Privacy Policy

This Privacy Notice for Learning Differently Limited (“Company”, “we”, “us”, or “our”) describes how and why we may collect, store, use, process, protect, and share your information when you use our services (“Services”), including when you:

• Visit our website at https://learningdifferently.africa or any website of ours that links to this Privacy Notice;
• Download and use our mobile applications, digital platforms, assessment tools, and online learning systems;
• Access artificial intelligence-assisted educational tools and support systems, including Dora;
• Participate in online learning, coaching, psychosocial support, teacher training, caregiver support, or educational interventions;
• Engage with us through assessments, consultations, webinars, events, support forums, or digital communication platforms;
• Interact with us in relation to screening, intervention planning, inclusive education support, therapy referrals, assessments, research, or safeguarding support.
  Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights, safeguarding protections, and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have questions or concerns, please contact us at:
  Email: [email protected]
  Safeguarding Contact: [email protected]

CHILDREN AND YOUNG PERSONS
Learning Differently Limited provides services, tools, assessments, educational support, psychosocial support, digital learning solutions, and technology platforms that may involve children and young persons under the age of 18, including learners with disabilities, neurodivergent learners, and learners requiring additional educational, behavioural, emotional, or developmental support.
We are committed to promoting the safety, dignity, wellbeing, inclusion, and protection of all children who interact with our Services, including through our digital platforms, assessments, interventions, online learning environments, mobile applications, and artificial intelligence tools such as Dora.Where our Services involve children, we apply enhanced safeguarding, privacy, and data protection measures in accordance with applicable laws, child protection principles, disability inclusion standards, and ethical educational practices. We may require the consent of a parent, guardian, school, therapist, or other authorised adult before collecting, processing, or sharing a child’s personal information.
We do not knowingly exploit, market directly to, or profile children using sensitive educational, behavioural, disability-related, or psychological data for commercial advertising purposes.

Where we identify concerns relating to child safety, abuse, exploitation, neglect, bullying, self-harm, trafficking, emotional harm, or safeguarding risks, we may take appropriate protective action, including escalation to relevant authorities where required by law.

SUMMARY OF KEY POINTS
This summary provides key points from our Privacy Notice.

• We may process personal information relating to children, parents, caregivers, educators, schools, professionals, and organisations using our Services.
• We may process sensitive personal information, including disability-related, developmental, behavioural, educational, psychosocial, assessment, and safeguarding-related information where necessary for service delivery and support.
• We process information to provide inclusive educational services, assessments, interventions, psychosocial support, safeguarding support, digital learning solutions, and technology-enabled educational assistance.
• We apply enhanced safeguards for children and vulnerable persons.
• Parents and guardians may request access to, correction of, or deletion of a child’s information subject to legal and safeguarding obligations.
• We do not knowingly sell children’s data.
• We do not use sensitive child-related information for behavioural advertising.
• We may share information with authorised schools, therapists, psychologists, assessors, safeguarding professionals, or authorities where necessary and legally permitted.
• We use organisational, technical, and administrative safeguards to protect information.
• We may use artificial intelligence-assisted systems such as Dora to support educational assessments and interventions, but these systems do not replace professional judgment.

1. WHAT INFORMATION DO WE COLLECT?

Personal Information You Disclose to Us
We collect personal information that you voluntarily provide to us when you:

• Register for our Services;
• Participate in assessments or interventions;
• Contact us;
• Request information;
• Participate in online or in-person programs;
• Engage with our digital tools;
• Submit educational or assessment information;
• Use our applications or support systems.

Categories of Information We May Collect
Depending on the nature of the Services, we may collect:

• Name, contact details, and demographic information;
• Parent or guardian information;
• Educational records and learning profiles;
• Assessment results and screening outcomes;
• Behavioural observations and developmental information;
• Disability-related information and accommodation needs;
• Executive functioning indicators;
• Literacy, numeracy, communication, and learning support information;
• Psychosocial and wellbeing information;
• Individualised Education Plans (IEPs);
• Therapy and intervention records;
• School-related information;
• Referral information;
• Progress tracking information;
• Audio, video, or image recordings where consent has been provided;
• Safeguarding and child protection information where necessary.

Sensitive Personal Information
We may process sensitive personal information including disability-related, behavioural, developmental, educational, psychosocial, safeguarding, and child- related information strictly for educational support, assessment, intervention,
inclusion, wellbeing, safeguarding, and service delivery purposes. Such processing shall be conducted in accordance with applicable data protection, child protection, disability inclusion, and safeguarding laws. Information from Schools and Professionals.
We may receive or process information submitted by:

• Schools;
• Teachers;
• Learning support assistants;
• Psychologists;
• Therapists;
• Assessors;
• Medical professionals;
• Caregivers;
• Partner organisations;
• Authorised educational or safeguarding professionals.

Child Protection and Safeguarding Information
Where necessary, we may collect information relating to:

• Child wellbeing;
• Safety concerns;
• Bullying;
• Abuse indicators;
• Neglect;
• Self-harm concerns;
• Emotional distress;
• Exploitation risks;
• Safeguarding referrals.

