KenyanTutors – Application Portal Privacy Policy

Privacy Policy – Tutor Application Portal

Last updated: 06 Dec 2025

1. Who we are (data controller)

This Privacy Policy explains how we collect, use and protect your personal data when you use the tutor application portal at apply.kenyantutors.com (the “Portal”).

For the purposes of data protection laws in Kenya (including the Data Protection Act, 2019), the UK and the EU (including GDPR/UK GDPR), the data controller is:

Fluent Path Ltd, trading as KenyanTutors
Company number: 15878992
Registered office: 82a James Carter Road, Mildenhall, Bury St. Edmunds, England, IP28 7DE
Email: hello@kenyantutors.com

This Policy applies only to the Portal. For information about how we handle data on the main KenyanTutors website and platform, please see the main KenyanTutors Privacy Policy .

2. The data we collect

When you submit a tutor application through the Portal, we may collect and process the following categories of personal data:

  • Identification data: full name, gender, date of birth.
  • Contact data: email address, phone/mobile number, postal address.
  • Location & address data: town/city, county/region, postcode/ZIP, and country as inferred from your details.
  • Professional data: subjects you can teach, teaching experience, education or qualifications as described in your application.
  • Media: profile photo and introduction video (where uploaded), including your image and voice.
  • Application metadata: application reference number, application status (e.g. new, under review, accepted, rejected), internal admin notes and review history.
  • Technical & security data: IP address, device and browser information, time and date of access, log data, and security-related data such as hCaptcha verification tokens.

3. How we use your personal data (purposes and legal bases)

We use your personal data for the following purposes:

  • Receiving and processing applications To receive, store and review your application, and to communicate with you about it.
    Legal bases: your consent (when you submit the form); our legitimate interests in recruiting tutors and administering our application process.
  • Assessing suitability To assess your skills, experience and suitability to become a tutor on KenyanTutors.
    Legal bases: our legitimate interests in operating and improving our tutoring platform; your consent in providing detailed information.
  • Profile creation (if successful) If you are accepted as a tutor, we may use your name, subjects, profile photo and introduction video to create and display your tutor profile on the KenyanTutors platform.
    Legal bases: performance of a contract (or steps prior to entering a contract) with you as a tutor; our legitimate interests in promoting tutors on the platform; your consent for use of your image and video.
  • Service improvement and analytics To analyse how the Portal is used and improve our recruitment processes, systems and security (for example, reviewing volumes of applications by month/year).
    Legal bases: our legitimate interests in improving and securing our services.
  • Security and fraud prevention To protect the Portal from misuse, detect automated or malicious activity, and investigate suspected fraud or abuse.
    Legal bases: our legitimate interests in maintaining the security and integrity of our systems; compliance with legal obligations where applicable.
  • Legal and regulatory compliance To comply with laws and regulations, respond to legitimate requests from authorities, and to establish, exercise or defend legal claims.
    Legal bases: compliance with legal obligations; our legitimate interests in protecting our legal rights.

4. Do you have to provide this data?

In order to submit an application, you must provide the information marked as required on the form. If you do not provide this information, we will not be able to process your application.

Uploading a profile photo and introduction video may be strongly recommended for your application, but where these are optional we will treat your choice to upload them as your consent.

5. How long we keep your data

We keep your personal data only for as long as is reasonably necessary for the purposes described above, including to meet legal, accounting or reporting requirements.

  • Unsuccessful applications: as a general guideline, up to 24 months from our final decision, unless a longer period is required by law or necessary to handle a complaint or legal claim.
  • Successful applications (active tutors): for the duration of your relationship with KenyanTutors as a tutor, and for a reasonable period afterwards (for example, to handle payments, disputes, or legal claims).

We may retain anonymised or aggregated information for longer periods, provided it is no longer possible to identify you from that information.

6. Sharing your data

We do not sell your personal data. We may share it with:

  • Internal staff and contractors who help review applications, manage the Portal and operate KenyanTutors.
  • Service providers who host and support our systems, such as cloud hosting, email and storage providers (for example, Amazon Web Services).
  • Professional advisers such as lawyers or accountants where reasonably necessary.
  • Authorities and regulators where required by law, or where we need to protect our rights or respond to lawful requests (for example, courts or data protection regulators).

If you become an active tutor, some information (such as your name, profile photo, subjects and introduction video) will be visible to users of the KenyanTutors platform, as described in the main KenyanTutors Privacy Policy.

7. International transfers

We may store and process your personal data on servers located outside the country where you are based, including in the United Kingdom and the European Economic Area (EEA), using reputable cloud providers such as Amazon Web Services.

Where we transfer personal data:

  • From Kenya to other countries, we do so in line with Kenya’s Data Protection Act and related Regulations, using safeguards such as countries with adequate data protection laws, standard contractual clauses, or your explicit consent where required.
  • From the UK/EEA to other countries, we rely on adequacy decisions, standard contractual clauses or similar safeguards, as permitted under GDPR/UK GDPR.

8. Your data protection rights

Depending on the laws that apply to you (including Kenya’s Data Protection Act and GDPR/UK GDPR), you may have some or all of the following rights:

  • Right of access – to request a copy of the personal data we hold about you.
  • Right to rectification – to ask us to correct inaccurate or incomplete data.
  • Right to erasure – to ask us to delete your data in certain circumstances.
  • Right to restriction – to ask us to restrict how we use your data in certain situations.
  • Right to object – to object to certain types of processing, particularly where we rely on legitimate interests.
  • Right to data portability – to receive certain data in a structured, commonly used and machine-readable format, and to have it transmitted to another controller where technically feasible.
  • Right to withdraw consent – where we rely on your consent (for example, for use of your photo/video), you can withdraw that consent at any time. This will not affect the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, please contact us at hello@kenyantutors.com. We may need to verify your identity before responding.

9. Complaints

If you are unhappy with how we handle your personal data, we encourage you to contact us first so we can try to resolve the issue.

You also have the right to lodge a complaint with a data protection authority:

  • In Kenya, this is the Office of the Data Protection Commissioner (ODPC). See the ODPC website for contact details and how to raise a complaint.
  • If you are in the EU or UK, you can contact your local data protection authority (for example, in the UK, the Information Commissioner’s Office).

10. Cookies and similar technologies

The Portal may use basic cookies or similar technologies for security and essential functionality, for example to help prevent automated spam submissions via hCaptcha and to keep the portal running smoothly.

For more information about cookies used across the KenyanTutors ecosystem, please refer to the main KenyanTutors Privacy Policy .

11. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in law, our services or our internal practices. When we do, we will update the “Last updated” date at the top of this page.

We encourage you to review this Policy periodically. If we make material changes, we may highlight them on the Portal or notify you by email where appropriate.

12. Contact us

If you have any questions about this Privacy Policy or how we handle your personal data, or you wish to exercise your data protection rights, please contact us at:

hello@kenyantutors.com
Please include your name and, if you have applied through this Portal, your application reference number so we can locate your record quickly.

This Portal Privacy Policy supplements the main KenyanTutors Privacy Policy . If there is any conflict between them, this Policy applies to your use of apply.kenyantutors.com.