Proposed Privacy Notice

1. Who is responsible for the information

Philani Academy operates MathNative and is the responsible legal entity identified for this draft.

Registered name

Philani Academy

Registration number

K2025900793

Postal / service address

D1051 Hlokozi Road, Highflats, 3306, South Africa

Information Officer / privacy contact

support@philani.academy.org

This draft is framed against the Protection of Personal Information Act 4 of 2013 (POPIA). It is not a legal determination that every current feature or international data transfer complies with every applicable law.

2. Information collected and where it comes from

Signup information is entered by the learner or account creator. School and grade information entered during signup is recorded as user-reported unless MathNative separately identifies it as verified. Guardians provide an email address and an approval declaration for an account recorded as belonging to a learner under 18. Learning, group, report, and device records are generated when the related features are used.

• Signup and account security: First and last name, email address, password hash, South African mobile number, date of birth, school or institution, grade, account status, email-verification status, and recovery details you provide. A learner recorded as under 18 must also provide a parent or legal guardian email address. Passwords are stored as hashes, not readable passwords.
• Profile, identity, and affiliation: Display name, profile image and cover, biography, school and grade affiliations, privacy and discovery choices, and profile activity. Profile can also contain residential address, emergency-contact name, relationship and phone number, and a South African ID number if supplied.
• Learning and shared work: Question prompts, typed answers, written mathematical work including LaTeX, quiz and assignment responses, learning sessions, posts, replies, uploaded files, group participation, and other material you choose to create or share.
• Safety, consent, and service records: Terms and Privacy Notice version acknowledgements, guardian approval email and status, privacy settings, reports and report details, blocks, notifications, active sessions, and push-notification device tokens where you enable them.

Signup currently requires names, email, password, date of birth, South African mobile number, school or institution, grade where applicable, and agreement to the Terms and acknowledgement of the Privacy Notice. A guardian email is required when the entered date of birth indicates the learner is under 18. Without required details, the account cannot be created or activated. Profile information, including residential and emergency-contact details, may be requested when completing a Profile; a South African ID number can be supplied there.

MathNative subscription checkout is not yet implemented. This draft does not describe payment-card collection as a current feature. If paid plans are introduced, the Privacy Notice and transaction disclosures must be updated before payment data is collected.

3. Why information is used

• Create, authenticate, recover, and administer accounts; verify the email address; and protect against unauthorised access.
• Use the date of birth entered at signup to decide whether the account must remain pending for guardian approval, send the approval email, and record the guardian declaration and policy versions.
• Provide learning sessions, assignments, groups, school and grade workspaces, profiles, posts, replies, sharing and privacy controls requested by users.
• Send account, learning, safety, and service notifications, including push notifications when that feature is enabled.
• Receive and assess user reports, protect learners and the service, investigate suspected misuse, record moderation access and outcomes, and respond to support requests.
• Meet legal obligations and establish, exercise, or defend legal claims where permitted by law.

Where MathNative asks for consent, the current system records the Terms and Privacy Notice version and the time of the choice at signup; for an account recorded as under 18, those records are captured through guardian approval. Counsel must confirm the applicable legal basis for each purpose and whether the current choice is sufficient for child data and optional features.

4. Profiles, classrooms, and audiences

Profile discovery and post audiences are separate controls. The audience selected for a post determines who may view it, subject to workspace permissions and other access rules. An administrator with access to a selected grade workspace may open profiles eligible for discovery in that workspace. A private profile is not made discoverable through that access; administrators and instructors may still have access where required for authorised service or classroom administration.

A recipient may save or redistribute material they can view. A setting that limits an audience cannot make a shared post or file confidential after a recipient receives it. Review the audience and remove other people’s identifying information before sharing.

5. AI-assisted quiz feedback

When a signed-in learner requests quiz feedback, MathNative sends the selected grade, question prompt, written mathematical work or LaTeX, and typed answer to Google’s Gemini API to generate a short response. The code does not add the learner’s account name or email to that request, but a learner could include identifying details in their typed work or prompt.

The output can be wrong and should be checked against class instruction. The current feature has no separate opt-in for sending that work to the AI provider. Google’s applicable retention, training, and processing terms and the legal basis for this use—especially for children—must be verified before this draft is published. No claim is made here that the provider does not retain or use API inputs.

6. Who may receive information

Access is limited by account and workspace permissions, but authorised administrators or instructors may view information needed to operate a workspace, assist with learning, review a safety report, or secure the service. The current moderation tools record administrator access to reports and record the moderation outcome. Information may also be disclosed if required or permitted by law, to protect a person from serious harm, or to establish or defend a legal claim.

