Privacy Policy

Version: 2026-08-01 · Effective from: 22 August 2026 · What changed

Controllers: African Wood Inc. (United States & Kenya), African Wood Limited (United Kingdom & Wales), and Dhamana Technologies Limited, acting as joint controllers for the Digital Competency Exchange.

This platform handles some of the most sensitive information a person has — passport images, a facial biometric, immunization and tuberculosis screening records. This policy says plainly what we hold, why, and what you can do about it.

What We Collect

Identity. Name, date of birth, nationality, country and city of residence, passport or national identity document, and a selfie.

Biometric data. A facial template derived from your selfie and the portrait in your identity document, used once to confirm they are the same person. This is special-category data.

Health data. Immunization records, tuberculosis screening, and any fitness-to-practise statement. This is special-category data.

Professional data. Degree and transcript, NCLEX and TruMerit results, home nursing licence, English test results, clinical experience, and professional references.

Account and technical data. Email, phone number, password hash, sign-in times, IP address, and the audit record of actions taken in the platform.

Employers and partners. Organization details, the name and title of the person signing an attestation, payment records, and payout destinations.

Why We Process It, and On What Basis

We do not use your data for advertising. We do not sell it. We do not make decisions producing legal effects about you by automated means alone — the identity check is automated, but a person reviews the outcome and a failed check never rejects you on its own.

You may withdraw consent at any time, including for the biometric check, by contacting an administrator through the portal. Withdrawal does not affect processing already carried out. Where consent is withdrawn for verification data, your profile cannot remain on the marketplace.

Who Sees What

Employers see a verified profile. Before they pay, identity is masked to initials. After they unlock a portfolio they see your name and a rendered summary of what we verified — never your underlying documents, and never a link to them. Referees' contact details are never included; a verified reference is not permission to approach the referee.

Your training or recruiting partner, where a college or agency sponsors you, sees your verification progress by phase and can open the documents in your file while that sponsorship is live — that is how they vouch for a transcript they issued. They cannot see your identity check result. Every document they open is recorded and shown to you by name, and asking us to end the sponsorship closes their access immediately, before anybody processes the request.

A law firm your employer retains for your visa or work permit sees only the document types you release to it, one type at a time, and only while its case is open. It is not your lawyer — it acts for the hospital, and you are told so before you can release anything to it. You can withdraw any release at any moment, without giving a reason, and it takes effect on the firm's next click. Documents about your family are never held here at all: you send those to the firm directly and we record only that it was asked for and that you say you sent it.

Our verification staff see your full file, and every document opened is recorded against the individual who opened it.

You can see which employers have opened your portfolio, and every document any partner or law firm has opened, at any time, in your dashboard.

What We Send You, and Where

Almost everything happens in the portal. You see what you need when you sign in, and a notice here never depends on an inbox.

We send email for seven things and no others, and the list is kept in step with the code rather than written once and left:

1. Reaching somebody who has never signed in to an account their organisation holds. 2. Reaching somebody who has stopped. 3. Telling you that something you started here is not finished. 4. Confirming that an email address belongs to whoever is using it to register. 5. Inviting somebody we have approached to create an account — a facility, a college, a law firm, or a nurse. 6. Telling an organisation its account has been opened. 7. Telling a nurse that her practice licence has lapsed and needs renewing with her own council.

The first three exist for one reason: they are the things we cannot tell you in the portal, because the portal is the thing you are not currently visiting.

The fourth is the opposite. Before anybody can create an account, we send a short code to the address they gave and they have to type it back. Nothing is created until they do. We added this because an automated account was registered here on 28 July 2026 — no harm was done, the account has been deleted, and the address it used never belonged to a person who wanted an account with us. A code sent this way signs you in to nothing, because at the point we send it there is nothing to sign in to.

The fifth is why a nurse may hear from us before she has an account. Somebody here may have met her, or been given her details by her college. The message says we invited her and carries a link that can create an account and nothing else. It holds nothing about her professional record, because at that point we hold nothing about her professional record. If it reaches the wrong person, what they can do with it is make an account in their own name, which they could already do.

The seventh is about your licence and nothing else. If the council that registered you shows your practice licence as expired, we tell you, because a facility cannot be shown a nurse whose licence is not current. Renewing it is between you and your council — we cannot do it for you and we will never ask you to pay us for it.

Once you hold an account, we write to you about your own unfinished profile and your licence, and about nothing else. The other five are about accounts, doors and addresses; none of them is about your professional record.

We will never send you a password, a sign-in code, a document, or a link that signs you in. An inbox is long-lived, widely synchronised and frequently breached; anything we put in one has to be worth nothing to whoever else reads it. If you receive a message claiming to be from us that contains any of those things, it is not from us.

We send one-time passcodes by SMS and by no other route. We keep a record of the fact that a message was sent, to whom and of what kind — never its contents.

Ask us to stop writing to an address and we will, and we keep a list of addresses we must not write to so that it stays stopped.

Processors We Use

partners. Candidates never transact, so candidates have no payment data.

and no notice from the platform reaches you by text message.

• Smile Identity — identity document reading and biometric comparison.
• Amazon Web Services — hosting, storage, and encryption key management.
• Stripe, PayPal, Pesapal — payments from employers and payouts to
• Twilio — SMS one-time passcodes. Nothing else is sent by SMS,
• Amazon Simple Email Service — the small number of emails we send.

Each is bound by a data processing agreement and acts only on our instructions.

A law firm is not one of these. A firm your employer retains decides for itself what it does with what you release — it answers to its own regulator and its own duties, not to our instructions — so it is a recipient in its own right rather than a processor acting for us. That is why the release is yours to give and yours to withdraw, rather than something we arrange on your behalf.

International Transfers

Candidate data originates largely in Kenya and is processed on infrastructure in the United States, and is disclosed to employers in the United States and Canada. Transfers out of the United Kingdom and the European Economic Area rely on the UK International Data Transfer Addendum and the European Commission's Standard Contractual Clauses. Transfers out of Kenya are made under the Data Protection Act 2019 on the basis of your consent and the contractual necessity of the placement you are seeking.

How Long We Keep It

withdrawal happened is retained for the audit trail.

employment law require.

append-only by design and is the record of what was done to your data.

• Active candidate profile — while your account is open.
• Withdrawn documents — the file is deleted immediately; the record that a
• Closed accounts — verification records for 24 months, then deletion.
• Placement contracts and financial records — 7 years, as tax and
• Immutable audit ledger — retained for the life of the platform. It is

Your Rights

You may request access to your data, correction of it, deletion of it, restriction of its processing, a portable copy of it, and you may object to processing. You may withdraw consent as described above.

To exercise any of these, contact an administrator in the portal, or write to the address in Contact below if you do not hold an account. We respond within 30 days.

You may complain to a supervisory authority: the Office of the Data Protection Commissioner in Kenya, or the Information Commissioner's Office in the United Kingdom.

Security

See Data Security.

Contact

African Wood Inc., 274 Liborio Dr., Middletown, Delaware 19709, United States | P O Box 1229-50200, Bungoma, Kenya. Data protection enquiries reach us through the portal, or by email to client.services@amakobe.com. You do not need an account with us to write to that address, and you do not need one to exercise any of the rights above — a person whose data we hold may never have signed in here at all.