Privacy Policy

1. INTRODUCTION

1.1 Purpose of this Policy

Sgela Edu Tech Proprietary Limited ("Sgela Edu Tech", "we", "us", or "our") respects your privacy and is committed to protecting the Personal Information we collect from you. This Privacy Policy explains how we collect, use, disclose, and safeguard your Personal Information when you use our Services, including our Website, App, and any related services.

1.2 Our Commitment to Privacy

We are committed to processing your Personal Information in accordance with the Protection of Personal Information Act, 2013 (POPIA) and other applicable South African data protection laws. This Privacy Policy reflects our dedication to transparency, accountability, and the protection of your privacy rights.

1.3 Relationship with Terms of Service

This Privacy Policy forms part of the Additional Terms referred to in our Terms of Service. It is incorporated by reference into the Terms of Service and should be read together with those Terms. Capitalised terms used but not defined in this Privacy Policy shall have the meanings ascribed to them in our Terms of Service.

1.4 Application of POPIA

Sgela Edu Tech is a Responsible Party as defined under POPIA. As such, we determine the purpose and means of processing Personal Information and are accountable for ensuring that such processing complies with POPIA's conditions for lawful processing.

1.5 Acceptance of this Policy

By using our Services, creating an Account, or otherwise providing us with your Personal Information, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with any part of this Privacy Policy, you must not use our Services or provide us with your Personal Information.

2. DEFINITIONS AND INTERPRETATION

2.1 Definitions

In this Privacy Policy, unless the context otherwise requires:

2.2 Interpretation

In this Privacy Policy, unless the context otherwise requires:

2.2.1 Words importing the singular shall include the plural and vice versa;

2.2.2 Words importing a natural person shall include a juristic person and vice versa;

2.2.3 Headings are for convenience only and shall not affect the interpretation;

2.2.4 References to any statute include any amendment or replacement thereof;

2.2.5 The word "including" shall be construed as "including without limitation".

3. SCOPE OF THIS PRIVACY POLICY

3.1 Application

This Privacy Policy applies to:

3.1.1 The Website (https://www.sgela.co.za and all sub-domains);

3.1.2 The App (accessible at https://sgela.co.za);

3.1.3 All Services provided by Sgela Edu Tech;

3.1.4 Our customer support services;

3.1.5 Our marketing and promotional activities; and

3.1.6 Any third-party integrations we offer.

3.2 Exclusions

This Privacy Policy does not apply to:

3.2.1 Third-party websites, apps, or services linked to or referenced on our Platform;

3.2.2 Information you provide to third parties;

3.2.3 Information that is publicly available; or

3.2.4 Information that is anonymised or de-identified.

4. INFORMATION WE COLLECT

4.1 Information You Provide to Us

4.1.1 Account and Registration Information

4.1.2 Educational and Learning Information

4.1.3 Communication Information

4.1.4 Payment and Transaction Information

4.1.5 User-Generated Content

4.2 Information Automatically Collected

4.2.1 Device Information

4.2.2 Usage Information

4.2.3 Technical Information

4.3 Information Collected from Third Parties

4.3.1 Third-Party Authentication Providers

When you use Google or Facebook authentication to create an Account or log in, we may receive:

4.3.2 Payment Processors

When you make payment through Payfast, we may receive:

Important: We do not receive or store your full payment card details. All payment card information is processed by Payfast in accordance with their privacy policy.

4.3.3 Analytics Providers

We receive information from Google Analytics to understand how you interact with our Services, including usage data, demographic information, and interaction patterns.

5. CHILDREN'S PRIVACY

5.1 General Principle

Sgela Edu Tech recognises the importance of protecting the privacy of children (Learners under the age of 18). We are committed to complying with POPIA and other applicable laws regarding the processing of Personal Information of children.

5.2 Parental Consent Requirement

In terms of South African law, any person under the age of 18 requires the consent or assistance of a Parent/Legal Guardian to legally enter into a reciprocal agreement. We do not knowingly collect or process Personal Information of Learners without the express consent of a Parent/Legal Guardian. By creating an Account on behalf of a Learner, the Parent/Legal Guardian:

5.2.1 Represents and warrants that they have the legal authority to act on behalf of the Learner;

5.2.2 Confirms that they understand and agree to this Privacy Policy;

5.2.3 Consents to the processing of the Learner's Personal Information;

5.2.4 Acknowledges that the Learner will have access to the Platform; and

5.2.5 Accepts responsibility for the Learner's use of the Platform.

5.3 Special Protections for Children

We implement additional safeguards for the processing of children's Personal Information:

5.3.1 We limit collection to what is necessary for the provision of our Services;

5.3.2 We do not use children's Personal Information for direct marketing without consent;

5.3.3 We do not share children's Personal Information except as necessary to provide the Services;

5.3.4 We maintain appropriate security measures; and

5.3.5 We provide Parent/Legal Guardians with access to and control over their child's information.

5.4 Parental Rights

Parents/Legal Guardians have specific rights regarding their child's Personal Information, including rights to access, correct, withdraw consent, request deletion, and object to processing.

