Privacy Policy

Sprout Life Skills ("Sprout," "we," "us," or "our") is a partnership operating in Kenya, with its registered address at TRC, Tigoni Road, Nairobi, Kenya. Sprout is the data controller responsible for the personal data described in this Privacy Policy, in connection with the Sprout Speakers Championship and the wider Sprout Life Skills platform (together, the "Platform").

Sprout is registered with the Office of the Data Protection Commissioner (ODPC) as a data controller under the Data Protection Act, 2019.

This Privacy Policy applies to:

• Parents and guardians who register a child for the Sprout Speakers Championship or any other Sprout program.
• Children who participate in Sprout programs, whose personal data is processed on their behalf by a parent or guardian.
• Visitors to our website and users of our online forms, WhatsApp channels, and related digital services.

Sprout processes personal data in accordance with the Data Protection Act, 2019 and applies appropriate safeguards to protect the personal data described in this policy. All privacy-related enquiries should be directed to support@sprouts.co.ke.

Depending on the Sprout program a child is enrolled in or participating in, we may collect:

• The child's first name, age, county or town of residence, and speech topic.
• Video and audio recordings submitted as part of a competition entry or coaching session.
• The parent or guardian's name, phone number, email address, and any information provided when registering or communicating with us.
• Records of communications between Sprout and a parent or guardian, including WhatsApp messages and emails.
• Basic technical data collected automatically through our website, such as IP address and browser type, to the extent necessary to operate the site securely.

We deliberately do not collect or publish a child's surname, school name, or exact home address as part of any public-facing content.

We collect personal data directly from a parent or guardian, through:

• Registration and entry forms.
• Video and audio submissions made on behalf of a child.
• Direct communication with our team, including WhatsApp and email.

We do not knowingly collect personal data directly from a child without a parent or guardian's involvement in the process.

Under Section 33 of the Data Protection Act, 2019, we may only process a child's personal data with the consent of a parent or guardian, given in a manner that protects and advances the child's best interests. Consent for the collection, use, and publication of a child's personal data, including video recordings, rests entirely with the parent or guardian, regardless of the child's age or the Sprout program they are enrolled in. We do not treat a child's own agreement, at any age, as a substitute for parental or guardian consent.

We use the personal data we collect to:

• Process a child's entry into the Sprout Speakers Championship or enrolment in another Sprout program.
• Review, judge, and, where selected, publish a child's speech.
• Communicate with parents or guardians about the status of an entry, coaching, or program logistics.
• Operate and improve the Platform.
• Where consented to, share a child's speech, or an excerpt of it, on Sprout's official social media channels, for the purpose of building public awareness of the competition and the wider movement it represents.

We do not use a child's personal data for automated decision-making or profiling that produces legal or similarly significant effects on the child.

Every video submission is reviewed manually before it is published anywhere. Judging is blind: judges score a submitted speech without being shown the child's surname, school, or town. We do not operate a public comments section on any published speech. A parent or guardian may request that a published speech be taken down at any time, for any reason, and we will act on that request as promptly as possible.

Regardless of any consent given for other purposes, we do not publicly display a child's surname, school name, or exact home address in connection with a published speech.

We share personal data with:

• Coaches and judges involved in reviewing and scoring a submission.
• Service providers who help us operate the Platform, including infrastructure, video delivery, messaging, and email providers, who process personal data only on our instructions and only for the purposes set out in this policy.
• Sprout's official social media channels, where a parent or guardian has specifically consented to this.

We do not sell personal data to third parties, and we do not share personal data for third-party marketing purposes unrelated to Sprout's own programs.

Some personal data, including video recordings, is processed and stored using third-party infrastructure providers located outside Kenya. Where this occurs, we take steps to ensure that appropriate safeguards are in place, consistent with the requirements of the Data Protection Act, 2019, which restricts the transfer of personal data outside Kenya unless adequate protection is demonstrated or the data subject has consented to the transfer.

We do not publicly disclose the specific technical architecture or service providers underlying the Platform. This does not affect a data subject's rights under this policy, and further detail can be requested directly by writing to support@sprouts.co.ke.

How long we retain personal data depends on the Sprout program a child is enrolled in or participating in. While a child is actively enrolled in a program, we retain the data necessary to deliver that program for as long as the enrolment continues.

Published Sprout Speakers Championship content, including a child's first name, age, town, topic, and speech video, is retained indefinitely as part of the ongoing public record of the competition, unless a parent or guardian requests its removal. Other personal data, such as contact details no longer needed for an active program, is retained only for as long as reasonably necessary for the purpose it was originally collected for.

We apply reasonable technical and organisational measures to protect personal data against unauthorised access, loss, or misuse. Because publicly detailing the specific security architecture of the Platform could itself create a security risk, we do not disclose those details in this policy. This does not limit a data subject's rights under this policy or under the Data Protection Act, 2019.

Under the Data Protection Act, 2019, a data subject has the right to:

• Be informed of how their personal data is used.
• Access the personal data we hold about them.
• Object to processing of their personal data.
• Request correction of inaccurate data.
• Request deletion of their personal data.

Where the data subject is a child, these rights are exercised on the child's behalf by their parent or guardian. To exercise any of these rights, contact support@sprouts.co.ke.

A parent or guardian may request that their child's video, or any personal data associated with it, be removed from the Platform and any Sprout-controlled social media channel at any time, for any reason, by contacting support@sprouts.co.ke. We will action a valid takedown request as promptly as possible.

If you believe we have not handled your or your child's personal data properly, you may raise this directly with us at support@sprouts.co.ke. You also have the right to lodge a complaint directly with the Office of the Data Protection Commissioner (ODPC).

Sprout programs serve children across three age bands: Sprout Spark (ages 6 to 9), Teen Titans (ages 10 to 13), and Sprout Stars (ages 14 to 17). Regardless of a child's age or program, consent for the collection, use, and publication of that child's personal data rests solely with their parent or guardian.

We may update this Privacy Policy from time to time. Where a change is material, we will take reasonable steps to notify parents and guardians, including by email or WhatsApp, before the change takes effect.

Sprout Life Skills
TRC, Tigoni Road, Nairobi, Kenya
support@sprouts.co.ke