Privacy Policy

Learn about our privacy practices and how we handle your data.

Last updated: July 23, 2026

This Privacy Policy describes how Iperlinks ("Company," "We," "Us," or "Our") collects, uses, discloses, and protects information when Schools, School Administrators, Teachers, Students, Parents/Guardians, and visitors ("You," "User") use MenjiApp (the "Service" or "Platform").

By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy. If You are a School or Institution enrolling Students on the Platform, this Policy works together with any Data Processing Agreement or institutional subscription agreement in place between the Company and the School.

Interpretation and Definitions

Interpretation

Words with an initial capital letter have the meanings defined below, whether they appear in the singular or plural.

Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for a School, School Administrator, Teacher, Parent, or Student to access the Service.
  • Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest, or voting securities.
  • Application refers to [Application Name], the software provided by the Company (desktop, web, or mobile).
  • Company (referred to as "the Company," "We," "Us," or "Our") refers to Iperlinks, Kinshasa, Democratic Republic of the Congo.
  • Cookies are small files placed on Your device by a website, storing details of Your browsing activity among other uses.
  • Country refers to: Democratic Republic of the Congo.
  • Device means any device that can access the Service, such as a computer, phone, or tablet.
  • Institution / School means the educational organization that has subscribed to the Service and on whose behalf School Administrators, Teachers, Parents, and Students operate Accounts.
  • Parent means a parent or legal guardian of a Student who has been granted access to the Service.
  • Personal Data (or "Personal Information") is any information relating to an identified or identifiable individual. We use "Personal Data" and "Personal Information" interchangeably unless a specific law requires a distinct term.
  • School Administrator means a User authorized by an Institution to manage that Institution's data, Users, and configuration on the Platform.
  • Service refers to the Application and/or the Website.
  • Service Provider means any natural or legal person who processes data on behalf of the Company, including third-party companies engaged to facilitate the Service, provide it on Our behalf, perform Service-related functions, or assist Us in analyzing Service usage.
  • Student means a learner enrolled by a School whose academic and profile data is processed through the Service.
  • Teacher means a User authorized by an Institution to manage classes, attendance, grading, or communication features.
  • Usage Data refers to data collected automatically, either generated by use of the Service or from the Service infrastructure itself (e.g., duration of a page visit).
  • Website refers to MenjiApp, accessible from https://menjiapp.com.
  • You means the individual accessing the Service, or the School or other legal entity on whose behalf that individual is acting, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using the Service, We may ask You, or the Institution on Your behalf, to provide certain personally identifiable information, including but not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Address, Country, State, Province, ZIP/Postal code, City
  • Social media profile information, when You choose to register or sign in using a third-party account (e.g., "Continue with Facebook," "Sign in with Google" or similar single sign-on options). Depending on the provider and Your privacy settings, this may include Your name, email address, and public profile photo.

Student and School Records

Because the Service is used to operate a School's academic and administrative functions, We may also process, on behalf of and at the direction of the Institution:

  • Enrollment information (grade/class, section, academic year, guardian relationships)
  • Attendance records
  • Academic performance data (grades, assignments, report cards)
  • Billing and fee-payment records related to school fees processed through the Platform
  • Communications exchanged through in-Platform messaging between School staff, Teachers, and Parents

Institutions are responsible for ensuring they have a lawful basis (such as consent, legitimate educational interest, or a legal obligation) for submitting Student and Parent Personal Data to the Service, and for responding to data subject requests from Parents or Students where the Institution is the data controller. The Company acts as a data processor / service provider with respect to Student data submitted by Institutions, except where this Policy states otherwise.

Usage Data

Usage Data is collected automatically when using the Service, and may include Your Device's IP address, browser type and version, the pages of the Service You visit, the time and date of Your visit, time spent on those pages, unique device identifiers, and other diagnostic data. When accessing the Service via a mobile device, We may similarly collect the type of mobile device, its unique ID, mobile operating system, and mobile browser type.

Information Collected While Using the Application

While using the Application, in order to provide certain features, We may collect, with Your prior permission:

  • Information regarding Your location
  • Information from Your Device's phone book (contacts list)
  • Pictures and other information from Your Device's camera and photo library

You can enable or disable access to this information at any time through Your Device settings.

