1. Introduction

This Cookie Policy explains how [Platform Legal Name] (“the Platform”, “we”, “us” or “our”) uses cookies and similar technologies when users access our website and online educational services.

The Platform provides educational services that may include student and tutor accounts, online lessons, assessments, examinations, learning records and related functions.

Cookies and similar technologies may be used to maintain secure sessions, support essential Platform functions, remember preferences and, where implemented, understand website usage and improve our services.

This Policy should be read together with our Privacy Policy and General Terms and Conditions.

The Platform will handle personal data collected through cookies and similar technologies in accordance with the Kenyan Data Protection Act, 2019, the applicable regulations, and other relevant laws and guidance.

2. What Are Cookies?

Cookies are small text files that a website may store on a user's device when the user visits the website. They may help a website maintain a login session, remember preferences or recognise a returning browser.

Similar technologies, including certain scripts, tags, pixels and local storage mechanisms, may perform related functions. Where relevant, this Policy also covers those technologies.

Some cookies operate only during a browser session, while others remain on the device for a specified period or until deleted.

3. Categories of Cookies

The Platform distinguishes between essential and non-essential cookies. The actual cookies used will depend on the Platform's technical configuration.

3.1 Essential Cookies

Essential cookies are those strictly necessary to provide a service requested by the user or to enable an essential function of the Platform.

Depending on the Platform's configuration, these may support:

• User authentication and login sessions.
• Secure access to student, tutor and authorised parent or guardian accounts.
• Session management and navigation between Platform pages.
• Security, fraud prevention and protection against unauthorised access.
• Access to lessons, assessments and other core learning functions, where technically necessary.
• Remembering cookie consent choices and essential privacy preferences.

A cookie will not be treated as essential merely because it is useful, convenient or beneficial to the Platform.

Where permitted by applicable law, strictly necessary cookies may operate without consent where they are required to provide a service expressly requested by the user or to perform an essential Platform function.

3.2 Non-Essential Cookies

Non-essential cookies are not strictly necessary to provide the service requested by the user.

If implemented, these may include analytics and usage-measurement cookies used to understand how users interact with the Platform and to help improve its educational and technical functions.

Depending on the tools used and their configuration, analytics may help us understand:

• Which pages and Platform features are used.
• How frequently users access particular sections.
• General patterns of website usage.
• Technical difficulties and performance issues.
• Usage trends that may inform improvements to Platform functions and lesson planning.

The information collected may include online identifiers, device or browser information, pages visited and interaction data. Whether that information constitutes personal data will depend on the information collected and whether an individual can be identified directly or indirectly.

Information needed for lesson planning, attendance, examination marking or student progress may also be collected through the Platform's ordinary systems. Its importance to educational services does not, by itself, make an analytics cookie essential.

Where consent is required under applicable law, non-essential cookies will remain disabled until valid consent has been obtained.

The Platform will not classify analytics cookies as essential solely because the information they generate may help us improve our services.

4. Cookie Notice and Consent

4.1 First-Visit Cookie Banner

The Platform intends to display a cookie banner when a user first visits the website. The banner will explain that the Platform uses essential cookies and may use non-essential cookies.

The banner will provide the following options:

• Accept non-essential cookies
• Reject non-essential cookies
• Cookie settings

The options to accept and reject non-essential cookies will be presented clearly and in a manner that enables users to make a genuine choice.

The banner must be supported by technical settings that give effect to the user's choice. Displaying a banner alone does not prevent cookies from being set.

4.2 Essential Cookies

Strictly necessary cookies may operate without consent where permitted by applicable law.

Blocking or deleting these cookies may affect login, session continuity, security or access to certain Platform functions.

4.3 Non-Essential Cookies

Where consent is required, non-essential cookies will not be activated before valid consent is obtained.

If a user rejects non-essential cookies, those cookies will remain disabled to the extent required by the user's choice and applicable law. Rejecting optional cookies should not, by itself, prevent access to core educational services.

Where the Platform relies on consent to process personal data through cookies or similar technologies, consent will be requested in accordance with the applicable requirements of the Kenyan Data Protection Act, 2019, including the requirements relating to informed, specific and freely given consent.

Where another lawful basis may apply, the Platform will assess that basis separately and will not treat the existence of a cookie banner as a substitute for establishing a lawful basis for processing personal data.

4.4 Changing or Withdrawing Preferences

Users will be provided with a way to reopen cookie settings after making their initial choice.

Through those settings, users may change their preferences or withdraw consent for non-essential cookies where consent is the basis for processing.

Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal. Following withdrawal, the Platform will take appropriate steps to stop the relevant consent-based processing and prevent further use of the affected cookies where required.

