Privacy Policy
CBC Best is committed to protecting your personal data. This policy explains how we collect, use, and safeguard information when you access our educational resources — in full compliance with Kenyan and international data protection law.
Overview & Scope of This Policy
Who we are and what this policy covers
CBC Best (operating at https://cbcbest.netlify.app) is an independent educational platform created and maintained by Ronny Mwenda (Ronny Best), a Mathematics and Computer Science teacher based in Embu County, Kenya. The platform is part of a broader digital ecosystem that also includes Bestronny.netlify.app (Ronny Best Mathematics resources), RonnyMwenda.netlify.app (personal portfolio and biography), and RonnyGame.netlify.app (educational games).
This Privacy Policy applies to all pages, features, discussion forums, downloadable resources, and contact mechanisms on cbcbest.netlify.app. It does not govern the practices of third-party websites that we link to, including KICD, TSC, KNEC, or the Ministry of Education.
CBC Best publishes original educational content aligned to Kenya's Competency Based Curriculum (CBC) as specified in the Basic Education Curriculum Framework (BECF) produced by the Kenya Institute of Curriculum Development (KICD), and operates with awareness of teacher professional standards set by the Teachers Service Commission (TSC). No content on this site is intended to misrepresent, duplicate, or replace official KICD or TSC publications.
Legal & Regulatory Basis
The laws and frameworks that govern this policy
This Privacy Policy is written in compliance with the following legal and regulatory instruments. Where Kenyan law is silent on a specific issue, we apply internationally accepted data protection principles as a baseline.
| Law / Framework | Jurisdiction | Relevance to CBC Best | Official Reference |
|---|---|---|---|
| Kenya Data Protection Act, 2019 (No. 24 of 2019) | Kenya | Primary law governing how we collect, process, store, and share personal data of Kenyan users | ODPC → |
| Data Protection (General) Regulations, 2021 | Kenya | Operational rules under the DPA — consent, registration, breach notification | Regulations → |
| General Data Protection Regulation (GDPR) | EU / EEA | Applied as best-practice for users accessing the site from European territories | GDPR.eu → |
| Kenya Information & Communications Act, Cap 411A | Kenya | Governs electronic communications and online content publication | CA Kenya → |
| Computer Misuse & Cybercrimes Act, 2018 | Kenya | Informs our approach to security, unauthorised access, and data integrity | Kenya Law → |
| Basic Education Act, 2013 | Kenya | Contextual law under which CBC operates — guides our content scope and responsible publication | KICD → |
The Office of the Data Protection Commissioner (ODPC) is Kenya's supervisory authority for data protection. If you believe your rights have been violated, you may lodge a complaint directly with the ODPC at odpc.go.ke/file-a-complaint.
Information We Collect
What data is collected, and how
CBC Best collects two categories of information: data you voluntarily provide to us, and data automatically generated by your device when you visit the site.
📝 Voluntarily Provided Data
- Forum participation — Display name, publicly visible posts and replies
- Contact form submissions — Name, email address, and message content
- Newsletter subscription — Email address only (opt-in basis)
- Resource downloads — No personal information required for downloads
📊 Automatically Collected Data
- Log data — IP address, browser type, operating system, referral URL
- Usage data — Pages visited, time on page, navigation patterns
- Device data — Screen resolution, language setting, device category
- Local storage — Forum preferences, selected tabs (stored in your own browser)
What we do NOT collect
- National ID numbers or passport numbers — never requested or stored
- Financial or payment information — CBC Best is a free platform; no transactions occur
- Precise geolocation data — we do not use GPS-level location tracking
- Biometric data — no fingerprints, face recognition, or voice data
- Sensitive personal data — health status, political opinions, religion, ethnicity are not collected
- Passwords — the site uses browser-based localStorage and does not operate its own authentication system
How We Use Your Information
Lawful purposes for processing your data
Under Section 30 of the Kenya Data Protection Act 2019, personal data must be processed for a specified, explicit, and legitimate purpose. The purposes for which CBC Best processes data are listed below, together with the lawful basis for each.
