INTRODUCTION

The purpose of this Privacy Policy is to describe how Pathfinder ECenter collects, uses and shares information about you through our online interfaces owned and controlled by us, including https://www.pece.co.ke and https://www.training.pece.co.ke (collectively referred to herein as the “Pathfinder ECenter Sites” or “Sites”). Please read this notice carefully. If you do not understand any aspects of our Privacy Policy, please feel free to contact us at info@pece.co.ke. Your use of our Sites is also governed by our Terms of Use.

If you do not accept the terms of this Privacy Policy or the Terms of Use, then please does not access, browse, or register for the Pathfinder ECenter Sites or enroll in any courses. If you choose not to provide certain information required to provide you with various services offered on the Pathfinder ECenter Sites, then you may not be able to establish a user account or obtain those services.

This Privacy Policy is organized as follows:

  • Key Terms Used in this Policy
  • Information that Pathfinder ECenter collects from You
  • Legal Basics for processing personal information
  • Your Rights to Your Personal Information
  • Cookies and Tracking Technologies on the Pathfinder ECenter Sites
  • How Your Information is Used
  • How Your Information is Shared
  • How to Manage Your Personal Information
  • Security Breach Notifications
  • Privacy Policy Updates
  • Contact Information

Key Terms Used in this Policy

Cookies – These are unique identifiers usually in the form of small data files placed on your device that send certain information about your activity on the Pathfinder ECenter Sites or in an email communication back to Pathfinder ECenter or the authorized third party that served the cookie.

Pathfinder ECenter Sites consists of all content and pages located within the https://www.pece.co.ke web domain, including its Moodle instance found at https://www.training.pece.co.ke,

Personal Information is information that specifically identifies you or that, when combined with other information, could be used to identify you, such as your name, location, IP address or other similar identifiers specific to you.

Tracking Technologies are web beacons, pixels, and similar technologies that are also unique identifiers used to track your online activity.

Information Pathfinder ECenter Collects from You

Pathfinder ECenter directly collects information when you:

  • sign up for an Pathfinder ECenter user account and create an Pathfinder ECenter user profile;
  • enroll and participate in online courses;
  • send email messages to Pathfinder ECenter (including messages to our help desk email: info@pece.co.ke and training@pece.co.ke);
  • participate in user surveys; and
  • participate in public forums, webinars, and other interactive experiences on the Pathfinder ECenter Sites.

Legal Basis for Processing Personal Information

Our legal basis for collecting, processing and using the Personal Information described in this Privacy Policy depends on the Personal Information we collect and the specific context in which we collect it. We may process your Personal Information because:

  • we need to perform a contract with you;
  • you have given us consent to do so;
  • the processing is in our vital or legitimate interests, such as properly identifying students for course certificates and transcripts, and it’s not overridden by your rights;
  • to comply with applicable law

Your Rights to Your Personal Information

You have certain rights in relation to your Personal Information. You can access your Personal Information provided in your profile and confirm that it remains correct and up-to-date or choose whether or not you wish to receive material from us or some of our partners by logging into the Sites and visiting your user account. If you would like further information in relation to your rights or would like to exercise any of them, you may also contact us via info@pece.co.ke.

You also have the right to request that we:

  • provide access to any Personal Information we hold about you;
  • prevent the processing of your Personal Information for direct-marketing purposes;
  • update any Personal Information which is out of date or incorrect;
  • delete any Personal Information which we are holding about you;
  • restrict the way that we process your Personal Information;
  • provide your Personal Information to a third party provider of services; or
  • provide you with a copy of any Personal Information which we hold about you.

We try to answer every email promptly where possible, and provide our response within the time period stated by applicable law. Keep in mind, however, that there will be residual information that will remain within our databases, access logs and other records, which may or may not contain your Personal Information. Please also note that certain Personal Information may be exempt from such requests in certain circumstances, which may include if we need to keep processing your Personal Information to comply with a legal obligation. When you email us with a request, we may ask that you provide us with information necessary to confirm your identity.

