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This is the Privacy Policy of CambriLearn (“we”, “us” or “our”). It tells you what personal information we collect about you and, where applicable, your child; why we collect it; who we share it with; how long we keep it; how we keep it safe; and the rights you have in relation to it.
It is written in plain language so that parents, guardians and learners can understand it. If there is anything you do not understand, please contact our Information Officer using the details in section 17 below.
This policy applies to:
This policy covers the entirety of CambriLearn’s activities. It is the only privacy policy you need to consult to understand how we handle your personal information. Where we introduce a new tool or feature, we describe it in this policy rather than maintaining a separate notice for each.
CambriLearn is operated, for the purposes of the processing of personal information in South Africa, by Top Dog Internet Sales (Pty) Ltd t/a CambriLearn (registration number 2010/013984/07), a company incorporated in the Republic of South Africa with its registered office at 155 West Street, Sandton, 2031, South Africa.
Our affiliated United States entity is CambriLearn USA, Inc. The South African and United States entities operate under a shared brand and shared platform. For personal information collected in connection with services provided in or from South Africa - which includes all of the learning platform and assessment processing described in this policy - the South African entity is the “responsible party” for the purposes of the Protection of Personal Information Act 4 of 2013 (“POPIA”), and the “controller” for the purposes of the European Union General Data Protection Regulation (“GDPR”), to the extent the GDPR applies.
We collect the following categories of personal information, depending on your interaction with us:
We collect personal information for the following purposes:
We process personal information on the following lawful bases under POPIA:
Where you or your child uses any feature on our platform through which communications take place - including the online chat, live group sessions and lessons, forums, CambriCommunity, comments, and any other channel we provide - the communications take place on systems we operate and may be monitored, moderated, recorded or reviewed by CambriLearn for the following purposes:
This monitoring is limited to communications that take place through CambriLearn channels. It does not extend to communications between you and any third party outside of the platform. Where lessons are recorded, this is disclosed at the time of the lesson and the recordings are retained in accordance with Section 12 below.
To the extent that this monitoring is governed by the Regulation of Interception of Communications and Provision of Communication-Related Information Act 70 of 2002 (“RICA”), you consent to it for the purposes set out above. You should not transmit, through any CambriLearn channel, any communication that you wish to remain private from CambriLearn.
CambriLearn uses an AI-assisted marking tool called CambriGrader to support our teachers in marking learner assessments. This is one of the tools we use to deliver our service and we describe it here for transparency.
How CambriGrader works:
Important points to note:
You have the right to object to the use of CambriGrader in respect of your or your child’s assessments. If you do, please contact our Information Officer (Section 17) and we will arrange for the affected assessments to be marked manually by a teacher. Objection does not affect any other aspect of the enrolment.
We share personal information only with the following categories of recipient and only to the extent necessary:
Operators process personal information on our behalf, in accordance with our instructions, and are bound by written contracts requiring them to maintain appropriate security and confidentiality. Our principal operators are:
A full list of operators is maintained in our internal Record of Processing Activities and is available on request to the Information Officer.
Where a learner is registered for formal assessment, we share the necessary registration details with the relevant examination body (such as Pearson Edexcel, Cambridge Assessment International Education, the IEB, SACAI or Cognia). These bodies act as independent responsible parties in respect of the personal information they receive.
Where a learner attends a CambriLearn-affiliated tutor centre, we share the necessary information with that centre to coordinate the learner’s support.
Where a subscription is purchased through one of our affiliates, we may share with that affiliate such information as is necessary to administer the affiliate relationship and the subscription. We do not share personal information with affiliates for their own marketing purposes.
We will disclose personal information where the law requires us to do so, or where disclosure is necessary to protect our rights or the safety of any person, including in response to subpoenas, court orders or other legal process.
We do not sell your personal information. We do not share your personal information with third parties for their own marketing purposes. We do not transfer personal information to any operator that does not undertake to maintain appropriate security and confidentiality.
Payments are processed by an external payment gateway. CambriLearn does not store full payment card numbers on its own systems. The payment gateway is responsible for compliance with the Payment Card Industry Data Security Standard (PCI DSS) in respect of card data.
Our website uses cookies and similar technologies, including Google Tag Manager and analytics cookies, to operate the site and to understand how it is used. Cookies fall into the following categories:
You can manage your cookie preferences through your browser settings and through the cookie banner on our website. Withdrawing consent to analytics and marketing cookies will not affect your access to the learning platform.
