Privacy Policy

1. Introduction

Iskills Info Technologies ("We", "Us", "Our") operates the HANAD Digital Entrepreneur's Application and Learner Portal (collectively, "the Platform") on behalf of ADRA Somalia under the EU-funded e-WINS Entrepreneurship Project, in partnership with the Ministry of Commerce and Industry of the Federal Republic of Somalia.

We are committed to protecting the privacy and personal data of every Learner, mentor, and platform user. This Privacy Policy explains what data we collect, why we collect it, how it is used and protected, and what rights you have over your information. This Policy is designed to comply with EU data protection standards applicable to this project.

By registering and using the Platform, you consent to the data practices described in this Policy.

2. Data Controller and Governance

The data controller responsible for your personal data under this Platform is:

• Primary Technical Partner: Iskills Info Technologies
• Implementing Partner: ADRA Somalia
• Governing Authority: Ministry of Commerce and Industry, Federal Republic of Somalia

A dedicated Data Protection Officer has been appointed to oversee all data handling activities. User consent mechanisms, data minimisation practices, and EU compliance standards govern every aspect of data management on the Platform.

3. What Data We Collect

3.1 Registration Data

When you create an account, we collect:

• Full name
• Phone number (used for OTP-based login)
• Gender
• Geographic corridor and region (Juba, Shabelle, or Somaliland)
• Preferred language (Somali Maxaa Tiri, Somali Maay, English, or Arabic)
• Organisation or business affiliation (where applicable)

3.2 Learning Activity Data

As you use the Platform, we collect:

• Course enrolment and completion records
• Lesson progress and time-on-task data
• Quiz and assessment scores and attempt history
• Certificate of Completion records
• Offline synchronisation logs (timestamps of sync events)

3.3 Device and Technical Data

For platform functionality and performance monitoring, we collect:

• Device type and operating system version
• App version in use
• Connectivity status and sync timestamps
• Anonymised crash and error logs

3.4 Communications Data

When you interact with mentors, peer forums, or the Help Desk, we collect:

• Help desk ticket content and status
• Peer discussion forum contributions
• Mentor-learner communication records (for moderation and support purposes)

3.5 What We Do Not Collect

We do not collect:

• Financial or payment information
• Location tracking or GPS data
• Biometric data
• Data from third-party social networks unless you use social login (optional)

4. How We Use Your Data

We collect and process your data only for the following legitimate purposes:

• Delivering personalised learning content and tracking your course progress
• Issuing Certificates of Completion with verifiable identifiers
• Enabling offline-first access and synchronising your progress securely
• Supporting mentorship, peer learning, and community moderation
• Providing Help Desk support and tracking resolution of your requests
• Generating anonymised, aggregated MEAL (Monitoring, Evaluation, Accountability and Learning) KPI reports required for EU donor compliance — individual learners are never personally identified in donor reports
• Conducting platform performance monitoring and quality assurance
• Fulfilling legal and contractual obligations under the e-WINS Project grant agreement

We do not use your data for commercial advertising, profiling for non-educational purposes, or sale to third parties.

5. Data Minimisation and Privacy by Design

The Platform is built on a data minimisation principle: we collect only the information strictly necessary for educational delivery and project accountability. Special identity safeguards are applied for women users to ensure that participation in community features remains secure and, where desired, anonymous. You may choose a display name different from your legal name for forum participation.

6. Informed Consent

Before accessing the Platform, every new user is guided through a transparent informed consent process during onboarding. This process clearly explains:

• What personal data is being collected
• Why it is collected and how it will be used
• Who will have access to the data
• Your rights in relation to your data

Consent is recorded and stored. You may withdraw consent at any time by contacting the Data Protection Officer, though this may affect your ability to use certain Platform features.

7. Data Sharing and Disclosure

7.1 Within the Project Partnership

Your data may be shared with:

• ADRA Somalia – as the implementing partner and project operator
• Ministry of Commerce and Industry – as the governing authority with Super Admin oversight
• Authorised Iskills Info Technologies personnel – for technical support and maintenance
• Assigned mentors and facilitators – limited to learner progress data relevant to their cohort

7.2 EU Donor Reporting

Aggregated and anonymised statistical data (such as total enrolments, completion rates, regional distribution, and assessment outcomes) is included in reports submitted to the European Union as required under the e-WINS Project grant agreement. No personally identifiable information is included in donor reports.

7.3 No Third-Party Commercial Sharing

We do not sell, rent, or share your personal data with any commercial third party. Data is never used for advertising or marketing purposes.

7.4 Legal Disclosure

We may disclose your data if required to do so by applicable law, court order, or to protect the safety of users or the integrity of the Platform.

8. Data Security

We implement industry-standard security measures to protect your personal data, including:

• All data transmission encrypted via HTTPS/TLS
• OAuth 2.0 / OIDC authentication with secure token handling
• Data encrypted at rest and in transit within the ADRA Server Environment
• Role-based access controls (RBAC) ensuring staff access only the data necessary for their duties
• Immutable audit logs recording all administrative data access events
• Regular security reviews and access permission audits every six to twelve months

In the event of a data breach, we will notify affected users and the Ministry as swiftly as possible, and no later than required under applicable law.

9. Data Retention

Your personal data is retained for the following periods:

• Active account data: retained for the duration of the e-WINS Project and any agreed post-project sustainability period
• Learning progress and certificate records: retained for a minimum of five years to support verification and impact assessment
• Help Desk ticket data: retained for three years for SLA compliance purposes
• Aggregated and anonymised reporting data: retained indefinitely for project impact evaluation

Upon request, personal data that is no longer required for the above purposes will be securely deleted or anonymised.

10. Your Rights

You have the following rights in relation to your personal data:

• Right of Access: you may request a copy of the personal data we hold about you
• Right to Rectification: you may request correction of inaccurate or incomplete data
• Right to Erasure: you may request deletion of your data, subject to legal and project retention obligations
• Right to Restriction: you may request that we limit processing of your data in certain circumstances
• Right to Data Portability: you may request your learning data in a portable, machine-readable format
• Right to Withdraw Consent: you may withdraw consent to data processing at any time without affecting the lawfulness of prior processing

To exercise any of these rights, please contact the Data Protection Officer using the details in Section 14.

11. Children's Privacy

The HANAD Platform is intended for adult women entrepreneurs. We do not knowingly collect personal data from individuals under the age of 18. If you believe a minor has registered without parental consent, please contact us immediately and we will take prompt action to remove the account.

12. Cookies and Local Storage

The HANAD mobile application does not use browser cookies. The app uses local device storage (SQLite) exclusively for offline content caching and progress synchronisation. This data is managed entirely on your device and synchronised securely with our servers when you are online. You can clear this local data by uninstalling the application.

13. Updates to This Policy

We may update this Privacy Policy from time to time in response to changes in law, project governance, or platform functionality. Where changes are material, we will notify you via an in-app notice prior to the change taking effect. Continued use of the Platform after notification constitutes acceptance of the revised Policy. The current version and effective date are always displayed at the top of this document.

14. Contact Us

For any questions, requests to exercise your rights, or to contact the Data Protection Officer, please reach us through:

• In-app: Submit a request via the HANAD Help Desk
• Email: privacy@iskillinfo.com
• Website: www.iskillinfo.com