Terms & privacy

Oddijo Platform Terms of Service and Privacy Policy. Operational rules of engagement and data protection governance.

Platform Operator: Loleni Digital Limited (Nairobi, Kenya)
Governing Framework: Laws of Kenya (Basic Education Act 2013, Data Protection Act 2019)
Effective Date: November 2026 (Version 3)
Target Users: Teachers, Parents / Guardians, and Students (3-Sided Ecosystem)

EXECUTIVE PREAMBLE & REGULATORY BOUNDARIES

Platform Legal Mandate: This Master Legal Document establishes the comprehensive operational regulations, terms of service, and data privacy policies governing the Oddijo educational platform. Oddijo is owned, operated, and maintained exclusively by Loleni Digital Limited, a corporate entity incorporated under the laws of the Republic of Kenya. The platform operates a three-sided digital learning network connecting verified educators ('Teachers'), parents or legal guardians ('Parents'), and enrolled learners ('Students').

Regulatory Compliance & IP Boundaries: These Terms are intended to operate consistently with the Constitution of Kenya, the Data Protection Act, 2019 (Cap. 411C), the Data Protection (General) Regulations, 2021, the Children Act, 2022 (Cap. 141), the Basic Education Act (Cap. 211), the Copyright Act, 2001 (Cap. 130), the Consumer Protection Act, 2012 (Cap. 501), the Computer Misuse and Cybercrimes Act, 2018 (Cap. 79C), and other applicable Kenyan law.

PART A: TERMS AND CONDITIONS OF SERVICE

1. DEFINITIONS

1.1 “Oddijo”, “Platform” or “Services” means the digital tutoring, communication, payment-interface and learning-support services made available by Loleni Digital Limited.

1.2 “Parent” includes a parent or legal guardian with lawful authority to act for a learner.

1.3 “Student” or “Learner” means a person below eighteen (18) years using the Platform for educational purposes.

1.4 Teachers are independent contractors and are not employees, agents or partners of Loleni Digital Limited.

1.5 A Parent or legal guardian contracts with Loleni Digital Limited for the provision of the Platform services to the Parent and, where applicable, the designated Student account.

1.6 “AI Features” means features that use automated models to generate or process content, including lesson plans, lesson aids (slide decks and handouts), quizzes, lesson transcripts and the Study Buddy question-and-answer tool.

2. PLATFORM OPERATOR & LEGAL RELATIONSHIPS

2.1 Corporate Entity: Loleni Digital Limited is the sole provider and legal operator of the Oddijo software suite.

2.2 Independent Contractor Status: Teachers onboarded on Oddijo operate strictly as independent education professionals and contractors. Registration on the platform does not create an employment contract, agency, joint venture, or partnership between any Teacher and Loleni Digital Limited. Teachers maintain full professional independence over their instructional techniques, subject to adherence to national curriculum standards and platform safety regulations.

2.3 Contracting Authority: Parents and legal guardians act as the sole contracting authorities for all minor students. By completing web or chatbot onboarding, Parents enter into a legally binding agreement with Loleni Digital Limited and authorize their designated student sub-accounts to access instructional services.

3. USER ONBOARDING, VERIFICATION & ROLE MANAGEMENT

3.1 Teacher Accreditation Verification: To ensure high instructional standards and child safety as required under Kenyan education laws, every Teacher is reviewed by Loleni before the Teacher’s account is activated, on the basis of the following:

a) TSC Registration: A Teacher may provide an active registration number issued by the Teachers Service Commission (TSC) at sign-up or later from the Teacher’s profile. Loleni validates the number when it is provided, and Parents are told that a Teacher is TSC-verified only after that validation. A Teacher who has not provided a TSC number may still be approved following Loleni’s review.
b) Contact Authentication: Sign-in through a Google or Facebook account, or through any email address confirmed by a one-time code sent to that address, together with verification of the Teacher's WhatsApp number by a One-Time Password (OTP). Changes to account settings and withdrawals of earnings require a further OTP sent to the Teacher's registered WhatsApp number.
c) Financial & Tax Details: Submission of M-PESA payment details. A Teacher may add a Kenya Revenue Authority (KRA) PIN at sign-up or later from the Teacher’s profile, and Loleni may require it before paying out earnings. Teachers are responsible for their own tax compliance. Loleni will withhold and remit tax from Teacher payouts where the law requires it.

