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SyntroLearn

SYNTROLEARN PRIVACY POLICY

LEARNING SA (PTY) LTD (Registration Number 2026/467676/07)

Last updated: 5 July 2026

LEARNING SA (PTY) LTD, trading as SyntroLearn (“SyntroLearn”, “we”, “us” or “our”), is a private company duly incorporated in accordance with the company laws of the Republic of South Africa, under registration number 2026/467676/07. We operate an online platform that connects students seeking academic support with independent tutors offering such support (the “Platform”).

This Privacy Policy explains, in plain and accessible terms, how we collect, use, store, share, and protect the personal information of everyone who uses the Platform, including students, parents or guardians acting on behalf of minor students, and tutors (collectively, “Users”, “you” or “your”). This Policy is issued in accordance with the Protection of Personal Information Act 4 of 2013 (“POPIA”) and should be read together with our Terms and Conditions, which govern your use of the Platform.

By accessing or using the Platform, creating an account, or otherwise providing us with your personal information, you acknowledge that you have read and understood this Policy. If you do not agree with any part of this Policy, you should not use the Platform.

1. DEFINITIONS

In this Policy, unless the context clearly indicates otherwise, the following terms shall bear the meanings assigned to them below, and cognate expressions shall bear corresponding meanings:

  1. “Information Officer” means the person appointed by SyntroLearn to ensure compliance with POPIA, as identified in the “Contact Us” clause below;
  2. “Information Regulator” means the Information Regulator established in terms of section 39 of POPIA;
  3. “Personal Information” has the meaning given to it in POPIA, and includes any information relating to an identifiable, living natural person and, where applicable, an identifiable, existing juristic person;
  4. “Platform” means the SyntroLearn website, web application, and any associated mobile applications, software, and services made available by SyntroLearn;
  5. “Processing” means any operation performed on Personal Information, including collection, receipt, recording, organisation, storage, updating, retrieval, use, dissemination, and destruction, as more fully defined in POPIA;
  6. “Student” means any individual who registers on the Platform to seek or receive tutoring services, and, where the individual is a minor, includes the parent or legal guardian who registers or manages the account on that minor’s behalf;
  7. “Tutor” means any individual who registers on the Platform to offer tutoring services to Students;
  8. “POPIA” means the Protection of Personal Information Act 4 of 2013, together with its regulations, as amended from time to time.

2. INFORMATION WE COLLECT

We collect Personal Information that is reasonably necessary to operate the Platform, to match Students with Tutors, to process payments, and to comply with our legal obligations. The categories of information we collect differ depending on whether you are registered as a Student or a Tutor, as set out below.

Information We Collect From Students

When a Student (or a parent or guardian on a minor Student’s behalf) registers on the Platform, we may collect the Student’s full name, date of birth, contact number, email address, physical or postal address, school or institution attended, grade or academic level, subjects for which tutoring is sought, and, where relevant to a minor Student, the full name and contact details of the parent or legal guardian.

We may also collect information relating to a Student’s learning needs, academic performance, preferences, scheduling availability, and any feedback or ratings submitted in respect of a Tutor, as well as payment and billing information required to process fees owed for tutoring services.

Information We Collect From Tutors

When a Tutor registers on the Platform, we may collect the Tutor’s full name, date of birth, identity number or passport number, contact number, email address, residential address, banking details for payment purposes, academic qualifications, curriculum vitae, subject specialisations, proof of qualifications, references, and, where applicable, a police clearance certificate or similar background screening documentation submitted voluntarily to enhance the Tutor’s profile.

We may further collect information relating to a Tutor’s availability, tutoring history on the Platform, ratings and reviews received from Students, and any communications exchanged with SyntroLearn regarding the Tutor’s conduct or performance on the Platform.

Information Collected Automatically

When you access or use the Platform, we may automatically collect certain technical information, including your Internet Protocol (IP) address, device type and identifiers, browser type and version, operating system, referring website, pages viewed, time spent on the Platform, and other usage or log data. This information is collected using cookies and similar tracking technologies, as further described in the “Cookies and Tracking Technologies” clause below.

