Legal
Privacy Policy
Effective date: 1 January 2026 |
Operator: Deep Light Media Limited |
Jurisdiction: Kenya
A note on sensitive data. The Mind Project is a mental health platform. Some visitors may share information about their mental health experiences, through forms, community spaces, or story submissions. We treat all such information with the highest level of care and confidentiality. We never share, sell, or use mental health-related personal disclosures for any purpose other than responding to you. This platform is not a clinical service and does not create a therapeutic relationship.
Legal review note: This policy was merged from your legal pack and aligned with the Kenya Data Protection Act 2019. Sections marked [PLACEHOLDER] need your confirmed analytics/newsletter/payment providers. Confirm ODPC registration, DPO appointment, and DPIA status with qualified Kenyan legal counsel before launch.
1. Who we are
The Mind Project is a dedicated African mental health storytelling and resource platform, operated by Deep Light Media Limited, a company incorporated in Kenya. Our platform is based in Nairobi, Kenya, and serves audiences across the African continent.
For the purposes of the Kenya Data Protection Act 2019 (KDPA), Deep Light Media Limited is the data controller responsible for your personal data when you use this website. Data protection queries and rights requests may be sent to our Data Protection Officer at dpo@themindproject.africa.
By using this site, submitting forms, or subscribing to communications, you also agree to our Terms and Cookie Policy where applicable.
Important: The Mind Project is not a clinical service, a crisis intervention platform, or a substitute for professional mental health care. Nothing on this platform constitutes therapy, diagnosis, or clinical advice.
Registered address: Block C, House No. C3, 825 Menelik Road, Kilimani, Nairobi, Kenya.
Postal address: P.O. Box 2079 - 00606, Nairobi, Kenya.
Email: info@themindproject.africa
Phone: +254 711 444 499
2. What data we collect
We collect personal data only when you actively provide it or when it is automatically generated by your use of this website.
Data you give us directly:
- Contact and enquiry forms: your name, email address, country, and message content.
- Story and essay submissions: your name (or chosen pseudonym), email address, bio, and the content of your submission, which may include personal mental health disclosures. See Section 4.
- Community participation: if you join our community spaces, your username and any content you post. Community spaces are moderated.
- Newsletter subscription: your email address and, optionally, your name. [PLACEHOLDER: insert newsletter platform name once confirmed]
- Donations: name, email address, and payment details processed by our payment provider. [PLACEHOLDER: insert payment processor name once confirmed]
Data collected automatically:
- Technical data including IP address, browser type, operating system, and pages visited, collected via Google Analytics 4 only if you consent. See our Cookie Policy.
- Cookies. See Section 6.
3. How we use your data
- Contact form submissions: to respond to your enquiry and route it to the right team member.
- Story submissions: to assess, edit, and publish your work; to correspond with you throughout the editorial process; and to maintain a record of published authorship.
- Community participation: to moderate discussion spaces and ensure they remain safe for all members.
- Newsletter subscriptions: to send our mental health newsletter. You may unsubscribe at any time via the link in every email.
- Donation processing: to process your contribution and send confirmation. Payment details are handled by our processor and never stored by The Mind Project.
- Analytics: to understand how our platform is used so we can improve it. We do not use analytics to identify individuals.
We do not sell your data. We do not share personal information with advertisers. We do not use your data for targeted advertising. We do not use mental health disclosures shared with us for any purpose other than the context in which they were shared. This is a structural commitment.
4. Mental health data, special category information
Under the KDPA, information about a person's physical or mental health constitutes special category data and is subject to heightened protection. When you share mental health information with us, whether in a story submission, a contact form, or community discussion, we treat it accordingly:
- Mental health disclosures shared in story submissions are accessible only to the editorial team members directly involved in your submission.
- We never reference, share, or publish personal mental health disclosures without your explicit, informed consent.
- If you choose to publish anonymously or under a pseudonym, we maintain strict separation between your real identity and your published name.
- Community moderation teams are trained in mental health-informed moderation and are bound by confidentiality obligations.
- We do not share special category data with any third party, including analytics providers, unless strictly necessary for the service you have requested and with appropriate safeguards in place.
