Terms and Conditions

Mtoto Afya Digital Wallet/Tool Terms and Conditions

Effective Date: 19th August 2026 · Last Updated: August 2026

1. Introduction

Welcome to the Mtoto Afya Digital Wallet/Tool ("Mtoto Afya", "the Tool", "we", "us" or "our").

Mtoto Afya is a digital child-health information and monitoring tool developed by Tiny Totos [insert legal entity name], in collaboration with and/or for use with relevant public-health stakeholders, including the Nairobi City County Government (NCCG) and, where applicable, the Ministry of Health (MoH).

The Tool is designed to support authorised Community Health Promoters ("CHPs"), programme personnel and other approved users in registering children and recording and monitoring information relevant to child health and continuity of care.

These Terms and Conditions govern access to and use of Mtoto Afya.

By accessing or using Mtoto Afya, an authorised user confirms that they have read, understood and agree to comply with these Terms, the Mtoto Afya Privacy Policy, applicable professional obligations and applicable Kenyan law.

Where a parent or guardian provides information about a child through or for purposes of Mtoto Afya, these Terms should be read together with the Privacy Policy and the applicable parent/guardian privacy notice and consent process.

2. Purpose of Mtoto Afya

Mtoto Afya is intended to improve visibility of children's health needs, particularly children who may otherwise be missed through conventional household-based community-health visits.

Depending on the implementation phase and approvals obtained, functionality may include:

  • Child registration and creation of a child health profile.
  • Collection of limited biographical and demographic information.
  • Recording the child's home and/or daycare location.
  • Recording parent, guardian or next-of-kin information.
  • Growth monitoring, including weight, height/length and Mid-Upper Arm Circumference (MUAC).
  • Calculation and presentation of growth indicators.
  • Recording immunisation history.
  • Identification of potentially overdue vaccinations.
  • Identification of children who may require additional attention.
  • Referral of children to appropriate health facilities or health personnel.
  • Follow-up of referrals and health interventions.
  • Authorised programme and public-health reporting.
  • Aggregated or anonymised analysis for planning, monitoring and improvement of child-health programmes.

Functionality may be introduced progressively and may vary depending on regulatory approval, programme requirements and integration with authorised government health systems.

3. Who May Use the Tool

Mtoto Afya is primarily intended for authorised users, which may include:

  • Community Health Promoters.
  • Authorised Tiny Totos personnel.
  • Authorised NCCG personnel.
  • Authorised Ministry of Health personnel.
  • Authorised healthcare workers.
  • Approved daycare or programme personnel, where applicable.
  • Other persons specifically authorised by the relevant data controller.

Access to identifiable children's health information is not granted merely because a person has access to the application.

Access shall be based on legitimate duties, approved roles and the principle of least privilege.

Where guest or temporary access is technically available, guest access must not permit unrestricted access to identifiable child health records or sensitive personal data unless an approved authentication, authorisation and accountability mechanism has been implemented.

4. Children and Parental/Guardian Authority

Mtoto Afya processes information concerning children, who require enhanced privacy and safeguarding protections.

Where consent is the applicable lawful basis for processing a child's information, the required consent must be obtained from the child's parent, guardian or other person legally authorised to act on behalf of the child.

Consent must be informed, specific and freely given and must be recorded in an appropriate manner.

Where information may lawfully be processed without prior parental or guardian consent — for example, where processing is specifically authorised or required by law, necessary to protect vital interests, or undertaken under another applicable lawful basis — the responsible data controller must document that basis before such processing occurs.

The mere absence of a parent or guardian from a daycare or assessment location does not by itself constitute consent to collect a child's personal or health information.

The best interests, dignity, safety and privacy of the child shall remain a primary consideration in the use of Mtoto Afya.

5. Responsibilities of Authorised Users

Every authorised user must:

  • Provide accurate information to the best of their knowledge.
  • Verify information where reasonably possible.
  • Collect only information required for an authorised purpose.
  • Follow approved parental/guardian notification and consent procedures.
  • Protect their login credentials and authentication mechanisms.
  • Prevent unauthorised persons from accessing the Tool.
  • Access only records required to perform their authorised duties.
  • Maintain confidentiality.
  • Follow applicable safeguarding, clinical, data-protection and information-security procedures.
  • Promptly report suspected inaccuracies, security incidents or unauthorised disclosures.
  • Comply with applicable policies and instructions issued by the relevant programme and data controller.

Users must not share passwords, OTPs or other authentication credentials.

6. Prohibited Uses

Users must not use Mtoto Afya to:

  • Unlawfully collect, access or disclose personal information.
  • Access children's records without an authorised purpose.
  • Obtain information out of curiosity or for personal benefit.
  • Discriminate against, stigmatise or harm a child or family.
  • Publicly disclose a child's health information.
  • Sell personal or health information.
  • Use children's personal information for unauthorised advertising, profiling or direct marketing.
  • Upload knowingly false or misleading information.
  • Alter or delete records without authority.
  • Circumvent access controls or security safeguards.
  • Extract or export data without authorisation.
  • Attempt to identify individuals from properly anonymised information.
  • Use information for research without required ethical, legal and institutional approvals.
  • Otherwise use the Tool in violation of applicable law.

7. Health Information and Clinical Decisions

Mtoto Afya is a supporting digital health and information-management tool. Unless expressly approved and certified for a particular clinical function, it does not replace professional medical examination, diagnosis or treatment.

