List of active policies

Full policy

1. Who these terms are between

These Terms of Service ("Terms") are a binding agreement between you 
("you", "the user") and Wirfon Group Investments Ltd, a company 
registered in Rwanda ("we", "us", "our"), the operator of WirfonCloud 
Academy at academy.wirfoncloud.com (the "Platform").

By creating an account or accessing the Platform, you confirm that you 
have read, understood, and agreed to these Terms and to our Privacy 
Policy. If you do not agree, please do not use the Platform.

2. Eligibility

You may use the Platform if:

  - You are at least 16 years old, or you have verifiable consent from a 
    parent or guardian if your country's age of digital consent is lower 
    and you are above that age.
  - You are not barred from receiving online education services under 
    the laws of your country of residence or the laws of Rwanda.
  - The information you provide during registration is true, accurate, 
    and current.

3. Your account

  - You are responsible for keeping your password confidential.
  - You are responsible for all activity that occurs under your account.
  - You must notify us promptly at info@wirfoncloud.com if you suspect 
    that your account has been compromised.
  - One person, one account. You may not share your account with others 
    or create multiple accounts to evade restrictions.
  - We may suspend or terminate your account if you violate these Terms.

4. Acceptable use

You agree NOT to use the Platform to:

  - Post, upload, or share content that is unlawful, defamatory, 
    obscene, hateful, threatening, harassing, or that infringes any 
    third party's rights.
  - Impersonate any person or organisation, or misrepresent your 
    affiliation with any person or organisation.
  - Cheat, plagiarise, share answer keys, or otherwise undermine the 
    academic integrity of courses and assessments.
  - Distribute malware, attempt to gain unauthorised access to the 
    Platform or its underlying systems, perform any form of penetration 
    testing without our written permission, or interfere with the 
    Platform's normal operation.
  - Use automated tools (bots, scrapers, crawlers) to collect data from 
    the Platform without our written permission, except for the 
    standard indexing performed by major search engines.
  - Send unsolicited bulk messages, spam, or chain letters through any 
    Platform feature (forums, messaging, email).
  - Resell, sublicense, or commercially exploit the Platform or its 
    content without our written permission.
  - Violate any applicable law or regulation.

5. Course content and intellectual property

  - All course content provided by us — including text, video, images, 
    quizzes, and downloadable materials — is owned by Wirfon Group 
    Investments Ltd or its licensors and is protected by copyright and 
    other intellectual property laws.
  - You are granted a personal, non-exclusive, non-transferable, 
    revocable licence to access and use that content for your own 
    learning. You may not redistribute, republish, sell, or create 
    derivative works without our written permission.
  - Content you upload (assignments, forum posts, messages, profile 
    information) remains yours. By uploading it you grant us a 
    worldwide, royalty-free licence to host, display, and process it 
    solely for the purpose of operating the Platform.
  - You are responsible for ensuring that content you upload does not 
    infringe anyone else's rights.

6. Free service in Phase 1

The Platform is provided free of charge during the current pilot phase. 
We may in the future introduce paid courses, paid features, or paid 
plans. If we do, we will give you advance notice and these Terms will 
be updated to cover any new commercial arrangements. No paid features 
exist on the Platform at this time.

7. Email and notifications

By creating an account, you consent to receive transactional emails 
from us — account verification, password resets, course-related 
notifications, and operational announcements. You may not opt out of 
transactional emails while your account is active, because they are 
necessary for the service to function. You may opt out of optional 
email types (such as newsletters or summary digests) through your 
account preferences.

8. Availability and changes

  - We aim to keep the Platform available at all times, but we do not 
    guarantee uninterrupted availability. The Platform may be 
    unavailable from time to time for planned maintenance, unplanned 
    incidents, or events outside our control.
  - We may change, add, or remove features at any time. We may also 
    discontinue the Platform with reasonable notice.
  - We may update these Terms from time to time. When we do, the 
    version number changes and you will be asked to accept the new 
    version on your next login. Continued use of the Platform after a 
    revision constitutes acceptance of the revised Terms.