| Purpose | Data Used | Lawful Basis (DPA 2019) |
|---|---|---|
| Operate and maintain the website | Log data, device data | Legitimate interest (Section 30(1)(f)) |
| Enable discussion forums | Display name, forum posts | Consent (Section 30(1)(a)) |
| Respond to contact inquiries | Name, email, message | Consent (Section 30(1)(a)) |
| Send newsletter updates | Email address | Explicit consent — opt-in only (Section 30(1)(a)) |
| Improve site content and navigation | Anonymised usage patterns | Legitimate interest (Section 30(1)(f)) |
| Prevent fraud and abuse | IP address, usage patterns | Legitimate interest / legal obligation |
| Comply with legal obligations | Any relevant data | Legal obligation (Section 30(1)(c)) |
We do not use your data for automated decision-making, profiling, or any purpose other than those stated above. We do not sell, rent, or trade personal data to third parties.
Cookies & Local Storage
How we store data in your browser
CBC Best primarily uses browser localStorage and sessionStorage rather than traditional HTTP cookies. These are technologies that store small amounts of data in your own browser — not on our servers.
What we store in your browser
- Forum post data — Public posts you make in the forums are saved in localStorage so they persist across sessions
- Navigation preferences — Your last active forum tab or section selection
- Contact form drafts — Temporary storage of form inputs while you are typing
- Progressive Web App (PWA) cache — Static assets (HTML, CSS, images) cached via the service worker for offline access
What we do NOT store
- Third-party advertising cookies (unless Google AdSense is active — see Section 10)
- Cross-site tracking pixels or social media tracking scripts
- Session tokens linked to a centralised account system
We intend to implement a cookie consent notice compliant with ODPC guidance before activating any third-party advertising. Until then, no persistent advertising cookies are set by CBC Best.
Third-Party Services & External Links
Services we use and sites we link to
CBC Best links to official Kenyan government and education authorities as primary references. We are not responsible for the privacy practices or content of any third-party sites.
Platform & infrastructure
- Netlify — Hosting and global CDN. Netlify may log IP addresses and request headers for security and performance purposes. See Netlify Privacy Policy.
- Google Fonts — Fonts are loaded from Google's CDN. Google may receive your IP address when fonts are requested. See Google Privacy Policy.
Official Kenyan education authorities (outbound links only)
- Kenya Institute of Curriculum Development (KICD) — kicd.ac.ke — the authoritative body for CBC curriculum frameworks and approved learning materials
- Teachers Service Commission (TSC) — tsc.go.ke — the employer and regulatory body for all public school teachers in Kenya
- Kenya National Examinations Council (KNEC) — knec.ac.ke — administers KPSEA, KJSEA, and KCSE national assessments
- Ministry of Education, Kenya — education.go.ke — national education policy and CBC implementation oversight
- Office of the Data Protection Commissioner (ODPC) — odpc.go.ke — Kenya's data protection supervisory authority
- Kenya Law Reform Commission — kenyalaw.org — official source for Kenyan legislation referenced in this policy
Ronny Mwenda's other platforms
- bestronny.netlify.app — Ronny Best Mathematics: additional Mathematics teaching resources and worked examples
- ronnymwenda.netlify.app — Personal portfolio and biography of Ronny Mwenda
- ronnygame.netlify.app — RonnyGame: educational games and interactive learning tools
Each of these sites is independently operated and has its own privacy practices. By navigating to them from CBC Best, you leave this policy's scope.
Data Security
How we protect your information
We implement appropriate technical and organisational measures to protect the data we hold, consistent with the requirements of Section 41 of the Kenya Data Protection Act 2019.
