Privacy Policy

This Privacy Policy explains what personal data ClinPlacer collects, how we use and protect it, and the rights you have over it, when you use our website, platform, or mobile applications (collectively, the "Services").

This Policy applies to Schools, Facilities, Students, Administrators, and any other User of the Services. It should be read alongside our Terms of Service, Cookie Policy, and — for Institutions — our Data Processing Agreement.

Where an Institution submits personal data about its Students or staff to the Platform, the Institution acts as the data controller for that data, and ClinPlacer acts as processor — see our Data Processing Agreement for how that relationship works. For data ClinPlacer collects directly to operate accounts and billing, ClinPlacer acts as controller, and this Policy describes that processing.

Depending on how you use the Services, we collect:

• Account information — name, email, phone number, role, and Institution affiliation
• Placement & academic data — enrollment status, rotation history, placement applications, attendance, and accreditation hours, submitted by Institutions
• Billing information — subscription plan, payment method reference, and transaction history
• Usage & technical data — log-in activity, device and browser information, and cookies as described in our Cookie Policy
• Support communications — messages you send us through the contact form, email, or live chat

We use personal data to:

• Provide the Services — coordinating placements, managing capacity, and generating reports
• Maintain account security, authenticate Users, and prevent fraud or misuse
• Process subscription payments and manage billing
• Respond to support requests and communicate service updates
• Understand aggregated, anonymized usage patterns to improve the Platform
• Comply with legal obligations, including those under the Kenya Data Protection Act, 2019

Under the Kenya Data Protection Act, 2019, we rely on the following legal bases to process personal data:

• Performance of a contract — to provide the Services under our Terms of Service
• Legitimate interests — to secure the Platform, prevent fraud, and improve the Services
• Legal obligation — where processing is required to comply with applicable law
• Consent — where we rely on your consent, such as for optional communications, and which you may withdraw at any time

We share personal data only where necessary to deliver the Services:

• Schools and Facilities — placement-relevant information is shared between the Institutions coordinating a Student's placement, as intended by the Platform's core function
• Sub-processors — service providers who help us operate the Platform, such as cloud hosting, live chat, and payment providers, listed in our Data Processing Agreement
• Legal & regulatory requests — where disclosure is required by law or a valid legal process

We do not sell personal data to third parties, and we do not use it for third-party advertising.

We retain personal data for as long as your account or your Institution's subscription is active, and as needed to provide the Services.

Following account or subscription termination, data is retained for up to 30 days to allow for export, after which it is permanently deleted from production systems, subject to any legal retention obligations — see our Terms of Service, Section 17.

Under the Kenya Data Protection Act, 2019, you have the right to:

• Access the personal data we hold about you
• Correct inaccurate or incomplete data
• Request deletion of your data, subject to any legal retention requirements
• Object to or restrict certain processing
• Request a copy of your data in a portable format
• Withdraw consent where processing is based on consent

If you are a Student or staff member and your data was submitted by your Institution, we may need to direct certain requests to that Institution as the data controller, or process them jointly. To exercise any of these rights, contact legal@clinplacer.com.

You also have the right to lodge a complaint with the Office of the Data Protection Commissioner of Kenya.

Most Students using the Platform are enrolled in post-secondary training and are adults. Where a Student is under 18, their Institution is responsible for ensuring any consent required by law has been obtained before submitting that Student's data to the Platform.

Where personal data is processed outside Kenya — for example, through a cloud hosting provider with infrastructure in another jurisdiction — we apply safeguards consistent with the cross-border transfer requirements of the Kenya Data Protection Act, 2019. See our Data Processing Agreement for detail.

We apply technical and organizational measures appropriate to the sensitivity of the data we hold, including encryption in transit and at rest, role-based access control, and monitoring. Full detail is on our Security & Trust page.

We use a limited set of cookies to keep the Platform secure and functional. Full detail on what we use and how to manage them is in our Cookie Policy.

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law.

• Material changes will be posted on this page with an updated "Last updated" date
• Where required by law, we will provide advance notice before material changes take effect
• Continued use of the Platform after an update constitutes acceptance of the revised Policy

For privacy questions or to exercise your data protection rights, reach out through the following channels:

Visit our Contact Form