Learnly Privacy Policy
Effective Date: 24 September 2025
1. Introduction
Welcome to Learnly! This Privacy Policy explains how Learnly ("we," "us," or "our") collects, uses, shares, and protects your personal information when you use our e-learning platform, including our website, services, and our AI-powered tutors (collectively, the "Service").
Our commitment is to be transparent about the data we collect and to protect your privacy. By registering for and using our Service, you agree to the collection and use of information in accordance with this policy.
2. Information We Collect
We collect information in a few different ways to provide and improve our Service.
A) Information You Provide to Us:
Account Information: When you register for a Learnly account as a student or educator, we collect personal information such as your full name, email address, and a password.
Course Content (Educators): Educators may upload course materials, which we store to provide the Service to their enrolled students.
Communications: If you contact us directly for support, we may receive additional information about you, such as your name, email address, and the contents of your message.
B) Information from Your Use of the AI Tutors:
Initial Anonymity: When you first interact with our AI Tutors, you are assigned a temporary guest name. We do not link your personal account information to the chat at this stage.
Conversation Data: We collect and store the contents of your conversation with the AI Tutor. This is done for the sole and specific purposes outlined in Section 3 of this policy.
Information for Escalation: The AI Tutor will only ask for your student email address if you explicitly choose to escalate a question or problem to your teacher/educator. This information is collected only at the moment of escalation and with your direct consent to do so.
C) Information We Collect Automatically:
Log Data: Like most websites, we collect information that your browser sends whenever you visit our Service. This may include your IP address, browser type, pages visited, and the time and date of your visit.
Cookies: We use cookies to operate and administer our site and to improve your experience. Please see Section 8 for more information.
3. How We Use Your Information
We use the information we collect for the following specific purposes:
To Provide and Maintain our Service: To create your account, host course content, and provide you with access to our platform.
To Facilitate AI Tutoring: To process your questions and provide responses from the AI Tutor based on the relevant course content.
To Enable Teacher Support: To store conversation logs for the specific purpose of allowing an educator to review a question that a student has escalated to them.
To Provide Platform Support: We may use conversation data with our Platform Assistant to diagnose and resolve technical issues that you escalate to our support team.
To Improve Our Platform: We may use anonymized and aggregated data to understand how our users interact with the Service and to make improvements. We will never use your personal conversation data for this purpose without your explicit consent.
To Comply with Legal Obligations: To enforce our agreements and comply with our legal obligations.
We will never sell your personal information or use your conversation data for marketing or advertising purposes.
4. How We Share Your Information
We do not share your personal information with external parties, except in the limited circumstances described below.
With Your Educator (Upon Escalation): When you consent to escalate a question, we will share the conversation transcript along with the student email you provided with the relevant educator for that course.
With Our Service Providers: We use third-party service providers to help us operate our Service. These providers are contractually obligated to protect your information and are not permitted to use it for any other purpose. Our key service providers are:
Amazon Web Services (AWS): Our primary platform, including student and educator data, is hosted on AWS servers.
LeadSystems: The AI chatbot widgets are provided through our LeadSystems (Pty) Ltd platform. This service processes the AI conversations to provide the tutoring service.
Our Commitment Regarding Third-Party AI Processing: Our AI service providers are engaged as "Operators" under POPIA, meaning they process data on our behalf and under our instruction. We have taken contractual and technical measures to ensure that our providers do not use any of your conversation data to train their own artificial intelligence models. Your data is used solely for the purpose of providing the tutoring service back to you.
For Legal Reasons: We may disclose your information if required to do so by law or in response to valid requests by public authorities.
5. Data Retention and Security
Data Retention: We retain your account information for as long as your account is active. If you choose to delete your account, your personal information will be permanently deleted from our production systems within 30 days. Conversation data from the AI Tutors that has been escalated to a teacher or our support team is retained for a period of up to 12 months after the issue is resolved to ensure a complete support history, after which it is securely deleted or fully anonymized.
Data Security: We take the security of your data very seriously and implement a range of security measures, including end-to-end encryption and strict access controls, to protect your information. However, no method of transmission over the Internet is 100% secure, and we cannot guarantee its absolute security.
6. Your Rights Under POPIA
As a user in South Africa, you have the following rights under the Protection of Personal Information Act (POPIA):
The right to be notified that your personal information is being collected.
The right to access the personal information we hold about you.
The right to request the correction, destruction, or deletion of your personal information.
The right to object to the processing of your personal information.
The right to withdraw consent at any time.
To exercise any of these rights, please contact us at [Your Support Email Address].
If you are not satisfied with our response to your query, you have the right to lodge a complaint with the South African Information Regulator.
Contact details for the Information Regulator:
Website: https://inforegulator.org.za/
Email: [email protected]
7. International Data Transfers
Our service providers may host and process your data in locations outside of South Africa. Where this is the case, we will take all reasonable steps to ensure that your data is treated securely and that the receiving party is subject to laws or binding agreements that provide an adequate level of protection.
8. Cookies and Tracking Technologies
We use cookies (small text files placed on your device) and similar technologies to provide our website and online services and to help collect data. Cookies allow us to store your preferences and settings, enable you to sign in, and analyze how our website and online services are performing. You can use your web browser's controls to limit how websites use cookies.
9. Children's Privacy
Our Service is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child without verification of parental consent, we will take steps to remove that information from our servers.
10. Information Officer
In accordance with the Protection of Personal Information Act, we have appointed an Information Officer who is responsible for ensuring our compliance with the Act. If you have any questions or concerns about how we handle your personal information, you may contact our Information Officer at the details below.
Information Officer: Charles Siwele, CEO
Email: [email protected]
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new policy on this page and updating the "Effective Date" at the top. We encourage you to review this Privacy Policy periodically for any changes.
12. Contact Us
If you have any questions about this Privacy Policy, please contact us at:
Email: [email protected]
Website: https://www.learnly.co.za