3.1.2 Loleni shall verify professional credentials and may suspend onboarding or access where information is materially false, expired or unverifiable.

3.1.3 Teachers must comply with applicable professional, child-safeguarding, curriculum and conduct requirements.

3.1.4 Verification does not constitute an endorsement of a Teacher's performance or guarantee of academic outcomes.

3.2 Parent Registration & Communication Hub: Parents create an account by completing the registration form opened from a Teacher’s invitation link. Platform communications, payment prompts, session reminders, and progress analytics are managed securely through an integrated WhatsApp chatbot system linked directly to the Parent's verified mobile number.

3.2.1 Parents must provide accurate information and maintain the confidentiality of account credentials.

3.2.2 Student accounts shall be created and managed through the Parent or legal guardian in accordance with the Platform's child-safety procedures.

3.2.3 Where a Student is a child, the Platform shall apply age-verification and verifiable parental/guardian-consent mechanisms appropriate to the processing involved.

3.2.4 The Platform shall not knowingly permit unmonitored private communications between Teachers and child Students outside approved Platform channels.

3.2.5 At registration the Parent separately confirms (a) acceptance of these Terms and the Privacy Policy, (b) that Loleni and the Teacher may communicate with the Student for educational purposes only, and (c) that Loleni may send updates to the Parent’s WhatsApp number. Each confirmation is recorded with its date, time and the version of these Terms accepted.

3.3 Student Sub-Account Management: Student app credentials (username and initial security key) are generated strictly by the platform and transmitted directly to the verified Parent's WhatsApp contact and shown to the Parent on completing registration. Students access the application using these managed sub-account credentials. Passwords may be updated at any time, with immediate automatic notification dispatched to the Parent.

4. FEES, PAYMENTS AND REFUNDS

4.1 Transparent Total Pricing: Oddijo provides a fully transparent, upfront pricing model. The total tuition fee payable for any class or lesson block is clearly communicated to the Parent prior to payment initiation. The total fee comprises Teacher tuition fees, platform fees and applicable taxes. No hidden or undisclosed surcharges shall be levied.

4.1.2 Payments shall be processed through the designated payment-service provider. Loleni shall not represent itself as a payment service provider unless it is duly authorised under applicable Kenyan law.

4.1.3 Payment for upcoming lessons: On registration the Parent pays for the Student’s upcoming scheduled lessons, up to a limit of ten (10) hours of lessons. Later lessons are paid for in the same way as they approach, and Loleni sends the Parent a payment request on WhatsApp. The quoted price is held for a short period, about fifteen (15) minutes, while the Parent pays. A Student cannot join a lesson that has not been paid for.

4.2 Safe Tuition Holding Framework: To ensure financial integrity and protect tuition funds, all Parent prepayments are held in a secure, segregated platform holding balance upon collection. Funds remain in this held state and are only transferred to a Teacher's available balance upon automated validation of lesson completion and verification of student attendance thresholds. A Parent is charged for the counted length of each lesson, as described in clause 5.1.

4.3 Unutilized Tuition Refund Guarantee: Loleni Digital Limited guarantees complete refund protection for unutilized tuition funds under the following conditions:

a) Refund Eligibility: Parents may request a refund for any unutilized or uncommitted prepaid tuition funds at any time through authorized support channels.
b) Disbursement Timeline: 100% of unutilized prepaid funds (including committed fees for classes that have not yet occurred) shall be refunded directly to the originating payment method within forty-eight (48) hours of request verification.
c) Transaction Netting: Refund transactions are processed net of standard transaction charges.
d) Automatic refunds: Where a Teacher removes a Student from a class, unused prepaid funds are refunded automatically to the number that paid. Lessons already held remain chargeable.

4.4 Teacher Earnings Settlement: Teacher balances represent verified completed instruction and earned referral incentives. Earnings are transferred to the Teacher's registered payout account upon request, subject to multi-factor authentication and deduction of applicable disbursement fees. Referral rewards are credited upon the referred Teacher's successful execution of their first live session.

