Kalimani
Privacy Policy
This Privacy Policy explains how Kaliverse, the operator of the Kalimani platform (“Kalimani,” the “Service,” or the “Platform”), collects, uses, discloses, and protects information when you use our website, mobile applications, learning management system (“LMS”), and AI-powered translation, localisation, and transcription tools, whether you are an individual learner or tutor (“B2C”) or a business/enterprise client (“B2B”).
By using Kalimani, you agree to the collection and use of information as described here. If you do not agree, please do not use the Service.
1. Who We Are and Our Role Under Data Protection Law
1.1 Kaliverse is the entity legally responsible for Kalimani and acts as the “data controller” (or equivalent term under applicable law, such as the Kenya Data Protection Act, 2019, the EU/UK General Data Protection Regulation (“GDPR”), and the California Consumer Privacy Act as amended by the CPRA (“CCPA/CPRA”)) for personal data collected directly from B2C users (learners, tutors, and cultural educators) and from visitors to our website.
1.2 Where a business or enterprise client (“Business Customer”) uses Kalimani’s AI localisation, translation, or transcription tools to process data belonging to that Business Customer’s own end users, employees, or contacts, Kaliverse acts as a “data processor” (or “service provider”/“processor” under CCPA/CPRA) on the Business Customer’s behalf. That relationship, and Kaliverse’s obligations as a processor, is governed by our separate Data Processing Agreement (“DPA”), which is incorporated into and forms part of the applicable enterprise agreement.
2. Information We Collect
We collect the following categories of information, depending on how you use Kalimani. This list is illustrative, not exhaustive, and we will update this Policy if we begin collecting materially new categories of data.
2.1 Information you provide directly
- Account and registration data
- Name, email address, phone number, username, password, and profile details.
- Payment and billing data
- Payment method details, billing address, and transaction history (processed via our payment providers — Kaliverse does not store full card numbers).
- Identity and vetting data for tutors and cultural educators
- Government-issued identification, credentials, certifications, and any background-check or verification documents submitted for onboarding.
- User-generated content (“UGC”)
- Pre-recorded videos, audio recordings and voice translations, text translations, written materials in African mother-tongue languages, cultural stories, artifacts, and documents that you upload, record, or submit through the Platform.
- Communications
- Messages you send us, including support requests and correspondence with tutors, learners, or our team.
2.2 Information collected automatically
- Device and browser data, including device/browser fingerprint, operating system, and browser type.
- IP address and approximate location derived from it.
- Usage and session logs, including pages viewed, features used, session duration, and click/interaction data.
- Cookies and similar tracking technologies (see Section 6).
2.3 Voice, video, and future biometric data
2.3.1 Because Kalimani’s core function involves translation, localisation, and transcription, we process voice recordings and video you or your organisation submit for these purposes.
2.3.2 We do not currently use voice recordings to generate biometric identifiers (i.e., unique voiceprints capable of identifying you). If we introduce this capability, we will update this Policy, identify the specific purpose (e.g., improving translation model accuracy), and obtain your separate, explicit consent before processing your voice data as biometric information, in accordance with applicable law.
3. How We Use Information
- To provide, operate, and maintain the Platform, including matching learners with tutors and cultural educators, and delivering AI translation, localisation, and transcription outputs.
- To process payments, subscriptions, credits/tokens, and enterprise billing.
- To verify tutor and educator identity and credentials before allowing them to offer paid services.
- To train, evaluate, and improve our in-house AI translation and transcription models, including models built using open-source materials and datasets.
- To communicate with you about your account, transactions, and updates to the Service.
- To detect, investigate, and prevent fraud, abuse, security incidents, and violations of our Terms & Conditions.
- To comply with legal obligations, including tax, accounting, and record-keeping requirements.
- To personalise your experience and, where you have not opted out, for analytics and marketing purposes.
4. Third-Party Subprocessors and Service Providers
We share personal data with the following categories of trusted third-party vendors (“Subprocessors”) strictly to operate the Service. We do not sell personal data.
- Hosting, CDN, and DNS
- Cloudflare (domain registration, content delivery, and hosting infrastructure; hosting located in Kenya and the European Union).
- Object storage
- Amazon Web Services (S3), for storage of uploaded content and media files.
- Authentication
- Google (Google Sign-In / Google Identity Services) for account login.
