Welcome to The Craft Catalyst

These Group Terms of Service (“Terms”) govern your access to and use of all platforms and services operated by The Craft Catalyst Limited (“The Craft Catalyst”, “we”, “us”, “our”), a company incorporated under the laws of Kenya. The Craft Catalyst owns and operates two distinct service lines:

• CraftEd — an authorised international student placement and recruitment agency that recruits eligible students from East Africa and places them at accredited partner universities in Malaysia for undergraduate, postgraduate, and professional programmes; and
• CraftEx — a virtual work simulation platform that provides AI-assessed, scenario-based professional skills development tools for students, job-seekers, and corporate clients across East Africa.

These Terms apply to both service lines (together, the “Platforms” or “Services”). Where a provision applies exclusively to one platform, this is stated clearly. By accessing or using either Platform, you agree to be bound by these Terms and our Group Privacy Policy. If you do not agree, you may not use the Services.

1. Definitions

The following terms have the meanings set out below and apply across both service lines:

• “The Craft Catalyst” / “Group” means The Craft Catalyst Limited, a company incorporated in Kenya, and all platforms and services it operates.
• “CraftEd” means The Craft Catalyst’s international student placement and university recruitment agency service, through which eligible students from East Africa are recruited and referred to partner universities in Malaysia.
• “CraftEx” means The Craft Catalyst’s virtual work simulation and professional skills assessment platform.
• “Platform(s)” / “Service(s)” means CraftEd, CraftEx, or both, as the context requires.
• “User” means any individual or entity that accesses or uses either Service, including Students, Partner Universities, and Corporate Clients.
• “Student” means an individual from East Africa who applies through CraftEd for placement at a Partner University in Malaysia, or who uses CraftEx for skills development or assessment.
• “Applicant” means a Student who has submitted a formal application through CraftEd for consideration by a Partner University.
• “Partner University” means an accredited Malaysian higher education institution that has appointed The Craft Catalyst as an authorised recruitment agent under a formal Agency Agreement.
• “Agency Agreement” means the formal appointment agreement between The Craft Catalyst and a Partner University, under which The Craft Catalyst is authorised to recruit and refer students on that university’s behalf.
• “Offer Letter” means a conditional or unconditional offer of admission issued directly by a Partner University to a Student following a successful application through CraftEd.
• “Corporate Client” means an organisation that accesses CraftEx to commission simulations, assess candidates, or offer the platform to its employees or recruits.
• “Simulation” means a virtual, scenario-based professional task hosted on CraftEx that is assessed by AI and/or human reviewers.
• “Content” means any information, documents, data, files, multimedia, or other material submitted to or generated on either Platform.
• “Premium Services” means paid subscription plans or add-on features available on either Platform.

2. Eligibility and Account Registration

2.1 Age and Capacity

You must be at least 18 years old to register an account on either Platform and to submit an application through CraftEd. Students aged 17 may use CraftEd solely with verified parental or guardian consent, given that Malaysian universities may consider applications from students who will reach 18 during their intended enrolment year. By registering, you confirm that you have the legal capacity to enter into a binding agreement.

2.2 Account Creation

• You must provide accurate, current, and complete information at registration and keep it up to date throughout your use of the Services.
• You are solely responsible for safeguarding your login credentials and for all activities conducted under your account.
• You must notify us immediately at legal@thecraftcatalyst.co.ke of any unauthorised access to your account.
• Each individual or entity may hold only one active account per Platform, unless expressly authorised in writing by The Craft Catalyst.

2.3 Identity Verification

CraftEd requires verification of identity and academic credentials before an application is submitted to a Partner University. You may be required to provide certified copies of your national identity document or passport, academic transcripts and certificates, proof of English language proficiency, and other supporting documents as specified by the relevant Partner University. Submission of fraudulent, forged, or materially misleading documentation is a serious breach of these Terms, may constitute a criminal offence under applicable law, and will result in immediate termination of your account and notification to the relevant Partner University and, where required, to regulatory authorities.

