CENTIPID ACADEMY

Privacy Policy

1. Overview

1.1 Purpose

This Privacy Policy explains how Centipid Technologies ("Centipid Academy", "we", "our", or "us") collects, uses, stores, shares, protects, and otherwise processes personal information obtained through Centipid Academy, including our website, applications, learning platform, and related services (collectively referred to as the "Platform").

We are committed to protecting your privacy and handling your personal information in a transparent, lawful, and secure manner.

This Privacy Policy applies to all individuals who interact with the Platform, including:

• visitors to our website;

• registered learners;

• instructors and course creators;

• purchasers of Courses or other Services;

• applicants seeking to become instructors; and

• individuals who communicate with us through our support channels.

By creating an Account, accessing the Platform, enrolling in a Course, publishing a Course, purchasing any Service, or otherwise using Centipid Academy, you acknowledge that your personal information will be processed in accordance with this Privacy Policy.

1.2 Plain Language Summary

We collect only the personal information necessary to operate Centipid Academy, deliver educational services, process Course purchases, administer instructor accounts, improve the Platform, and comply with applicable legal obligations.

We do not sell your personal information.

We use trusted third-party service providers to help us operate the Platform, including payment processors, cloud hosting providers, email delivery services, analytics providers, and security providers. These service providers may process personal information only for the purposes of providing services to Centipid Academy and are required to protect your information appropriately.

Where required by applicable law, we will obtain your consent before processing your personal information for specific purposes.

We are committed to complying with applicable data protection laws, including the Kenya Data Protection Act, 2019, and, where applicable, other international privacy laws.

2. Who We Are

Centipid Technologies is a technology company incorporated in the Republic of Kenya.

Centipid Academy is an online learning platform operated by Centipid Technologies that enables learners to access educational Courses, complete assessments, earn certificates, and participate in other educational activities. The Platform also enables approved instructors to create, publish, market, and manage educational content.

For the purposes of applicable data protection laws, Centipid Technologies is generally the Data Controller of the personal information collected through Centipid Academy.

Company Information

3. Scope of this Privacy Policy

This Privacy Policy applies to personal information collected through:

• the Centipid Academy website;

• learner and instructor accounts;

• Course enrolment and participation;

• Course purchases and payments;

• instructor applications and Course publication;

• assessments, quizzes, certificates, and learning activities;

• customer support interactions;

• promotional programmes, referral programmes, Platform Credits, and similar initiatives;

• surveys, feedback forms, and communications; and

• any other products or services operated under Centipid Academy unless a separate privacy policy expressly applies.

This Privacy Policy does not apply to:

• third-party websites linked from the Platform;

• third-party payment providers, whose collection and processing of personal information are governed by their own privacy policies; or

• websites or services operated independently by instructors or other third parties.

Where this Privacy Policy conflicts with mandatory requirements under applicable law, those legal requirements shall prevail.

4. Information We Collect

The information we collect depends on how you interact with the Platform. Some information is provided directly by you, while other information is collected automatically when you use our Services.

4.1 Account Information

When you create an Account, we may collect information including:

• your full name;

• email address;

• telephone number;

• country of residence;

• organisation or employer (where applicable);

• profile photograph (optional);

• account username;

• encrypted password and authentication credentials; and

• any other information you choose to include in your profile.

Some of this information is required to create and manage your Account, while other information is optional and intended to personalise your experience.

4.2 Learner Information

When you enrol in or participate in Courses, we may collect information relating to your learning activities, including:

• Courses viewed, purchased, and enrolled in;

• lesson completion and learning progress;

• assessment attempts and scores;

• assignment submissions;

• certificates earned;

• Course reviews and ratings;

• discussion forum participation (where available);

• bookmarks, saved Courses, or wishlists (where available);

• Platform Credits;

• referral activity; and

• learning preferences and accessibility settings.

This information enables us to deliver educational services, measure learning progress, generate certificates, and improve the learning experience.

