Qwill Privacy Policy
This Privacy Policy explains how we collect, use, store, share, and protect personal information when you use Qwill, a digital maths practice product ("Qwill", "the Service"). It is written to comply with the Protection of Personal Information Act, 2013 (POPIA). Please read it together with the Qwill Terms and Conditions, of which it forms part.
By using Qwill or making a purchase, you confirm that you have read and understood this Policy.
1.Who is responsible for your information
The responsible party (the party that decides why and how your personal information is processed) is:
- Legal entity: AI Sorted (Pty) Ltd ("AI Sorted", "we", "us", "our")
- Registration number: 2026/353444/07
- Registered and trading address: 225 Willson Street, Fairland, Randburg, Gauteng, 2170, South Africa
- Email: dean@aisorted.co.za
Information Officer: Dean Hodgskiss (Managing Director), reachable at dean@aisorted.co.za. The Information Officer is responsible for our POPIA compliance and is your point of contact for any privacy question, request, or complaint.
2.What this Policy covers
This Policy covers personal information we process about: the parent, guardian, or other adult who buys and holds the account ("you"); and the learner for whom the Service is used ("the learner"). It applies to the Qwill website and application and to any related communication with us.
3.What personal information we collect
We aim to collect the minimum needed to run the Service.
From the account holder (parent or guardian):
- name and email address;
- login and account details;
- records of your purchases (what you bought and when); and
- messages you send us, such as support queries.
We do not receive or store your full card or banking details. Payment is handled by our payment gateway (see clause 8).
About the learner:
- a learner profile only: a first name or nickname, and the grade and term being practised; and
- practice activity and results, such as which tests were attempted and the scores.
We do not require or collect a learner's surname, identity number, photograph, or any special personal information.
Automatically, when you use the Service:
- basic technical and usage information such as device type, browser, and pages or activities used, collected through cookies and analytics (see clause 7).
4.How we collect it
We collect personal information directly from you when you create an account, make a purchase, set up a learner profile, or contact us. We also collect technical and usage information automatically through cookies and analytics tools when you use the Service. We are not required by law to collect this information, but without the account and learner details we cannot provide the Service.
5.Why we process it, and our legal basis
We process personal information to:
- create and manage your account and learner profiles, and give access to purchased content (basis: performance of our contract with you);
- process your payment and confirm your purchase (basis: contract);
- track practice activity and show results and progress (basis: contract);
- respond to your support queries (basis: contract and our legitimate interest in helping you);
- maintain, secure, and improve the Service through analytics (basis: our legitimate interest in a safe, working, improving product);
- send you marketing about Qwill, where you have agreed to receive it (basis: your consent, see clause 9); and
- meet our legal and regulatory obligations, such as keeping records (basis: legal obligation).
We will not use your information for a new, unrelated purpose without telling you and, where required, getting your consent.
6.Children's personal information
Qwill is used by learners who are children under POPIA (under 18). The law gives children's personal information special protection and requires the consent of a "competent person", normally a parent or guardian.
We do not deal with children directly. Accounts are created and controlled by an adult account holder. When you set up a learner profile, you confirm that you are the parent or guardian of that learner, or have their consent, and that you consent, as the competent person, to us processing the learner's profile and practice results for the purposes in this Policy.
We keep what we hold about a learner to the minimum (a first name or nickname, grade and term, and results), and we do not use a learner's information for marketing. You can review, correct, or ask us to delete a learner profile at any time using the contact details below.
7.Cookies and analytics
We use cookies and similar technologies for two purposes:
- Essential cookies: needed to log you in, keep your session active, and run the Service. These cannot be switched off without breaking the Service.
- Analytics cookies: to understand how the Service is used so we can improve it, for example which features are used and where users have difficulty. We use a third-party analytics provider for this. Analytics data is about usage and devices, not learner results.
You can control cookies through your browser settings. Blocking essential cookies may stop parts of the Service from working.
8.Marketing communications
If you opt in, we may email you marketing about Qwill, such as new content, tips, and offers. We only send marketing to the adult account holder, never to learners.
Every marketing email includes a way to unsubscribe, and you can opt out at any time by using that link or by emailing dean@aisorted.co.za. Opting out of marketing does not stop transactional messages you need, such as receipts, access details, and important service notices.
9.Who we share your information with
We do not sell your personal information. We share it only with parties that help us run the Service ("operators"), and only as far as they need it to do their job for us under a confidentiality and data-protection agreement. These include:
- Payfast (Payfast by Network): our payment gateway, which processes your payment securely. Payfast handles your card details directly under its own terms and privacy policy.
- Our hosting provider: which stores the Service and its data.
- Our analytics provider: which provides the usage analytics described in clause 7.
- Our email and communication tools: used to send you account, support, and (if you opted in) marketing messages.
We may also disclose information where the law requires it, to protect our rights, or to prevent fraud or harm.
10.Storage and cross-border processing
We host and store Qwill's data on servers in South Africa. Some of our operators, such as the payment gateway and the analytics provider, may process limited information outside South Africa. Where that happens, we take reasonable steps to ensure the information is protected by laws, binding rules, or contracts that offer protection comparable to POPIA, as required by section 72 of POPIA.
11.How we keep your information secure
We take reasonable and appropriate technical and organisational steps to protect personal information against loss, unauthorised access, and misuse, including secure hosting, access controls, and encryption of data in transit (the site uses SSL/https). No system is completely secure, but we work to keep risks low and to act quickly if a problem arises. If a security compromise affects your personal information, we will notify you and the Information Regulator as POPIA requires.
12.How long we keep it
We keep personal information only as long as we need it for the purposes in this Policy, or as long as the law requires. In practice, we keep account and learner information while your account is active, and for a reasonable period afterwards. We keep purchase and payment records for as long as tax and company law require. When information is no longer needed, we delete or de-identify it.
13.Your rights
Under POPIA you have the right to:
- be told what personal information we hold about you and to ask for a copy;
- ask us to correct or update information that is wrong or incomplete;
- ask us to delete or destroy information we no longer have a lawful reason to keep;
- object to processing in certain circumstances, including marketing;
- withdraw consent you have given, without affecting processing already done;
- not have your information processed for direct marketing without your consent; and
- complain to us and to the Information Regulator.
To exercise any of these rights, email dean@aisorted.co.za. We may need to confirm your identity first. We will respond within a reasonable time and as POPIA requires.
14.How to complain
Please contact us first at dean@aisorted.co.za so we can try to resolve your concern. You also have the right to complain to the Information Regulator:
- The Information Regulator (South Africa)
- Address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
- Complaints email: POPIAComplaints@inforegulator.org.za
- General enquiries: enquiries@inforegulator.org.za
- Website: inforegulator.org.za
15.Changes to this Policy
We may update this Policy from time to time, for example when the Service or the law changes. The current version is always available on the AI Sorted website, with the "Last updated" date at the top. Material changes take effect when posted, and your continued use of the Service after that means you accept the updated Policy.
16.Contact us
For any privacy question or request:
- AI Sorted (Pty) Ltd, attention: Information Officer
- Email: dean@aisorted.co.za
- Address: 225 Willson Street, Fairland, Randburg, Gauteng, 2170, South Africa