Such information shall only be processed where necessary, proportionate, and legally permitted.

Social Media Login Data
We may provide you with the option to register using existing social media accounts. Children may not independently create accounts through social media logins without parental or guardian consent.

Application Data
If you use our applications or digital platforms, we may collect:

Geolocation Information
We may request access to location-based information where necessary for certain services. Precise geolocation data relating to children shall only be collected where strictly necessary and with informed parental or guardian consent.

Mobile Device Data
We may collect:

• Device IDs;
• Browser type;
• Operating system information;
• Internet Protocol (IP) addresses;
• Mobile carrier information;
• System configuration information;
• Application usage information.

Push Notifications
We may request permission to send notifications regarding accounts, services, educational reminders, safeguarding notices, or platform features. Notifications directed toward children shall be age-appropriate, non-exploitative, educational, and supportive in nature.

2. INFORMATION AUTOMATICALLY COLLECTED

We automatically collect certain technical and usage information when you visit or use our Services. This may include:

• IP address;
• Device information;
• Browser information;
• Operating system;
• Device characteristics;
• Usage behaviour;
• Referral URLs;
• Language preferences;
• Platform interaction information;
• Access dates and times.

We collect this information to:

• Maintain service functionality;
• Improve platform performance;
• Support accessibility;
• Protect platform security;
• Improve user experience;
• Monitor safeguarding and misuse risks;
• Conduct analytics and reporting.

Cookies and Tracking Technologies
We may use cookies and similar technologies for:

• Security;
• Authentication;
• Accessibility;
• Performance optimisation;
• Educational analytics;
• User experience improvements.

We do not knowingly use behavioural advertising, manipulative engagement techniques, or commercial profiling practices targeting children. We do not use sensitive disability, behavioural, psychological, or educational data for targeted commercial advertising.

3. HOW DO WE PROCESS YOUR INFORMATION?

We process your information for a variety of reasons depending on how you interact with our Services. These purposes may include:

• Providing educational services and interventions;
• Conducting assessments and screenings;
• Supporting inclusive education;
• Delivering psychosocial support;
• Facilitating coaching and therapy referrals;
• Supporting parents, teachers, caregivers, and schools;
• Promoting child wellbeing and safeguarding;
• Monitoring learner progress;
• Improving accessibility and inclusion;
• Delivering digital learning experiences;
• Providing customer support;
• Sending educational or service-related communications;
• Maintaining platform safety and security;
• Preventing fraud and misuse;
• Conducting research and impact evaluation;
• Improving our Services and technology systems.

We may also process information:

• To identify usage trends;
• To improve interventions;
• To evaluate service effectiveness;
• To determine educational impact;
• To support early identification and intervention.

Safeguarding and Protection
We may process information where necessary to:

• Protect children and vulnerable individuals;
• Respond to safeguarding concerns;
• Prevent harm;
• Escalate child protection concerns;
• Support crisis intervention;
• Comply with legal reporting obligations.

Where there is concern regarding abuse, exploitation, trafficking, neglect, self-harm, bullying, or significant safeguarding risk, we may disclose relevant information to authorised safeguarding authorities or professionals in accordance with applicable laws.

Artificial Intelligence and Automated Systems

Learning Differently Limited may use artificial intelligence-assisted systems, including Dora, to support educational screening, assessment support, intervention recommendations, data analysis, and inclusive learning support.
These systems are designed to support — and not replace — professional judgment.
Users may request human review of significant automated recommendations or assessment outcomes where applicable.

4. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

We process personal information only where we have a lawful basis to do so. These legal bases may include:

• Consent;
• Parental or guardian consent;
• Contractual necessity;
• Legitimate interests;
• Compliance with legal obligations;
• Protection of vital interests;
• Safeguarding obligations;
• Educational support obligations.

Where required, we will seek informed consent prior to conducting:

• Assessments;
• Screenings;
• Interventions;
• Coaching;
• Counselling;
• Therapy-related referrals;
• Recording sessions;
• Sharing reports.

Where appropriate, we may also seek age-appropriate assent from children in addition to parental or guardian consent.

5. CHILD PROTECTION AND SAFEGUARDING

Learning Differently Limited is committed to maintaining safe, inclusive, respectful, trauma-informed, and neurodiversity affirming environments for all children and vulnerable individuals. We recognise that children interacting with our Services may be at increased risk of:

• Exploitation;
• Cyberbullying;
• Emotional harm;
• Grooming;
• Online abuse;
• Discrimination;
• Exclusion;
• Stigma;
• Mental health distress.

To support child safety, we may:

• Implement safeguarding protocols;
• Moderate digital interactions;
• Restrict inappropriate communications;
• Escalate safeguarding concerns;
• Vet relevant staff and consultants;
• Conduct safeguarding training;
• Monitor platform misuse;
• Provide reporting mechanisms for safety concerns.

All relevant employees, consultants, coaches, therapists, facilitators, assessors, and contractors working with children may undergo safeguarding onboarding, child protection training, and appropriate vetting procedures.
We may maintain internal safeguarding procedures for responding to:

• Abuse allegations;
• Bullying;
• Exploitation;
• Harmful conduct;
• Child protection disclosures;
• Emergency safeguarding situations.