4.5 Lessons that cannot be completed: If a Teacher has not joined fifteen (15) minutes after the scheduled start, the lesson is cancelled and the Parent is not charged. If a lesson is voided because of a fault in the Platform, the Parent is not charged and the Teacher is still paid by Loleni. If a lesson is interrupted for a reason outside the Platform’s control, such as the Student’s own connection, the lesson remains chargeable in accordance with the attendance rules in clause 5.1.

5. LESSON EXECUTION, ATTENDANCE & QUALITY MONITORING

5.1 Automated Attendance Auditing: Student attendance is calculated as the active duration of student participation during a live session relative to the counted length of the lesson, subject to minimum thresholds. A Student who leaves and rejoins within two (2) minutes is treated as present throughout. The counted length of a lesson is the scheduled length, reduced where the Teacher starts late, ends early or stops teaching before leaving the lesson. To prevent artificial lesson extension, automated transcript and activity analysis (including the Teacher’s speech, slide movement and any quiet time the Teacher has declared for activities such as exercises) is performed to identify and deduct inactive or unearned idle session time at the conclusion of a class. Long silences during a lesson are flagged for review but are not deducted. A lesson that nobody ends closes automatically shortly after its scheduled end.

5.2 Live Engagement Analytics: To give Teachers and Parents an objective indication of engagement, the Platform records whether the Student’s app is in front of the Student during a live lesson and the Student’s responses to short on-screen prompts, and combines them into an attention indicator for each lesson. The indicator is informational only. It is shown to the Teacher and, as a weekly average, to the Parent in progress summaries. It is never shown to the Student and is not used to calculate fees, attendance or grades. The method of calculation is proprietary to Loleni.

5.3 Educational Scaffolding & Disclaimers: The platform provides automated pedagogical tools, including visual learning aids aligned with the Kenyan legacy 8-4-4 system, the Competency-Based Education (CBE), the International Baccalaureate (IB) and Cambridge (IGCSE/A-Level) frameworks, alongside lesson plans, lesson aids and automated post-lesson quizzes generated with the help of artificial intelligence, and a Study Buddy tool that answers a Student’s questions from the materials of the Student’s current class. AI Features can make mistakes. Teachers should review a lesson aid before sharing it, may edit or withdraw a quiz, and Students can report a question that looks wrong. Quizzes are sent only to Students who attended a minimum part of the lesson, and a Student may send a question to the Teacher through the Study Buddy. These tools are provided for supplementary learning support and do not replace the Teacher. Loleni Digital Limited disclaims liability for individual instructional outcomes or academic variations.

6. INTELLECTUAL PROPERTY & ACCOUNT TERMINATION

6.1 Intellectual Property Rights: Subject to third-party rights and user-generated content, all software code, graphic user interfaces, mascot designs, database structures, vector algorithms, curriculum scaffolding frameworks, and brand marks associated with Oddijo are the exclusive intellectual property of Loleni Digital Limited. Unauthorized reverse engineering, scraping, or duplication is strictly prohibited.

6.1.2. Users receive a limited, non-exclusive, non-transferable right to use the Platform for its intended purpose during the period of authorised access.

6.1.3. Nothing in these Terms transfers ownership of a Teacher's pre-existing teaching materials or a Parent's or Student's lawful content to Loleni, except for the limited licences expressly stated in these Terms.

6.2 Permanent Account Deletion Protocol: Users may terminate their account at any time via in-app settings under the 'Delete Forever' protocol. Upon initiation: (a) Teacher earned balances are settled within 24 hours net of standard disbursement fees; (b) Parent unutilized prepayments are automatically refunded to the originating payment method; (c) All associated personal data is permanently deleted from active systems, except records that Loleni must keep by law, such as financial and tax records, and except as provided in (d); and (d) Where a Teacher deletes their account, the Teacher's academic content, meaning lesson plans, lesson aids (such as slide decks and handouts), documents the Teacher uploaded or shared, and lesson transcripts, together with the search data made from them, remains available, including through the Study Buddy, to the Students who were enrolled in the Teacher's classes on the date of the deletion request, for six (6) months from that date, so that their learning is not interrupted. No new material is shared during that period, and the Teacher's personal details are removed at once. At the end of the six (6) months, the academic content and the stored files are permanently deleted.