4.3 Instructor Information

Where you apply to become or act as an Instructor, we may collect additional information including:

• professional biography;

• qualifications, certifications, and experience;

• organisation or business information;

• instructor profile information;

• Course submissions;

• Course revisions and publication history;

• Course performance analytics;

• learner feedback and Course ratings;

• earnings information;

• bank account details required for instructor payouts; and

• tax information where required by applicable law.

We collect this information to evaluate instructor applications, publish Courses, administer instructor accounts, process revenue sharing, and fulfil our contractual and legal obligations.

4.4 Payment Information

When you purchase a Course or receive payments as an Instructor, we may collect information relating to those transactions, including:

• billing name;

• billing address where applicable;

• payment references;

• transaction identifiers;

• invoices and receipts;

• payment status;

• purchase history;

• refund history;

• settlement currency;

• payout history; and

• bank account information provided by Instructors for revenue payments.

Centipid Technologies does not store complete payment card details. Payment card information is collected and processed directly by our authorised payment service providers in accordance with their own privacy and security practices.

4.5 Platform Usage Information

When you access or use the Platform, certain technical information is collected automatically, including:

• IP address;

• browser type and version;

• operating system;

• device type;

• language preferences;

• pages visited;

• Courses accessed;

• time spent using the Platform;

• login timestamps;

• device identifiers;

• application error logs; and

• security and audit logs.

This information helps us maintain the security, performance, and reliability of the Platform and understand how our Services are being used.

4.6 Communications and Support Information

When you contact Centipid Academy or interact with us, we may collect information including:

• emails and correspondence;

• customer support requests;

• live chat messages (where available);

• survey responses;

• feedback submitted through the Platform;

• bug reports;

• feature requests; and

• other communications you voluntarily provide.

This information helps us respond to enquiries, resolve technical issues, improve our Services, and maintain records of our interactions.

4.7 Information Collected Automatically

We may also collect certain information automatically through technologies such as cookies, log files, and similar technologies used to operate the Platform.

5. How We Use Your Information

Centipid Academy uses the personal information we collect only where necessary to provide, improve, protect, and administer the Platform. Depending on how you interact with the Platform, we may use your information for the following purposes.

5.1 Providing the Platform

We use your information to:

• create and manage your Account;

• authenticate your identity when you sign in;

• enrol you in Courses;

• deliver learning content;

• track learning progress;

• administer assessments and quizzes;

• issue certificates;

• maintain your learner profile; and

• provide Platform features requested by you.

5.2 Processing Payments

We use your information to:

• process Course purchases;

• process instructor payouts;

• maintain payment records;

• issue invoices and receipts;

• process refunds;

• administer Platform Credits;

• administer referral programmes; and

• comply with applicable financial and tax obligations.

5.3 Supporting Instructors

Where you apply to become or act as an Instructor, we use your information to:

• review instructor applications;

• evaluate Course submissions;

• administer Course publication;

• monitor Course quality;

• calculate instructor earnings;

• process revenue sharing;

• facilitate instructor payments; and

• communicate with you regarding your Courses and instructor account.

5.4 Customer Support and Communications

We use your information to:

• respond to enquiries and support requests;

• investigate technical issues;

• notify you about changes affecting your Account or the Platform;

• send Course-related communications;

• send security notices;

• send transactional communications relating to purchases, payments, certificates, or instructor earnings; and

• send product updates, newsletters, or marketing communications where permitted by law or with your consent.

You may opt out of receiving non-essential marketing communications at any time. However, you will continue to receive communications necessary for the operation of your Account or the delivery of Services.

5.5 Platform Improvement

We use information about how the Platform is used to:

• improve the learner experience;

• improve instructor tools;

• analyse Course performance;

• develop new features;

• diagnose technical issues;

• improve accessibility;

• measure Platform performance; and

• conduct research and analytics using aggregated or anonymised information where appropriate.