• Vercel: website hosting and Blob file storage used by resource-upload features.
• Google: Gemini API for requested AI quiz feedback; Firebase Cloud Messaging for push notifications when configured.
• Resend: email delivery for verification, password recovery, guardian approval, deletion, and service messages.
• Ably: realtime notification-change signals, including an internal account identifier, when configured.
• Jitsi / JaaS: live-session features where enabled; the provider, data flows, and current deployment configuration must be verified.
• Database host: MathNative uses a PostgreSQL database, but the production host and region are not identified in the application source and must be confirmed before publication.

Some resource-bank uploads currently use Vercel Blob public-access URLs. A person who obtains such a URL may be able to retrieve that file. Do not upload private learner records, confidential assessment material, or other personal information through a flow intended for shared educational resources. The intended access model must be confirmed before release.

The service is accessible internationally. These providers may process information outside South Africa; their exact processing countries, subprocessors, contract terms, and safeguards for cross-border transfers have not been verified in this draft. No statement that information stays in South Africa should be inferred.

7. Children and guardian approval

Signup uses the date of birth entered by the account creator. When it indicates that the learner is under 18, the account remains inactive until a parent or legal guardian uses the single-use approval link, which expires after 24 hours, and declares authority to approve. Email verification is a separate step. The service records the declaration; it does not independently verify the date of birth or relationship.

Expiry prevents use of the approval link; it does not by itself delete the learner account or approval-request record. A new link can be requested through the guardian approval page.

Signup currently has no minimum-age floor. Whether the present design is sufficient for children under 13, for South African children generally, or under laws where the service is accessible requires specialist review before release. This notice does not represent that guardian approval alone satisfies every applicable child-protection law.

8. Retention, exports, and deletion

Account information is retained while the account is active for the purposes described above. The current deletion page says that, after confirmed full-account deletion, deletion is processed immediately and minimal operational records may remain for up to 30 days for security, fraud prevention, backup recovery, or legal compliance. The precise records covered and the technical purge schedule must be confirmed before this proposed notice is adopted. Information may be kept longer where law requires or permits it, or where needed to resolve a dispute or protect the service.

A guardian approval link expires after 24 hours, but the associated account and request record are not automatically deleted on expiry. A data-only deletion request is emailed to support for review; submitting it does not itself delete the data.

A signed-in user can download an account export from Profile. The export is a JSON file and has record limits: up to 500 records for some categories, including posts, reports, blocks, group memberships and follows, and up to 1,000 for some notification and learning-response categories. It may not contain every record on a long-running account. Contact the Information Officer about information not included.

To delete an account, use Profile → Security, or if unable to sign in use the account and data deletion page. A full-deletion email link expires after one hour. A date-of-birth correction cannot currently be made in Profile; request it through the Information Officer.

9. Your choices and rights

Subject to applicable law and its exceptions, you may ask to access or correct personal information, object to or withdraw consent where that is the basis for processing, or request deletion. Use the available controls in MathNative or contact the Information Officer at support@philani.academy.org. We may ask for information needed to verify that you control the account before responding. Date-of-birth corrections require support review.

If you have a concern about how your information or request was handled, please contact our Information Officer first at support@philani.academy.org and explain what happened and what outcome you are seeking. This gives Philani Academy an opportunity to review and address your concern directly. Contacting us first is a request to help resolve the issue; it is not a condition for exercising a right or complaint process available under POPIA or other applicable law, including any right to lodge a complaint with the Information Regulator.

10. Security and incidents

MathNative uses account and workspace access controls, stores account passwords as hashes, rate-limits sensitive request flows, and records privileged access to moderation reports. These measures reduce risk but cannot guarantee that an online service will never experience unauthorised access or data loss.

If a security compromise occurs, Philani Academy will notify the Information Regulator and affected people as and when required by POPIA and other applicable law. Website/app diagnostic data, cookie behaviour, provider security terms, and the operational incident-notification process must be confirmed before this notice is adopted.

11. Changes and governing framework

A revised notice must show its version and effective date. Material changes will be explained and, where consent is required, the relevant user or authorised guardian will be asked for a fresh choice. The current system records policy versions during signup and guardian approval but does not request renewed acknowledgement from existing accounts; this must be addressed before adopting a material update.

This draft uses POPIA as the primary framework. It does not determine whether additional privacy or child-protection rules apply to users outside South Africa. The current published Privacy Notice remains version 2026-10-04 until legal and operational review is complete.