Privacy Policy for Menyax.co

Last Updated: August 9, 2025

Table of Contents

1. Introduction

2. What Data We Collect

3. How We Collect Data About You

4. How and Why We Use Your Data

5. Who We Share Your Data With

6. Security

7. Data Retention

8. Your Rights Under Rwandan Law

9. International Data Transfers

10. Children's Privacy

11. Updates & Contact Information

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1. Introduction

Welcome to Menyax.co, a marketplace for online learning. This Privacy Policy explains how TWIKASMM Limited ("Menyax.co", "we", "us", or "our") collects, uses, shares, and protects your personal data when you visit or use our website, mobile apps, and services (the “Services”).

We are committed to processing your data in full compliance with Rwanda's Law N° 058/2021 of 13/10/2021 relating to the Protection of Personal Data and Privacy (the "DPP Law") and other applicable international standards. 1 This policy is designed to be clear and transparent, helping you understand your rights and how we use your information to provide a secure and effective learning experience. 3

By using our Services, you agree to the terms of this Privacy Policy. You shouldn’t use the Services if you don’t agree with this Privacy Policy or any other agreement that governs your use of the Services.

2. What Data We Collect

We collect different data from or about you depending on how you use the Services. "Personal data" is any information that can be used to identify you as an individual. 4 Below are some examples to help you better understand the data we collect.

2.1 Data You Provide to Us

We collect and store the data you provide directly when you create an account, purchase content, publish content, or otherwise use the Services.

Data Category	Description
Account Data	When you create or update your account, we collect and store data like your full name, email address, and password. We assign you a unique identifying number.
Profile Data	You can choose to provide profile information like a photo, headline, biography, language, website link, social media profiles, or country. Your Profile Data will be publicly viewable by others.
Shared Content	Parts of the Services let you interact with other users or share content publicly. This includes posting reviews, asking or answering questions, and sending messages to other users. This Shared Content may be publicly viewable by others depending on where it is posted.
Learning Data	When you enroll in and take courses, we collect data about your activity, including courses started and completed, your progress, quiz and assignment submissions, and certificates of completion.
Student Payment Data	When you make purchases, we collect certain data about your purchase (such as your name and ZIP code) as necessary to process your order. You must provide certain payment and billing data directly to our payment processing partners, including your name, credit card information, and billing address. For security, Menyax.co does not collect or store sensitive cardholder data, such as full credit card numbers.
Instructor Data	If you are an instructor, you can link your payment account (e.g., Mobile Money, PayPal, or bank account) to the Services to receive payments. When you link a payment account, we collect and use certain information, including your payment account email address, account ID, physical address, or other data necessary to send payments to your account. We also collect information required for tax purposes.
Communications and Support	If you contact us for support or to report a problem or concern, we collect and store your contact information, messages, and other data about you like your name, email address, location, and any other data you provide or that we collect through automated means. We use this data to respond to you and research your question or concern.

2.2 Data We Collect Automatically

When you access the Services, we collect certain data by automated means.

Data Category	Description
System Data	Technical data about your computer or device, like your IP address, device type, operating system type and version, unique device identifiers, browser, browser language, and other systems data.
Usage Data	Usage statistics about your interactions with the Services, including courses accessed, time spent on pages or the Service, pages visited, features used, your search queries, click data, date and time, and other data regarding your use of the Services.
Approximate Geographic Data	We collect your approximate geographic location, including information like country, city, and geographic coordinates, calculated based on your IP address.

For more detailed information on our automated data collection, please see our Cookie Policy.

3. How We Collect Data About You

We use tools like cookies, web beacons, and similar tracking technologies to gather the data listed above. Some of these tools offer you the ability to opt out of data collection. For more information, including how to manage your preferences, please read our Cookie Policy.

4. How and Why We Use Your Data

We use your data to do things like provide our Services, communicate with you, troubleshoot issues, secure against fraud and abuse, improve and update our Services, analyze how people use our Services, serve personalized advertising, and as required by law or necessary for safety and integrity. We only process your personal data where we have a lawful basis to do so under the DPP Law. 5

Our legal bases for processing include:

• Performance of a Contract: Much of our processing is necessary to perform our agreement with you, such as operating the platform, processing payments, and providing access to courses.

• Legitimate Interests: We process data for our legitimate interests, such as improving our Services, marketing, and ensuring security, provided these interests are not overridden by your rights.

