Legal

Privacy Policy

Last updated: June 2026 · Compliant with the Kenya Data Protection Act, 2019

Hekima AI Limited(“Hekima AI”, “we”, “our”) operates the learning platform at hekima-ai.org and the Hekima AI mobile app. We are committed to protecting the personal data of every learner, job seeker, and visitor who uses our services.

This policy explains what personal data we collect, why we collect it, how we use and share it, and what rights you have under the Kenya Data Protection Act, 2019 (the “Act”).


1. Who We Are (Data Controller)

Hekima AI Limited is the data controller responsible for your personal data. We are registered in Kenya and are subject to the Kenya Data Protection Act, 2019.

Hekima AI Limited

Email: support@hekima-ai.org

Website: hekima-ai.org

2. Information We Collect

Account information

  • Email address and name
  • Password (stored as a secure one-way hash — we never see your actual password)
  • Google account details, if you sign in with Google (website only)

Learning activity

  • Courses enrolled in, lessons completed, quiz attempts and scores
  • Capstone project submissions
  • Certificates issued (verified via hekima-ai.org/verify)
  • Course feedback and ratings you submit voluntarily

AI tutor (Rafiki) conversations

Messages you send to Rafiki, our AI tutor, are processed in real time by AI providers listed in Section 5. We do not permanently store the full text of your Rafiki conversations on our servers, but AI providers may retain message data in accordance with their own privacy policies.

Payment information

We record your subscription plan, the amount paid (in KES), and a transaction reference number. We never receive or store your M-Pesa PIN, card number, or bank details — those are handled exclusively by Pesapal, our payment processor.

Device and technical information (app users)

  • Device type, operating system version, and app version
  • Push notification token (for study reminders, if you grant permission)

Usage and analytics data

  • Pages and features you visit or use, and when
  • IP address and approximate location (country/region level)
  • Last active date (used to send optional re-engagement nudges)

3. How We Use Your Information

PurposeLegal basis (Kenya DPA 2019)
Create and manage your accountPerformance of contract
Deliver course content, track your progress, and issue certificatesPerformance of contract
Power the Rafiki AI tutorPerformance of contract
Process payments and maintain financial recordsPerformance of contract; legal obligation
Send transactional emails (payment receipts, password resets, welcome messages)Performance of contract
Send optional learning nudge emails (max 4 per year, easy opt-out)Legitimate interest; consent
Improve our courses, platform, and AI tutorLegitimate interest
Detect fraud and ensure securityLegitimate interest; legal obligation

4. Sharing Your Data

We do not sell your personal data. We share it only as necessary to provide our services, with the following categories of third-party processors:

ProviderPurposeLocation
AnthropicRafiki AI tutor (Claude)USA
GoogleRafiki AI (Gemini); Google sign-inUSA
OpenAIRafiki AI (GPT-4o)USA
xAIRafiki AI — current events queries (Grok)USA
PesapalPayment processing (M-Pesa, card)Kenya
VercelWeb platform hostingUSA/EU
Amazon Web ServicesCloud infrastructure, payments backendUSA
UpstashDatabase (account data, progress, analytics)EU/USA
PostHogProduct analytics (pseudonymous)EU
ResendTransactional email deliveryEU
Expo (EAS)Mobile app distribution and updatesUSA

We may also disclose your data if required by Kenyan law, a court order, or a lawful request by a public authority.

5. International Data Transfers

Several of our service providers are based outside Kenya (primarily in the USA and EU). Under the Kenya Data Protection Act 2019, we are required to ensure that any transfer of personal data outside Kenya is to a country that provides an adequate level of protection, or that appropriate safeguards are in place. We rely on the data processing agreements and standard contractual terms of each provider listed above to meet this requirement.

6. Your Rights Under the Kenya Data Protection Act 2019

As a data subject under Kenyan law, you have the following rights:

  • Right to be informed — to know what data we hold about you and how we use it (this policy fulfils that right).
  • 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 personal data (subject to legal and contractual obligations).
  • Right to restrict processing — to ask us to limit how we use your data in certain circumstances.
  • Right to data portability — to receive your data in a structured, machine-readable format.
  • Right to object — to object to processing based on legitimate interest, including direct marketing.
  • Right to withdraw consent — where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, email us at support@hekima-ai.org. We will respond within 21 days as required by the Act.

7. Data Retention

Data typeRetention period
Account data (email, name, password hash)Duration of account + 90 days after deletion request
Learning progress and certificatesDuration of account + 90 days
Payment records7 years (Kenya tax and financial record-keeping requirements)
Analytics and usage data13 months rolling (PostHog default)
Email unsubscribe preferencesIndefinitely (to honour your opt-out)

8. Security

We apply appropriate technical and organisational measures to protect your personal data, including:

  • HTTPS encryption for all data in transit
  • Passwords stored as irreversible cryptographic hashes (bcrypt)
  • Access controls limiting who within our team can access personal data
  • Payment details handled exclusively by PCI-DSS-compliant Pesapal — we never see your card or M-Pesa PIN

No system is completely secure. If you discover a security vulnerability, please report it responsibly to support@hekima-ai.org.

9. Children and Young People

Our platform is intended for learners aged 16 and above. We do not knowingly collect personal data from children under 16. If you believe a child under 16 has provided us with personal data, please contact us at support@hekima-ai.org and we will delete it promptly.

10. Cookies and Analytics

We use essential cookies to keep you logged in and to protect against CSRF attacks. We also use PostHog, an analytics tool, to understand how the platform is used. PostHog data is pseudonymised (linked to a hashed identifier, not directly to your name or email). You can opt out of analytics tracking by contacting us.

11. Changes to This Policy

We may update this policy from time to time. When we make material changes, we will notify you by email and by posting a notice on the platform at least 14 days before the changes take effect. Your continued use of Hekima AI after that date means you accept the updated policy.

12. Contact Us and How to Complain

For any privacy-related questions, to exercise your rights, or to raise a concern, contact us:

Hekima AI Limited

Email: support@hekima-ai.org

Website: hekima-ai.org

If you are not satisfied with our response, you have the right to lodge a complaint with the Office of the Data Protection Commissioner (ODPC) of Kenya:

Office of the Data Protection Commissioner

Website: www.odpc.go.ke

Email: info@odpc.go.ke


© 2026 Hekima AI Limited. This policy is governed by the laws of Kenya.