Cookies and Tracking Technologies

Like many companies, Pathfinder ECenter uses Cookies and other common Tracking Technologies, such as Google Analytics, on the Pathfinder ECenter Sites and in email communications to help Pathfinder ECenter better understand your use and needs of the Pathfinder ECenter Sites, current and future Pathfinder ECenter -related products and services, and how Pathfinder ECenter can improve. For example:

  • based on your cookie settings, Pathfinder ECenter may track information indicating, among other things, which pages of the Pathfinder ECenter Sites were visited, the order in which they were visited, when they were visited, and which hyperlinks and other user interface controls were used;
  • Pathfinder ECenter may log the IP address, operating system, and browser software you used when accessing the Pathfinder ECenter Sites, and Pathfinder ECenter may be able to determine from an IP address your Internet Service Provider and the geographic location of your point of connectivity; and
  • Pathfinder ECenter may track and collect information from emails that Pathfinder ECenter sends to you, for example whether you opened the email or clicked on any links from the email.

Pathfinder ECenter also partners with third parties to help us track and understand your activity on the Pathfinder ECenter Sites, how you interact with Pathfinder ECenter’s social media, and how you find or may be referred to the Pathfinder ECenter Sites. Pathfinder ECenter uses Cookies and other Tracking Technologies for the following purposes:

  • when necessary for system administration, security, and integrity to ensure the Pathfinder ECenter  Sites works properly for you. Without these technologies, the Pathfinder ECenter  Sites may not function correctly;
  • to enable analytics, performance and functionality, to help Pathfinder ECenter  gather information about how visitors use the Pathfinder ECenter  Sites and monitor Pathfinder ECenter  Sites performance, and to enhance your experience by recognizing and remembering whether you have visited the Pathfinder ECenter  Sites before and may have any personal preferences; and
  • to support marketing by enabling Pathfinder ECenter  to deliver content relevant to your interests on the Pathfinder ECenter  Sites and third-party Sites based on how you interact with Pathfinder ECenter , its advertisements or content. Pathfinder ECenter  may use “first-party” cookies, which means cookies served by Pathfinder ECenter , and also “third-party” cookies, which means cookies served by third parties that help Pathfinder ECenter  track this information.
  • To help grow our community we purchase advertising on Facebook.com. Facebook offers a tool called “Pixel” that enables us to evaluate the effectiveness of our Facebook ads to reach more people who are interested in our courses. Any data we collect from Facebook Pixel is subject to this Privacy Policy and our Terms of Use. Any data Facebook collects from Pixel is subject to Facebook’s privacy policy.

You have some options for managing Cookies and other Tracking Technologies. These include:

  • Modifying your browser settings: You should be able to control how and whether your web browser accepts Cookies by adjusting its privacy and security settings. The “help” feature of the menu bar on most browsers will tell you how to stop accepting new Cookies, how to receive notification of new Cookies, and how to disable existing Cookies. If you reject Pathfinder ECenter’s Cookies, some functions and conveniences of the Pathfinder ECenter Sites may not work properly.
  • Opting-out of certain third-party tracking and advertising: Some of the third parties used by Pathfinder ECenter for Cookies and Tracking Technologies offer the ability to opt-out from their tracking by following processes described on their websites. Pathfinder ECenter is not responsible for the effectiveness of any third-party opt-out options.