• Your Consent: Where required by law, we will process your data based on your explicit consent, for example, for sending direct marketing communications or placing non-essential cookies. 3

• Legal Obligation: We may process your data to comply with our legal obligations, such as for financial reporting or responding to lawful requests from authorities.

5. Who We Share Your Data With

We may share your data with third parties under the following circumstances or as otherwise described in this Privacy Policy:

• With Your Instructors: We share data that we have about you with instructors for the courses you enroll in or about which you request information. This data may include your name, country, browser language, operating system, and your activity on Menyax.co. We do not share your email address with instructors. This data helps instructors improve their content and understand their student base. 7

• With Other Students and Instructors: Depending on your settings, your shared content and profile data may be publicly viewable, including to other students and instructors. If you ask a question to an instructor, your information (including your name) may also be publicly viewable.

• With Service Providers, Contractors, and Agents: We share your data with third-party companies who perform services on our behalf, like payment processing, data analysis, marketing and advertising services, email and hosting services, and customer services and support. These service providers may access your personal data and are required to use it solely as we direct, to provide our requested service. 4

• For Analytics: We use third-party analytics services like Google Analytics. They use data collection tools to help us analyze your use of the Services, including information like the third-party website you arrive from, how often you visit, and usage and performance data. We use this data to improve the Services.

• For Security and Legal Compliance: We may disclose your data to third parties if we (in our sole discretion) have a good faith belief that the disclosure is:

• Permitted or required by law;

• Requested as part of a judicial, governmental, or legal inquiry, order, or proceeding;

• Reasonably necessary to enforce our Terms of Use, this Privacy Policy, and other legal agreements;

• Required to detect, prevent, or address fraud, abuse, misuse, potential violations of law, or security or technical issues; or

• Reasonably necessary in our discretion to protect against imminent harm to the rights, property, or safety of Menyax.co, our users, employees, members of the public, or our Services.

• During a Change in Control: If Menyax.co undergoes a business transaction like a merger, acquisition, or sale of all or a portion of our assets, we may share, disclose, or transfer all of your data to the successor organization during such transition or in contemplation of a transition.

• With Your Permission: With your consent, we may share data with third parties outside the scope of this Privacy Policy.

6. Security

We use appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal data that we collect and store. 1 These measures vary based on the type and sensitivity of the data. Unfortunately, however, no system can be 100% secured, so we cannot guarantee that communications between you and Menyax.co, the Services, or any information provided to us in connection with the data we collect through the Services will be free from unauthorized access by third parties. Your password is an important part of our security system, and it is your responsibility to protect it.

7. Data Retention

We will retain your personal data for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements, or to resolve disputes. 1

8. Your Rights Under Rwandan Law

Under Rwanda's DPP Law, you have certain rights regarding your personal data. You have the right to:

• Be Informed: Receive clear and transparent information about how we process your personal data.

• Access Your Data: Request a copy of the personal data we hold about you.

• Rectify Your Data: Ask us to correct any data that you believe is inaccurate or incomplete.

• Erase Your Data: Request the deletion of your personal data, under certain legal conditions.

• Object to Processing: Object to our processing of your personal data, particularly for direct marketing.

• Restrict Processing: Ask us to limit the processing of your data under certain conditions.

• Data Portability: Request that we transfer the data we have collected to another organization, or directly to you, under certain conditions.

To exercise any of these rights, or if you have any questions about your rights, please contact us at info@menyax.co. 4

9. International Data Transfers

Menyax.co is headquartered in Rwanda, and to provide the Services, we may transfer your data to and process it in other countries. Some of our third-party service providers (like payment processors and cloud hosting services) are based outside of Rwanda. When we transfer your data internationally, we will ensure it is protected to the same high standards required by the DPP Law by using legally approved safeguards, such as standard contractual clauses. 8

10. Children's Privacy

Our Services are intended for users who are at least 16 years of age. We do not knowingly collect personal data from children under 16. If we learn that we have collected personal data from a child under 16 without the required parental consent, we will take reasonable steps to delete it as soon as possible. 1 If you believe that we may have collected data from a child under 16, please contact us at

info@menyax.co.

11. Updates & Contact Information

From time to time, we may update this Privacy Policy. If we make any material changes, we will notify you by email, through a notice on the Services, or as required by applicable law. 1 Changes will become effective on the day they are posted unless stated otherwise.

If you have any questions, concerns, or disputes regarding our Privacy Policy, please feel free to contact our privacy team at info@menyax.co or at our mailing address:

TWIKASMM Limited

KG 601 St

Kigali, Rwanda