Your data, plainly.
Last updated: 17 September 2026
1. Who we are
OCH Debbie (“OCH”, “we”, “us”) is Africa’s cyber career platform, operated by Ongoza Cyber Hub. Contact: hello@ongozacyberhub.com. Data Protection enquiries: privacy@ongozacyberhub.com.
2. What we collect
We collect only what the service needs to run.
- Account. Email, first/last name, country, timezone, phone (only if you pair WhatsApp), authentication state.
- Profile. Your track choice, intent, time budget, focus question, energy state — the answers from onboarding plus what you write in the coach.
- Usage. Drills attempted, scores, streaks, milestones, credentials issued, last-active timestamps.
- AI conversations. Your messages to Debbie and her responses. Used to personalize coaching and improve safety guardrails. Not used to train external models.
- Payments. We do NOT see or store your card number or M-Pesa PIN. Paystack processes payment and shares only the transaction outcome, last 4 digits of the card, and the customer code.
- Technical. IP address (for abuse detection and geographic personalization), user agent, error reports, performance metrics. No tracking pixels from ad networks.
3. Why we collect it (lawful bases)
- Contract. Account + profile + usage are required to deliver the coaching service you signed up for.
- Legitimate interest. Technical telemetry and security logs, to keep the service running and to detect abuse.
- Consent. WhatsApp pairing, optional product-update emails. You can revoke at any time from /settings.
- Legal obligation. Tax records, payment receipts, regulator subpoenas if we receive them under Kenyan / Nigerian / South African law.
4. Sub-processors
These companies process your data on our behalf. We choose them for reputation and DPAs; we do not sell your data to anyone.
- Clerk — authentication (US-hosted; SOC 2)
- Neon — Postgres database (US-hosted)
- Vercel — application hosting (US-hosted; SOC 2)
- Anthropic — the Claude model that powers Debbie (US-hosted; messages are processed but not used for model training per Anthropic’s commercial terms)
- Paystack — payments (PCI-DSS Level 1)
- Resend — transactional email
- Twilio — WhatsApp messaging (when WhatsApp pairing is active)
- Sentry — error monitoring (PII-scrubbed; session replays only with your consent)
- PostHog — product analytics, only with your consent (EU-hosted)
- Microsoft — Teams meetings and webinars for live sessions you register for (your name and email are shared to issue your join link)
- GitHub — only if you choose to connect your GitHub account to the Strategist
5. Data residency
Our database and application servers are hosted in the United States. For users in Nigeria, South Africa, and Kenya, this means your personal data crosses a border to reach us. We rely on the standard contractual safeguards (model clauses, sub-processor DPAs) but you have the right to know.
If you require Africa-resident storage (some employers do), email privacy@ongozacyberhub.com — we’re evaluating an Africa region for 2027.
6. Retention
We keep your data for as long as your account is active. When you delete your account from /settings, we hard-delete your profile, usage, and AI conversations within 30 days. Payment receipts are retained for 7 years for tax compliance.
7. Your rights
Under NDPR, POPIA, DPA Kenya, and GDPR, you have the right to:
- Access the data we hold about you
- Correct anything that is wrong
- Delete your account and all associated personal data
- Export your data in machine-readable form
- Object to specific processing (e.g. analytics)
- Lodge a complaint with your local regulator (NDPC in Nigeria; Information Regulator in South Africa; ODPC in Kenya)
Most of these are self-service from /settings. Anything you can’t do yourself, email privacy@ongozacyberhub.com — we respond within 7 working days.
8. Children
OCH accounts are for people aged 18 and older, and everyone confirms their age when they sign up. We do not knowingly collect data from anyone under 18. If you believe a minor has created an account, email us and we will close it and delete its data.
9. Cookies + similar
10. Security
All traffic is TLS-encrypted. Passwords are hashed by Clerk (we never see them). Payment details are tokenized by Paystack (we never see them). We follow least-privilege access internally; only engineers on-call can query the production database, and queries are logged.
If you discover a security vulnerability, please email security@ongozacyberhub.com rather than disclosing publicly. We do not yet have a paid bug bounty but we acknowledge every reporter.
11. Changes to this policy
We update this page when our practices change. The “Last updated” date at the top reflects the latest revision. Material changes (new sub-processor, new data category, change of legal entity) are emailed to all active users at least 14 days before they take effect.
12. Contact
Data Protection Officer: privacy@ongozacyberhub.com
General enquiries: hello@ongozacyberhub.com