CLIREN Learning Management System (CLIREN LMS)
Effective Date: 1 September 2026
Operated by: CLIREN Centre – Clinical Research Network Centre
CLIREN Centre respects your privacy and is committed to protecting the personal information of learners, instructors, visitors and other users of the CLIREN Learning Management System (“CLIREN LMS”).
This Privacy Policy explains what information we collect, why we collect it, how we use and protect it, when it may be shared, and the choices and rights available to you. It is intended to support compliance with the Kenya Data Protection Act, 2019 (Cap. 411C) and applicable data protection regulations. The Act regulates the processing of personal data and establishes rights for data subjects and obligations for data controllers and processors.
1. Who We Are
CLIREN Centre (Clinical Research Network Centre) operates CLIREN LMS, an educational platform providing training and professional development in clinical research, data management and related disciplines.
For personal information collected directly through CLIREN LMS for CLIREN’s own training activities, CLIREN Centre generally determines why and how that information is processed and therefore acts as the data controller.
2. Information We Collect
Depending on how you interact with CLIREN LMS, we may collect:
Account and identification information, such as your name, username, email address, telephone number, country, organization or institution and other information provided during registration.
Professional and educational information, such as your occupation, professional role, institution, educational background or areas of interest where this information is required for a particular programme.
Course and learning information, including courses enrolled in, lessons completed, attendance, quiz and assessment results, assignment submissions, practical exercises, discussion activity, course progress, feedback and completion status.
Certification information, including your name, course completed, completion date, assessment results where applicable, and certificate identifiers.
Payment and transaction information, where you enrol in a paid programme. Payment transactions may be processed through third-party payment providers. CLIREN does not necessarily receive or retain complete payment-card or mobile-money credentials.
Technical information, such as IP address, browser type, device information, login timestamps, system activity and security logs.
Communications, including enquiries, support requests, feedback, emails and other communications you send to us.
3. How We Collect Information
We may collect information when you:
- Create or update a CLIREN LMS account;
- Register or pay for a course, webinar or training programme;
- Participate in lessons, assessments and practical exercises;
- Submit assignments, projects or feedback;
- Attend online or physical training activities;
- Request technical or administrative support;
- Subscribe to communications where offered; or
- Interact with CLIREN LMS and its associated systems.
Some technical information may be collected automatically when you access the platform.
4. Why We Process Your Information
We process personal information where there is an appropriate legal basis and for legitimate, specified purposes. Depending on the circumstances, relevant bases may include consent, performance of a contract, compliance with legal obligations and legitimate interests. The ODPC recognizes these among the bases relevant to personal-data processing.
We may use your information to:
- Create and administer your account;
- Process course registration and enrolment;
- Deliver learning content and training;
- Track course participation and progress;
- Administer quizzes, assignments and assessments;
- Provide learner support;
- Communicate course announcements and schedule changes;
- Issue and verify certificates;
- Process payments and maintain financial records;
- Improve our courses, LMS and learner experience;
- Conduct internal reporting and quality assurance;
- Protect the security and integrity of CLIREN systems;
- Prevent fraud, abuse and unauthorized access;
- Meet applicable legal and regulatory requirements; and
- Send marketing communications where permitted and, where required, with your consent.
We will not use personal information for purposes materially incompatible with those for which it was collected without an appropriate legal basis.
5. Data Protection Principles
CLIREN aims to process personal information lawfully, fairly and transparently; collect it for explicit and legitimate purposes; limit collection to what is necessary; maintain appropriate accuracy; retain identifiable information only as long as necessary; and implement appropriate safeguards.
These principles reflect the requirements of Kenya’s data protection framework.
6. Clinical Research and Sensitive Data
Because CLIREN provides training in clinical research and data management, some courses may use clinical research examples, datasets and practical exercises.
Learners must not upload identifiable participant or patient information, confidential clinical research records, or sensitive study data to CLIREN LMS unless expressly authorized to do so.
Where clinical datasets are provided for training, CLIREN will seek to use simulated, anonymized, appropriately de-identified, publicly available or otherwise authorized data.
Under Kenya’s data protection framework, information such as health, genetic and biometric information may constitute sensitive personal data and requires additional protection.
7. How We Share Personal Information
CLIREN does not sell learners’ personal information.
We may share information with appropriately authorized parties where necessary, including:
- CLIREN instructors and authorized administrative staff;
- Technology and hosting providers;
- Payment-processing providers;
- Email and communication service providers;
- Webinar or virtual-learning service providers;
- Professional service providers supporting CLIREN operations;
- Partner institutions involved in delivering a programme, where applicable; and
- Government, regulatory or law-enforcement authorities where disclosure is legally required.