Information From Other Sources

In limited circumstances, we may receive Personal Information about you from third parties, such as payment processors confirming a transaction, or another User who reports a concern involving you. We will only use such information in a manner consistent with this Policy.

3. HOW WE USE YOUR INFORMATION

We process Personal Information for the following purposes, each of which constitutes a lawful basis for processing under POPIA:

  1. to create, verify, and manage User accounts and profiles on the Platform;
  2. to match Students with suitable Tutors based on subject, level, availability, and stated preferences;
  3. to facilitate communication between matched Students and Tutors;
  4. to process, invoice, and reconcile payments for tutoring services rendered;
  5. to verify Tutor qualifications and, where submitted, background screening documentation;
  6. to respond to queries, complaints, and support requests;
  7. to monitor, investigate, and act upon reports of misconduct, breaches of our Terms and Conditions, or unlawful conduct;
  8. to send administrative communications, including booking confirmations, invoices, and service updates;
  9. with your consent (which you may withdraw at any time), to send marketing communications regarding features, promotions, or services that may be of interest to you;
  10. to maintain the security, integrity, and proper functioning of the Platform, including the prevention of fraud;
  11. to comply with applicable laws, regulations, court orders, or requests from a competent regulatory authority.

4. LEGAL BASIS FOR PROCESSING AND POPIA COMPLIANCE

SyntroLearn processes Personal Information only where a lawful justification exists under section 11 of POPIA, including where the Processing is necessary to conclude or perform under a contract to which the relevant User is a party (such as our Terms and Conditions), where it is necessary to pursue our legitimate interests or those of a third party (such as maintaining the safety and integrity of the Platform), where it is required to comply with an obligation imposed by law, or where the User has given consent to the Processing.

We collect only the minimum Personal Information reasonably required for the purposes described in this Policy, and we take reasonable steps to ensure that the information we hold is complete, accurate, not misleading, and updated where necessary.

5. CONDITIONS FOR LAWFUL PROCESSING OF PERSONAL INFORMATION

In addition to requiring a lawful justification for Processing, POPIA sets out eight conditions with which a responsible party must comply when processing Personal Information. SyntroLearn is committed to complying with each of these conditions, as summarised below:

  1. Accountability: SyntroLearn ensures that the conditions for lawful Processing, and all measures giving effect to such conditions, are complied with at the time of determining the purpose and means of Processing, and during the Processing itself;
  2. Processing Limitation: Personal Information is processed lawfully and in a reasonable manner that does not infringe your privacy, and is collected only directly from you (or, in the case of a minor Student, from a parent or guardian), save where an exception recognised by POPIA applies, and only to the minimum extent necessary and adequate for the purposes for which it is collected;
  3. Purpose Specification: Personal Information is collected for a specific, explicitly defined, and lawful purpose connected to the operation of the Platform, as set out in this Policy, and is not kept for longer than is necessary to achieve that purpose, save as permitted by law;
  4. Further Processing Limitation: Any further Processing of Personal Information is carried out in a manner that is compatible with the purpose for which it was originally collected;
  5. Information Quality: SyntroLearn takes reasonably practicable steps to ensure that the Personal Information we hold is complete, accurate, not misleading, and updated where necessary, having regard to the purpose for which it is processed;
  6. Openness: SyntroLearn maintains documentation of its Processing operations and makes this Policy available to Users to ensure transparency regarding how their Personal Information is processed;
  7. Security Safeguards: SyntroLearn implements appropriate, reasonable technical and organisational measures to protect the integrity and confidentiality of Personal Information, as further described in the “Data Security” clause below;
  8. Data Subject Participation: You have the right to establish whether SyntroLearn holds your Personal Information, to request access to and correction of that information, and, where applicable, to request its deletion, as further described in the “Your Rights Under POPIA” clause below.