If at any time you wish to withdraw consent for us to hold mental health information you have shared with us, contact dpo@themindproject.africa or info@themindproject.africa. Published mental health narratives are removed within 14 days of a valid withdrawal request; other data within 21 days unless law requires longer retention.
5. Data sharing
We do not sell, rent, or trade your personal data. We share data only in the following limited circumstances:
- Service providers: Third-party tools for newsletter delivery, payment processing, and website analytics. These providers act as data processors and are contractually prohibited from using your data for their own purposes.
- Legal obligation: We may disclose data if required by Kenyan law, court order, or lawful public authority request.
- Within Deep Light Media Limited: Data may be accessed by other entities in the group only where strictly necessary and relevant to your original interaction with The Mind Project. Mental health disclosures are never shared across entities without explicit consent.
- Crisis situations: In the rare event that content shared with us suggests immediate risk to life, we may take reasonable steps to connect the person with emergency services. We will always attempt to contact the person directly first.
6. Cookies and analytics
We use cookies for essential site function and, with your consent, for analytics. Full details are in our Cookie Policy. Use the Cookie settings link in the site footer to review preferences.
- Essential cookies: Required for the website to function. Cannot be disabled.
- Analytics cookies: Google Analytics 4 — used only if you consent via our cookie settings panel. No advertising cookies.
We do not use advertising cookies or third-party tracking cookies for targeted ads.
7. Data breach notification
If a personal data breach occurs that is likely to create a risk to your rights, we will notify the Office of the Data Protection Commissioner (ODPC) without undue delay and, where required, within 72 hours of becoming aware. Where the breach poses a high risk to you, we will notify affected individuals without undue delay.
8. How long we keep your data
- Contact form messages: Up to 12 months, unless an ongoing relationship requires retention.
- Unpublished story submissions: Up to 12 months from final communication, then deleted.
- Published stories and author records: Retained indefinitely for the integrity of the public record, unless removal is requested. Pseudonymous records do not contain identifying information beyond what you approved.
- Newsletter subscriber data: Retained while subscribed. Deleted within 30 days of unsubscription.
- Community participation data: Retained while you are an active member. Deleted within 30 days of account closure.
- Donation records: 7 years, as required by Kenyan financial regulations.
- Analytics data: Aggregated and anonymised; no individual data retained beyond 26 months.
- Contributor consent records: 3 years from the date of consent.
9. Your rights under the Kenya Data Protection Act 2019
- Right of access: Request a copy of the personal data we hold about you.
- Right to rectification: Request correction of inaccurate or incomplete data.
- Right to erasure: Request deletion of your personal data, subject to legal retention requirements and public interest considerations for published work.
- Right to restrict processing: Ask us to limit how we use your data.
- Right to data portability: Request your data in a machine-readable format.
- Right to object: Object to our processing of your data for direct marketing at any time.
- Right to withdraw consent: For special category data (including mental health information), withdraw consent at any time without affecting the lawfulness of prior processing.
To exercise any right, contact dpo@themindproject.africa or info@themindproject.africa. We will respond within 21 days (14 days for withdrawal of published mental health content). You may lodge a complaint with the Office of the Data Protection Commissioner of Kenya.
10. Children and young people
We recognise that mental health challenges disproportionately affect young people, and that young people may seek out this platform. Our general content is accessible to all ages. However:
- Community spaces require users to be 18 or over, or to have parental or guardian consent.
- We do not knowingly collect personal data from children under 13 without parental consent.
- Story submissions from contributors under 18 require the involvement of a parent or guardian in the editorial process.
- All content featuring or directed at young people is subject to additional editorial safeguarding review.
If you believe a child has submitted personal data without appropriate consent, contact info@themindproject.africa and we will act promptly.
11. Changes to this policy
We may update this Privacy Policy as our services develop. Material changes will be noted at the top of this page with an updated effective date, and newsletter subscribers will be notified directly. Continued use of the platform after changes constitutes acceptance of the updated policy.
12. Contact us about privacy
We aim to respond to all privacy enquiries within 5 business days.