1. Who We Are
Camp Counselors Africa ("CCA", "we", "us", or "our") is the data controller responsible for the personal data described in this Privacy Policy.
Camp Counselors Africa
Rongai, Kenya
P.O. Box 60177-00200, Nairobi, Kenya
Email: info@campcounselorsafrica.co.ke
Phone: +254 736 68 79 79 / +254 790 668 073
2. What Personal Data We Collect
- Identity & contact data — full name, email address, phone number, age, home country, and county/town of residence.
- Application & placement data — preferred destination country/city, work experience, relevant skills, swimming ability, earliest available departure date, and anything else you share when applying.
- AI Matcher inputs — details you voluntarily submit to our AI Program Matcher and Cover Letter Writer, including your skills, work history, and interests.
- Communications — records of calls, emails, or WhatsApp messages with our admissions team.
- Technical & usage data — collected only if and when analytics tools are enabled on this site (see Section 8 — none are active as of this update).
3. How and Why We Use Your Data
| Purpose | Data Used | Lawful Basis |
|---|---|---|
| Processing your program application | Identity, contact, and application data | Contract performance / consent (GDPR); consent or contractual necessity (Kenya DPA) |
| Generating your AI eligibility read or cover letter | AI Matcher inputs | Explicit consent |
| Responding to enquiries | Contact data, communication records | Legitimate interest / consent |
| Website analytics (if/when enabled) | Technical & usage data, cookies | Consent (EU) / disclosed legitimate interest with opt-out (Kenya) |
5. International Data Transfers
Some of the providers above process data outside Kenya and the EEA (primarily the United States). Where this happens, we rely on appropriate safeguards, including Standard Contractual Clauses for EU-relevant transfers and recognized transfer mechanisms under section 48 of Kenya's Data Protection Act, 2019.
6. Data Retention
- Application data: retained for 24 months following your last interaction with us, or until program placement is complete plus 12 months, whichever is longer.
- AI Matcher inputs: retained only as needed to generate your requested output.
7. Your Rights
Subject to applicable law, you have the right to:
- Access — request a copy of the personal data we hold about you.
- Rectification — request correction of inaccurate or incomplete data.
- Erasure — request deletion of your personal data, subject to legal retention obligations.
- Restriction — request that we limit how we use your data.
- Portability — request your data in a structured, machine-readable format.
- Objection — object to processing based on legitimate interest, including direct marketing.
- Withdraw consent — withdraw previously given consent at any time.
Use the form below to exercise any of these rights.
9. Data Breach Notification
In the event of a personal data breach likely to affect your rights, we will notify the relevant supervisory authority without undue delay — within 72 hours where feasible, in line with GDPR Article 33 and equivalent obligations under Kenya's Data Protection Act — and notify affected individuals directly where the risk is high.
10. Your Right to Complain
- Kenya: the Office of the Data Protection Commissioner (ODPC) — www.odpc.go.ke
- EU/EEA: the data protection authority in your country of residence or habitual work.
11. Contact Us / Data Protection Contact
For any questions about this policy or to exercise your data rights:
Email: info@campcounselorsafrica.co.ke
Postal address: Camp Counselors Africa, P.O. Box 60177-00200, Nairobi, Kenya
Data Subject Rights Request Form
Complete this form to exercise any of your data protection rights. We aim to respond within one month of receiving a valid request.
Clicking submit opens your email app with these details pre-filled, addressed to our data protection contact. We may ask you to confirm your identity before actioning the request.