Privacy Policy

This Privacy Policy describes how Third Party Learning Limited trading as Opportunity Activation("we", "us", "our") processes personal data when you browse opportunities, apply, register as a mobiliser, use institution portals, or interact with our Academy at oppactivation.com.

Operator: Third Party Learning Limited trading as Opportunity Activation. Registered July 2024, Nairobi. Office: Bebuda Plaza. Telephone: +254 180 193 221. Company registration number will be published when confirmed by the operator. Privacy contact: privacy@oppactivation.com.

1. Roles and platform context

Opportunity Activation is a multi-tenant opportunity and performance-mobilisation platform. We operate the platform. Partner institutions receive applications and confirm outcomes for their programmes. Mobilisers refer learners under published attribution and commission rules. Meta (Facebook, Instagram, WhatsApp) may be used as an acquisition, messaging and measurement layer — Meta is never the source of truth for admissions, verified enrolment, certification, placement or mobiliser commission.

2. Data we collect

• Identity and contact details (name, email, phone) when you apply or register
• Learner, mobiliser, institution-admin and partner account data and roles
• Opportunity preferences, applications, education/career information and uploaded documents
• Referral codes, UTM parameters, Meta click identifiers (fbclid and eligible fbc/fbp where lawful and consented), IP/device technical data and consent records
• M-Pesa / payment-provider identifiers and commission ledger records
• WhatsApp message metadata for service notifications (not application answers in templates)
• Lead Ads form submissions when you submit a Meta instant form mapped to an institution campaign

3. Purposes and lawful bases

We process data to:

• Match you to opportunities and route applications to partner institutions
• Attribute mobiliser referrals and calculate commissions after institution-confirmed outcomes
• Operate institution and admin portals and the Academy
• Send service notifications (email / SMS / WhatsApp utility messages where enabled)
• Measure marketing performance with Meta Pixel / Conversions API only after advertising consent
• Prevent fraud, secure accounts, and comply with law

Where required under the Kenya Data Protection Act 2019, we rely on consent, contractual necessity, or legitimate interests as appropriate. Advertising technologies and WhatsApp marketing messages require affirmative consent.

4. Sharing and visibility

• Partner institutions you apply to or express interest in (application routing)
• Mobilisers who referred you — limited attribution and status visibility only; not full application answers, grades, disability, financial circumstances or identity documents
• Infrastructure providers (hosting, email, payment processors)
• Meta Platforms when you use WhatsApp, Lead Ads, or consented advertising measurement
• Regulators or authorities when legally required

5. International transfers

Service providers and Meta may process data outside Kenya. We use appropriate contractual and organisational safeguards consistent with applicable law.

6. Retention

We retain application, consent, attribution and commission records for as long as needed to fulfil the purposes above, resolve disputes, meet institutional obligations and legal requirements. Exact retention periods by class are maintained in our internal retention schedule and available on request to privacy@oppactivation.com.

7. Security

We use encryption in transit (HTTPS), access controls, token encryption at rest for integration secrets, audit logging and role-based access. No method of transmission over the internet is 100% secure.

8. Automated and ranking logic

Opportunity recommendations and ranking may use profile and preference data to surface relevant programmes. You may contact us for more information about meaningful logic that significantly affects you.

9. Your rights

Depending on applicable law, you may request access, correction, deletion, restriction or portability of your data, and withdraw consent where processing is consent-based. Withdrawal of advertising consent is available via Cookie settings. Account deletion instructions: Delete account / Meta data deletion.

10. Children

The platform is directed at adults and learners eligible for listed opportunities. Where a programme admits minors, we apply age-appropriate safeguards and parental/guardian requirements as specified by the institution and applicable law.

11. Complaints

Contact privacy@oppactivation.com. You may also complain to the Office of the Data Protection Commissioner (Kenya): https://www.odpc.go.ke/.

12. Meta / advertising technologies

Meta Pixel, Conversions API audience use and Lead Ads audience matching are disabled until legal approval is recorded and you grant advertising consent. See our Cookie Notice.

13. Changes

Material changes will be notified via the site. Version: 2026-08-25. Effective date: 2026-08-25.