ShuleGram ("we," "our," or "us") is committed to protecting the privacy and security of all users of our educational social platform. This Data Protection Policy outlines how we collect, use, store, and safeguard the personal information of Learners (students), Parents, and Teachers ("you" or "your") in compliance with the Kenya Data Protection Act, 2019, and other applicable regulations.
By using ShuleGram, you agree to the practices described in this policy. We encourage you to read this policy carefully to understand how we protect your information.
Key terms used throughout this policy:
Provided by the school or Parent:
Important: Explicit parental consent is required before any Learner profile is created or data is processed.
For Tutors/Counselors:
For Transactions:
We process your data based on lawful grounds and for specific purposes:
| Purpose of Processing | Lawful Basis |
|---|---|
| To provide core app functionality (e.g., sharing updates, live streams) | Performance of a Contract & Consent (explicit consent for Learners) |
| To facilitate the services marketplace and process payments | Performance of a Contract & Legitimate Interests |
| To utilize AI features (translation, behavior analytics) | Explicit Consent (opt-in required for analytics) |
| To send notifications about a Learner's activities (e.g., live stream alerts) | Legitimate Interests (vital interest of the Parent) |
| To ensure platform security and prevent misuse | Legitimate Interests & Legal Obligation |
| For product development and troubleshooting | Legitimate Interests |
Your personal data is never sold to third parties. We share data only under strict, transparent conditions.
A Learner's data (photos, videos, updates) is shared only with:
We use trusted third-party providers for:
These partners are bound by strict data processing agreements.
We may disclose data if required by Kenyan law or to protect the vital interests of a user.
The protection of Learner data is our highest priority. We implement multiple safeguards to ensure children's safety.
We require school-verified or digitally verified consent from a Parent before a Learner's profile is activated.
Learner profiles for children over 10 that allow them to showcase work are subject to a "double-approval" system, requiring both Teacher and Parent consent before any content is made visible.
Automatic blurring in group photos for children without consent
Sensitive content viewable only once, not saved to device
All media watermarked to deter unauthorized redistribution
We implement robust technical and organizational measures to protect your data:
We retain personal data only for as long as necessary to fulfill the purposes outlined in this policy, or as required by law.
Retained for a period defined by the school and Parent agreement (e.g., 1 academic year), after which it is automatically anonymized or deleted.
Deleted upon user request or after a period of account inactivity.
Under the Kenya Data Protection Act, you have the following rights:
Access and receive a copy of your personal data
Rectify inaccurate or incomplete data
Object to or restrict the processing of your data
Request deletion of your data ("Right to be Forgotten")
Receive your data in a portable format
Withdraw consent at any time
To exercise these rights, please contact us at dpo@shulegram.co.ke
Data is primarily processed within Kenya or the East African Community.
If any data transfer outside this region occurs, we will ensure it is protected by adequate safeguards as required by Kenyan law.
We may update this policy periodically. We will notify users of any material changes via the app or email and will require renewed consent where necessary.
For any questions, concerns, or requests regarding this policy or your data
dpo@shulegram.co.keYou also have the right to lodge a complaint with the Office of the Data Protection Commissioner (ODPC) of Kenya.