3. Platform Use and User Conduct

3.1 Permitted Use

You may use the Platforms for the following purposes:

On CraftEd:

• Create and manage a student profile for university placement purposes
• Browse partner universities, programmes, entry requirements, and tuition fees
• Submit applications to Partner Universities through The Craft Catalyst as your authorised agent
• Upload supporting documentation required for admission
• Track the status of your application and receive updates from The Craft Catalyst
• Receive and review Offer Letters issued by Partner Universities
• Access pre-departure guidance and orientation materials provided by The Craft Catalyst

On CraftEx:

• Enrol in and complete virtual work simulations
• Receive AI-generated performance feedback and skills assessments
• Earn and share digital skills badges and competency certificates
• Access candidate simulation results (Corporate Clients, subject to User consent)
• Commission custom simulation content (Corporate Clients, under a separate agreement)

3.2 Prohibited Activities

You agree not to engage in any of the following on either Platform:

• Submit false, forged, plagiarised, or misleading information or documents
• Misrepresent your academic qualifications, language proficiency, financial means, or immigration status
• Use either Platform for any activity that is unlawful under Kenyan law, Malaysian law, or the applicable law of your country of residence
• Harass, abuse, threaten, impersonate, or harm any other User, employee, agent, or third party
• Attempt to gain unauthorised access to any part of the Platforms, other user accounts, or our systems
• Upload, transmit, or introduce malicious software, viruses, or harmful code
• Scrape, copy, harvest, or systematically extract data from the Platforms without prior written authorisation
• Create multiple accounts to circumvent restrictions, bans, or application limitations
• Use either Platform for commercial purposes outside the intended placement or simulation framework
• Interfere with, disrupt, or degrade the performance or security of either Platform

4. CraftEd — International Student Placement Agency Terms

4.1 Agency Relationship

The Craft Catalyst operates CraftEd as a licensed and authorised student recruitment agent. In this capacity:

• The Craft Catalyst acts as the agent of each Partner University for the specific purpose of identifying, counselling, and referring prospective students from East Africa for admission to that university’s programmes.
• The Craft Catalyst does not act as the agent of the Student. Students are advised to make independent enquiries and, where appropriate, seek independent advice before committing to any programme or university.
• The existence of an Agency Agreement between The Craft Catalyst and a Partner University does not constitute an endorsement by The Craft Catalyst of that university’s academic quality, graduate outcomes, facilities, or student experience beyond what is published on the CraftEd platform.

4.2 Scope of Services Provided by CraftEd

Under the CraftEd service, The Craft Catalyst will, subject to these Terms:

• Provide Students with accurate information about Partner University programmes, entry requirements, tuition fees, and application deadlines as supplied by the relevant Partner University
• Assist Students in preparing and submitting complete, accurate applications on their behalf to Partner Universities
• Liaise with Partner Universities on the Student’s behalf regarding application status, conditional offer requirements, and enrolment procedures
• Communicate Offer Letters and other official correspondence from Partner Universities to Students promptly
• Provide general pre-departure guidance on student visa applications, travel, accommodation, and orientation, where available
• Facilitate, where applicable, introductions to scholarship and financial aid opportunities offered by Partner Universities

4.3 Services Not Provided by CraftEd

The Craft Catalyst expressly does not, through CraftEd:

• Guarantee admission to any Partner University or any specific programme
• Guarantee the award of any scholarship, bursary, or financial assistance
• Provide immigration, visa, or legal advice. Students must obtain independent advice on Malaysian student visa requirements from the relevant embassy, the Malaysian Immigration Department, or a licensed immigration adviser
• Accept responsibility for delays, refusals, or changes in Malaysian student visa processing or immigration policy
• Accept responsibility for the academic content, quality, accreditation status, or outcomes of any programme offered by a Partner University
• Act as a guarantor of any financial, academic, or contractual obligation of a Partner University to a Student

4.4 Offer Letters and Admission Decisions

All Offer Letters are issued directly by the Partner University and constitute a legal agreement solely between the Student and that university. The Craft Catalyst is not a party to any offer of admission. Students must read all terms and conditions attached to an Offer Letter carefully before accepting. The Craft Catalyst accepts no liability for changes to, withdrawal of, or conditions imposed within an Offer Letter by a Partner University.