5.6 Security and Fraud Prevention

We may process personal information to:

• verify user identities;

• detect and prevent fraud;

• investigate suspected misuse of the Platform;

• enforce our Terms of Service and Instructor Terms;

• protect the security and integrity of the Platform; and

• comply with legal and regulatory requirements.

6. Legal Basis for Processing

Where required by applicable data protection laws, Centipid Academy processes personal information only where there is a lawful basis for doing so.

Depending on the circumstances, we rely on one or more of the following legal bases.

Where we rely on your consent to process personal information, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

7. Sharing and Disclosure of Personal Information

Centipid Academy does not sell your personal information.

We disclose personal information only where necessary to operate the Platform, comply with legal obligations, or protect our legitimate interests.

7.1 Service Providers

We may share personal information with trusted third-party service providers that assist us in operating the Platform, including providers of:

• cloud hosting and infrastructure;

• payment processing;

• email delivery;

• analytics;

• customer support tools;

• security monitoring;

• fraud prevention;

• content delivery;

• video hosting;

• error monitoring; and

• other technical services required to operate the Platform.

These providers may process personal information only on our behalf and only for purposes consistent with this Privacy Policy.

7.2 Business Transactions

Where Centipid Technologies undergoes a merger, acquisition, restructuring, financing transaction, or sale of all or part of its assets, personal information may be transferred as part of that transaction.

Where required by law, affected Users will be notified before such a transfer takes effect.

7.3 Legal Requirements

We may disclose personal information where we reasonably believe disclosure is necessary to:

• comply with applicable law;

• comply with a court order or lawful request from a competent authority;

• protect the rights, property, or safety of Centipid Technologies, our Users, or the public;

• investigate suspected fraud or unlawful activity; or

• enforce our Terms of Service, Instructor Terms, or other applicable agreements.

7.4 With Your Consent

We may disclose personal information to other third parties where you have expressly authorised us to do so.

8. International Data Transfers

Centipid Academy may store or process personal information in countries outside the Republic of Kenya where this is necessary to operate the Platform.

Where personal information is transferred outside Kenya, we will take reasonable steps to ensure that the information continues to receive an appropriate level of protection consistent with applicable data protection laws.

These safeguards may include:

• contractual data protection obligations imposed on our service providers;

• transferring only the information necessary for the relevant purpose;

• implementing appropriate technical and organisational security measures; and

• complying with applicable legal requirements governing cross-border transfers of personal information.

Where required by law, we will rely on an appropriate legal basis before transferring personal information internationally.

Users acknowledge that some of our service providers may operate infrastructure in multiple jurisdictions and that personal information may therefore be processed outside the country in which it was originally collected.

If you require further information regarding the safeguards we apply to international transfers of personal information, you may contact us using the details provided in this Privacy Policy.

9. Data Retention

We retain personal information only for as long as necessary to fulfil the purposes described in this Privacy Policy, comply with our legal obligations, resolve disputes, enforce our agreements, and protect the legitimate interests of Centipid Academy.

The length of time we retain personal information depends on the type of information and the purpose for which it was collected.

Where legal obligations require us to retain certain information for longer periods, we will retain that information only for as long as necessary to comply with those obligations.

Where personal information is no longer required, we will securely delete, anonymise, or otherwise dispose of it in accordance with our internal data retention procedures.

10. Security Measures

Centipid Academy implements appropriate technical, organisational, and administrative measures designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or unauthorised access.

Our security measures may include:

• encryption of personal information during transmission where appropriate;

• secure storage of personal information;

• role-based access controls to limit access to authorised personnel;

• authentication measures to protect user accounts;

• regular monitoring of the Platform for security threats;

• logging and auditing of security-related activities;

• periodic review and improvement of our security practices; and

• staff training on privacy, confidentiality, and information security.

Although we take reasonable steps to safeguard personal information, no method of electronic storage or transmission over the internet can be guaranteed to be completely secure. Accordingly, we cannot guarantee the absolute security of personal information.

