We are committed to protecting your personal data. This policy explains what information we collect, why we collect it, and how we keep it safe — in full compliance with the Kenya Data Protection Act, 2019.
TrainingComplex Institute ("TrainingComplex", "we", "us", "our") is a professional training and capacity-building organisation registered in Kenya, headquartered in Nairobi. We provide short courses, certificate programmes, and corporate training solutions across leadership, project management, finance, human resources, ICT, monitoring & evaluation, and other professional disciplines.
For the purposes of the Kenya Data Protection Act, 2019 (the "Act"), TrainingComplex is the Data Controller in respect of the personal data you provide to us. Our designated Data Protection Contact can be reached using the details in Section 13.
We collect personal data that you provide to us directly, data generated when you use our services, and in some cases data from third parties. The categories we collect include:
We use the personal data we hold about you for the following purposes:
| Purpose | Types of data used |
|---|---|
| Process enrolment and course registration | Identity, contact, enrolment, payment |
| Issue invoices, receipts and financial records | Identity, contact, payment |
| Deliver training, share course materials and assignments | Identity, contact, enrolment |
| Issue certificates and transcripts upon completion | Identity, enrolment, professional |
| Provide customer and learner support | Identity, contact, communications |
| Send training reminders, schedule updates and pre-course information | Contact, enrolment |
| Send marketing communications about new courses and promotions (with your consent) | Contact, professional |
| Improve our website, courses, and learner experience | Usage, device, cookie |
| Comply with legal obligations (tax, accreditation, anti-fraud) | Identity, payment, communications |
| Respond to corporate training enquiries and proposals | Identity, contact, professional |
We will never use your personal data for automated decision-making that produces significant legal or similarly significant effects without your explicit consent.
Under the Kenya Data Protection Act, 2019, we must have a lawful basis for processing your personal data. The bases we rely on are:
We do not sell your personal data. We share it only in the following limited circumstances:
Our primary operations are based in Kenya. Where we use cloud-based tools or services operated by companies outside Kenya (for example, email platforms or cloud hosting), your data may be transferred to and processed in other countries.
When we transfer personal data outside Kenya, we ensure an adequate level of protection is in place by:
You may request details of the safeguards in place for any international transfer by contacting us (Section 13).
Our website uses cookies — small text files stored on your device — to make the site work, remember your preferences, and understand how visitors use it.
| Category | Purpose | Consent required? |
|---|---|---|
| Strictly necessary | Navigation, session management, security | No — essential |
| Functional | Remember language, region, and preferences | No — improves experience |
| Analytics | Understand which pages are visited and how long (aggregated, anonymised) | Yes — opt-in |
| Marketing | Measure effectiveness of any advertising campaigns | Yes — opt-in |
You can control or delete cookies through your browser settings at any time. Disabling strictly-necessary cookies may affect how the site functions. You can also contact us to withdraw consent for analytics or marketing cookies.
We retain your personal data only for as long as necessary to fulfil the purposes described in this policy, or as required by law. Our standard retention periods are:
At the end of the applicable retention period, data is securely deleted or anonymised.
Under the Kenya Data Protection Act, 2019, you have the following rights regarding your personal data:
Request a copy of the personal data we hold about you and information about how we process it.
Request correction of inaccurate or incomplete personal data we hold about you.
Request deletion of your personal data where there is no overriding lawful reason for us to continue processing it.
Request that we limit the way we use your data in certain circumstances while a dispute is being resolved.
Receive a copy of your data in a structured, commonly-used, machine-readable format.
Object to processing based on legitimate interests or for direct marketing purposes at any time.
Withdraw consent for marketing communications at any time — use the unsubscribe link in any email or contact us directly.
Lodge a complaint with the Office of the Data Protection Commissioner (ODPC) if you believe your rights have been violated.
To exercise any of these rights, please submit a written request to us (see Section 13). We will respond within 30 days. We may need to verify your identity before processing the request.
We take the security of your personal data seriously and implement appropriate technical and organisational measures, including:
In the event of a personal data breach that is likely to affect your rights and freedoms, we will notify you and the Office of the Data Protection Commissioner (ODPC) as required by law — within 72 hours of becoming aware.
Our training programmes are designed for working professionals and adults aged 18 and over. We do not knowingly collect personal data from individuals under 18 without the explicit consent of a parent or legal guardian.
If you believe we have inadvertently collected data from a minor, please contact us immediately at the details in Section 13 and we will promptly delete such information.
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. When we make material changes, we will:
We encourage you to review this policy periodically. Continued use of our services after an update constitutes acceptance of the revised policy.
If you have any questions about this Privacy Policy, wish to exercise your rights, or want to raise a data protection concern, please contact us:
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 at www.odpc.go.ke.