6. WHY WE COLLECT INFORMATION

6.1 Lawful Purposes

We collect, use, and disclose Personal Information for the following lawful purposes:

6.1.1 Providing and Managing the Services

6.1.2 Improving and Developing the Services

6.1.3 Security and Fraud Prevention

6.1.4 Communication and Marketing

7. LAWFUL GROUNDS FOR PROCESSING

7.1 POPIA Lawfulness Requirements

Under POPIA, we must have a lawful ground for processing Personal Information. We rely on the following lawful grounds:

7.1.1 Consent

Where you have given your explicit, voluntary, and informed consent for the processing of your Personal Information. Consent is obtained:

7.1.1.1 When you create an Account and accept this Privacy Policy;

7.1.1.2 When you provide specific consent for a particular purpose; and

7.1.1.3 When you adjust your privacy settings.

You may withdraw your consent at any time by contacting us at Terms@sgela.co.za or by adjusting your Account settings. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

7.1.2 Contractual Necessity

Processing is necessary for the performance of a contract to which you are a party, including:

7.1.2.1 Creating and managing your Account;

7.1.2.2 Providing the Services you have requested;

7.1.2.3 Processing payments for subscriptions; and

7.1.2.4 Providing customer support.

7.1.3 Legal Obligation

Processing is necessary to comply with a legal obligation imposed on us by law, including:

7.1.3.1 Compliance with POPIA and other data protection laws;

7.1.3.2 Compliance with tax and financial reporting requirements;

7.1.3.3 Responding to court orders or lawful requests; and

7.1.3.4 Compliance with applicable consumer protection regulations.

7.1.4 Protecting a Legitimate Interest of the Data Subject

Processing is necessary to protect the legitimate interests of the Data Subject, including:

7.1.4.1 Protecting the safety and well-being of Learners; and

7.1.4.2 Preventing harm or fraud.

7.1.5 Legitimate Interests of the Responsible Party

Processing is necessary for pursuing our legitimate interests, provided those interests are not overridden by your rights. Our legitimate interests include:

7.1.5.1 Improving, developing, and personalising our Services;

7.1.5.2 Ensuring the security and integrity of our Platform;

7.1.5.3 Preventing fraud and unauthorised access;

7.1.5.4 Conducting research and analytics;

7.1.5.5 Marketing our Services;

7.1.5.6 Managing our business; and

7.1.5.7 Protecting our legal rights and interests.

8. AI SERVICES

8.1 Introduction

Sgela Edu Tech provides AI Services as part of our educational platform, powered by Gemini by Google. These AI Services are designed to enhance the learning experience through personalised recommendations, intelligent tutoring, automated assessments, and other AI-powered features.

8.2 AI Processing Activities

The AI Services may process your Personal Information for the following purposes:

8.2.1 AI-Powered Learning Assistance

8.2.2 AI-Powered Assessment

8.2.3 AI-Powered Analytics

8.3 AI Processing of Personal Information

8.3.1 Information Used by AI

The AI Services may process the following categories of Personal Information:

8.3.1.1 Learning activities, including quizzes, assessments, and practice questions;

8.3.1.2 Performance data, including scores and progress;

8.3.1.3 Learning preferences;

8.3.1.4 Prompts, queries, and conversations with AI assistants;

8.3.1.5 Uploaded content; and

8.3.1.6 User behaviour.

8.3.2 AI Outputs

The AI Services generate outputs based on your Personal Information, including:

8.3.2.1 Personalised learning recommendations;

8.3.2.2 Automated feedback on assessments;

8.3.2.3 Performance reports and analytics;

8.3.2.4 Learning progress predictions;

8.3.2.5 Curated learning pathways; and

8.3.2.6 AI-generated explanations.

8.4 Automated Decision-Making

8.4.1 Use of Automated Decision-Making

We use Automated Decision-Making as part of our AI Services, including:

8.4.1.1 Content personalisation and recommendations;

8.4.1.2 Automated grading and assessment;

8.4.1.3 Progress predictions and learning pathway planning; and

8.4.1.4 Performance analytics and reporting.

8.4.2 Your Rights Regarding Automated Decision-Making

You have rights regarding Automated Decision-Making:

8.4.2.1 The right to be informed of Automated Decision-Making;

8.4.2.2 The right to request human review of automated decisions;

8.4.2.3 The right to object to Automated Decision-Making; and

8.4.2.4 The right to request an explanation of the logic behind decisions.

To exercise these rights, please contact us at Terms@sgela.co.za.

8.5 Human Review

8.5.1 When Human Review Occurs

We may conduct human review of AI-generated outputs in the following circumstances:

8.5.1.1 To ensure quality control and accuracy;

8.5.1.2 To respond to User complaints;

8.5.1.3 To address AI system errors; and

8.5.1.4 To investigate potential misuse.

8.5.2 Safeguards for Human Review

When human review occurs:

8.5.2.1 Access is limited to authorised personnel;

8.5.2.2 Reviewers are bound by confidentiality obligations;

8.5.2.3 Personal Information is anonymised where possible; and

8.5.2.4 Information is not used for any purpose other than review.

8.6 Limitations of AI Services

8.6.1 Accuracy Disclaimer

AI Services are provided for informational and educational purposes only. AI-generated content may contain errors or inaccuracies and should not be relied upon as the sole source of learning.

8.6.2 No Guarantee of Outcomes

We do not guarantee that the use of AI Services will result in improved academic performance, increased success rates, or any specific educational outcomes.

9. COOKIES AND TRACKING TECHNOLOGIES

9.1 What Are Cookies

Cookies are small text files stored on your device when you visit a website. They help websites remember your preferences, analyse usage, and improve your experience.

9.2 Types of Cookies We Use

9.3 Third-Party Cookies

We allow third-party service providers to place cookies on your device. These include Google (for analytics) and PostHog (for product analytics).

9.4 Cookie Management

9.4.1 Browser Settings

Most browsers allow you to control cookies through your browser settings. You can block all cookies, block third-party cookies, delete existing cookies, and set preferences.

9.4.2 Consequences of Blocking Cookies

If you block essential cookies:

9.4.2.1 You may not be able to log in to your Account;

9.4.2.2 Certain features may not function;

9.4.2.3 Your preferences may not be remembered; and

9.4.2.4 The Platform may not function correctly.

9.5 Other Tracking Technologies

We may also use PostHog for product analytics and tracking user behaviour.

10. SHARING PERSONAL INFORMATION

10.1 General Principle

We do not sell, rent, or trade your Personal Information to third parties. We only share your Personal Information as described in this Privacy Policy.

10.2 Sharing with Service Providers

We engage third-party service providers to perform services on our behalf. These providers may have access to your Personal Information only as necessary to perform their services and are contractually obligated to:

10.2.1 Process Personal Information only for specified purposes;

10.2.2 Implement appropriate security measures;

10.2.3 Not disclose Personal Information without our authorisation;

10.2.4 Not retain Personal Information longer than necessary; and

10.2.5 Comply with POPIA and other applicable laws.

10.3 Sharing with Parents/Legal Guardians

We may share Personal Information of Learners with the Parent/Legal Guardian who created the Account, including:

10.3.1 Learning progress and performance data;

10.3.2 Assessment results;

10.3.3 Usage statistics; and

10.3.4 Account and contact information.

10.4 Legal and Regulatory Disclosures

We may disclose Personal Information if required by law, court order, or other legal process, including:

10.4.1 Compliance with POPIA and other data protection laws;

10.4.2 Response to subpoenas, court orders, or legal demands;

10.4.3 Cooperation with law enforcement and regulatory authorities;

10.4.4 Protection of our rights, property, or safety;

10.4.5 Prevention of fraud or illegal activity; and

10.4.6 Enforcement of our Terms of Service.

10.5 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of assets, we may transfer Personal Information to a successor entity. We will:

10.5.1 Notify you of any such transfer;

10.5.2 Ensure the successor entity is bound by this Privacy Policy;

10.5.3 Provide you with the opportunity to withdraw consent; and

10.5.4 Comply with POPIA and other applicable laws.

11. INTERNATIONAL TRANSFERS

11.1 General Principle

We may transfer Personal Information outside the Republic of South Africa to third-party service providers located in other countries. We do so only when necessary to provide our Services and in compliance with POPIA.

