation and management | Parent/guardian name, email, phone | Performance of contract |
| Processing subscription payments | Phone number, payment provider tokens | Performance of contract |
| Communicating with you about your account | Email, phone number | Performance of contract |
| Sending platform updates and new features | Email address | Legitimate interests |
| Generating progress reports for parents and teachers | Learner activity and quiz data | Performance of contract |
| Improving the AI tutor and platform features | Anonymised interaction logs | Legitimate interests |
| Referral and affiliate commission tracking | Session ID, referral code, subscription data | Legitimate interests |
| Compliance with legal obligations | All categories as required | Legal obligation |
| Fraud prevention and platform security | IP address, session data | Legitimate interests |
5.1 ElimuAI is designed to be used by learners from Pre-Primary 1 (PP1) to Grade 9. All learners on the platform are under 18 years of age and are therefore classified as children under applicable data protection laws.
5.2 We require a parent or legal guardian to create and manage a child’s account. By creating a child account, the parent or guardian provides explicit, verifiable consent for the collection and processing of that child’s data as described in this Policy.
5.3 We apply the following additional protections to children’s data:
5.4 For school accounts, the school acts as a co-data controller for student data within its roster. Schools must ensure they have obtained appropriate parental consent. Parents and guardians may at any time request access to, correction of, or deletion of their child’s data by contacting us at support@elimuai.africa. We will respond within 21 days.
We do not sell your personal data.
We share data only in the following limited circumstances:
| Recipient | Data Shared | Purpose | Location |
|---|---|---|---|
| Stripe Inc. | Payment tokenisation data | Card payment processing | USA (SCCs) |
| Safaricom PLC (M-Pesa) | Phone number, transaction ref | M-Pesa payment processing | Kenya |
| Anthropic PBC | Anonymised AI query content | AI tutor responses | USA (SCCs) |
| Cloud infrastructure | Encrypted user & content data | Platform hosting & storage | East Africa region |
| Channel partners | Commission tracking data only | Commission calculation | KE / UG / TZ |
| Law enforcement | As legally required | Legal compliance | Jurisdiction-specific |
7.1 Some of our service providers are located outside Kenya, Uganda, and Tanzania. Where we transfer personal data outside the originating country, we ensure appropriate safeguards are in place, including:
7.2 We ensure that any cross-border transfer of children’s data is subject to the same or higher level of protection as required under the law of the originating country.
| Data Category | Retention Period | Basis |
|---|---|---|
| Active subscriber account data | Duration of subscription + 2 years | Contractual obligation |
| Learner activity and progress data | Duration of subscription + 1 year | Service delivery |
| AI interaction logs (anonymised) | 3 years (anonymised after 12 months) | Platform improvement |
| Payment records | 7 years | Kenyan tax & financial regulations |
| Referral and commission records | 5 years | Legal and commercial records |
| Deleted account data | 30 days (then permanently deleted) | Dispute resolution window |
| Teacher/school data | Duration of subscription + 2 years | Contractual obligation |
Depending on your country of residence, you have the following rights regarding your personal data:
| Right | Description | Available in |
|---|---|---|
| Right of Access | Request a copy of the personal data we hold about you | KE · UG · TZ |
| Right to Rectification | Request correction of inaccurate or incomplete data | KE · UG · TZ |
| Right to Erasure | Request deletion of your data (subject to legal retention) | KE · UG · TZ |
| Right to Data Portability | Receive your data in a structured, machine-readable format | KE · UG · TZ |
| Right to Object | Object to processing based on legitimate interests | KE · UG · TZ |
| Right to Restrict Processing | Request that we limit how we use your data | KE · UG · TZ |
| Right to Withdraw Consent | Withdraw consent at any time without affecting prior processing | KE · UG · TZ |
| Right to Lodge a Complaint | Complain to the relevant Data Protection Authority | KE · UG · TZ |
To exercise any of these rights, submit a request through the ElimuAI app (Settings → Privacy → Data Rights) or email support@elimuai.africa. We will respond within 21 days in Kenya and Uganda, and within 30 days in Tanzania.
If you are not satisfied with how we have handled your data, you may lodge a complaint with the relevant authority:
| Country | Authority | Website |
|---|---|---|
| 🇰🇪 Kenya | Office of the Data Protection Commissioner (ODPC) | www.odpc.go.ke |
| 🇺🇬 Uganda | Personal Data Protection Office (PDPO) | www.pdpo.go.ug |
| 🇹🇿 Tanzania | Personal Data Protection Commission (PDPC) | www.pdpc.go.tz |
11.1 We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, alteration, or disclosure. These measures include:
11.2 In the event of a data breach affecting your personal data, we will notify you and the relevant Data Protection Authority within 72 hours of becoming aware of the breach, in accordance with applicable law.
Please refer to our separate Cookie and Tracking Notice for detailed information on the cookies and tracking technologies used on the ElimuAI Platform. You can manage your cookie preferences at any time through the cookie consent banner in the app.
We may update this Privacy Policy from time to time. When we make material changes, we will notify you via email and an in-app notice at least 14 days before the changes take effect. The updated Policy will always be available at elimuai.africa/privacy. Continued use of the Platform after the effective date constitutes acceptance of the updated Policy.
| Channel | Details |
|---|---|
| support@elimuai.africa | |
| Phone | +254 725 647 575 |
| Address | Venus Unzag Limited, Nairobi, Kenya |
| Website | https://elimuai.africa/privacy |
| Data Rights Portal | In-app: Settings → Privacy → Data Rights |
support@elimuai.africa · +254 725 647 575 · elimuai.africa
Version 1.0 · 1 April 2026 · Governed by the Laws of Kenya, Uganda, and Tanzania