Purpose of this notice
This notice is published in terms of the Promotion of Access to Information Act 2 of 2000 (“PAIA”) and the Protection of Personal Information Act 4 of 2013 (“POPIA”). It tells you who our Information Officer is, what records we hold, how to request access to a record, and how to complain to the Information Regulator.
It sits alongside our Privacy Policy, which explains in detail what personal information we process and why.
Particulars of the responsible party
Sino Learn
Registration number: N/A
Eglin Road, Sandton, 2191
Johannesburg, South Africa
Email: info@sinolearn.co.za
Website: learn.sinotutor.co.za
Information Officer
Our Information Officer is responsible for compliance with POPIA and PAIA, and is your first point of contact for any request or complaint about personal information.
Angel Maile
Information Officer, Sino Learn
Eglin Road, Sandton, 2191
Johannesburg, South Africa
Email: info@sinolearn.co.za
Records we hold
Subject to the exclusions and grounds for refusal in PAIA, we hold the following categories of record:
- Learner account records - name, email address, grade, selected subjects, profile picture.
- Study activity records - bookmarks, timetable entries, study plans, and which resources an account has opened.
- Sino AI chat records - questions asked and answers given.
- Feedback and contact records - messages sent to us through the app or this website.
- Study material - past examination papers, memoranda, notes and summaries.
- Company records - statutory, financial, employment and tax records held under legislation such as the Companies Act, the Income Tax Act and the Basic Conditions of Employment Act.
How to request access to a record
To request access to a record we hold:
- Complete the prescribed PAIA request form, available from the Information Regulator’s website at inforegulator.org.za.
- Send the completed form to our Information Officer at info@sinolearn.co.za, or by post to the address above.
- Provide enough detail for us to identify the record and to identify you, and state the form of access you want.
- If you are requesting a record in order to exercise or protect a right, explain which right.
We will respond within 30 days. That period may be extended in the circumstances PAIA allows, and we will tell you if it is. A prescribed fee may apply to a request for access to records other than your own personal information; we will tell you before doing the work.
If you simply want to see, correct or delete your own account information, you do not need the PAIA form. Email info@sinolearn.co.za and we will help you directly.
When we may refuse a request
PAIA requires or permits us to refuse a request in certain cases, for example where granting it would unreasonably disclose someone else’s personal information, where the record is legally privileged, where it contains confidential commercial information, or where it would prejudice a person’s safety. If we refuse, we will tell you in writing which ground we rely on and how to appeal or complain.
Your rights as a data subject
POPIA gives you the right to be told what personal information we hold, to have it corrected or deleted where appropriate, to object to processing on reasonable grounds, to withdraw consent, and to complain. Our Privacy Policy sets these out in full, including the special protections that apply to learners under 18.
Complaints to the Information Regulator
Please raise a concern with our Information Officer first so that we can put it right. You may, at any stage, lodge a complaint with the Information Regulator (South Africa):
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
P.O. Box 31533, Braamfontein, Johannesburg, 2017
Complaints: complaints.IR@justice.gov.za
General enquiries: enquiries.IR@justice.gov.za
Telephone: 010 023 5200
Website: https://inforegulator.org.za
PAIA manual
Our PAIA manual is available free of charge from our Information Officer on request at info@sinolearn.co.za.