11.2 Countries of Transfer

Personal Information may be transferred to countries where our service providers are located. Our primary cloud hosting is in South Africa (Google Cloud - South Africa region), but some providers may process data in other jurisdictions.

11.3 Safeguards for International Transfers

When transferring Personal Information outside South Africa, we implement appropriate safeguards, including:

11.3.1 Use of standard contractual clauses or model clauses;

11.3.2 Contractual protections requiring compliance with POPIA or equivalent standards;

11.3.3 Prohibition on further transfer without authorisation;

11.3.4 Appropriate security measures; and

11.3.5 Enforcement of data subject rights.

11.4 Your Rights Regarding International Transfers

You have the right to:

11.4.1 Be informed of the countries to which your Personal Information is transferred;

11.4.2 Request a copy of the safeguards used;

11.4.3 Object to international transfers where appropriate; and

11.4.4 Lodge a complaint with the Information Regulator.

12. DATA RETENTION

12.1 Retention Principles

We retain Personal Information only for as long as necessary to fulfil the purposes for which it was collected, including:

12.1.1 Providing the Services;

12.1.2 Complying with legal obligations;

12.1.3 Resolving disputes;

12.1.4 Enforcing our agreements; and

12.1.5 Protecting our rights.

12.2 Retention Periods

12.3 Retention of Inactive Accounts

As stated in our Terms of Service, if you have not used your Account for 3 (three) years, we may consider you an inactive User. We may:

12.3.1 Contact you to confirm whether you wish to continue;

12.3.2 Archive your Account data;

12.3.3 Delete your Account after reasonable notice; and

12.3.4 Retain only the Personal Information required by law.

12.4 Post-Termination Retention

Upon termination of your Account:

12.4.1 We will delete your Account and you will no longer be able to access the Services;

12.4.2 We will remove your payment information but retain other information as necessary;

12.4.3 We will retain Personal Information as necessary to comply with legal obligations; and

12.4.4 We will securely dispose of Personal Information when no longer needed.

13. SECURITY

13.1 Our Commitment to Security

We are committed to protecting the Personal Information we process from unauthorised access, use, disclosure, alteration, or destruction. We implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk.

13.2 Technical Measures

We implement the following technical measures:

13.3 Organisational Measures

We implement the following organisational measures:

13.4 Security Limitations

13.4.1 No Absolute Security

While we implement robust security measures, no method of transmission over the internet is 100% secure. We cannot guarantee absolute security.

13.4.2 User Responsibilities

You also have a role in protecting the security of your Personal Information:

13.4.2.1 Use strong passwords and keep them confidential;

13.4.2.2 Do not share your Account access credentials;

13.4.2.3 Log out of your Account when not in use;

13.4.2.4 Ensure your devices are secure;

13.4.2.5 Report any suspected security breaches immediately; and

13.4.2.6 Monitor your Account for unauthorised activity.

13.5 Data Breach Notification

If we become aware of a security breach that involves your Personal Information, we will:

13.5.1 Investigate the breach promptly;

13.5.2 Assess the risk to affected Data Subjects;

13.5.3 Notify the Information Regulator as required by law;

13.5.4 Notify affected Data Subjects where legally required;

13.5.5 Take appropriate remedial action; and

13.5.6 Cooperate with regulatory authorities.

14. USER RIGHTS UNDER POPIA

14.1 Overview

Under POPIA, you have certain rights regarding your Personal Information. We respect these rights and have established processes to enable you to exercise them.

14.2 Summary of Rights

14.3 Right of Access

14.3.1 What You Can Access

You have the right to request a copy of your Personal Information that we hold, including categories, purposes, sources, and recipients.

14.3.2 How to Exercise

To exercise your right of access:

14.3.2.1 Submit a request in writing to Terms@sgela.co.za;

14.3.2.2 Provide sufficient information to verify your identity;

14.3.2.3 Specify the Personal Information you wish to access; and

14.3.2.4 Include a copy of your identification document.

14.3.3 Response Time

We will respond to your access request within a reasonable time, generally within 30 (thirty) calendar days.

14.3.4 Fees

We may charge a reasonable fee to cover the cost of copying, printing, administrative costs, and delivery.

14.4 Right to Correction

14.4.1 What You Can Correct

You have the right to request the correction of inaccurate or incomplete Personal Information.