Technical safeguards
- HTTPS / TLS encryption — All traffic between your browser and cbcbest.netlify.app is encrypted using TLS 1.2 or higher, enforced by Netlify's infrastructure
- Service Worker isolation — The PWA service worker caches only public assets and does not intercept authenticated sessions
- No centralised user database — Forum data is stored in your browser's localStorage rather than on a remote server, substantially reducing server-side data exposure risk
- Minimal data collection — We do not collect data beyond what is necessary for the specific function being used (data minimisation principle)
Organisational safeguards
- Single administrator — Ronny Mwenda is the sole person with access to site configuration, contact form submissions, and newsletter subscriber lists
- Regular dependency updates — Third-party scripts and hosting configurations are reviewed and updated regularly
- No third-party data processors — We do not contract external companies to process user data on our behalf (except Netlify for hosting)
Data Retention
How long we keep your information
We retain personal data only for as long as necessary to fulfil the purpose for which it was collected or as required by Kenyan law. The table below summarises our retention schedule.
| Data Type | Storage Location | Retention Period | Deletion Method |
|---|---|---|---|
| Forum posts and replies | Your browser (localStorage) | Until you clear browser data, or on deletion request | Clear browser storage or submit a deletion request |
| Contact form submissions | Browser localStorage + email inbox of site owner | Up to 12 months from submission date | Email deletion request to site owner |
| Newsletter subscriber email | Email list (site owner managed) | Until you unsubscribe | Unsubscribe link in every newsletter email |
| Server log / access data | Netlify infrastructure | Up to 30 days (Netlify standard) | Automatic purge by Netlify |
| Anonymised analytics | Aggregated, no personal identifiers | Up to 14 months | Automatic aggregation, no individual records |
To request deletion of any personal data held by CBC Best, contact us via the contact form with the subject line "Data Deletion Request". We will process your request within 30 days.
Your Rights as a Data Subject
Rights under the Kenya Data Protection Act 2019 and GDPR
Part IV of the Kenya Data Protection Act 2019 establishes the rights of data subjects. These rights are summarised below. EU residents may additionally rely on equivalent rights under the GDPR.
Right to Access
Request a copy of personal data we hold about you (Section 26, DPA 2019)
Right to Rectification
Correct inaccurate or incomplete personal data (Section 27, DPA 2019)
Right to Erasure
Request deletion of your personal data ("right to be forgotten") (Section 28, DPA 2019)
Right to Object
Object to processing of your data for specific purposes (Section 32, DPA 2019)
Right to Portability
Receive your data in a structured, machine-readable format (Section 29, DPA 2019)
Right to Restrict Processing
Limit how we use your data in certain circumstances (Section 30, DPA 2019)
Right to Withdraw Consent
Withdraw previously given consent at any time without penalty
Right to Lodge a Complaint
Complain directly to the ODPC at odpc.go.ke
To exercise any of these rights, submit a written request via our contact form using the subject line "Privacy Request — [Right Type]" (e.g., "Privacy Request — Erasure"). We will respond within 30 days of receiving a valid request, consistent with the DPA 2019 timelines. No fee is charged for exercising your rights.
Children's Privacy
Special protections for learners under 18
CBC Best serves students across the entire CBC grade structure — including learners in Primary School (Grades 1–6, ages approximately 6–12), Junior Secondary (Grades 7–9, ages approximately 13–15), and Senior Secondary (Grades 10–12, ages approximately 16–18). We take the protection of younger users with the utmost seriousness.
Children under 13 years of age
We do not knowingly collect personal information from children under the age of 13 without verifiable parental consent, consistent with Section 51 of the Kenya Data Protection Act 2019 and the protections applicable under international frameworks. The discussion forums are designed for educational use and moderated to ensure they remain appropriate for all age groups.
If you are a parent or guardian and believe that your child under the age of 13 has submitted personal information to CBC Best without your consent, please contact us immediately at the email address below. We will promptly investigate and delete the information from our records.
Learners aged 13–18
Learners in this age group may use the site independently for educational purposes. We encourage parents and teachers to review this policy together with their students. Content published on CBC Best is written for academic and educational purposes and aligns with the values and learning outcomes described in the KICD Basic Education Curriculum Framework (BECF).
