Privacy Policy

KunjaniAI Ltd

Company No. 217829 - Republic of Mauritius

Last Updated: 10 September 2026 · Effective Date: 24 March 2026

1. Introduction

KunjaniAI Ltd (Company No. 217829), a private company limited by shares incorporated in the Republic of Mauritius, trading as Kunjani (“Kunjani,” “we,” “us,” or “our”), is committed to protecting your privacy and personal data.

This Privacy Policy explains how we collect, use, process, store, and disclose personal data when you use the Kunjani platform, delivered through WhatsApp, Microsoft Teams, our web applications (including kunjani.co and play.kunjani.co), and related services (collectively, the “Service”).

Kunjani is part of a group of companies with operations in Mauritius, South Africa, and the United Kingdom. This Privacy Policy should be read together with our Terms and Conditions and Acceptable Use Policy.

Kunjani LTD publishes and provides the Kunjani service through Microsoft Teams, supported by other Kunjani group companies where applicable. An existing signed customer agreement identifying another provider continues to govern that relationship unless amended. The customer organisation normally determines the purposes of learner-data processing; the company providing the service processes that data on its instructions. Separate account, billing, support and security processing is described by its applicable purpose and company role.

2. Regulatory Compliance

Kunjani processes personal data in compliance with the Data Protection Act 2017 of Mauritius (“DPA 2017”).

Where we process personal data of individuals in the European Economic Area, we also comply with the General Data Protection Regulation (“GDPR”). Where we process personal information of individuals in South Africa, we also comply with the Protection of Personal Information Act (“POPIA”).

3. Lawful Basis for Processing

We process personal data only where we have a lawful basis to do so under the DPA 2017, Section 28. Our lawful bases include:

  • Consent: Where you or your organisation has given us specific, informed, and unambiguous consent to process your personal data for defined purposes.
  • Contract: Where processing is necessary to perform our obligations under a contract with you or your organisation, or to take steps at your request prior to entering into a contract.
  • Legitimate Interest: Where processing is necessary for our legitimate business interests (such as improving the Service, preventing fraud, and ensuring security), provided those interests do not override your rights and freedoms.
  • Legal Obligation: Where processing is necessary to comply with applicable laws and regulations.

4. Personal Data We Collect

4.1 Information You Provide

When you create an account, register for a subscription, or use the Service, we may collect: your name, email address, phone number, job title and organisation, username and password, and payment information (for Paid Subscriptions).

4.2 Information Generated Through Use

When you interact with the Service, we collect: responses to training activities (including text, voice notes, photos, and videos), performance data and assessment results, usage data (such as activity completion, engagement metrics, and timestamps), and messages exchanged through the platform.

4.3 Information Collected Automatically

We automatically collect: device and browser information, IP addresses, usage analytics and log data, and information collected through cookies and similar technologies.

4.4 Information From Third Parties

If you register using a third-party service (such as Google or Microsoft), we may receive basic profile information from that service in accordance with its privacy policy and your authorisation.

5. How We Use Personal Data

We use personal data to: provide and operate the Service, including delivering training activities and generating learner feedback; process payments and manage subscriptions; communicate with you about your account, service updates, and support requests; generate performance analytics and reports for Clients; improve the Service through aggregated usage analysis; comply with legal obligations; and, with your consent, send marketing communications (you may opt out at any time).

6. Artificial Intelligence and Automated Processing

The Service uses artificial intelligence to provide automated feedback on learner responses, generate content suggestions, and produce performance analytics. This involves automated processing of User Content, including text, voice, photo, and video submissions.

Important:Kunjani's AI features provide learning feedback and performance information. The Service is not intended to make decisions that produce legal effects or similarly significant effects on individuals without human involvement.

You have the right to request human review of any AI-generated assessment or feedback. To exercise this right, contact us at info@kunjani.co.

We do not sell personal data or use it to train AI models for unrelated purposes. AI processing is limited to providing and improving the Service.

6.1 AI Assistants and Connectors (MCP)

Kunjani offers an optional connector (a Model Context Protocol, or “MCP,” server) that lets you use a third-party AI assistant, such as Claude or ChatGPT, to view and build your Kunjani training content. The connector is off until you explicitly enable it and authorise it.

When you connect an AI assistant, it can, on your instruction and within the permissions you grant: list the decks your account can see; and create or update decks, learning outcomes, and activities in your account. The connector accesses only data your account is already authorised to access; it grants no additional access. Your authentication credential (an OAuth grant or a personal API token) is passed through to the Kunjani service to perform the action you requested and is not used to build any separate profile of you.

Content you send to, or receive from, the third-party AI assistant is also processed by that assistant's provider under that provider's own privacy terms, which are outside Kunjani's control. Review the privacy terms of the assistant you connect.

You can disconnect at any time by revoking the connector's authorisation or deleting the API token in your Kunjani account settings. Revoking access stops all further connector activity immediately.

7. Disclosure of Personal Data

We may disclose personal data to:

  • Clients: We provide performance data, analytics, and assessment results to the Client organisation that enrolled you in a training programme.
  • Service Providers: We use carefully selected third-party service providers for hosting, data storage, payment processing, email delivery, and analytics. These providers are contractually required to process personal data only as instructed by us and to implement appropriate security measures.
  • Messaging Platforms: The Service operates through WhatsApp and Microsoft Teams. Your use of these platforms is subject to their respective privacy policies. We minimise the personal data shared with these platforms to what is necessary for service delivery.
  • AI Assistants You Connect:If you enable the Kunjani connector (MCP), the third-party AI assistant you authorise (for example Claude or ChatGPT) receives the deck, outcome, and activity data you ask it to read or write, under that provider's privacy terms.
  • Group Companies: We may share personal data with companies within the Kunjani group (including our South African and United Kingdom entities) for operational purposes, subject to appropriate safeguards.
  • Legal Requirements: We may disclose personal data where required by law, regulation, court order, or governmental request.
  • Business Transfers: In the event of a merger, acquisition, or sale of assets, personal data may be transferred to the acquiring entity. We will notify you of any such transfer.