4.5 Accuracy of Student Information

Students bear full and sole responsibility for the accuracy, completeness, and authenticity of all information and documents submitted through CraftEd. If a Partner University discovers at any time — including after enrolment — that a Student submitted false or misleading information, the university may withdraw the offer or terminate enrolment at its absolute discretion. The Craft Catalyst accepts no liability for any consequence arising from a Student’s misrepresentation.

4.6 Agency Fees and Commissions

The Craft Catalyst’s recruitment agency services to Students through CraftEd are provided free of charge to the Student. The Craft Catalyst receives commission payments directly from Partner Universities upon successful enrolment of referred students. This commercial arrangement does not affect The Craft Catalyst’s obligation to provide Students with accurate and balanced information.

4.7 Student Fees Payable to Partner Universities

Tuition fees, registration fees, accommodation deposits, and all other charges payable to Partner Universities are the sole obligation of the Student. All such payments must be made directly to the relevant Partner University in accordance with that university’s payment terms. The Craft Catalyst does not collect, hold, or transmit student fees to universities and accepts no liability for any financial transaction between a Student and a Partner University. Students are strongly advised to make all payments only to official university bank accounts and to retain all payment receipts.

4.8 Refunds

Any refund of fees paid to a Partner University is governed exclusively by that university’s own refund policy and applicable Malaysian consumer protection and education law. Students must direct all refund requests directly to the Partner University. The Craft Catalyst may, at its discretion and without obligation, assist Students in communicating a refund request to a Partner University but cannot compel any refund outcome.

4.9 Pre-Departure and Post-Arrival Support

The Craft Catalyst will provide general pre-departure orientation materials and, where available, connect Students with peer networks or alumni in Malaysia. This support is offered as a courtesy and does not constitute legal, financial, or pastoral care advice. Once a Student has arrived in Malaysia and commenced studies, the Student’s primary support relationship is with their Partner University. The Craft Catalyst’s active agency obligations conclude upon the Student’s confirmed enrolment, unless otherwise agreed in writing.

4.10 Malaysian Regulatory Compliance

Partner Universities listed on CraftEd are, to the best of The Craft Catalyst’s knowledge at the time of listing, accredited by the Malaysian Qualifications Agency (MQA) and registered with the Ministry of Higher Education Malaysia (MOHE). Students are encouraged to independently verify a programme’s accreditation status at www.mqa.gov.my before accepting an offer. The Craft Catalyst does not warrant the continued accreditation or operational status of any Partner University and will update its listings promptly upon receiving notice of any material change.

4.11 Kenyan Regulatory Compliance

The Craft Catalyst’s student recruitment activities in Kenya are conducted in accordance with applicable Kenyan law. Students and their guardians are advised that study-abroad arrangements entered into through a recruitment agent should be independently verified. Any complaints regarding CraftEd’s conduct may be directed to The Craft Catalyst’s complaints process (Section 11) or, where applicable, to a relevant Kenyan consumer protection authority.

5. CraftEx — Virtual Work Simulation Terms

5.1 Nature of Simulations

CraftEx provides structured virtual work simulations designed to assess and develop professional competencies. Simulations are not employment, do not create any employment or agency relationship, and completion of a simulation does not constitute a guarantee of employment, a professional qualification, or academic credit unless expressly confirmed in writing.

5.2 AI Assessment and Scoring

• Simulation tasks are assessed by The Craft Catalyst’s AI engine, which generates performance scores, competency ratings, and written feedback.
• AI assessments are advisory. They do not constitute the final view of any employer and are not binding on any hiring decision.
• Where an AI assessment has a material impact on a significant decision affecting a User, that User has the right to request human review as described in Section 6.3 and the Group Privacy Policy.
• The Craft Catalyst does not warrant that AI assessments are free from error, bias, or limitation.