Advertising Policy
Current and future use of advertising on CBC Best
CBC Best is currently a free, non-commercial educational platform. No advertising is displayed at this time. In the future, we may integrate Google AdSense to generate revenue that supports the cost of maintaining and expanding the platform. If and when this occurs, the following will apply:
Google AdSense — how it works
- Interest-based advertising: Google uses cookies and similar technologies to show ads that may be relevant to your interests based on your browsing history across Google's network
- Personally identifiable information: CBC Best will not pass personally identifiable information to Google AdSense. Ads are served based on contextual and interest signals managed entirely by Google
- Google's role as data processor: Google acts as an independent data controller for its advertising systems. Their data practices are governed by the Google Privacy Policy and How Google uses data when you use our partners' sites or apps
- DoubleClick DART cookie: When AdSense is active, Google's DoubleClick DART cookie may be used to serve ads. Users may opt out of this cookie by visiting Google Ads Settings
Our advertising commitments
- We will never display ads in a way that is misleading, harmful, or inappropriate for a student or teacher audience
- A cookie consent notice will be displayed before any advertising cookies are set, as required by ODPC guidance
- We will not show ads on pages or sections specifically designed for young learners under 13
- All advertising will comply with Google AdSense Programme Policies and Kenya's Consumer Protection Act 2012
International Data Transfers
Where your data may be processed
CBC Best is hosted on Netlify's global CDN, which may process data on servers located in the United States, Europe, and other regions. Under the Kenya Data Protection Act 2019, international transfers of personal data are permitted where the recipient country provides an adequate level of protection, or where appropriate safeguards (such as standard contractual clauses) are in place.
Netlify operates under its own Privacy Policy and GDPR/CCPA compliance framework, which we consider provides adequate safeguards for the limited infrastructure data processed through their platform.
Google Fonts requests are routed through Google's CDN and may involve data processing in the United States. Google operates under Standard Contractual Clauses for international data transfers.
By using CBC Best, you acknowledge that your data may be transferred to and processed outside Kenya. We take reasonable steps to ensure such transfers are compliant with applicable law.
Updates to This Privacy Policy
How and when this policy may change
We may update this Privacy Policy from time to time to reflect changes in the law, our practices, or the features of CBC Best. When we make material changes, we will:
- Update the "Last Updated" date at the top of this page and in the page hero banner
- Post a visible notice on the CBC Best homepage for a period of at least 30 days after the change
- Send an email notification to newsletter subscribers where the change materially affects how their data is used
We encourage you to review this page periodically. Your continued use of CBC Best after any changes to this policy constitutes acceptance of the revised terms, to the extent permitted by Kenyan law.
Previous versions of this policy are available on request — contact us via the contact form with the subject line "Previous Privacy Policy Version".
Contact the Data Controller
How to reach us with privacy questions or requests
For all privacy-related queries, data subject requests, or concerns about this policy, please contact the data controller directly:
Ronny Mwenda (Ronny Best)
Mathematics & Computer Science Teacher · Embu County, Kenya
Data Controller — CBC Best (cbcbest.netlify.app)
| Contact Channel | Details | Use For |
|---|---|---|
| Contact Form | cbcbest.netlify.app/about-contact.html | All privacy requests, deletion requests, access requests, complaints |
| ronnymwenda89@gmail.com | Urgent data breach notifications or legal correspondence | |
| Platform | Embu County, Kenya | Formal written correspondence (provide return address in email) |
We aim to respond to all privacy requests within 30 days. If your request is complex or you have submitted multiple requests, we may extend this period by up to two additional months and will notify you of the extension.
If you are not satisfied with our response, you have the right to lodge a complaint with Kenya's Office of the Data Protection Commissioner (ODPC):
- ODPC Website: www.odpc.go.ke
- File a Complaint: odpc.go.ke/file-a-complaint
- ODPC Physical Address: Upper Hill, Nairobi, Kenya