Growth classifications, alerts, vaccination reminders and other automated outputs are intended to support appropriately trained personnel.

A result generated by the Tool should be interpreted according to applicable Ministry of Health guidelines and professional protocols.

Where a child appears seriously unwell or requires urgent medical attention, users should follow applicable emergency and referral procedures rather than relying solely on the Tool.

8. Accuracy of Information

We seek to maintain accurate and reliable information, but some information recorded in Mtoto Afya may be supplied by parents, guardians, daycare personnel, CHPs, health workers or existing records.

Users responsible for entering information must take reasonable steps to confirm its accuracy.

Parents and guardians may request correction of inaccurate information concerning themselves or their children, subject to applicable legal and health-record requirements.

9. Growth Monitoring and Automated Calculations

Mtoto Afya may calculate indicators using measurements entered by authorised personnel and recognised health standards, including applicable WHO growth standards.

The reliability of a result depends partly on the accuracy of information and measurements entered into the Tool.

The Tool may flag unusual measurements or potentially concerning health indicators for verification or follow-up.

Such flags are intended to support, rather than replace, appropriate professional assessment.

10. Immunisation Information

Where enabled, Mtoto Afya may record vaccination information and identify vaccinations that appear outstanding based on the information available.

Vaccination information should, wherever practicable, be verified against an authoritative record such as the Mother & Child Health booklet or another approved health record/system.

An absence of vaccination information in Mtoto Afya does not necessarily mean that a child has not received the vaccination.

11. Referrals and Follow-Ups

Where referral functionality has been approved and activated, authorised users may use Mtoto Afya to facilitate referral and follow-up.

Referral functionality is subject to approved Ministry of Health/NCCG pathways and any required technical, governance and regulatory approvals.

Mtoto Afya does not guarantee availability of treatment, acceptance by a particular health facility or a particular medical outcome.

12. Location Information

Mtoto Afya may collect location information where required for an authorised programme purpose, including identifying the location of a daycare, child registration or health assessment and supporting referral or accountability processes.

Location information must not be collected continuously or used to track children, parents, guardians or users beyond the approved purpose.

13. Privacy and Data Protection

Personal information processed through Mtoto Afya shall be handled in accordance with the Mtoto Afya Privacy Policy, the Data Protection Act, 2019, applicable regulations and guidance, applicable digital-health legislation and other applicable Kenyan law.

Health information and information concerning children require enhanced protection.

Mtoto Afya shall apply privacy-by-design and data-minimisation principles appropriate to the nature and risks of the information being processed.

14. Data Sharing

Personal information may only be shared where there is a documented and lawful purpose.

Depending on the programme and applicable approvals, authorised recipients may include Tiny Totos, NCCG, the Ministry of Health, authorised healthcare providers, approved technology/service providers or other legally authorised entities.

Identifiable child-level information must not be shared merely because aggregate programme information is required.

Where only planning, monitoring or statistical information is required, anonymised or aggregated information should be used wherever reasonably possible.

Government or third-party system integration shall be subject to applicable approvals, certification, security requirements and data-sharing arrangements.

15. Intellectual Property

Except for third-party materials, government materials and content otherwise identified, software, designs and other intellectual property associated with Mtoto Afya remain the property of Tiny Totos or the applicable rights holder.

Users receive only the limited right to access and use the Tool for authorised purposes.

16. Security

Users must take reasonable precautions to protect information accessed through Mtoto Afya.

This includes protecting devices, using approved authentication methods, logging out where appropriate, not sharing accounts and immediately reporting suspected unauthorised access or loss of a device containing Mtoto Afya information.

We may suspend or restrict an account where necessary to protect children, users, data or systems.

17. Suspension and Termination

Access may be suspended or terminated where:

  • A user is no longer authorised.
  • The user's employment, assignment or programme role ends.
  • Misuse or suspected misuse occurs.
  • Security is compromised.
  • These Terms are breached.
  • Suspension is required by law, a competent authority or an authorised data controller.

Termination of access does not automatically require deletion of health records where their continued retention is required or permitted by law.

18. Availability and Changes

We may update, modify, suspend or discontinue functionality where reasonably necessary, including for security, regulatory compliance, maintenance, programme changes or technical improvements.

Material changes affecting the processing of personal information will be reflected in the Privacy Policy and, where required, communicated to affected persons.

19. Limitation of Liability

Nothing in these Terms excludes or limits liability that cannot lawfully be excluded.

Subject to applicable law, Tiny Totos shall not be responsible for consequences arising solely from inaccurate information supplied by third parties, unauthorised use of the Tool, failure to follow applicable medical or referral procedures, or circumstances beyond its reasonable control.

Nothing in this section reduces any statutory obligations relating to children's rights, privacy, data protection, health information or cybersecurity.

20. Governing Law

These Terms are governed by the laws of the Republic of Kenya.

Any dispute shall be addressed in accordance with applicable Kenyan law and the jurisdiction of the competent Kenyan courts or other authorised dispute-resolution body.

21. Contact

Questions about Mtoto Afya or these Terms may be directed to:

For privacy and data-protection enquiries:

22. Acceptance

Authorised users accessing Mtoto Afya confirm that they have read and understood these Terms and agree to use the Tool only in accordance with these Terms, applicable policies, their professional responsibilities and Kenyan law.

Where parental or guardian consent is required for processing a child's information, acceptance of these user Terms by a CHP, daycare operator or other user does not substitute for the required parent or guardian consent.