14.4.2 How to Exercise

To exercise your right to correction:

14.4.2.1 Submit a request in writing to Terms@sgela.co.za;

14.4.2.2 Specify the inaccurate information;

14.4.2.3 Provide supporting evidence; and

14.4.2.4 Include the corrected information.

14.4.3 Correction Process

Upon receiving a valid request:

14.4.3.1 We will investigate the alleged inaccuracy;

14.4.3.2 If we agree, we will make the correction;

14.4.3.3 We will notify third parties who have received the incorrect information; and

14.4.3.4 We will inform you of the outcome.

14.5 Right to Deletion

14.5.1 When You Can Request Deletion

You have the right to request deletion of your Personal Information when:

14.5.1.1 It is no longer necessary for the purposes collected;

14.5.1.2 You withdraw consent and there is no other lawful ground;

14.5.1.3 You object and there are no overriding legitimate grounds;

14.5.1.4 The processing is unlawful; or

14.5.1.5 Deletion is required by law.

14.5.2 Limitations

Deletion may not be possible where:

14.5.2.1 Retention is required by law;

14.5.2.2 The information is necessary for legal proceedings; or

14.5.2.3 There are overriding legitimate grounds.

14.6 Right to Object

14.6.1 When You Can Object

You have the right to object to processing:

14.6.1.1 At any time, for direct marketing;

14.6.1.2 On grounds relating to your situation, where processing is based on legitimate interests.

14.6.2 How to Object

To exercise your right to object:

14.6.2.1 Submit a request to Terms@sgela.co.za;

14.6.2.2 Specify the processing you object to; and

14.6.2.3 Provide reasons (where required).

14.7 Right to Withdraw Consent

14.7.1 How to Withdraw

You may withdraw your consent at any time by:

14.7.1.1 Changing your Account settings;

14.7.1.2 Contacting us at Terms@sgela.co.za; or

14.7.1.3 Terminating your Account.

14.7.2 Consequences of Withdrawal

Withdrawal of consent may result in:

14.7.2.1 Termination of your Account;

14.7.2.2 Inability to access the Services;

14.7.2.3 Deletion of certain Personal Information; and

14.7.2.4 Continued processing where other lawful grounds exist.

14.8 Right to Data Portability

14.8.1 What You Can Request

You have the right to receive your Personal Information in a structured, commonly used, machine-readable format and transfer it to another responsible party.

14.8.2 Scope

Data portability applies to Personal Information:

14.8.2.1 That you have provided to us;

14.8.2.2 That is processed by automated means; and

14.8.2.3 Where processing is based on consent or contractual necessity.

14.9 Right to Lodge a Complaint

14.9.1 Complaint to Sgela Edu Tech

If you have a concern, please first contact us at Terms@sgela.co.za so we can address your concern.

14.9.2 Complaint to the Information Regulator

You have the right to lodge a complaint with the Information Regulator:

14.10 Right to Object to Direct Marketing

You have the right to object to the processing of your Personal Information for direct marketing. You can:

14.10.1 Unsubscribe using the link in any marketing email;

14.10.2 Change your preferences in your Account settings; or

14.10.3 Contact us at Terms@sgela.co.za.

15. HOW TO EXERCISE YOUR RIGHTS

15.1 Contacting Us

To exercise any of your rights under this Privacy Policy, please contact us:

15.2 What to Include in Your Request

Please include:

15.2.1 Your full name and contact details;

15.2.2 The right you wish to exercise;

15.2.3 Specific details of your request;

15.2.4 A copy of your identification document (for verification); and

15.2.5 Any other information to help locate your Personal Information.

15.3 Verification

We may request specific information to verify your identity to ensure we do not disclose Personal Information to unauthorised persons.

15.4 Response Time

We will respond within a reasonable time, generally within 30 (thirty) calendar days. If we require more time, we will notify you.

15.5 Refusal

We may refuse a request if:

15.5.1 We cannot verify your identity;

15.5.2 The request is manifestly unfounded or excessive;

15.5.3 Disclosure would adversely affect the privacy of others;

15.5.4 The request would require disproportionate effort; or

15.5.5 We are legally prohibited from complying.

16. MARKETING COMMUNICATIONS

16.1 General Principle

We may send you marketing communications if you have consented to receive them or if we have a legitimate interest.

