1. Introduction & Our Commitment to Your Privacy
AFEX Hub (‘we’, ‘us’, or ‘our’) is committed to protecting the privacy of every student, parent, guardian, and visitor who interacts with us. This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you visit our website (golive.co.ke/afexhub) or engage our services.
We collect and process your personal data in accordance with the Kenya Data Protection Act (2019) and, where applicable, the European Union General Data Protection Regulation (GDPR). By using our website or engaging our services, you consent to the practices described in this Policy.
If you have any questions or concerns about how we handle your information, please contact our Data Protection contact at info.kenya@afexhub.co.ke.
2. Who We Are (Data Controller)
For the purposes of applicable data protection law, the data controller is:
• Organisation: AFEX Hub
• Address: Westcom Point, Mahiga Mairu Avenue, Westlands, Nairobi, Kenya
• Email: info.kenya@afexhub.co.ke
• Phone: 0704 904 500
As data controller, we determine the purposes and means of processing your personal data. We are responsible for ensuring that your data is handled lawfully, fairly, and transparently.
3. What Personal Data We Collect
3.1 Data You Provide Directly
When you contact us, complete a form on our website, or engage our services, we may collect the following categories of personal data:
• Identity Data — Full name, date of birth, nationality
• Contact Data — Email address, phone number, home address
• Academic Data — School name, year of study, grades, SAT scores, extracurricular activities, academic transcripts
• Financial Data — Information about family income and financial circumstances, provided solely for the purpose of financial aid strategy advice (we do not store payment card details)
• Application Data — University application materials, personal statements, essays, and related documents shared with us during a consulting engagement
• Communications Data — Records of emails, WhatsApp messages, and other correspondence between you and AFEX Hub
3.2 Data Collected Automatically
When you visit our website, we may automatically collect certain technical data including:
• IP address and approximate geographic location
• Browser type and version
• Pages visited and time spent on the site
• Referring website or search terms used to find us
This technical data is collected through cookies and similar technologies. Please see our Cookie section (Section 10) for more details.
4. How We Use Your Personal Data
We use your personal data only for the following purposes, and only where we have a lawful basis to do so:
PURPOSE DATA USED LAWFUL BASIS
Respond to enquiries and provide requested services Identity, Contact, Communications Contract / Legitimate Interest
Deliver consulting, SAT, and admissions programs Identity, Contact, Academic, Application Contract
Provide financial aid strategy advice Identity, Contact, Financial Contract / Consent
Send program updates, resources, and event invitations Identity, Contact Legitimate Interest / Consent
Improve our website and services Technical, Usage Legitimate Interest
Comply with legal obligations All categories as required Legal Obligation
Maintain records of our work and outcomes Identity, Academic, Application Legitimate Interest
5. How Long We Keep Your Data (Retention)
We retain personal data only for as long as necessary for the purposes described in this Policy, or as required by law. Our standard retention periods are:
• Consultation records — 2 years from the date of consultation
• Active program client data — Duration of the program plus 3 years
• Application materials (essays, transcripts, etc.) — 3 years after program completion
• Financial information — 7 years (to meet Kenyan tax and financial record-keeping requirements)
• Website technical data — 12 months from collection
• Marketing communications data — Until you unsubscribe or withdraw consent
After the applicable retention period, data is securely deleted or anonymised so it can no longer be linked to you as an individual.
6. Who We Share Your Data With
We do not sell, rent, or trade your personal data to any third party. We may share your personal data with:
6.1 Service Providers
We work with carefully selected third-party service providers who assist us in operating our business — such as email communication platforms, cloud storage providers, and website hosting. These providers are contractually required to handle your data securely and only in accordance with our instructions.
6.2 Universities & Institutions
As part of your admissions consulting engagement, we may assist you in submitting application materials to universities on your behalf. In doing so, we share only the application data that you have explicitly authorised us to submit.
6.3 Legal Requirements
We may disclose your personal data where required to do so by law, court order, or lawful request from a government authority in Kenya or another jurisdiction.
6.4 Business Transfers
In the event of a merger, acquisition, or sale of all or part of our business, your personal data may be transferred to the acquiring entity, subject to the same protections described in this Policy.
7. Data Security
We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it against unauthorised access, disclosure, alteration, or destruction. These measures include:
• Secure, encrypted storage of all client data
• Access controls ensuring only authorised AFEX Hub personnel can access client files
• Regular review of our security practices
• Secure communication channels for sharing sensitive documents
While we take all reasonable precautions, no method of data transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security, and we encourage you to use secure connections when communicating with us.
8. Your Rights
Under the Kenya Data Protection Act (2019) and, where applicable, the GDPR, you have the following rights in relation to your personal data:
• Right of Access — You may request a copy of the personal data we hold about you.
• Right to Rectification — You may request that we correct any inaccurate or incomplete personal data we hold about you.
• Right to Erasure — You may request that we delete your personal data in certain circumstances (for example, if it is no longer necessary for the purpose for which it was collected).
• Right to Restrict Processing — You may request that we temporarily halt processing of your data in certain circumstances.
• Right to Data Portability — You may request that we provide your personal data to you in a structured, machine-readable format.
• Right to Object — You may object to processing based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent — Where processing is based on your consent, you may withdraw that consent at any time.
To exercise any of these rights, please contact us at info.kenya@afexhub.co.ke. We will respond to your request within 30 days. We may need to verify your identity before processing your request.
9. International Data Transfers
As we work with students applying to universities in the United States, Canada, and other countries, your data may be processed or accessed by service providers or institutions located outside Kenya. Where data is transferred internationally, we ensure appropriate safeguards are in place — such as contractual clauses requiring the recipient to protect your data to equivalent standards.
Where we transfer data to countries in the European Economic Area or to countries covered by GDPR, we comply with the relevant GDPR requirements for international transfers.
10. Cookies
Our website uses cookies — small text files stored on your device — to improve your browsing experience and understand how visitors use our site. We use:
• Essential cookies — Required for the website to function correctly (cannot be disabled)
• Analytics cookies — Help us understand how visitors interact with our site (e.g. Google Analytics). These are anonymised and do not identify individual visitors.
• Marketing cookies — Used to show you relevant content. These are only set with your consent.
You can control cookies through your browser settings at any time. Disabling non-essential cookies will not prevent you from using our website. By continuing to use our site, you consent to our use of cookies as described above.
11. Children’s Privacy
Many of our students are under 18. We collect and process data relating to minors only with the explicit consent of a parent or guardian. Parents and guardians are responsible for reviewing this Privacy Policy on behalf of their children and for providing consent where required.
We do not knowingly collect personal data from children under the age of 13 without verified parental consent. If you believe we have collected data from a child under 13 without proper consent, please contact us immediately at info.kenya@afexhub.co.ke.
12. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or technology. Updated versions will be posted on this page with a revised ‘Last Updated’ date. We encourage you to review this Policy periodically. Continued use of our website or services after any update constitutes acceptance of the revised Policy.
13. Contact & Complaints
If you have any questions, concerns, or complaints about how we handle your personal data, please contact us:
• Email: info.kenya@afexhub.co.ke
• Phone: 0704 904 500
• Address: Westcom Point, Mahiga Mairu Avenue, Westlands, Nairobi, Kenya
If you are unsatisfied with our response, you have the right to lodge a complaint with the Office of the Data Protection Commissioner of Kenya (odpc.go.ke).
For EU/EEA residents: You may also lodge a complaint with your local supervisory authority in your EU member state.