7. USER CONTENT AND LICENCE

7.1 Where a user uploads or submits content, the user retains ownership of rights they lawfully hold in that content.

7.2 The user grants Loleni a limited licence to host, reproduce, transmit and process that content only to the extent reasonably necessary to provide, secure, improve and administer the Services, subject to the Privacy Policy.

7.3 Loleni shall not use identifiable Student content for unrelated advertising or public promotion without an appropriate lawful basis and, where required, separate consent.

7.4 Where a Teacher deletes their account, the licence in clause 7.2 continues for the Teacher's academic content for six (6) months from the date of the deletion request, solely so that the Students enrolled in the Teacher's classes on that date can continue to use it as described in clause 6.2(d). The licence then ends and the content is deleted.

8. ACCOUNT SUSPENSION AND TERMINATION

8.1 Loleni may suspend or terminate access where reasonably necessary for security, child safety, fraud prevention, material breach of these Terms, non-payment, unlawful conduct or protection of the Platform and its users.

8.2 Before suspension or termination, Loleni shall, where reasonably practicable and lawful, provide notice and an opportunity to remedy the breach.

8.3 Termination does not extinguish accrued payment obligations or rights that by their nature survive termination.

8.4 Personal data shall be retained or deleted in accordance with the Privacy Policy and applicable legal retention requirements.

9. COMPLAINTS AND DISPUTE RESOLUTION

9.1 Complaints should first be submitted through the Platform's designated support channels.

9.2 Nothing in these Terms limits a consumer's statutory rights or a person's right to complain to a competent regulator or seek lawful relief.

9.3 Any contractual dispute not resolved through the internal complaints process may be referred to a competent Kenyan court after parties have exhausted mediation or arbitration channels.

PART B: PRIVACY POLICY & DATA PROTECTION GOVERNANCE

1. DATA CONTROLLER & LEGAL BASIS FOR PROCESSING

1.1 Statutory Role: Loleni Digital Limited acts as the Data Controller and Data Processor pursuant to the Data Protection Act 2019 (DPA) of Kenya. Loleni Digital Limited processes personal data under the lawful bases of contractual necessity, statutory obligation under education laws, legitimate interest in safeguarding learners, and explicit consent.

2. CATEGORIES OF PERSONAL DATA COLLECTED

2.1 Role-Based Data Categories: The platform collects and processes necessary data categorized across platform roles as follows:

a) Teacher Data: Full name, preferred name, TSC accreditation number (where provided), national ID/passport details, email address, sign-in provider and account identifier, WhatsApp mobile contact, M-PESA financial number, KRA PIN (where provided), subject/grade specifications, live audio and video during instruction (video is not recorded; audio is processed to produce a transcript of the Teacher’s speech), lesson transcripts, documents and lesson plans the Teacher uploads or creates, device and notification identifiers, and transaction settlement histories.
b) Parent Data: Full name, mobile phone number, WhatsApp contact identifier, M-PESA transaction identifiers, digital payment receipts, child relationship records, consent records, and support communication logs.
c) Student Minor Data: Full name, age, grade/form level, school affiliation, app session focus indicators, interactive engagement response times, attendance and presence records, post-lesson assessment scores and answers, standing within the class, and AI Study Buddy query interactions. The Platform does not store what Students say during live lessons.

3. MINOR PROTECTION & PARENTAL CONSENT (DPA SECTION 33)

3.1 Verifiable Parental Consent: In strict compliance with Section 33 of the Data Protection Act 2019 and the Basic Education Act 2013, processing of minor personal data is conducted exclusively under verifiable parental consent. Student app credentials are transmitted solely to verified Parent WhatsApp contacts. Direct unmonitored external messaging between third parties and minor learners is strictly prohibited on the platform.

3.2 Automated Parental Oversight: To maintain total parental oversight, the Oddijo chatbot dispatches automated academic summaries periodically to the Parent's WhatsApp contact.

