Privacy Policy

1. About This Policy

Alpha Kenya Trust (“Company”, “we”, “us” or “our”) operates alpha.ke and run.themarriagecourse.org, a platform providing free educational and principally Christian, religious and faith-based Courses and Content.

This Privacy Policy explains how we collect, use, store, share and protect personal data when you register for or use the Platform through our website or WhatsApp.

This Policy is intended to comply with the Data Protection Act, 2019 of Kenya, and applicable regulations made under it.

2. Data Controller

For personal data collected in connection with registration and use of the Platform, Alpha Kenya is the data controller and determines why and how that personal data is processed.

Our contact details are:

Where applicable:
Data Protection Officer/Privacy Contact: Mercy Nderitu / +254 115831719

3. Personal Data We Collect

We limit registration data to information reasonably required to administer the Platform. We may collect:

• Name;
• Email address;
• Mobile telephone number, particularly where you elect to access Courses or communications through WhatsApp;
• Church or congregation attended; and
• Position or leadership role within the church, if any.

We collect this information directly from you, including when you register through the website, WhatsApp or an authorised registration process.

4. Religious Information

Information concerning the church you attend and any leadership role you hold may reveal or indicate your religious beliefs. Such information may therefore constitute sensitive personal data under Kenyan law.

We will:

• Collect and process this information only where permitted by applicable law;
• Use it only for legitimate purposes connected with the Platform and its Courses;
• Limit access to persons who reasonably require it;
• Not use it for unrelated profiling or advertising;
• Not sell it; and
• Not disclose it outside the Company except where there is an appropriate legal basis and applicable safeguards.

Where explicit consent or another specific statutory condition is required for processing such information, we will obtain or establish that condition before processing it.

5. Why We Use Your Information

We may use personal data to:

• Register you for and provide access to Courses;
• Identify and communicate with you;
• Deliver Content through the website or WhatsApp;
• Administer Course participation;
• Send Course notices and reminders;
• Provide technical or user support;
• Understand the churches and ministry leadership represented among Course participants where legitimately required for Course administration;
• Maintain Platform security;
• Respond to complaints or legal issues;
• Comply with applicable law; and
• Send marketing communications only where you have chosen to receive them.

We will not use personal data for purposes that are incompatible with the purpose for which it was collected without establishing an appropriate lawful basis.

6. Lawful Basis for Processing

Depending on the processing activity, we may rely on:

• Processing necessary to provide the Platform and Courses you have requested;
• Our legitimate interests in administering, securing and improving the Platform, where those interests do not override your rights;
• Compliance with a legal obligation;
• Your consent, where consent is the appropriate legal basis; or
• Another lawful basis permitted by applicable data protection law.

Where information concerning your church or church leadership constitutes sensitive or special-category data, we will additionally rely on an applicable legal condition permitting the processing of that category of data.

Consent, where relied upon, must be freely given, specific, informed and capable of withdrawal.

7. WhatsApp

If you elect to use WhatsApp, we will use your telephone number and related registration information to:

• Register you for relevant Courses;
• Deliver Course Content;
• Send Course instructions and reminders;
• Provide support; and
• Communicate information relating to your participation.

Use of WhatsApp is optional unless expressly stated otherwise for a particular Course.

Where our WhatsApp service is connected to another system through an integration provider, personal data may pass through that provider before being transmitted to our systems. Such providers will, where they process data solely on our instructions, act as data processors and will be required to apply appropriate contractual and security safeguards.

WhatsApp and its operator may separately process information under their own terms and privacy policies.

Where a WhatsApp group or community is used, your number, profile name or other WhatsApp information may be visible to other participants depending on WhatsApp functionality and your privacy settings.

8. Processors and Service Providers

We may use appropriately selected service providers to provide:

• Website hosting;
• WhatsApp integration;
• Database or customer-management systems;
• Communication services;
• Cybersecurity; and
• Technical support.

Where a service provider acts as our processor, it may process personal data only for authorised purposes and in accordance with our documented instructions and applicable contractual safeguards. Processors are not permitted to use your personal data for their own unrelated purposes.