5.3 Skills Badges and Certificates

Digital skills badges and competency certificates issued through CraftEx represent successful completion of a specific simulation at a defined performance threshold. They are not professional licences, regulated qualifications, or academic credentials unless a specific endorsement by a recognised body is disclosed on the Platform.

5.4 Corporate Client Access to Simulation Data

A Corporate Client may access a User’s CraftEx simulation results only where:

• the User has applied directly to that Corporate Client through CraftEx; or
• the User has given explicit, informed consent for their results to be shared with that specific client; or
• the Corporate Client has commissioned a bespoke simulation and the User enrolled with prior notice that results would be accessible to that client.

Anonymised, aggregated data that does not identify any individual may be shared with Corporate Clients or research partners for sector-level insights.

5.5 Custom Simulations

Corporate Clients that commission custom simulation content must execute a separate Commercial Services Agreement governing content ownership, confidentiality, candidate data handling, and fees. Custom simulation scenarios developed collaboratively with a Corporate Client are the joint intellectual property of The Craft Catalyst and that client as specified in the Commercial Services Agreement.

5.6 Academic Integrity

Users must complete all simulation tasks independently. The Platform’s AI systems detect patterns consistent with third-party assistance or unauthorised AI tools. Where dishonesty is detected, the simulation result may be withheld or voided, the User will be notified and given an opportunity to respond, and repeat or serious violations may result in account suspension or termination.

6. AI Systems Across Both Platforms

6.1 General Use of AI

Both CraftEd and CraftEx employ AI and automated systems to support:

• CraftEd: AI-assisted matching of Student profiles to suitable Partner University programmes based on academic background, budget, career interests, and eligibility criteria
• CraftEx: AI-powered scoring, feedback generation, and skills gap analysis for simulation tasks

6.2 Limitations of AI

AI outputs on both Platforms are tools to support — not replace — human judgement. Programme matching recommendations on CraftEd are indicative only; Students must independently verify their eligibility directly with the Partner University. The Craft Catalyst does not warrant that AI-generated outputs are error-free, unbiased, or suitable for any specific purpose beyond their intended use.

6.3 Right to Human Review

Where an automated decision produces a result that materially affects a User — such as exclusion from a programme recommendation list or a failing simulation score — the User may request a human review by writing to dpo@thecraftcatalyst.co.ke with the subject line “Automated Decision Review”. We will respond within 10 business days.

7. Data Protection and Privacy

7.1 The Craft Catalyst as Data Controller

The Craft Catalyst Limited is the registered Data Controller for both Platforms under the Kenya Data Protection Act, 2019 (ODPC Registration No. [INSERT]). All personal data collected through CraftEd and CraftEx is processed in accordance with the Group Privacy Policy, which forms an integral part of these Terms and is incorporated herein by reference.

7.2 Sharing Data with Partner Universities

By submitting an application through CraftEd, you explicitly consent to The Craft Catalyst sharing your personal data, academic records, and supporting documents with the Partner University or universities to which you have applied. This sharing is necessary to fulfil the application service. Partner Universities receiving your data are independent data controllers and are bound by their own privacy policies and applicable Malaysian data protection law, including the Personal Data Protection Act 2010 (Malaysia) (PDPA 2010). The Craft Catalyst is not responsible for the data handling practices of Partner Universities once data has been lawfully transferred.

7.3 International Data Transfer — Malaysia

The submission of your application through CraftEd necessarily involves the transfer of your personal data from East Africa to Malaysia. Such transfers are made on the basis of contractual necessity (to perform the placement service you have requested) and are subject to the safeguards described in the Group Privacy Policy. Malaysia’s PDPA 2010 provides a legal framework for personal data protection, and Partner Universities are required under their Agency Agreements with The Craft Catalyst to handle student data in compliance with applicable law.

7.4 Applicable Laws

We process personal data in compliance with the Kenya Data Protection Act, 2019; Uganda’s Data Protection and Privacy Act, 2019; Rwanda’s Law No. 058/2021; Tanzania’s Personal Data Protection Act, 2022 (where in force); Ethiopia’s applicable digital legislation; and Malaysia’s Personal Data Protection Act, 2010 for data transferred to Partner Universities. We apply the standard affording the greatest protection to the individual in all cases.