We do not sell personal data to third parties. We do not share identifiable personal data with third parties for their own marketing purposes.

8. International Data Transfers

KunjaniAI Ltd is based in Mauritius. Your personal data may be transferred to and processed in countries other than your country of residence, including South Africa, the United Kingdom, and other countries where our hosting providers and service providers operate.

Where personal data is transferred outside Mauritius, we ensure that appropriate safeguards are in place in accordance with the DPA 2017, Part VI. Where personal data of EEA residents is transferred outside the EEA, we ensure compliance with GDPR Chapter V, including the use of standard contractual clauses or other approved transfer mechanisms. Where personal data of South African residents is transferred outside South Africa, we comply with POPIA Section 72.

9. Data Retention

We retain personal data for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, accounting, or reporting requirements. When personal data is no longer required, we will securely delete or de-identify it in accordance with DPA 2017, Section 27.

Specific retention periods: account data is retained for the duration of your account and for 12 months after termination; training activity data and performance records are retained for the duration of the Client's subscription and for 12 months thereafter, unless a longer period is agreed; and payment records are retained for the period required by applicable tax and financial legislation.

10. Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, or destruction, as required by DPA 2017, Section 31. These measures include encryption of data in transit and at rest, access controls, regular security assessments, and incident response procedures.

No method of transmission or storage is completely secure. If you believe your account or data has been compromised, please contact us immediately at info@kunjani.co.

11. Data Breach Notification

In the event of a personal data breach, we will notify the Data Protection Commissioner of Mauritius as required by DPA 2017, Section 25, without undue delay. Where the breach is likely to result in a high risk to the rights and freedoms of data subjects, we will also notify affected individuals as required by DPA 2017, Section 26.

Where the breach involves personal data of EEA residents, we will also notify the relevant supervisory authority under GDPR Article 33 within 72 hours of becoming aware of the breach. Where the breach involves personal information of South African residents, we will notify the Information Regulator and affected data subjects as required by POPIA Section 22.

12. Your Rights

Under the DPA 2017 and, where applicable, GDPR and POPIA, you have the following rights regarding your personal data:

  • Access: You may request confirmation of whether we process your personal data and, if so, request a copy of that data (DPA 2017, Section 41).
  • Correction: You may request that we correct inaccurate or incomplete personal data (DPA 2017, Section 42).
  • Erasure: You may request that we erase your personal data in certain circumstances (DPA 2017, Section 43).
  • Objection: You may object to the processing of your personal data on legitimate grounds (DPA 2017, Section 45).
  • Restriction: You may request that we restrict the processing of your personal data in certain circumstances.
  • Data Portability: Where applicable under GDPR, you may request your personal data in a structured, commonly used, machine-readable format.
  • Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of processing based on consent before its withdrawal (DPA 2017, Section 24(5)).
  • Human Review of Automated Decisions: You may request human review of any decision made solely by automated processing, including AI-generated assessments (DPA 2017, Section 46).
  • Withdraw Connector Access:You may revoke any AI assistant connector's authorisation, or delete a personal API token, at any time in your account settings to immediately stop connector access to your data.

To exercise any of these rights, please contact us using the details in Section 15. We will respond to your request within a reasonable period. You also have the right to lodge a complaint with the Data Protection Commissioner of Mauritius.

13. Cookies and Similar Technologies

When you request access to our investment deck, we collect your name, email address, optional investor type, and viewing activity to understand investor interest and inform follow-up. Activity includes slides viewed, approximate visible viewing time, repeat visits, device category, and approximate country. A browser cookie remembers your access for 90 days. Details are stored using Cloudflare and are available only to authorised administrators. Contact info@kunjani.co to request deletion.

Our web applications use cookies and similar technologies to ensure functionality, remember your preferences, and analyse usage. We categorise cookies as: strictly necessary cookies (required for the Service to function); functional cookies (to remember your preferences and settings); and analytics cookies (to understand how the Service is used and to improve it).

We obtain your consent before placing non-essential cookies, in accordance with the DPA 2017. You can manage your cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of the Service.

14. Children's Privacy

The Service is not directed at individuals under the age of 18. Where a Client uses the Service for training that involves individuals under 18, the Client is responsible for ensuring that appropriate parental or guardian consent is obtained in accordance with the DPA 2017, Section 30, and any other applicable legislation. We do not knowingly market to individuals under 18.

15. Privacy Contact Details

For the Microsoft Teams service: Kunjani LTD. Contact: info@kunjani.co.

Group company: KunjaniAI Ltd

Company No.: 217829

Address: 88 Coastal Rd, Riambel, Savanna, Mauritius

Email: info@kunjani.co

If you are not satisfied with our response to a privacy-related request, you have the right to lodge a complaint with:

The Data Protection Office (Mauritius)

Website: dataprotection.govmu.org

Email: dpo@govmu.org

For South African residents, you may also lodge a complaint with the Information Regulator (inforegulator.org.za). For EEA residents, you may lodge a complaint with your local supervisory authority.

16. Sensitive Data

Please do not submit sensitive personal data (such as national identity numbers, health information, or biometric data) through the Service unless specifically required by a training activity and authorised by your Client organisation. Where sensitive personal data is processed, we apply additional safeguards in accordance with DPA 2017, Section 29.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Where changes are material, we will notify you at least 30 days before the updated policy takes effect, either through the Service or by email. The “Last Updated” date at the top of this policy indicates the most recent revision.