Tracking Technologies, Cookies, and Similar Technologies

We use Cookies and similar tracking technologies (beacons, tags, scripts) to operate, secure, and improve the Service, and, where applicable, to support advertising and remarketing described below.

  • Cookies or Browser Cookies. You can instruct Your browser to refuse all Cookies or indicate when a Cookie is sent. Some parts of the Service may not function properly without Cookies.
  • Web Beacons. Certain sections of the Service and Our emails may contain small electronic files (clear gifs, pixel tags, single-pixel gifs) that let the Company count visitors to a page or recipients who opened an email.

Cookies may be "Persistent" (remain until deleted or expiry) or "Session" (deleted when You close Your browser).

Where required by law, We use non-essential cookies (analytics, advertising, and remarketing cookies) only with Your consent, obtained through Our cookie consent tool. You may withdraw or change Your consent at any time; withdrawal does not affect the lawfulness of processing carried out before withdrawal.

We use Cookies for the following purposes:

  • Necessary / Essential Cookies (Session) — administered by Us; required to authenticate Users, maintain session state, and prevent fraudulent use of accounts.
  • Cookies Policy / Notice Acceptance Cookies (Persistent) — administered by Us; record whether a User has accepted the use of cookies.
  • Functionality Cookies (Persistent) — administered by Us; remember login details, language, or role-based preferences (e.g., which School an Administrator last accessed).
  • Analytics Cookies (Persistent/Session) — administered by Us and Our analytics providers (see "Analytics" below); measure how the Service is used to help Us improve it.
  • Advertising & Remarketing Cookies (Persistent) — administered by Us and Our advertising partners (see "Advertising" and "Remarketing" below); used only in connection with free-tier accounts as described below.

Analytics

We use Google Analytics, and may use similar analytics tools, to monitor and analyze use of the Service. Google Analytics collects information such as how often Users use the Service, what features they use, and aggregated usage patterns, and may use this data to contextualize and personalize its own advertising network. You can opt out of Google Analytics by installing the Google Analytics opt-out browser add-on, and can learn more about Google's privacy practices at the Google Privacy & Terms site.

Email Communications

We send Users transactional emails necessary for the Service (e.g., account verification, password resets, billing receipts, attendance/grade notifications configured by a School). Separately, Users may opt in to receive marketing emails from Us, such as product updates, tips, or promotional offers. You can unsubscribe from marketing emails at any time using the unsubscribe link included in each email, or by contacting Us directly; this will not affect transactional emails required for the operation of Your Account.

Advertising

Users on a free subscription tier may be shown advertisements within the Service. Users on paid subscription tiers do not see advertisements. Advertisements shown to free-tier Users may be based on Usage Data and, where permitted and consented to, interest-based advertising data collected through the tracking technologies described above. We do not use Student accounts, or any data collected from Students under this Policy, to serve advertising — advertising is limited to adult, non-Student Account types (e.g., School Administrators or independent adult Users on a free tier), consistent with Our commitment described in "Children's Privacy" below.

Remarketing

We use remarketing services (such as Google Ads remarketing and/or Meta/Facebook remarketing pixels) to advertise the Service on third-party websites to Users who previously visited the Service, where such Users are eligible to be shown advertising under this Policy. Remarketing relies on Cookies to serve ads based on past visits. You can opt out of Google's use of Cookies for interest-based advertising by visiting Google Ads Settings, and can generally manage interest-based ads across providers through the Network Advertising Initiative opt-out page or the Digital Advertising Alliance opt-out page.

Invisible reCAPTCHA

To protect the Service from spam, bots, and abuse, We use Google's Invisible reCAPTCHA. reCAPTCHA collects hardware and software information, such as device and application data, and sends it to Google for analysis; this occurs in the background as part of Our security measures. Use of reCAPTCHA is subject to the Google Privacy Policy and Google Terms of Service.