9. Suspension and termination

  - You may close your account at any time by emailing 
    info@wirfoncloud.com.
  - We may suspend or terminate your account, with or without notice, 
    if we reasonably believe that you have violated these Terms, that 
    your account has been compromised, or that your continued use of 
    the Platform poses a risk to other users or to the Platform itself.
  - On termination, your right to use the Platform ends immediately. 
    Provisions of these Terms that by their nature should survive 
    termination — including intellectual property, disclaimers, and 
    limitation of liability — will survive.

10. Disclaimer of warranties

The Platform is provided "as is" and "as available". To the maximum 
extent permitted by law, we disclaim all warranties, express or 
implied, including warranties of merchantability, fitness for a 
particular purpose, non-infringement, and accuracy of content. We do 
not warrant that the Platform will be uninterrupted, error-free, or 
free of harmful components, or that any defects will be corrected.

11. Limitation of liability

To the maximum extent permitted by law, Wirfon Group Investments Ltd, 
its directors, employees, and affiliates will not be liable for any 
indirect, incidental, special, consequential, or punitive damages, or 
for any loss of data, profits, revenue, or goodwill, arising out of 
or in connection with your use of the Platform — even if we have been 
advised of the possibility of such damages.

Nothing in this section limits liability that cannot be limited under 
applicable law, including liability for gross negligence, wilful 
misconduct, or death or personal injury caused by negligence.

12. Indemnification

You agree to indemnify and hold harmless Wirfon Group Investments Ltd 
from any claim, demand, loss, or expense (including reasonable legal 
fees) arising from your violation of these Terms, your misuse of the 
Platform, or your infringement of any third party's rights.

13. Governing law and disputes

These Terms are governed by the laws of Rwanda, without regard to 
conflict-of-laws principles. Any dispute arising from or related to 
these Terms or the Platform will be submitted to the competent courts 
of Kigali, Rwanda, except where mandatory consumer-protection laws of 
your country of residence give you the right to bring proceedings in 
your local courts.

14. Severability

If any provision of these Terms is found unenforceable, the remaining 
provisions remain in full force and effect, and the unenforceable 
provision will be replaced by an enforceable provision that most 
closely matches the original intent.

15. Contact

Wirfon Group Investments Ltd
info@wirfoncloud.com
academy.wirfoncloud.com

Full policy

1. Who we are

WirfonCloud Academy - part of wirfonCloud - is an online learning platform operated by Wirfon Group 
Investments Ltd, a company registered in Rwanda ("we", "us", "our"). 
We are the data controller for personal data processed through 
academy.wirfoncloud.com.

Contact for any privacy matter: info@wirfoncloud.com

2. What personal data we collect

When you register and use this site, we collect:

  - Account information: full name, email address, and the password you 
    choose (stored as a one-way hash, never in plain text).
  - Profile information you choose to provide: country, city, profile 
    picture, description, language preference, timezone.
  - Course activity: courses you enrol in, content you view, quiz attempts 
    and scores, assignments you submit, forum posts, messages you send, 
    and grades you receive.
  - Technical information: IP address, browser type, operating system, and 
    pages visited, recorded in server access logs.
  - Communication preferences: which email notifications you have chosen 
    to receive.

3. Why we collect it (legal basis)

We process this data on the following legal bases:

  - Performance of a contract: to deliver the courses you have enrolled in.
  - Legitimate interest: to keep the platform secure, prevent abuse, and 
    improve the service.
  - Consent: where you have explicitly opted in, such as receiving 
    optional newsletters or notifications. You can withdraw consent at 
    any time.
  - Legal obligation: where we must retain records to comply with 
    Rwandan law or a lawful request from a regulator.