6. YOUR RIGHTS UNDER POPIA

As a data subject, you have a number of rights in respect of the Personal Information that we hold about you. These rights include the right to:

  1. be notified that Personal Information about you is being collected;
  2. establish whether SyntroLearn holds Personal Information about you, and to request access to that information;
  3. request the correction, updating, or deletion of Personal Information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or obtained unlawfully;
  4. object, on reasonable grounds, to the Processing of your Personal Information;
  5. withdraw any consent you have previously given, at any time, without affecting the lawfulness of Processing carried out before such withdrawal;
  6. lodge a complaint with SyntroLearn’s Information Officer or, failing satisfactory resolution, with the Information Regulator, regarding the manner in which your Personal Information has been processed;
  7. submit a complaint to the Information Regulator regarding an alleged interference with the protection of your Personal Information.

To exercise any of these rights, please contact our Information Officer using the details set out in the “Contact Us” clause below. We will respond to legitimate requests within a reasonable time and, in any event, within the timeframes prescribed by POPIA. We may require you to verify your identity before we act on a request, in order to protect your information from unauthorised access.

7. DIRECT MARKETING COMMUNICATIONS

In accordance with section 69 of POPIA, SyntroLearn will only send you direct marketing communications by way of electronic communication (including email, SMS, or push notification) where you have given your prior consent to receive such communications, or where you are an existing User and the communication relates to similar products or services offered by SyntroLearn, in which event you will be given a reasonable opportunity to object, free of charge, at the time your information was collected and on each subsequent communication.

You may withdraw your consent to receive direct marketing communications, or opt out of further such communications, at any time, free of charge, by using the “unsubscribe” facility provided in the relevant communication, by adjusting your notification preferences on the Platform, or by contacting us using the details in the “Contact Us” clause below. Opting out of direct marketing communications will not affect our ability to send you operational or transactional communications necessary for the proper functioning of your account and the Platform, such as booking confirmations, invoices, or notices regarding changes to this Policy or our Terms and Conditions.

8. COOKIES AND TRACKING TECHNOLOGIES

The Platform uses cookies and similar tracking technologies to operate effectively, to remember your preferences, to understand how the Platform is used, and to improve our services. Cookies are small text files placed on your device when you visit a website.

We use the following categories of cookies: strictly necessary cookies, which are required for the Platform to function (such as those enabling you to log in and remain logged in); functional cookies, which remember your preferences and settings; analytics cookies, which help us understand how Users interact with the Platform so that we can improve it; and, where applicable, marketing cookies used to tailor communications to your interests.

You may control or disable cookies through your browser settings. Please note that disabling certain cookies, particularly strictly necessary cookies, may affect the functionality of the Platform and your ability to use certain features.

9. SHARING OF INFORMATION AND THIRD PARTIES

We do not sell Personal Information to third parties. We may, however, share Personal Information in the following circumstances, and only to the extent reasonably necessary:

  1. with a matched Student or Tutor, to the extent necessary to facilitate the tutoring relationship (for example, sharing a Tutor’s profile and contact details with a Student, and vice versa);
  2. with payment processors and financial institutions engaged to process transactions on the Platform, currently facilitated by Electronic Funds Transfer (EFT), and which may in future include card payment processors, instant EFT providers, or third-party payment gateways such as Stripe or PayPal, each of which processes Personal Information in accordance with its own privacy policy and applicable law;
  3. with service providers who assist us in operating the Platform, including hosting providers, customer support tools, communication tools, and analytics providers, each of whom is contractually bound to protect your Personal Information and to process it only for the purposes we specify;
  4. with a regulatory authority, law enforcement agency, or court of law, where required or permitted by applicable law, or where necessary to protect the rights, property, or safety of SyntroLearn, our Users, or the public;
  5. with a prospective purchaser, investor, or successor in the event of a merger, acquisition, restructuring, or sale of all or part of our business, subject to that party’s undertaking to protect your Personal Information in a manner consistent with this Policy;
  6. with your explicit consent, for any other purpose not covered above.

Where we engage a third-party operator to process Personal Information on our behalf, we take reasonable steps to ensure that the operator processes such information only with our knowledge and authorisation, and that it maintains the confidentiality and security of the information, as required by POPIA.

10. CROSS-BORDER TRANSFERS

Certain third-party service providers and payment processors we engage, whether now or in the future, may store or process Personal Information outside the borders of South Africa. Where this occurs, we take reasonable steps to ensure that the recipient of the information is subject to a law, binding corporate rules, or a binding agreement which provides an adequate level of protection that is substantially similar to the conditions for the lawful Processing of Personal Information set out in POPIA, or that you have consented to the transfer.