Payments

Paid subscriptions are processed through third-party payment processors (e.g., [Payment Processor Name]). We do not store full payment card numbers on Our servers; payment processors collect and process the payment information necessary to complete Your transaction in accordance with their own privacy policies and applicable card-industry security standards (PCI-DSS).

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain the Service, including monitoring usage and operating multi-tenant School environments securely and separately from one another.
  • To manage Your Account: to manage Your registration and the role-based access (Superadmin, School Administrator, Teacher, Parent, Student) associated with Your Account.
  • For the performance of a contract: the subscription agreement between the Institution and the Company, or any purchase You make through the Service.
  • To contact You: by email, phone, SMS, or push notification, regarding updates, security notices, attendance/grade alerts, or informative communications related to the Service.
  • To send marketing communications: where You have opted in, to provide news, offers, and information about goods or services similar to those You already use.
  • To manage Your requests: to attend to and manage requests You submit to Us.
  • To serve advertising to free-tier, non-Student Accounts, and to operate remarketing campaigns, as described above.
  • For business transfers: to evaluate or conduct a merger, divestiture, restructuring, or sale of assets involving Personal Data.
  • For other purposes: data analysis, identifying usage trends, evaluating the effectiveness of promotional campaigns, and improving the Service.

We may share Your Personal Data in the following situations:

  • With Service Providers: to monitor and analyze use of the Service, process payments, send communications, or provide customer support.
  • For business transfers: in connection with a merger, asset sale, financing, or acquisition.
  • With Affiliates: who will be required to honor this Privacy Policy.
  • With business partners: to offer certain products, services, or promotions.
  • Within the same Institution: Student data may be visible to authorized Teachers, School Administrators, and Parents linked to that Student, as configured by the Institution's use of the Platform.
  • With other Users: if the Service offers public or shared areas, information shared there may be visible to other authorized Users of that School.
  • With Your consent: for any other purpose disclosed to and agreed to by You.

We do not sell Student Personal Data, and We do not share Student Personal Data with advertisers or data brokers.

Retention of Your Personal Data

The Company retains Personal Data only as long as necessary for the purposes set out in this Policy, to comply with legal obligations, resolve disputes, and enforce Our agreements. Where possible, We apply shorter retention periods and reduce identifiability through deletion, aggregation, or anonymization. Unless stated otherwise, periods below are maximums ("up to"):

  • Account Information — User Accounts: retained for the duration of the account relationship, plus up to 24 months after closure.
  • Student and School Records — retained for the duration of the Institution's subscription and enrollment period, plus any additional period required by the Institution's applicable education record-retention laws, after which data is deleted or returned to the Institution per the subscription/data processing agreement.
  • Customer Support Data — support tickets and chat transcripts: up to 24 months from closure.
  • Usage Data — analytics data, application usage statistics, and server logs: up to 24 months from collection.

We may retain data beyond these periods where required by law, to establish or defend legal claims, at Your explicit request, or due to technical backup limitations, as described further in this Policy.

Transfer of Your Personal Data

Your information may be processed at the Company's operating offices and other locations where Our processing partners are located, which may be outside Your country. Where required by law, We ensure appropriate safeguards (such as Standard Contractual Clauses) are in place for international transfers, and no transfer takes place unless adequate controls exist to protect Your data.

Delete Your Personal Data

You have the right to delete, or request Our assistance in deleting, the Personal Data We have collected about You, subject to the note below regarding School-managed Student data. You may update or delete certain information directly within Your Account settings, or contact Us to request access, correction, or deletion. For Student data, requests should generally be directed first to the Student's Institution, which acts as the data controller for that data; We will support the Institution in fulfilling such requests. We may need to retain certain information where We have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

  • Business Transactions: in a merger, acquisition, or asset sale, Your Personal Data may be transferred; We will provide notice before it becomes subject to a different Privacy Policy.
  • Law Enforcement: We may disclose Personal Data if required by law or in response to valid requests by public authorities.
  • Other Legal Requirements: to comply with a legal obligation, protect Our rights or property, investigate wrongdoing, protect the safety of Users or the public, or defend against legal liability.

