Welcome
At Sarabi Kids, protecting your child's personal information matters to us as much as protecting your
child at a session. This notice explains how we collect, use and protect your child's information and
yours, in line with the Kenya Data Protection Act 2019.
Who we are
Sarabi Kids is a children's development programme for children aged 6 to 14, built around movement,
problem-solving, creativity, confidence and real world skills, and running both in person and online. Sarabi Kids is the data controller
responsible for the personal information described in this notice. You can reach us using the details at
the end.
The information we collect, and why
Enquiries, events and marketing
If you give us your name and contact details at a mall stand, an expo, a school event, through our
website or by message, we use them to answer your enquiry and, where you have agreed, to tell you when
registration opens and what is coming up. We rely on your consent for marketing messages, and every
message we send includes a way to stop receiving them. Where you simply asked us a question and did not
agree to marketing, we use your details to answer you and then delete them.
We do not collect information about a child at this stage beyond an age or age range, and we do not
ask children at our stands for their contact details.
Registration and enrolment
About your child: full name, date of birth, age, sex where you choose to give it, kit size, and the
answers you give us about what your child enjoys and finds difficult. About you: full name, relationship
to the child, phone number, email address, emergency contact details, the people you authorise to collect
your child, and payment records. We use this to enrol your child, place them in the right space, keep
them safe, and communicate with you.
Your child's sex is treated as sensitive personal data under the Act, so the question is optional. Where
you give it, we use it for kit, for changing and toilet arrangements, and for how we group and supervise
children. It is seen only by the people running your child's sessions, it is never used for anything else,
and your child's place does not depend on your answer.
Medical information
Conditions, allergies, medication, physical limitations and family doctor details where you give them.
This is health data and is treated as sensitive personal data under the Act. We collect it only to keep
your child safe and to respond properly to an injury or a medical emergency. Access is restricted to the
coaches and mentors responsible for your child on the day and to whoever is handling an incident.
Online sessions
Part of every season runs online. To run those sessions we hold the name your child appears under on
screen, the times they joined and left, and anything they type in the group chat during the session.
Nothing more.
We record a session only where there is a reason to, for example so that a child who missed it can
catch up. We tell the group at the start whenever a recording is running. Recordings are stored with
access limited to the mentors who need them, are deleted once we no longer need them, and are never
published or shared outside Sarabi Kids without your consent.
Sessions run on a mainstream video conferencing service, which acts only as our processor and on our
written instructions. It may process information outside Kenya, and the section below on where your
information is held applies to it. You may ask us at any time which service we use.
Transport
Where you ask for transport, we hold the pick-up point, the route, the days your child travels and the
names of the people authorised to receive your child at the pick-up point. We treat this as information
about where a child can be found and share it only with the driver and accompanying adult on that route.
The Growth Note
Each child has a Growth Note, which is a short written record kept by the mentor who works with them.
It records what the mentor observes across a season: what the child is working on, what is developing,
and what comes next. It is written in plain words. It contains no grades, no ranking and no comparison
with other children, and it is not used to decide anything about your child other than how we coach and
mentor them.
The Growth Note is part of how we mentor your child and how we keep you informed about their progress,
so we keep one for every child. You may read it at any time, ask us to correct anything in it, and ask us
to delete it. It is shared with you, and inside Sarabi Kids only with the mentor and coaches working
directly with your child. It is never shared with another parent, a school, a sponsor or a partner.
Photographs and video
We take photographs and video at sessions and events. We use them only for the purposes you have
ticked on the registration form, which are listed separately for our website, social media, printed
promotional material and recordings of online sessions, so that you can agree to some and not others. You may withdraw
consent at any time. Withdrawal does not affect material lawfully published before your request reaches
us, and we will remove what we reasonably can.
Our legal basis for processing
- Marketing messages and event follow-up — Your consent
- Enrolling your child and running the programme — Performance of our agreement with you, and your consent as parent or guardian
- Medical information and emergency response — Your explicit consent, and the vital interests of your child
- Your child's sex, where you choose to give it — Your explicit consent as parent or guardian
- Transport arrangements — Performance of our agreement with you
- Online sessions — Performance of our agreement with you
- Recordings of online sessions — Your consent
- The Growth Note — Performance of our agreement with you, and your consent as parent or guardian
- Photographs and video — Your consent, given separately for each purpose
- Safeguarding records and reporting — Our legal obligations, and the vital interests of a child
- Accounting and tax records — Our legal obligations
Where we rely on consent, you may withdraw it at any time, and withdrawing it does not affect anything
we lawfully did before you withdrew it.
Who we share it with
We do not sell or rent your information and we do not use children's information for advertising.
We share it only with medical personnel and emergency services in the event of an injury or medical
emergency; with government or regulatory authorities where the law requires it, including the Directorate
of Children's Services where a safeguarding report must be made; and with the service providers who help
us operate, such as our payment provider, our messaging provider and the video conferencing service used for
online sessions, each of whom is contractually required to protect it and to use it only on our
instructions. You may ask us at any time who these providers currently are.
Where your information is held
Your information is held in Kenya and on cloud services that may store it outside Kenya. Where
information leaves Kenya, we satisfy ourselves that it is protected to a standard comparable with the Act,
and we keep a record of that assessment. You may ask us which providers we currently use.
How long we keep it
- Enquiry details where you did not agree to marketing — Up to 3 months
- Marketing contact details — Until you withdraw consent, or 2 years without contact
- Registration and enrolment records — 3 years after your child's last season
- Medical information — 1 year after your child's last season, unless attached to an incident
- Growth Notes — 3 years after your child's last season, or until you ask us to delete
- Online session join records and group chat — No longer than we need them, then deleted
- Recordings of online sessions — No longer than we need them, then deleted
- Photographs and video — Until consent is withdrawn, then removed from our own channels
- Safeguarding and incident records — As long as the law and our duty of care require, which may be until the child reaches 18 and beyond
- Payment and accounting records — 7 years, as tax law requires
Your rights
As a parent or guardian you have the right to be told how your child's information is used, to see it,
to have it corrected, to have it deleted where we have no overriding obligation to keep it, to object to
certain uses, to withdraw consent, and to ask us to restrict what we do with it while a question is being
resolved. We respond within seven days of receiving a request and complete it within thirty days, or tell
you why we need longer. There is no charge.
You may also complain to the Office of the Data Protection Commissioner if you believe your rights
have been infringed. We would rather you came to us first, but you do not have to.
How we protect your information
We take reasonable technical and organisational measures to protect information from loss, misuse and
unauthorised access. Access to registration and medical information is limited to the people who need it
to run the programme safely. Anyone with access is trained and bound by confidentiality. If a breach
occurs that is likely to cause you or your child real harm, we notify the Office of the Data Protection
Commissioner within 72 hours of becoming aware of it and tell you without undue delay.
Children's information
All personal information relating to your child is collected with your consent as their parent or
guardian. We do not knowingly collect personal information directly from children without a parent or
guardian involved. Where a child is old enough to have a view about their own information, we listen to
it. You may update or correct anything at any time.
Changes to this notice
We may update this notice. Where a change is significant we tell parents directly. The latest version
is always available from Sarabi Kids and on our website.
Our privacy promise
At Sarabi Kids, trust is earned. We collect only what we genuinely need to keep your child safe, run
the programme and communicate with you. We will never sell your personal information, and we will never
knowingly use your child's information in a way that is inconsistent with this notice. Your child's
safety, dignity and privacy come first.
Contact us
Questions about this notice, or any request about your information, go to connect@sarabikids.com or
+254 739 129 949.
Sarabi Kids