How Your Information is used

Pathfinder ECenter uses information, including Personal Information, to carry out the following purposes:

  • Operate and improve the Pathfinder ECenter Sites – This includes creating and improving features that support the Pathfinder ECenter community and enable Pathfinder ECenter Sites usage at scale. This also may include personalizing the Pathfinder ECenter Sites, so your learning experience is tailored to your interests and needs.
  • Create, administer, provide, and teach courses – This includes creating and improving the delivery of our courses and programs on the Pathfinder ECenter Sites. This may also include personalizing courses, so your learning experience is tailored to your interests and needs, and assessing your performance and awarding certificates.
  • Offer and improve products and services – This includes enabling you to navigate the Pathfinder ECenter Sites, to enroll and participate in courses and programs on the Pathfinder ECenter Sites, to learn effectively in such courses and programs, and to purchase or obtain products and services on the Pathfinder ECenter Sites.
  • Develop and maintain the security and performance of the Pathfinder ECenter  Sites – This includes tracking Pathfinder ECenter  Sites outages and creating software solutions, detecting violations of the Terms of Service, and monitoring uses, misuses, and potential misuses of the Pathfinder ECenter  Sites.
  • Communicate with you – This includes answering your questions, notifying you of Pathfinder ECenter Sites maintenance and updates, marketing to you about course offerings, programs, news, and related products and services of Pathfinder ECenter.
  • Track Pathfinder ECenter Sites usage against goals and mission – This includes performing analytics to evaluate access to and performance in courses and course-related products and services and to report aggregate usage information (not Personal Information) to business partners and external audiences.
  • Exercise, enforce, and comply with legal rights and obligations – This includes responding to court orders, or other legal process; and investigating, preventing, or taking action regarding illegal activities, suspected fraud, security or technical issues, or to protect the rights, property, or safety of Pathfinder ECenter , or others, and as otherwise required by applicable law.

Pathfinder ECenter may also seek your consent for additional uses of information, including Personal Information, and will use it only for the purpose described to you. All use of Personal Information is subject to applicable law.

How Your Information is Shared

Pathfinder ECenter shares information, including Personal Information, with third parties for the following purposes:

  • With service providers, contractors, and other third parties that help carry out the uses described above – Pathfinder ECenter requires third parties to: (1) abide by this Privacy Policy and applicable law; (2) handle Personal Information in a confidential manner and maintain adequate security; and (3) use Personal Information only as needed to fulfill the relevant purpose(s). In some cases, the Pathfinder ECenter Sites and individual courses are integrated with third-party services or contain links to websites published by third parties, including other content providers as well as service providers. These third parties are responsible for their own privacy practices, so you should pay attention anytime you are redirected to a third-party websites and be sure to review its privacy policy.
  • With other learners in courses that you take and with other visitors to the Pathfinder ECenter Sites, to create an interactive learning environment, support class participation, and share course information – This includes sharing comments, coursework, or other information or content that you submit to a portion of the Pathfinder ECenter Sites, such as our Discourse Forums designed for viewing by other class members or for public communication. This also includes providing opportunities for you to communicate with other users who may have similar interests or educational goals, for instance, recommending specific study partners or connecting potential student mentees and mentors. In such cases, Pathfinder ECenter may use all information collected about you to determine who might be interested in communicating with you.
  • With employers, government programs, institutions, or other enterprises that sponsor your enrollment in a course for training or other educational purposes – If an entity partners with Pathfinder ECenter  or otherwise sponsors your course participation, Pathfinder ECenter  will share information with the entity as needed to confirm your enrollment, participation, progress, and completion status in that course.
  • With affiliates of Pathfinder ECenter, or with successors in the event of a merger, acquisition, or reorganization, for their use consistent with this Privacy Policy.

Pathfinder ECenter may also seek your consent for additional disclosures of information, including Personal Information, and will share it only as described to you. In addition, Pathfinder ECenter  may share with the public and with third parties, including but not limited to researchers and business partners, information and Personal Information that is anonymized or aggregated in a manner that does not personally identify you.

How to Manage Your Personal Information

You can manage your Personal Information through learner features on the Pathfinder ECenter Sites and requests to the Pathfinder ECenter learner support team. Pathfinder ECenter will provide support to the extent required by applicable law and more broadly when possible, as a courtesy in our sole discretion.