9. Who We Share Information With

Personal data may be made available, where reasonably necessary, to:

• Authorised Company personnel;
• Authorised Course administrators;
• Instructors, where limited information is necessary to administer a Course;
• Technology and WhatsApp integration providers acting on our behalf;
• Professional advisers, where necessary;
• Regulators, courts or public authorities, where required by law; and
• Other persons where you have authorised the disclosure or another lawful basis applies.

We do not sell personal data.

10. International Data Transfers

Some technology, hosting or WhatsApp-related service providers may process personal data outside Kenya or, where the GDPR applies similar laws, outside the European Economic Area.

Where personal data is transferred internationally, we will ensure that the transfer is made in accordance with applicable data protection law and subject to appropriate safeguards. These may include:

• Adequacy decisions;
• Approved contractual safeguards;
• Standard contractual clauses where applicable;
• Other recognised transfer mechanisms; or
• Another lawful basis for the transfer.

Where sensitive personal data is transferred outside Kenya, we will comply with the additional consent and safeguard requirements applicable under Kenyan law.

11. Data Security

We apply appropriate technical and organisational measures designed to protect personal data against:

• Unauthorised access;
• Loss or destruction;
• Alteration;
• Unlawful disclosure; and
• Other unlawful processing.

Measures may include access controls, secure systems, confidentiality requirements, appropriate technical safeguards and contractual restrictions on service providers.

12. Data Retention

We retain personal data only for as long as reasonably necessary for:

• Course and Platform administration;
• The purpose for which the information was collected;
• Legal or regulatory requirements;
• Resolving disputes; or
• Establishing or defending legal claims.

When personal data is no longer required, it will be securely deleted, anonymised or otherwise disposed of in accordance with our retention procedures. Our processors will retain personal data only for as long as authorised or instructed by us, subject to applicable law.

13. Marketing Communications

Marketing is optional and separate from Course registration. You will be asked to select one of the following:

Neither option will be pre-selected.

Where available, you may also choose:

Your choice will not affect your ability to access Courses or use the Platform. Where you opt in, we will maintain an appropriate record of your consent.

You may withdraw your consent at any time by:

• Using an unsubscribe facility;
• Using the stated WhatsApp/SMS opt-out mechanism;
• Changing your communication preferences, where available; or
• Contacting us at info@alpha.ke / +254 115831719.

Withdrawal will not affect the lawfulness of processing undertaken before consent was withdrawn. Administrative Course communications are separate from marketing and may continue where necessary to provide the Service you requested.

14. Your Data Protection Rights

Subject to applicable law, you may have the right to:

• Be informed about how your personal data is used;
• Access personal data held about you;
• Correct inaccurate or incomplete information;
• Request deletion of personal data;
• Request restriction of processing;
• Object to processing;
• Object to direct marketing;
• Receive eligible personal data in a portable format;
• Withdraw consent where processing is based on consent; and
• Lodge a complaint with a competent data protection authority.

To exercise a right, contact: info@alpha.ke / +254 115831719 (Telephone/WhatsApp).

We may take reasonable steps to verify your identity before acting on a request.

15. Marketing Objections

You have the right to object to direct marketing at any time. Once you withdraw or opt out of marketing communications, we will stop using your personal data for that purpose, subject to the reasonable technical time required to implement your request.

Opting out is free of charge and will not affect your access to the Platform.

16. Personal Data Breaches

If a personal data breach occurs, we will:

• Investigate and contain the incident;
• Assess the potential risk to affected individuals;
• Take appropriate remedial measures;
• Maintain appropriate records; and
• Notify the relevant supervisory authority and affected individuals where required by applicable law.

17. Children

We do not knowingly process a child’s personal data through the Platform except where the relevant Course permits participation by minors and the consent or other safeguards required by applicable law have been put in place.

18. Complaints

If you have a privacy concern, please contact us first at: info@alpha.ke / +254 115831719 (Telephone/WhatsApp).

You also have the right to complain to the Office of the Data Protection Commissioner of Kenya (ODPC).

19. Changes to This Policy

We may update this Privacy Policy to reflect changes in law, technology or the operation of the Platform. Where a material change affects how personal data is used, we will provide appropriate notice and obtain further consent where required by law.

20. Contact Us

For questions, requests or complaints concerning personal data, contact:

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