- Payments
- M-Pesa (for individual/B2C payments) and Paddle (as merchant of record for business/enterprise billing).
- Analytics
- Cloudflare Web Analytics and Google Analytics (additional analytics providers may be added; this Policy will be updated accordingly).
- Transactional email
- Resend, for account, billing, and service notifications.
- AI processing
- Translation and transcription are performed primarily using Kaliverse’s own in-house AI models. Where any component relies on third-party or open-source AI tooling, we require that no personal data is used by that third party to train its own general-purpose models without our authorisation.
4.1 We maintain contracts with each Subprocessor requiring them to protect personal data to a standard consistent with this Policy and applicable law, and to use the data only for the purposes we specify.
4.2 For Business Customers, a current list of Subprocessors used in connection with processing performed under a DPA is available on request and is referenced as an exhibit to the DPA. We will provide advance notice of any new Subprocessor and a reasonable opportunity to object, as set out in the DPA.
5. International Data Transfers
5.1 Kalimani serves users globally, and our infrastructure is hosted in both Kenya and the European Union. As a result, your information may be transferred to, stored, and processed in countries other than your country of residence, including countries that may not have data protection laws equivalent to those in your home jurisdiction.
5.2 Where we transfer personal data out of the European Economic Area, the United Kingdom, or other jurisdictions with restrictions on cross-border transfer, we rely on appropriate safeguards, such as the European Commission’s Standard Contractual Clauses (“SCCs”) or an equivalent recognised transfer mechanism, together with supplementary technical and organisational security measures.
6. Cookies and Tracking Technologies
6.1 We use cookies and similar technologies for authentication and core functionality (“strictly necessary”), analytics and performance measurement, and marketing/advertising purposes.
6.2 On your first visit, you will be presented with a cookie consent banner allowing you to accept all cookies, reject non-essential cookies, or manage preferences by category. You may withdraw or change your consent at any time through your browser settings or our cookie preference centre. See also our Cookies Policy.
6.3 Rejecting non-essential cookies will not prevent you from using core Platform features but may limit personalisation and analytics.
7. Data Retention
7.1 We retain personal data for as long as your account is active and as necessary to provide the Service.
7.2 Following account closure, we retain account data for up to ninety (90) days to allow for reactivation, dispute resolution, and backup rotation, after which it is deleted or anonymised, except where longer retention is required by law.
7.3 Billing, invoicing, and financial transaction records are retained for seven (7) years to comply with Kenyan tax and accounting record-keeping requirements, and equivalent requirements in other jurisdictions where applicable.
7.4 Content you have sold or licensed to other users (for example, paid translation or cultural-content entries) may continue to be retained and distributed to purchasers under the terms of the licence you granted, even after you close your account, as described in our Terms & Conditions.
8. Your Rights
Depending on your location, you may have rights to access, correct, delete, restrict, or port your personal data, to object to certain processing (including profiling and direct marketing), and to withdraw consent at any time. Kenyan residents may exercise rights under the Data Protection Act, 2019; EU/UK residents under the GDPR; and California residents under the CCPA/CPRA, including the right to know, delete, correct, and opt out of the sale or sharing of personal information (Kaliverse does not sell personal information).
8.1 To exercise any of these rights, contact us using the details in Section 11. We will respond within the timeframe required by applicable law and may need to verify your identity before actioning a request.
8.2 If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority (in Kenya, the Office of the Data Protection Commissioner).
9. Data Security
We implement technical and organisational measures designed to protect personal data against unauthorised access, alteration, disclosure, or destruction, including encryption in transit, access controls, and vendor security requirements. No system is completely secure, and we cannot guarantee absolute security.
10. Children’s Data
Kalimani’s LMS may be used by learners under the age of 18 where a parent, guardian, or educational institution has enrolled them or consented on their behalf. Where we knowingly process personal data of a minor, we rely on parental or guardian consent, or another lawful basis recognised under applicable law, and limit collection to what is necessary for the educational service provided. Parents or guardians may contact us to review, correct, or request deletion of a minor’s data.
11. Contact Us
If you have questions about this Privacy Policy or wish to exercise your data protection rights, contact us at [email protected], or by post at Kaliverse, P.O. Box 45844, Nairobi, Kenya.
12. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes via the Platform or by email, and will update the “Effective Date” above. Continued use of Kalimani after changes take effect constitutes acceptance of the revised Policy.