Deleting cookies already stored on a device may require the relevant cookies to be removed or to expire, depending on the technology involved.

4.5 Recording Cookie Preferences

The Platform may use an essential cookie or similar technology to remember a user's cookie preferences and record the choice made.

Any consent records retained will be limited to what is reasonably necessary to demonstrate and administer the user's preferences and meet applicable legal obligations.

5. Information Collected Through Cookies

Depending on the technologies implemented, information collected may include:

• IP addresses or other online identifiers.
• Device and browser information.
• Pages visited and Platform features accessed.
• Dates, times and duration of website visits.
• Interaction and navigation information.
• Technical errors and performance information.
• Cookie settings and consent records.

The information actually collected will depend on the specific technology and its configuration.

Cookies are not necessarily used to collect or store lesson recordings, examination answers, examination marks or tutor feedback. Such information may instead be processed and stored through the Platform's ordinary systems independently of cookies.

Where information collected through cookies constitutes personal data, it will be processed in accordance with applicable law and the Platform's Privacy Policy.

The Platform will seek to ensure that personal data collected through cookies is adequate, relevant and limited to what is necessary for the purposes for which it is processed.

6. Third-Party Cookies and Service Providers

Certain cookies or similar technologies may be provided or operated by third-party service providers engaged to support the Platform.

If third-party analytics tools are implemented, those providers may receive information collected through the relevant technologies, depending on the tool, its configuration and the applicable service arrangements.

The identity of third-party providers, the information shared, the purposes of processing, the retention arrangements and any relevant transfers of personal data outside Kenya must be verified before publication of a definitive cookie inventory.

Where a third party processes personal data, the Platform will address the relevant data-protection responsibilities, contractual arrangements and safeguards in accordance with applicable law.

Any transfer of personal data outside Kenya will be assessed against the applicable requirements of the Kenyan Data Protection Act, 2019 and relevant regulations.

7. Cookie Duration

Cookies may be session cookies or persistent cookies.

Session cookies generally expire when the browser session ends.

Persistent cookies remain on a device for a specified period or until deleted, depending on their configuration.

The duration of each cookie depends on its purpose and the technology used. The Platform will seek to ensure that cookie-related personal data is not retained in identifiable form for longer than necessary for the relevant purpose, unless a lawful basis for longer retention applies.

A detailed inventory identifying the actual cookie names, providers, purposes and expiry periods will be completed once the Platform's technical configuration has been verified.

8. Managing Cookies Through Your Browser

Users may also manage cookies through their browser settings. Depending on the browser, users may be able to block cookies, delete existing cookies or receive notifications when cookies are set.

Blocking or deleting essential cookies may affect login, security, sessions, lesson access or other Platform functions.

Browser settings are separate from the Platform's cookie preference mechanism. Users should use the Platform's cookie settings to manage choices offered for non-essential cookies.

9. Children's Privacy

The Platform may be used by children and other students under the age of eighteen. We recognise the importance of protecting children's personal data and providing privacy information in a clear and accessible manner.

Personal data relating to children will be processed in accordance with the Kenyan Data Protection Act, 2019, applicable regulations, relevant requirements relating to children's data, and the Platform's Privacy Policy.

Where the processing of a child's personal data requires parental or guardian consent or authorisation under applicable law, the Platform will apply appropriate arrangements to obtain and record it.

The appropriate person to make a cookie choice will depend on the circumstances, the user's age and capacity, the nature of the processing, and applicable legal requirements. This Policy does not assume that every cookie choice automatically requires parental consent.

The Platform will seek to ensure that its cookie notice and preference mechanism are understandable and that applicable safeguards for children's personal data are observed.

10. Data Protection and Security

The Platform will handle personal data collected through cookies and similar technologies in accordance with applicable data-protection principles, including lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, security and accountability.

Appropriate technical and organisational measures will be applied to protect personal data against unauthorised access, loss, misuse, alteration or disclosure, taking into account the nature of the information and the risks involved.

Individuals retain the rights available to them under applicable Kenyan data-protection law. Requests concerning personal data collected through cookies may be made using the contact details provided in Section 12.

11. Changes to This Cookie Policy

We may update this Policy to reflect changes in the Platform's services, technologies, data-handling practices or applicable law.

The updated Policy will be published on the Platform with a revised “Last Updated” date.

Where a change materially affects the use of non-essential cookies or the purposes for which personal data is processed, the Platform will provide appropriate information and seek renewed consent where required by applicable law.

12. Contact Information

For questions about this Cookie Policy, cookie preferences or the processing of personal data, please contact:

Email: support@vazaki.com

Address: Nairobi

Telephone: 0797606888/ 0797606912

We will handle enquiries and requests in accordance with applicable law and the Platform's Privacy Policy.