4. AUTOMATED PROCESSING & THIRD-PARTY INTEGRATIONS

4.1 Purpose of Automated Processing: Automated processing is utilized exclusively to calculate session attendance proportions, generate live engagement indicators, produce curriculum-aligned quizzes from session materials, transcribe lessons, generate lesson plans, lesson aids and quizzes, and surface relevant past-lesson study context. Automated analytics are not utilized for discriminatory profiling or non-educational automated decision-making. No decision with a legal or similarly significant effect on a person is made solely by automated means: fees are calculated by fixed rules from lesson length and attendance, and a person at Loleni support can review any charge on request.

4.2 Authorized Technical Processors: Data is shared with accredited third-party service providers solely to perform essential operational functions under strict data processor agreements:

a) Safaricom M-PESA: For mobile payment processing, payment collections, and earnings disbursements.
b) Meta / WhatsApp Business Infrastructure: For OTP verification (including security codes for account changes and withdrawals), payment notifications, and student progress reports.
c) Secure Cloud Hosting Infrastructure: For encrypted database storage, user access management, file storage and secure document serving.
d) AI Language Model Providers: For processing lesson text to generate curriculum-aligned lesson plans, lesson aids, quizzes and Study Buddy answers, and to create search embeddings of lesson content. Personal identifiers are removed from text before it is sent, and providers are not permitted to use it to train their models. Teachers’ lesson-planning requests may also use a web-search provider with identifiers removed.
e) Speech Transcription Provider: Audio of the Teacher’s speech during live lessons is sent to a speech-to-text provider to produce a transcript.
f) Video Conferencing Provider: To host live lessons.
g) Email Delivery Provider: To send sign-in codes to Teachers who sign in with an email address.

4.3 International Transfers: Some of these providers process data outside Kenya, including in the European Economic Area. Loleni transfers personal data outside Kenya only where the Data Protection Act 2019 allows it, such as where adequate safeguards are in place, and requires each provider to protect it under a written agreement.

4.4 Retention: Raw lesson audio is deleted thirty (30) days after the transcript is final. Lesson transcripts and the search data made from them are kept for twelve (12) months after the last enrolment in the class and then deleted. Records that the law requires Loleni to keep, such as financial and tax records, are kept for the legally required period. On an erasure request, transcripts, search index entries and stored files are removed. Where a Teacher deletes their account, the Teacher's academic content and the search data made from it are kept for six (6) months from the date of the deletion request, so that the Students of the Teacher's classes can continue to use them, and are then deleted (Part A, clause 6.2(d)).

4.5 Child Safety: If a Student’s question or message indicates a risk to the Student’s safety, it is flagged to Loleni support, where a person decides whether and whom to contact.

5. TECHNICAL SAFEGUARDS & DATA SUBJECT RIGHTS

5.1 Technical Security Architecture: Loleni Digital Limited enforces rigorous security protocols, including encryption of data in transit (TLS) and at rest, cryptographic signature verification for webhook callbacks, WhatsApp OTP verification for withdrawals and changes to account settings, one-time email codes for email sign-in, and rate limits on code requests.

5.2 Data Subject Rights & Regulatory Recourse: Pursuant to the Data Protection Act 2019, users (and Parents on behalf of minor students) possess the right to: (a) Access personal data records held by the platform; (b) Request correction of inaccurate details; (c) Object to automated profiling; and (d) Exercise complete erasure via 'Delete Forever' settings (subject, for a Teacher's academic content, to the six-month period in Part A, clause 6.2(d)); (e) Receive a copy of their data in a portable format; and (f) Withdraw consent at any time, without affecting processing already done. Regulatory inquiries or complaints may be addressed to the Data Protection Officer at Loleni Digital Limited (dpo@oddijo.com) or lodged with the Office of the Data Protection Commissioner (ODPC), Kenya.

LEGAL ACKNOWLEDGMENT & CORPORATE AUTHORIZATION

By registering, accessing, or continuing to use the Oddijo platform, Users confirm that they have read, understood, and agreed to be bound by these Master Terms of Service and Privacy Policy. Issued under the authority of the Board of Directors, Loleni Digital Limited, Nairobi, Kenya.

THIS WEBSITE: COOKIES AND ANALYTICS

This section covers oddijo.com only.

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