Security of Your Personal Data

We use commercially reasonable technical and organizational measures to protect Your Personal Data, including tenant-level data isolation between Schools, encryption in transit, and access controls based on User role. However, no method of transmission or storage is 100% secure, and We cannot guarantee absolute security.

Detailed Information on the Processing of Your Personal Data

Service Providers We use may have access to Your Personal Data. These vendors collect, store, use, process, and transfer information in accordance with their own privacy policies. Examples may include:

  • Google Analytics — usage analytics (see "Analytics" above).
  • Google reCAPTCHA — spam and bot protection (see "Invisible reCAPTCHA" above).
  • [Payment Processor Name] — payment processing for paid subscriptions.
  • [Email Delivery Provider] — transactional and marketing email delivery.
  • [Customer Support Tool] — customer support ticketing.

Children's Privacy and COPPA Compliance

We recognize that the Service is used within Schools and may process Personal Data belonging to children under the age of 13, as well as Students under other applicable local ages of digital consent (e.g., 16 under GDPR unless a Member State sets a lower age).

  • Purpose limitation. Where We process Personal Data of a child under 13, We do so solely for internal system management, administrative, and statistical purposes necessary to operate the Service on behalf of the enrolling School (e.g., attendance, grading, class assignment, reporting). We do not use children's Personal Data for advertising, do not build advertising profiles from it, and do not sell or share it with third parties for marketing purposes.
  • School consent mechanism. Where a School or Institution submits a Student's Personal Data to the Service to support the School's educational mission, We rely on the School to obtain any necessary parental consent or to act under an applicable "school official" exception recognized under laws such as COPPA, and We enter into appropriate data processing terms with the Institution to that effect.
  • Parental rights. Parents or legal guardians who are aware their child has provided Us with Personal Data outside the School enrollment context, or who wish to review, correct, or request deletion of their child's Personal Data, may contact Us or their child's School directly. If We learn We have collected a child's Personal Data without appropriate School authorization or parental consent, We will take steps to remove that information from Our servers.
  • No behavioral advertising to minors. Consistent with the "Advertising" section above, Student and other minor Accounts are never shown interest-based or remarketing advertisements.

GDPR Compliance (European Economic Area, UK, and Switzerland)

Where the GDPR or UK GDPR applies to Our processing of Your Personal Data, the following additional provisions apply:

Data Controller and Processor Roles

For Personal Data relating to School Administrators, Teachers, and independent adult Users, the Company generally acts as the data controller. For Student and Parent Personal Data submitted by an Institution, the Company generally acts as a data processor, and the Institution acts as the data controller, under the terms of the applicable subscription or data processing agreement.

Legal Bases for Processing

We process Personal Data on one or more of the following legal bases:

  • Consent — for example, for marketing emails or non-essential cookies.
  • Performance of a contract — to provide the Service under Our Terms or a School's subscription agreement.
  • Legitimate interests — for example, to secure the Service, prevent fraud, or improve Our product, balanced against Your rights and interests.
  • Legal obligation — for example, retaining certain financial records.

Your Data Protection Rights

Subject to applicable conditions and exceptions, You have the right to:

  • Access the Personal Data We hold about You.
  • Rectify inaccurate or incomplete Personal Data.
  • Erase Your Personal Data ("right to be forgotten").
  • Restrict or object to certain processing, including processing based on legitimate interests or for direct marketing.
  • Data portability — receive Your Personal Data in a structured, commonly used, machine-readable format.
  • Withdraw consent at any time, without affecting the lawfulness of prior processing.
  • Lodge a complaint with Your local data protection supervisory authority.

Where the Company acts as a processor for Student/Parent data, these requests are generally directed to and fulfilled through the Institution, with Our support.

International Transfers

Where Personal Data is transferred outside the EEA/UK, We rely on adequacy decisions or appropriate safeguards such as the European Commission's Standard Contractual Clauses (or the UK's International Data Transfer Addendum), as applicable.

Contact

Questions about GDPR compliance, or requests to exercise the rights above, can be directed to Our contact details below, or to Our Data Protection Officer at [DPO Contact Email], if designated.