6. WHEN AND WITH WHOM DO WE SHARE YOUR INFORMATION?

We may share information where necessary with:

• Schools;
• Teachers;
• Therapists;
• Psychologists;
• Assessors;
• Learning support professionals;
• Safeguarding professionals;
• Service providers;
• Technology providers;
• Researchers;
• Legal authorities;
• Regulatory bodies.

We only share information:

• Where consent has been provided;
• Where legally required;
• Where necessary for safeguarding;
• Where necessary for educational support;
• Where necessary for service delivery.

We do not sell children’s personal data.
We do not permit third parties to use sensitive educational, disability-related, behavioural, or child-related information for unrelated commercial advertising purposes.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

We retain information only for as long as necessary to:

• Deliver services;
• Meet safeguarding obligations;
• Comply with legal obligations;
• Resolve disputes;
• Maintain records;
• Support continuity of care and intervention.

Children’s information shall not be retained indefinitely. Retention periods may vary depending on:

• The nature of the services;
• Legal obligations;
• Educational requirements;
• Safeguarding considerations.

Where information is no longer necessary, we will securely delete, anonymise, or de-identify it.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

We implement organisational, technical, and administrative safeguards designed to protect information from:

• Loss;
• Misuse;
• Unauthorised access;
• Disclosure;
• Alteration;
• Destruction.

These safeguards may include:

• Encryption;
• Access controls;
• Password protections;
• Staff confidentiality obligations;
• Safeguarding protocols;
• Security monitoring;
• Secure cloud infrastructure;
• Role-based permissions.

Where a breach involving children’s data or sensitive educational information occurs, we may take enhanced notification and mitigation measures in accordance with applicable laws. However, no internet-based system can be guaranteed to be completely secure.

9. YOUR PRIVACY RIGHTS

Depending on applicable laws, users and parents/guardians may have rights to:

• Access personal information;
• Correct inaccurate information;
• Request deletion of information;
• Restrict certain processing;
• Withdraw consent;
• Object to processing;
• Request copies of records.

Parents and guardians may exercise rights relating to their child’s information subject to:

• Safeguarding obligations;
• Legal requirements;
• Educational obligations;
• Court orders;
• Verification of lawful authority.

Requests may be submitted to:
Email: [email protected]

10. ACCESSIBILITY, INCLUSION, AND NON-DISCRIMINATION

Learning Differently Limited is committed to promoting accessibility, inclusion, dignity, and equal participation for persons with disabilities and neurodivergent individuals.

We strive to design our Services in ways that support:

• Accessibility;
• Inclusive learning;
• Diverse communication needs;
• Reasonable accommodations;
• Trauma-informed engagement;
• Neurodiversity-affirming practices.

We do not intentionally discriminate based on:

• Disability;
• Learning differences;
• Neurodivergence;
• Communication style;
• Gender;
• Socioeconomic background;
• Religion;
• Ethnicity;
• Age.

11. ONLINE SAFETY AND DIGITAL COMMUNITY STANDARDS

Where our Services include online communities, digital learning spaces, forums, support groups, chats, or peer interaction features, users must:

• Engage respectfully;
• Avoid bullying or harassment;
• Refrain from abusive conduct;
• Avoid sharing inappropriate content;
• Respect safeguarding standards.

We reserve the right to:

• Remove harmful content;
• Restrict access;
• Suspend accounts;
• Report harmful behaviour;
• Escalate safeguarding concerns.

12. RESEARCH, ANALYTICS, AND IMPACT EVALUATION

Learning Differently Limited may conduct research, analytics, and impact evaluation activities to improve educational inclusion, interventions, accessibility, and service delivery.
Where research involves children or vulnerable individuals, we will implement:

• Ethical safeguards;
• Appropriate consent procedures;
• Confidentiality protections;
• Data minimisation practices.

Where possible, research data shall be anonymised or de-identified.

13. CROSS-BORDER DATA TRANSFERS

Some information may be processed or stored using cloud systems or service providers located outside Kenya. Where cross-border transfers occur, we will take reasonable steps to ensure appropriate safeguards are in place to protect personal information.

14. EMERGENCY AND CRISIS DISCLAIMER

Our Services are not emergency response services. If a child or individual is in immediate danger or experiencing a mental health or safeguarding emergency, users should contact emergency services, local authorities, or relevant child protection agencies immediately.

15. APPLICABLE LAWS AND STANDARDS

This Privacy Notice is informed by applicable laws, standards, and principles including:

• The Constitution of Kenya (2010);
• The Data Protection Act (2019);
• The Children Act (2022);
• The Persons with Disabilities Act;
• Applicable child safeguarding standards;
• Disability inclusion principles;
• Ethical educational and psychosocial support standards.

16. UPDATES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time. Updated versions will be posted on our website and platforms with revised effective dates.

17. CONTACT US

If you have questions, concerns, safeguarding reports, or privacy-related requests, you may contact:
Learning Differently Limited
Website: https://learningdifferently.africa
Email: [email protected]
Privacy Requests: [email protected]
Safeguarding Contact: [email protected]