Service providers processing information on our behalf are expected to process it only for authorized purposes and to apply appropriate safeguards.
8. International Data Transfers
Some technology or cloud-service providers used by CLIREN may process or store information outside Kenya.
Where personal data is transferred outside Kenya, CLIREN will seek to ensure that the transfer complies with applicable data protection requirements and that appropriate safeguards are in place. Kenya’s data protection principles restrict transfers outside Kenya unless adequate safeguards or another lawful basis applies.
9. Data Security
CLIREN takes reasonable administrative, organizational and technical measures to protect personal information against unauthorized access, disclosure, alteration, loss or destruction.
Measures may include access controls, authentication, secure communications, system logging, backups, software updates, role-based permissions and restrictions on access to personal information.
No internet-based service can, however, guarantee absolute security.
10. Passwords and Account Security
You are responsible for maintaining the confidentiality of your CLIREN LMS password and should not share your account with another person.
Please notify CLIREN promptly if you suspect unauthorized access to your account.
CLIREN will never require you to disclose your password by email or ordinary support communication.
11. Cookies and Similar Technologies
CLIREN LMS may use cookies and similar technologies that are necessary to operate the platform, maintain user sessions, remember preferences, improve functionality, understand platform usage and support security.
Where non-essential analytics, advertising or similar cookies are introduced, appropriate information and consent mechanisms will be provided where required.
A separate Cookie Policy may provide further details about the technologies used by the platform.
12. Data Retention
We retain personal information only for as long as reasonably necessary for the purposes for which it was collected and to satisfy legitimate educational, administrative, contractual, legal and regulatory requirements.
Some records, such as course completion, certification, financial transactions and audit information, may need to be retained for longer periods.
When personal information is no longer required, it may be securely deleted, anonymized or otherwise disposed of in accordance with applicable requirements.
13. Your Data Protection Rights
Subject to applicable law and relevant exceptions, you may have rights concerning your personal information, including the right to:
- Be informed about how your personal information is used;
- Request access to personal information held about you;
- Request correction of inaccurate or misleading information;
- Object to certain processing;
- Request deletion of information in applicable circumstances;
- Request restriction of certain processing; and
- Exercise other applicable rights, including data portability where relevant.
The ODPC identifies rights including being informed, access, rectification, erasure, portability, objection and restriction of processing.
You may contact CLIREN using the details below to exercise an applicable right. We may need to verify your identity before fulfilling the request.
14. Marketing Communications
Where you have agreed to receive information about new courses, webinars, events or other CLIREN activities, we may send you promotional communications.
You may withdraw from such communications at any time using the unsubscribe mechanism provided or by contacting us.
Unsubscribing from marketing does not prevent us from sending essential communications relating to your account, active course, payment, assessment or certificate.
15. Children’s Privacy
CLIREN LMS is primarily intended for adult learners and professionals.
Where CLIREN offers a programme to minors, appropriate consent and safeguards will be implemented in accordance with applicable law. Kenya’s ODPC notes that certain data-subject rights concerning minors may be exercised by a person with parental authority or a guardian.
16. Third-Party Websites and Services
CLIREN LMS may contain links to third-party websites, software or learning resources.
Those services may have their own privacy policies and data-processing practices. CLIREN is not responsible for the privacy practices of independent third-party websites merely because the LMS provides a link to them.
We encourage users to review the privacy information provided by those services.
17. Data Breaches
If CLIREN becomes aware of a personal-data breach, we will assess the incident, take appropriate steps to contain and investigate it, and make notifications where required by applicable data protection law.
The Office of the Data Protection Commissioner provides mechanisms for reporting personal-data breaches and complaints concerning data protection.
18. Complaints
If you have concerns about how CLIREN processes your personal information, please contact us first so that we can investigate the matter.
You also have the right, where applicable, to raise a data-protection complaint with Kenya’s Office of the Data Protection Commissioner (ODPC). The ODPC is the government agency responsible for regulating personal-data processing and protecting privacy rights under Kenya’s Data Protection Act.
Office of the Data Protection Commissioner
19. Changes to This Privacy Policy
We may update this Privacy Policy periodically to reflect changes to CLIREN LMS, our services, technologies or applicable legal requirements.
The latest version will be published on CLIREN LMS with an updated effective date. Where changes materially affect how we process personal information, we will take reasonable steps to notify affected users.
20. Contact Us
For questions about this Privacy Policy, requests concerning your personal information or other privacy-related matters, contact:
CLIREN Centre
Clinical Research Network Centre
Matai House
Bofa Road, Off Katoa Homes
Bofa – Maweni, Kilifi, Kenya
Telephone: 0782 555 006
Email: hello@cliren.org
Website: CLIREN Centre
Learning Platform: CLIREN LMS