Because we use international providers (in particular Google LLC for the Gemini AI marking service, and various cloud infrastructure providers), some of your personal information may be transferred to, and stored or processed in, countries outside South Africa, including the United States, the European Union and the United Kingdom.
We rely on the following safeguards under section 72 of POPIA to ensure that your information remains adequately protected:
If you have questions about the safeguards in place for any particular transfer, please contact our Information Officer.
We keep personal information only for as long as is necessary for the purpose for which it was collected, or as required by law. Our default retention periods are:
Google’s logs of prompts and responses on the paid Gemini API are retained by Google for a limited period for the sole purpose of detecting and preventing abuse, as described in Google’s terms.
At the end of the applicable retention period, we delete or de-identify the personal information.
We take the security of your personal information seriously. We have implemented appropriate technical and organisational measures, including:
No system is completely secure. If you suspect that the security of your account has been compromised, please contact our Information Officer immediately.
Many of our learners are children under the age of 18; many others, particularly at A-Level and equivalent post-matric levels, are adults of 18 or older. The position differs between the two groups.
For learners who are children, we process personal information only with the prior consent of a parent or legal guardian (a “competent person” as defined in POPIA), given at enrolment through our Terms and Conditions. The consent extends to all the processing described in this policy, including the use of CambriGrader and the cross-border transfers described in Section 11. The competent person may withdraw consent at any time by contacting our Information Officer. Withdrawal will not affect the lawfulness of any processing carried out before the withdrawal but may affect our ability to continue providing services.
For learners who are 18 years of age or older (or who have reached the age of adulthood in their country of residence), the learner gives consent in their own capacity at enrolment. References elsewhere in this policy to consent given by a parent or legal guardian apply, in the case of adult learners, to consent given by the learner directly.
We do not market to children. Marketing communications are sent only to (a) parents and guardians who have opted in, or (b) adult learners who have opted in.
We will only send you marketing communications by electronic means (such as email or SMS) if you have separately opted in to receiving them, or if you are an existing customer and the marketing relates to similar products or services to those you have already purchased.
Every marketing communication includes an unsubscribe link or instructions for opting out. You can also opt out at any time by emailing hello@cambrilearn.com or by contacting our Information Officer.
You have the following rights in relation to the personal information we hold about you and your child:
To exercise any of these rights, please contact our Information Officer (Section 17). We will respond within 30 days of receiving a complete request. There is no charge for exercising these rights, although we may charge a reasonable fee for the production of copies of voluminous records, in accordance with the prescribed fees under POPIA.
Our Information Officer is the person responsible for compliance with POPIA in our organisation. The Information Officer is registered with the Information Regulator of South Africa.
You can contact the Information Officer at:
Top Dog Internet Sales (Pty) Ltd t/a CambriLearn
Attention: The Information Officer
155 West Street, Sandton, 2031
Email: hello@cambrilearn.com
Telephone: +27 010 020 8570
If you believe that we have processed your personal information unlawfully, or that we have not properly responded to a request you have made, you have the right to complain.
We would prefer the opportunity to address your concern. Please contact our Information Officer at the details in Section 17. We will acknowledge your complaint within seven (7) days and provide a substantive response within thirty (30) days.
If you are not satisfied with our response, or if you would prefer to complain directly, you may lodge a complaint with the Information Regulator of South Africa:
Information Regulator (South Africa)
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
PO Box 31533, Braamfontein, Johannesburg, 2017
Telephone: +27 (0)10 023 5200
General enquiries: enquiries@inforegulator.org.za
POPIA complaints: POPIAComplaints@inforegulator.org.za
Website: https://inforegulator.org.za
The Regulator publishes a complaint form on its website. You may use that form or write to the Regulator setting out the substance of your complaint.
If your personal information is involved in a security compromise that is likely to cause you harm, we will notify you and the Information Regulator as soon as reasonably possible after we become aware of the compromise and have established its scope. Our notification will include the nature of the compromise, the steps we have taken to address it, and any steps we recommend you take to protect yourself.
We may update this policy from time to time. Minor changes — such as updates to contact details or clarifications of existing provisions — will take effect immediately on publication of the updated policy.
Material changes that introduce new processing purposes, new categories of recipient, or new categories of personal information will not apply to your personal information unless we have given you specific notice of the change and, where required, obtained fresh consent. Continued use of our services after a material change will not by itself be treated as consent to that change.
The effective date of this policy is set out at the top of this document.
If you would like a copy of this policy in an alternative accessible format, please contact our Information Officer.