11. DATA RETENTION AND DELETION

We retain Personal Information only for as long as is reasonably necessary to fulfil the purposes for which it was collected, or as required to comply with applicable legal, regulatory, tax, accounting, or reporting obligations, or to resolve disputes and enforce our agreements.

As a general guide, and unless a longer or shorter period is required by law, we retain account and profile information for as long as your account remains active, and for a further period thereafter to allow for the resolution of any outstanding disputes, complaints, or financial reconciliations. Where you request the deletion of your account, we will delete or de-identify your Personal Information within a reasonable period, save to the extent that we are required or permitted by law to retain it, for example for financial record-keeping purposes.

12. DATA SECURITY

We implement appropriate technical and organisational measures, in accordance with section 19 of POPIA, to safeguard the confidentiality, integrity, and availability of Personal Information in our possession or under our control, and to prevent loss, damage, unauthorised destruction, or unlawful access to or Processing of such information.

While we take reasonable and appropriate steps to protect Personal Information, no method of electronic storage or transmission is entirely secure, and we cannot guarantee absolute security. Should a security compromise occur that has affected or may have affected your Personal Information, we will notify the Information Regulator and affected Users as soon as reasonably possible, in accordance with our obligations under POPIA.

13. MINORS AND PARENTAL CONSENT

We recognise that many Students who use the Platform are minors. Where a Student is a minor, the Platform requires that a parent or legal guardian register the account, provide the necessary consents, and take responsibility for the minor’s use of the Platform, in accordance with POPIA’s provisions on the Processing of personal information of children.

We process the Personal Information of a minor Student only where such Processing is carried out with the consent of, and under the supervision of, a parent or guardian, or where the Processing is necessary to establish, exercise, or defend a right or obligation in law, or is otherwise permitted under POPIA.

14. PROMOTION OF ACCESS TO INFORMATION ACT (PAIA)

In addition to your rights under POPIA, you may have a right of access to certain records held by SyntroLearn under the Promotion of Access to Information Act 2 of 2000 (“PAIA”). SyntroLearn’s PAIA manual, which sets out the categories of records held and the procedure for requesting access to such records, is available on request from our Information Officer using the details in the “Contact Us” clause below, and, where applicable, will be made available on the Platform.

A request for access to a record under PAIA must be made using the prescribed form and may be subject to the payment of a prescribed fee. SyntroLearn will process any such request in accordance with the timeframes and procedures set out in PAIA.

15. CHANGES TO THIS POLICY

We may update or amend this Policy from time to time to reflect changes in our practices, our services, or applicable law, including as we introduce additional payment methods or features. Where we make material changes, we will take reasonable steps to notify Users, including by posting a notice on the Platform or updating the “last updated” date at the top of this Policy. Your continued use of the Platform after such changes take effect will constitute your acceptance of the revised Policy.

16. DATA SUBJECT COMPLAINTS AND CORRECTIONS

If you believe that Personal Information we hold about you is inaccurate, incomplete, or has been processed unlawfully, or if you wish to lodge any complaint regarding our handling of your Personal Information, please contact our Information Officer using the details set out in the “Contact Us” clause below. We will investigate your complaint and respond within a reasonable time.

If you are not satisfied with our response, or with the manner in which your complaint has been handled, you have the right to submit a complaint to the Information Regulator of South Africa, whose contact details are: Information Regulator (South Africa), JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001; email: complaints.IR@justice.gov.za; website: www.justice.gov.za/inforeg.

17. CONTACT US

If you have any questions, requests, or complaints regarding this Privacy Policy or the manner in which we process your Personal Information, please contact our Information Officer at:

  1. Company: LEARNING SA (PTY) LTD, trading as SyntroLearn (Registration Number 2026/467676/07)
  2. Attention: The Information Officer
  3. Email: info@syntrolearn.com
  4. Postal Address: 39 Pitzer Road, Glen Austin, Johannesburg, Gauteng, 1684

We will endeavour to acknowledge and address all queries and complaints promptly and in accordance with our obligations under POPIA.

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