Access and correct your Personal Information

Much of your Personal Information is available in your Pathfinder ECenter account. Your name, email address, and other identifiable profile information is editable through the profile settings in your Pathfinder ECenter account except as noted below. Your account dashboard lists all current and archived courses in which you have enrolled and includes links to any course certificates you may have earned. The dashboard also contains copies of your answers and other participation and performance in courses. Please contact Pathfinder ECenter learner support to access and update this or other information. Exceptions: Pathfinder ECenter  does not track or index every time or every place on the Pathfinder ECenter  Sites when or where a learner may volunteer Personal Information, so Pathfinder ECenter  may not be able to help you locate or manage all such instances. Pathfinder ECenter encourages you to use discretion before volunteering Personal Information on the Pathfinder ECenter Sites.

Restrict or object to the processing of Personal Information

If you want to manage emails and other communications to you, you may update your preferences in your Pathfinder ECenter account dashboard; follow the steps described in links at the bottom of email messages, or contact Pathfinder ECenter support. You may object to, or request that Pathfinder ECenter stop, its use of your Personal Information for other purposes by contacting Pathfinder ECenter . Please note that if you choose to restrict Pathfinder ECenter’s ability to process Personal Information, and the processing is otherwise required to provide you with various services and products offered on the Pathfinder ECenter Sites, you may not be able to establish or maintain a Pathfinder ECenter user account or enroll for courses or earn certificates.

Delete account and Personal Information

To request deletion of your Pathfinder ECenter account and Personal Information, you should send us an email requesting deletion or cancellation. Because deletion on the Pathfinder ECenter system is a permanent action and cannot be reversed, Pathfinder ECenter may ask you to complete a process that aims to confirm your authority to manage the Pathfinder ECenter account affected by your request. With respect to your Pathfinder ECenter account, Pathfinder ECenter will permanently:

  • deactivate your Pathfinder ECenter  account;
  • remove the active profile;
  • anonymize or delete forum posts;
  • delete certificates from provider site;
  • retire your username; and
  • remove you from Pathfinder ECenter  email lists.

Data Retention

Pathfinder ECenter will retain your Personal Information for as long as your account is active or as needed to provide you with services; to maintain a record of your transactions for financial reporting, audit, and compliance purposes; and to comply with Pathfinder ECenter’s legal obligations, resolve disputes, enforce its agreements, and as otherwise permitted by applicable law. Upon your request that Pathfinder ECenter deactivate your account and delete your information we will follow the process described herein.

Security Breach Notifications

If Pathfinder ECenter learns of a security breach involving its copy of your Personal Information, Pathfinder ECenter may attempt to notify you electronically so that you may take appropriate protective steps. By using the Pathfinder ECenter Sites or providing Personal Information to Pathfinder ECenter, you agree that Pathfinder ECenter can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Pathfinder ECenter Sites. If a security systems breach occurs, Pathfinder ECenter may post a notice on the Pathfinder ECenter homepage (https://www.pece.co.ke/backup) or elsewhere on the Pathfinder ECenter Sites and may send an email to you at the email address associated with your Pathfinder ECenter account. Depending on where you are located, you may have a legal right to receive notice of a security breach, involving your Personal Information, in writing.

Privacy Policy Updates

This Privacy Policy will be reviewed and updated from time to time. When changes are made, the Privacy Policy will be labeled as “Revised (date),” indicating that you should review the new terms, which will be effective immediately upon posting on this page, with an updated effective date. By accessing the Pathfinder ECenter Sites after any changes have been made, you accept the modified Privacy Policy and any changes contained therein. In case you miss the notification referenced above, be sure to return to this page periodically to ensure familiarity with the most current version of this Privacy Policy.

Contact Information

If you have privacy concerns, have disclosed data you would prefer to keep private, or would like to access the Personal Information that Pathfinder ECenter maintains about you, please contact us at info@pece.co.ke.

Effective Date: September 1, 2018