16.2 What We Send

Marketing communications may include:

16.2.1 Newsletters with product updates;

16.2.2 Promotional offers and discounts;

16.2.3 Educational content and resources;

16.2.4 Event invitations and announcements; and

16.2.5 Surveys and feedback requests.

16.3 Opt-Out

You can opt out of marketing communications at any time by:

16.3.1 Clicking the unsubscribe link in any marketing email;

16.3.2 Changing your communication preferences in your Account settings; or

16.3.3 Contacting us at Terms@sgela.co.za.

16.4 Service Communications

Service communications are necessary for the provision of the Services and include:

16.4.1 Account-related notifications;

16.4.2 Transaction confirmations;

16.4.3 Subscription renewal reminders;

16.4.4 Service updates and maintenance notifications;

16.4.5 Responses to support requests; and

16.4.6 Legal and regulatory notices.

You cannot opt out of service communications as they are necessary for the provision of the Services.

16.5 Third-Party Marketing

We do not share your Personal Information with third parties for their own marketing purposes without your explicit consent. There is no third-party marketing or advertising on our Platform.

17. THIRD-PARTY SERVICES

17.1 General Principle

Our Platform may contain links to third-party websites, apps, and services. This Privacy Policy does not apply to the privacy practices of these third parties.

17.2 Responsibility for Third Parties

17.2.1 We are not responsible for the privacy practices of third parties;

17.2.2 We do not endorse or accept responsibility for third-party content;

17.2.3 Third-party privacy policies may differ from ours; and

17.2.4 Your interactions with third parties are at your own risk.

17.3 Social Media Integration

The Platform may allow you to connect with social media sites, including Google and Facebook. When you connect:

17.3.1 The social media site's privacy policy will apply;

17.3.2 You are bound by the social media site's terms;

17.3.3 We may receive Personal Information from the social media site; and

17.3.4 The social media site may receive information from us.

18. USER RESPONSIBILITIES

18.1 General Responsibilities

You are responsible for:

18.1.1 Providing accurate and up-to-date Personal Information;

18.1.2 Keeping your Personal Information secure;

18.1.3 Protecting your Account credentials;

18.1.4 Not sharing your Account with others;

18.1.5 Using the Services in accordance with our Terms of Service;

18.1.6 Not uploading unlawful content;

18.1.7 Reporting security incidents promptly; and

18.1.8 Complying with applicable laws.

18.2 Accuracy of Information

You must:

18.2.1 Provide accurate and complete Personal Information;

18.2.2 Update your Personal Information as necessary;

18.2.3 Not provide false or misleading information;

18.2.4 Not impersonate any other person; and

18.2.5 Not use another User's Account.

18.3 Account Security

You must:

18.3.1 Use strong passwords;

18.3.2 Keep your password confidential;

18.3.3 Not share your Account access credentials;

18.3.4 Log out of your Account when not in use;

18.3.5 Notify us immediately of any unauthorised access; and

18.3.6 Ensure your devices are secure.

19. CHANGES TO THIS PRIVACY POLICY

19.1 Updates

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements.

19.2 Notification of Changes

We will notify you of material changes by:

19.2.1 Sending an email to the address associated with your Account;

19.2.2 Posting a prominent notice on our Website and/or App; and

19.2.3 Updating the "Last Updated" date at the top of this policy.

19.3 Timing of Changes

19.3.1 Minor changes may take effect immediately upon posting;

19.3.2 Material changes will take effect 30 (thirty) calendar days after notification; and

19.3.3 Where required by law, we will obtain your consent.

19.4 Your Acceptance

Your continued use of our Services after the effective date of changes constitutes your acceptance of the updated Privacy Policy. If you do not agree, you should discontinue using our Services and contact us to close your Account.

20. CONTACT INFORMATION

20.1 Contact Details

For any questions, concerns, or requests regarding this Privacy Policy or the processing of your Personal Information, please contact us at:

21. COMPLIANCE REVIEW

22. ACKNOWLEDGEMENT

By using the Services, creating an Account, or providing Personal Information to Sgela Edu Tech, you acknowledge that:

1. You have read and understood this Privacy Policy;
2. You agree to the collection, use, and disclosure of your Personal Information as described in this Privacy Policy;
3. You consent to the processing of your Personal Information for the purposes set out in this Privacy Policy;
4. You understand your rights under POPIA and how to exercise them;
5. You have provided accurate and complete Personal Information;
6. You will keep your Personal Information up to date; and
7. You will comply with all applicable laws and regulations.

END OF PRIVACY POLICY