8. Intellectual Property

8.1 Platform Ownership

The Platforms, including all software, branding, design, simulation content, AI models, features, and documentation, are the exclusive property of The Craft Catalyst and are protected under Kenyan and international intellectual property law. Nothing in these Terms transfers any intellectual property rights to Users.

8.2 User Content Licence

You retain ownership of all original Content you submit to either Platform. By submitting Content, you grant The Craft Catalyst a non-exclusive, worldwide, royalty-free licence to use, store, display, and process your Content solely for the purpose of operating, improving, and delivering the Services. This licence terminates when you delete your account, except where retention is required by law or legitimate operational necessity as described in the Group Privacy Policy.

8.3 Application Documents

Documents submitted through CraftEd for placement purposes (transcripts, certificates, personal statements, and similar materials) are used solely to facilitate your application to Partner Universities. The Craft Catalyst will not reproduce, publish, or use such documents for any purpose other than delivering the CraftEd service without your explicit written consent.

8.4 Simulation Work (CraftEx)

Users retain ownership of simulation responses. The Craft Catalyst retains all rights in simulation scenarios, scoring rubrics, and AI models. Anonymised, aggregated simulation data (where no individual is identifiable) may be used for research, product development, and publication.

9. Fees and Payment

9.1 CraftEd — No Student Fees

The Craft Catalyst’s placement agency services are provided to Students at no charge. The Craft Catalyst is remunerated by commission from Partner Universities. Students must not pay any fee to The Craft Catalyst or any of its representatives in connection with CraftEd placement services. If you are asked to pay a fee to The Craft Catalyst in connection with a CraftEd application, please report this immediately to security@thecraftcatalyst.com

All tuition, registration, accommodation, and other fees payable to Partner Universities are the sole obligation of the Student and must be paid directly to the university. Refer to Section 4.7 for further detail.

9.2 CraftEx — Premium Services

CraftEx offers a free-access tier and paid Premium Services. All fees are quoted in Kenyan Shillings (KES) unless otherwise stated. Payment is due at the time of subscription or purchase. All fees are non-refundable except as required by applicable Kenyan consumer protection law or as expressly stated in our Refund Policy. You are responsible for all applicable taxes on your use of Premium Services.

10. Disclaimers and Limitation of Liability

10.1 CraftEd — Placement Outcomes

The Craft Catalyst does not guarantee that:

• any Student will receive an offer of admission from any Partner University;
• any Student will be granted a Malaysian student visa;
• any Partner University will maintain its accreditation, fee structure, programme offering, or operational status;
• any scholarship, bursary, or financial assistance will be awarded; or
• a Student’s academic or professional outcomes in Malaysia will meet their expectations.

Students make the ultimate decision to apply and to accept any offer of admission. The Craft Catalyst’s liability in connection with the CraftEd agency service is limited to the quality of the facilitation service it provides and does not extend to the decisions, policies, or conduct of Partner Universities.

10.2 CraftEx — Simulation Outcomes

The Craft Catalyst does not guarantee that completion of any simulation or receipt of any skills badge will result in employment, career advancement, or any specific professional outcome.

10.3 Third-Party Actions

The Craft Catalyst is not responsible for the conduct, representations, or decisions of Partner Universities, visa authorities, government agencies, accommodation providers, or any other third party. Users engage with such parties at their own risk.

10.4 Maximum Liability

To the maximum extent permitted by applicable law, The Craft Catalyst’s total aggregate liability for all claims arising from a User’s use of either Platform shall not exceed the greater of KES 100,000 or the total amount paid by that User for Premium Services in the twelve months preceding the claim. This limitation does not apply to liability for fraud, wilful misconduct, or death or personal injury caused by our negligence.

10.5 Indemnification

You agree to indemnify and hold harmless The Craft Catalyst, its directors, officers, employees, and agents from and against any claim, loss, damage, cost, or liability (including reasonable legal fees) arising from: (a) your breach of these Terms; (b) your violation of applicable law; (c) Content or documentation you submit; or (d) misrepresentation of your academic or personal circumstances.

