Privacy Policy

Introduction

This Privacy Policy explains how Sino Learn(“Sino Learn”, “we”, “us”) collects, uses, shares and protects personal information when you use the Sino Learn mobile app and this website.

We are the responsible partyfor this information as defined in the Protection of Personal Information Act 4 of 2013 (“POPIA”). Sino Learn is used by school learners, including children under 18, so we take particular care with the information we hold. Please read this policy together with our Terms & Conditions.

Our lawful basis for processing

POPIA requires that we meet at least one lawful condition before we process your personal information. We rely on the following:

Consent. You (or, if you are under 18, your parent or guardian) consent to us creating an account and processing the information described below.
Performance of a contract. We must process your account information to give you the service you signed up for.
Legitimate interests. We process limited technical information to keep the service secure, prevent abuse, and fix faults.
Legal obligation. We may process information where a law requires it.

You may withdraw consent at any time. Withdrawing consent does not make our earlier processing unlawful, but it may mean we can no longer provide the service.

What we collect

We collect only what the service needs to work:

Account information: your name, email address and password (stored in hashed form; we never see your password).
Profile information: your grade, the subjects you select, your focus areas, and an optional profile picture.
Study activity: the papers and notes you open, your bookmarks, your timetable entries and your study plans.
Sino AI chat history: the questions you ask Sino AI and the answers it gives, saved to your account so you can revisit them.
Feedback and support messages you choose to send us, including messages sent through the contact form on this site.
Technical information: app version, device type and basic error logs, used to diagnose faults and keep the service secure.

We do not collect your identity number, your physical address, your school marks, or payment details. Sino Learn is free and we do not process card information.

Why we use it, and purpose limitation

We use your information only for the purposes it was collected for: to give you access to past papers, memos and notes; to personalise which subjects and grade you see; to run Sino AI and keep your chat history; to let you plan your studying; to respond to your feedback; and to keep the service working and secure.

We do not sell your personal information. We do not use your information for advertising or behavioural profiling, and we do not share it with advertisers. If we ever want to use your information for a new purpose, we will ask you first.

Children's information

Sino Learn is designed for learners in Grades 8 to 12, which means most of our users are children under 18. POPIA treats the personal information of a child as special personal information and requires the consent of a competent person, normally a parent or legal guardian.

If you are under 18, you must have your parent or guardian’s permission before you create an account and use Sino Learn.
By allowing a child to use Sino Learn, a parent or guardian consents to the processing described in this policy.
A parent or guardian may ask to see, correct or delete their child’s information, or withdraw consent, by contacting us at info@sinolearn.co.za.
We collect the minimum necessary from a learner and we do not require a child to disclose more than is reasonable to use the service.

Sino AI and your questions

Sino AI is a study assistant. When you send it a question, the text of that question, and the relevant context from your profile such as your grade and subject, is sent to our AI processing provider so that an answer can be generated. The exchange is then saved to your account.

Do not put personal details you would not want stored, such as identity numbers or contact details of other people, into a Sino AI chat. You can delete a chat session from your account at any time.

Sino AI can be wrong. It is a study aid, not a teacher and not an examiner, and it must not be used to cheat. See our Acceptable Use Policy.

We share personal information only with operators who process it on our instruction, under contract, and who are required to keep it secure:

Supabase - our database, authentication and file storage provider.
Our AI processing provider - processes Sino AI questions to generate answers.
Our hosting and email providers - deliver this site and transactional email such as password resets.

We may also disclose information if the law requires it, or to establish, exercise or defend a legal claim.

Cross-border transfers

Some of our operators host infrastructure outside South Africa, which means your personal information may be transferred to and stored in another country. This includes our Supabase project and our AI processing provider.

Section 72 of POPIA permits such a transfer where the recipient is subject to a law, binding corporate rules or a binding agreement that provides an adequate level of protection comparable to POPIA, or where the transfer is necessary to perform our contract with you. We rely on contractual safeguards with our operators to meet this requirement.

How long we keep it

We keep your information for as long as your account is open. If you delete your account, we delete or de-identify your personal information, except where a law requires us to keep a record for longer.

Basic security and error logs are kept for a short period and then discarded.

How we protect it

We use appropriate, reasonable technical and organisational measures as required by section 19 of POPIA. These include encryption in transit, hashed passwords, database row-level security so that one learner cannot read another learner’s data, and restricted administrative access.

No system is perfectly secure. Keep your password private, and tell us immediately if you think someone else has access to your account.

Your rights

Under POPIA you have the right to:

Access - ask what personal information we hold about you and request a copy.
Correction - ask us to correct information that is wrong, misleading or out of date.
Deletion - ask us to delete information we are no longer entitled to keep, or delete your account entirely.
Objection - object, on reasonable grounds, to our processing of your information.
Withdraw consent - at any time, as described above.
Complain - to us, and to the Information Regulator.

To exercise any of these rights, email info@sinolearn.co.za. We will respond within a reasonable time. See our POPIA & PAIA notice for the formal request procedure.

If something goes wrong

If personal information is accessed or acquired by an unauthorised person, section 22 of POPIA requires us to notify the Information Regulator and every affected person as soon as reasonably possible after discovering the breach. Our notification will describe what happened, the likely consequences, and what you can do to protect yourself.

Information Officer and complaints

Our Information Officer is:

Angel Maile
Sino Learn
Eglin Road, Sandton, 2191
Johannesburg, South Africa
info@sinolearn.co.za

If you are not satisfied with how we have handled your information, you may 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
Enquiries: enquiries.IR@justice.gov.za
Telephone: 010 023 5200

Changes to this policy

We may update this policy as the service changes. We will update the “Last updated” date above, and if a change is significant we will tell you in the app before it takes effect.