4. Where your data is stored

Your data is stored on Amazon Web Services infrastructure in the eu-west-1 
region (Dublin, Ireland). Because our users may be located anywhere in the 
world, your personal data may be transferred from your country to Ireland 
and processed there. The European Union's General Data Protection 
Regulation (GDPR) governs that processing and provides a comprehensive 
framework of protections, including the rights described in section 8 of 
this policy. Amazon Web Services Ireland Limited operates under those 
rules and under the AWS Data Processing Addendum, which we have accepted 
on your behalf.

We use the following AWS services to handle your data:
  - Amazon RDS for PostgreSQL — course, account, and activity data
  - Amazon EFS — uploaded files (assignments, course materials)
  - Amazon ElastiCache — temporary session data
  - Amazon SES — outbound transactional email
  - Amazon CloudWatch Logs — server logs (retained 30 days)
  - Amazon CloudTrail — administrative audit logs

5. How we protect your data

  - All connections to the site use HTTPS with TLS 1.2 or higher.
  - All stored data is encrypted at rest using AWS-managed encryption keys.
  - Database connections are forced to TLS.
  - Administrative access is via AWS Systems Manager Session Manager 
    (no SSH, no shared passwords).
  - Passwords are hashed with a one-way function and never visible to 
    administrators.
  - The site is fronted by Amazon CloudFront, which provides DDoS 
    protection at the network edge.
  - We follow the security baseline defined in our internal Phase 1 
    requirements document.

6. How long we keep it

  - Active account data: for as long as your account exists.
  - Course activity (grades, submissions): for as long as your account 
    exists, plus 12 months after deletion for academic record purposes.
  - Server access logs: 30 days.
  - Audit logs (CloudTrail): 90 days, then automatically deleted.
  - Backups: 7 days rolling, then automatically expired.

If you ask us to delete your account, we delete your personal data within 
30 days, except where we are legally required to retain a record.

7. Who we share your data with

We do not sell your personal data. We share it only with:

  - Amazon Web Services Ireland Limited, our infrastructure provider, 
    under the AWS Data Processing Addendum.
  - Regulators or law-enforcement bodies in Rwanda, Ireland, or your 
    country of residence, when legally compelled.

We do not use advertising networks, social-media tracking, or analytics 
services that share data with third parties.

8. Your rights

You have the right to:

  - Access the personal data we hold about you.
  - Correct data that is inaccurate.
  - Delete your account and personal data ("right to be forgotten"), 
    subject to legal retention requirements.
  - Export your data in a portable format.
  - Object to specific processing activities.
  - Lodge a complaint with a data-protection supervisory authority. If you 
    are in Rwanda, this is the National Cyber Security Authority (NCSA), 
    which oversees data protection under Law No. 058/2021. If you are in 
    the European Union, the European Economic Area, or the United Kingdom, 
    you may complain to the data-protection authority in your country of 
    residence (for example, the Data Protection Commission in Ireland or 
    the ICO in the United Kingdom). If you are elsewhere, you may complain 
    to the equivalent authority in your jurisdiction.

To exercise any of these rights, email info@wirfoncloud.com. We will 
respond within 30 days.

9. Cookies and similar technologies

We use only essential cookies:

  - A session cookie that keeps you logged in.
  - A security cookie that protects against cross-site request forgery.

We do not use advertising or tracking cookies.

10. Children

This platform is not directed at children under 16. We do not knowingly 
collect personal data from children under 16 without verifiable parental 
consent. Some countries set a lower age of digital consent (for example, 
13 in the United States under COPPA, or 13-15 in several EU member states 
under GDPR Article 8). If you are below the age of digital consent in 
your country, please do not create an account without the permission of 
a parent or guardian. If we become aware that we have collected personal 
data from a child without appropriate consent, we will delete that data 
promptly.

11. Changes to this policy

We may update this policy from time to time. When we do, the version 
number changes and all users are asked to review and accept the new 
version on their next login. The current version and date are shown at 
the top of this document.

12. Contact

Wirfon Group Investments Ltd
info@wirfoncloud.com
academy.wirfoncloud.com