11. Complaints and Dispute Resolution

11.1 Internal Complaints Process

If you have a complaint about the CraftEd or CraftEx service, you should first submit a written complaint to security@thecraftcatalyst.com We will acknowledge your complaint within 3 business days and provide a substantive response within 15 business days. Complaints relating to data protection should be directed to dpo@thecraftcatalyst.co.ke.

11.2 Governing Law

These Terms are governed by the laws of Kenya. For Users in Uganda, Tanzania, Rwanda, or Ethiopia, mandatory local consumer protection laws that cannot be excluded by contract apply in addition to Kenyan law to the extent required. Issues arising from the conduct of Partner Universities in Malaysia are subject to Malaysian law and the jurisdiction of Malaysian courts, and the Student’s agreement with the Partner University.

11.3 Mediation

If a complaint is not resolved through our internal process, the parties agree to attempt mediation through a recognised Kenyan mediation service, such as the Nairobi Centre for International Arbitration (NCIA) or the Chartered Institute of Arbitrators — Kenya Branch, before pursuing litigation. Mediation costs are shared equally unless otherwise agreed.

11.4 Jurisdiction

If mediation fails, disputes shall be resolved by the competent courts of Kenya, subject to any mandatory local law requirements in the User’s country of residence.

12. Termination

12.1 Termination by User

You may close your account at any time by contacting security@thecraftcatalyst.com. For CraftEd users, note that closing your account will not automatically withdraw any pending applications submitted to Partner Universities; you must separately notify the relevant university of any withdrawal.

12.2 Termination by The Craft Catalyst

We may suspend or terminate your account, with or without notice, if we reasonably believe you have breached these Terms, violated applicable law, submitted fraudulent documents, or engaged in conduct harmful to other Users or third parties. Serious breaches — particularly submission of forged academic documents — will be reported to the relevant Partner University and, where required, to regulatory or law enforcement authorities.

12.3 Effect of Termination

Upon termination, your access to the Platforms ceases immediately. For CraftEd, any pending applications not yet forwarded to a Partner University will be cancelled. Applications already submitted to a Partner University prior to termination remain with that university; The Craft Catalyst will notify the university of the account closure. Sections 1, 7, 8, 10, 11, and any accrued payment obligations survive termination.

13. Changes to These Terms

We may update these Terms at any time. We will notify Users of material changes via email and a prominent notice on both Platforms at least 30 days before the new version takes effect. For changes that materially affect your rights, we may require explicit re-acceptance. Continued use of either Platform after the effective date constitutes acceptance of the revised Terms.

14. General Provisions

14.1 Entire Agreement

These Terms, together with the Group Privacy Policy and any applicable Agency Agreement or Commercial Services Agreement, constitute the entire agreement between you and The Craft Catalyst with respect to your use of the Platforms.

14.2 Severability

If any provision is found invalid or unenforceable, it will be severed and the remaining provisions continue in full force.

14.3 Waiver

No failure to exercise any right under these Terms operates as a waiver of that right or of any subsequent breach.

14.4 Assignment

You may not assign your rights or obligations under these Terms without our prior written consent. The Craft Catalyst may assign these Terms in connection with a merger, acquisition, or restructuring with 30 days’ notice.

14.5 Force Majeure

The Craft Catalyst will not be liable for delays or failures caused by events beyond our reasonable control, including natural disasters, government actions, civil unrest, power failures, or third-party service outages. We will notify you promptly and take reasonable steps to restore normal service.

14.6 Language

These Terms are in English. In the event of a conflict between an English version and any translated version, the English version prevails.

15. Contact Information

The Craft Catalyst — Legal and Compliance

• Email: security@thecraftcatalyst.com
• Phone: +254 742 950 093
• Address: Riverside Drive

Platform-Specific Enquiries

• CraftEd (Placement): info@thecraftcatalyst.com
• CraftEx (Simulations): info@craftex.com

Data Protection Officer

• Email: security@thecraftcatalyst.co.ke