In the event of a personal data breach, Centipid Academy will investigate the incident promptly and, where required by applicable law, notify affected individuals and the relevant regulatory authorities within the timeframes prescribed by law.

If you believe your Account or personal information has been compromised, you should notify us immediately using the contact details provided in this Privacy Policy.

11. Your Privacy Rights

Subject to applicable data protection laws, you may have one or more of the following rights in relation to your personal information.

11.1 Right of Access

You may request confirmation of whether we process your personal information and obtain a copy of the personal information we hold about you.

11.2 Right to Rectification

You may request that we correct or update inaccurate, incomplete, or outdated personal information.

11.3 Right to Erasure

You may request the deletion of your personal information where:

• the information is no longer necessary for the purpose for which it was collected;

• you withdraw consent where consent was the legal basis for processing;

• processing is unlawful; or

• applicable law otherwise grants you the right to request deletion.

This right may be limited where we are legally required to retain certain information.

11.4 Right to Restrict Processing

You may request that we temporarily restrict the processing of your personal information in circumstances permitted by applicable law.

11.5 Right to Data Portability

Where applicable, you may request that we provide your personal information in a structured, commonly used, and machine-readable format, or transfer it to another service provider where technically feasible.

11.6 Right to Object

Where we process personal information based on our legitimate interests, you may object to such processing where permitted by law.

11.7 Right to Withdraw Consent

Where we rely on your consent to process personal information, you may withdraw that consent at any time.

Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

11.8 Exercising Your Rights

To exercise any of the rights described in this section, please contact us using the contact details provided in this Privacy Policy.

We may request additional information to verify your identity before responding to your request.

We will respond within the time required by applicable law.

11.9 Complaints

If you believe that we have processed your personal information in a manner that is inconsistent with applicable data protection laws, you have the right to lodge a complaint with the relevant supervisory authority, including the Office of the Data Protection Commissioner (Kenya), or any other competent authority having jurisdiction.

12. Children's Privacy

Centipid Academy recognises the importance of protecting the privacy of children and young people.

In accordance with our Terms of Service, individuals under the age of eighteen (18) years may create and use an Account only with the consent of a parent or legal guardian where such consent is required by applicable law.

We do not knowingly collect personal information from children in a manner that is inconsistent with applicable law.

Where we become aware that personal information has been collected from a child without the required consent, we may suspend or delete the relevant Account and take reasonable steps to delete the associated personal information unless we are legally required to retain it.

Parents or legal guardians who believe that a child has provided personal information without appropriate consent may contact us using the details provided in this Privacy Policy to request that the information be reviewed, corrected, or deleted where appropriate.

13. Changes to this Privacy Policy

Centipid Academy may update this Privacy Policy from time to time to reflect changes in our services, business operations, legal obligations, technology, or data processing practices.

Where we make material changes to this Privacy Policy, we will take reasonable steps to notify Users before the changes become effective. Such notification may be provided through the Platform, by email, or by other appropriate means.

The "Last Updated" date at the beginning of this Privacy Policy indicates when this document was most recently revised.

Your continued use of the Platform after an updated Privacy Policy becomes effective constitutes your acknowledgement of the revised Privacy Policy, to the extent permitted by applicable law.

Where applicable law requires your consent for a particular change in the way we process your personal information, we will obtain that consent before implementing the change.

14. Contact Information

If you have any questions, concerns, or requests relating to this Privacy Policy or the way Centipid Academy processes your personal information, please contact us using the details below.

You may also contact us to:

• request access to your personal information;

• request correction or deletion of your personal information;

• exercise any of your rights under applicable data protection laws;

• withdraw consent where processing is based on consent;

• report a suspected privacy or security concern; or

• submit questions or complaints relating to our privacy practices.

We will acknowledge and respond to privacy-related enquiries within the timeframes required by applicable law.