California Privacy Rights — CCPA and CPRA

If You are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), gives You additional rights described below. These rights apply to Personal Information the Company controls; where the Company processes Student or School data solely as a "service provider" on behalf of an Institution, the Institution remains responsible for responding to CCPA requests concerning that data, and We will assist as required by Our data processing terms.

Categories of Personal Information We Collect

In the preceding 12 months, We may have collected the following categories of Personal Information, as defined under the CCPA: identifiers (name, email, phone, address, online identifiers); customer records information (billing details); commercial information (subscription and purchase history); internet or other electronic network activity (Usage Data, cookies); geolocation data (where enabled); professional or education-related information (School role, class/enrollment data, for Students and staff); and inferences drawn from the above to create a profile reflecting preferences, for Users eligible to receive advertising.

We do not knowingly collect or process "sensitive personal information," as defined under the CPRA, beyond what is reasonably necessary to provide the Service (such as precise geolocation, where you enable it, and account log-in credentials).

Your CCPA/CPRA Rights

  • Right to Know — what Personal Information We have collected, used, disclosed, or sold/shared about You, and the categories of sources, purposes, and third parties involved.
  • Right to Delete — request deletion of Personal Information We have collected from You, subject to certain exceptions.
  • Right to Correct — request correction of inaccurate Personal Information.
  • Right to Opt-Out of Sale/Sharing — We do not "sell" Personal Information for money. To the extent Our use of advertising/remarketing cookies for free-tier, non-Student Accounts constitutes "sharing" for cross-context behavioral advertising under the CPRA, You may opt out using Our cookie preference tool or by contacting Us, and via the "Do Not Sell or Share My Personal Information" mechanism described below.
  • Right to Limit Use of Sensitive Personal Information — where applicable to any sensitive categories We process.
  • Right to Non-Discrimination — We will not deny, charge different prices for, or provide a different level of service because You exercised a CCPA/CPRA right.

Do Not Sell or Share My Personal Information

We do not sell Personal Information. To opt out of any "sharing" for cross-context behavioral advertising associated with free-tier advertising or remarketing cookies, You can use Our cookie consent tool, adjust Your browser settings, or contact Us using the details below. We do not sell or share the Personal Information of consumers we know are under 16 years of age.

Exercising Your Rights / Authorized Agents

You may submit a verifiable consumer request by contacting Us using the details in "Contact Us" below. You may designate an authorized agent to make a request on Your behalf, subject to Our ability to verify the agent's authority and Your identity.

Shine the Light

California residents may separately request information about disclosures of Personal Information to third parties for their own direct marketing purposes, once per calendar year, free of charge, by contacting Us.

CalOPPA Compliance

Consistent with the California Online Privacy Protection Act (CalOPPA):

  • Any individual or entity may visit Our site anonymously to review this Privacy Policy, before creating an Account or providing any Personal Data.
  • This Privacy Policy's URL is included in Our footer, and on any page where Personal Data may be requested.
  • Users will be notified of material changes to this Privacy Policy via email and/or a prominent notice on the Service, at least [X] days before such changes take effect, and by updating the "Last updated" date above.
  • Users may change their Personal Data by emailing Us at [Contact Email] or through their Account settings.
  • Do Not Track: We currently do not respond to Do Not Track ("DNT") browser signals, as no uniform industry standard for DNT has been adopted. You can control tracking through the cookie and advertising opt-outs described elsewhere in this Policy.
  • Third parties that may collect Personally Identifiable Information about a User's online activities over time and across different websites when using the Service are limited to Our disclosed analytics, advertising, remarketing, and security Service Providers described above.

Links to Other Websites

The Service may contain links to other websites not operated by Us. If You click a third-party link, You will be directed to that party's site. We advise You to review the Privacy Policy of every site You visit; We have no control over and assume no responsibility for third-party content, policies, or practices.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will notify You via email and/or a prominent notice on the Service prior to a material change taking effect, and update the "Last updated" date above. You are advised to review this Privacy Policy periodically.

Contact Us

If You have questions about this Privacy Policy, You can contact Us:

  • By email: info.menjiapp@gmail.com

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