Privacy & POPIA
Draft for legal review — last updated [DATE]. This notice must be checked by a South African privacy lawyer before it is relied on.
1. Who we are
- Responsible party: [LEGAL NAME OF BUSINESS / OWNER], trading as AI Buddies
- Registration number: [CIPC NUMBER, if any] · VAT number: [VAT NUMBER or “not VAT registered”]
- Physical address: [STREET ADDRESS, TOWN, POSTAL CODE] · Postal address: [IF DIFFERENT]
- Information Officer: [NAME], [EMAIL], [PHONE] (registered with the Information Regulator on [DATE])
2. Children
Our learners are children (under 18). Under the Protection of Personal Information Act (POPIA), we only process a child’s personal information with the prior consent of a parent or legal guardian. Accounts are created and managed by the parent or guardian. Please use a nickname for your child.
3. What we collect and why
- Parent or guardian: name, email, phone and payment details needed to buy courses and give access (contract; legal duties such as tax records).
- Learner (on the learning platform): nickname, grade, course progress and quiz scores (to deliver the courses, with parental consent).
- AI buddy (if used): the typed or spoken question is sent to our AI and speech providers to produce an answer. We do not store chats or recordings. Visitor IP addresses are briefly kept in scrambled (hashed) form only to stop misuse.
- Website: essential cookies only (for example language choice and, if you buy, the basket). We do not use advertising or tracking cookies.
4. Who helps us (operators)
Website hosting: xneelo (South Africa). Learning platform: Coursebox [CONFIRM HOSTING REGION]. Payments: Paystack (card details go directly to Paystack, never to us) [CONFIRM]. AI and speech: [PROVIDER NAMES AND REGIONS]. Each operator processes information only on our instructions under a written agreement.
5. Information sent outside South Africa
Some operators may process information outside South Africa. We only do this where POPIA section 72 allows it (for example adequate protection or binding agreements) and, where required for children’s information, after obtaining any authorisation needed from the Information Regulator. [LEGAL REVIEW: confirm s57/s72 position.]
6. Photos and voices of Zack and Matthew
The pictures (and any voice clips) of Zack and Matthew on this site are used with their parents’ written consent. The AI buddy is a computer program; it is not Zack or Matthew.
7. How long we keep information
Order and invoice records: as long as tax law requires [CONFIRM WITH ACCOUNTANT, generally 5 years]. Learner accounts: until the parent asks us to delete them or [PERIOD] after the last activity. Security logs: [PERIOD].
8. Your rights
You may ask to see, correct or delete your or your child’s information, object to processing, or withdraw consent at any time by emailing [EMAIL]. We will not send marketing without your opt-in. You may complain to the Information Regulator: inforegulator.org.za, enquiries@inforegulator.org.za.
9. Security and breaches
We use HTTPS, strong passwords with two-factor login for administrators, and keep secret keys off the public website. If a breach affects your information, we will tell you and the Information Regulator as POPIA section 22 requires.
10. PAIA manual, terms and refunds
Our PAIA manual: [LINK]. Course terms: [LINK]. Cancellation and refund policy: [LINK]. (Electronic Communications and Transactions Act section 43 details: business name, address, prices including VAT, and these policies.)