Privacy Policy.
Last updated: 24 September 2026 · Version MENTOR-PRIV-2026-09-24 · In terms of the Protection of Personal Information Act 4 of 2013 (POPIA)
Summary: For learners, your school decides what is collected and how long it is kept — AOLC processes it on the school's instruction. We collect your name, email, school details, and grade to operate the CAT and IT Mentor service. Your chat messages and any files you upload are processed by our AI provider (Anthropic, or OpenAI as a standby) outside South Africa. If you speak a question instead of typing it, a recording of your voice is sent outside South Africa to be turned into text (Groq, or OpenAI as a standby); if Coal reads a reply aloud, only the text of that reply is sent (ElevenLabs, or OpenAI as a standby). We use teacher contact details for marketing only with explicit consent. You may request deletion of your data at any time.
1. Who We Are (Responsible Party and Operator)
Your school is the responsible party in terms of POPIA for the personal information of its learners and staff processed through AOLC CAT and IT Mentor. AOLC (Pty) Ltd is the operator, which means we process that information on the school's written instruction and for no purpose of our own.
In practice this means:
- The school decides what is collected, who may see it, and how long it is kept. We act on that instruction.
- The school holds the relationship with parents and guardians, and obtains any consent required for a learner under 18.
- We keep a record of the school's confirmation that consent was obtained — who confirmed it, when, and against which version of this policy — and we make that record available to the school on request. It is the school's evidence, held by us.
- We do not use learner information for marketing, and we do not sell or share it.
Where there is no school — the public “Try it now” demonstration, and teachers who register directly — AOLC is the responsible party for the limited information described below. The demonstration keeps nothing after the visit ends.
AOLC contact: systems@aolc.co.za · aolc.tech
For anything about a learner's information, contact the school first; we will answer the school.
2. What Personal Information We Collect
| Data | Who | Purpose |
|---|---|---|
| Full name, email address, password (hashed) | All users | Account authentication |
| School name, type, province, address, phone | Teachers | School registration; lead management |
| Principal name, number of learners | Teachers | Lead qualification for AOLC services |
| Grade (10, 11, or 12) | Students | Tailoring AI responses to curriculum level |
| Chat messages, uploaded files and AI responses | All users | Generating tutoring responses (processed by our AI provider outside South Africa — see section 4) |
| A recording of your voice, only if you choose to speak a question instead of typing it | All users | Turning what you said into text so the Mentor can answer it (sent outside South Africa for transcription, not stored by us — see section 4) |
| Marketing consent + timestamp | Teachers | POPIA-compliant record of consent |
| IP address, session data | All users | Security and rate limiting |
3. How We Use Your Information
- Service delivery: Authenticating your account and providing the AI tutoring service.
- Curriculum personalisation: Using your grade to tailor AI responses to the correct CAPS level.
- Marketing (teachers only, with consent): Sending information about AOLC products, services, and educational resources. You may withdraw consent at any time by emailing systems@aolc.co.za.
- Lead management: School registration details are used internally by AOLC to follow up with schools about our services.
- Security: Preventing abuse, rate limiting, and protecting user accounts.
4. Third-Party Processing — Our AI and Voice Providers
Chat messages you send, and any files you upload, are transmitted to our AI provider to generate responses. Our AI provider is Anthropic (the Claude models). If Anthropic is unavailable, we may instead use OpenAI as a standby provider. Either provider processes this information as an operator on our behalf, and not for its own purposes.
This means your messages and files are transferred to, and processed outside, South Africa. Each provider's handling of this information is described in its privacy policy: Anthropic and OpenAI.
Voice — speaking to Coal, and Coal speaking back
The Mentor can read replies aloud, and you can ask a question by speaking instead of typing. Both features use providers outside South Africa, and they send different things:
| Feature | Provider | What is sent |
|---|---|---|
| Coal reads a reply aloud | ElevenLabs (United States), or OpenAI as a standby | Only the text of the Mentor's own reply. Your question is not sent, no recording of you is sent, and your name, email and grade are not sent. |
| You speak a question | Groq (United States), or OpenAI as a standby | A recording of your voice, so that it can be turned into text. The recording is sent for transcription only; we do not store it. |
Speaking a question therefore sends a recording of your voice outside South Africa. If you would rather that did not happen, type your question instead — every part of the Mentor works by typing, and reading replies aloud does not send any recording of you. You can switch spoken replies off at any time under Access.
Previously, speaking a question used your web browser's own speech recognition. In Chrome and Edge that also sends the audio out of the country, to the browser's maker, under their terms rather than ours.
Do not include sensitive personal information (ID numbers, financial details, medical information) in chat messages, uploaded files, or spoken questions.
5. Children's Personal Information
Many users of this service are under 18 years of age. In terms of POPIA, the processing of a child's personal information requires the consent of a parent or guardian.
That consent is obtained by the school, not by AOLC. The school holds the relationship with the parent and is the responsible party. When a teacher approves a learner, the teacher confirms on the school's behalf that the necessary consent has been obtained, and we record that confirmation — who made it, when, and against which version of this policy — so that the school can produce it if it is ever asked to.
We collect the minimum from a learner (name, email and grade only), we do not use a learner's information for marketing, and we do not sell or share it.
6. Data Retention
For learners, the school's own retention schedule applies. As the school's operator we do not set a lifetime of our own and we do not delete a learner's record on our own initiative. The school instructs us, and we act on that instruction and record who gave it and when. Each school's operator agreement states its schedule; ask your school for it.
On request we will give the school a report of what we hold about its learners and how old each record is, so that it can instruct us accurately.
- Chat messages are held in your browser and in the server session for that visit only. They are not stored in our database.
- Your browser also keeps a copy of some things on the device you are using — see section 6a.
- Teacher and school accounts, where AOLC is the responsible party, are kept while the account is active and removed within 30 days of a deletion request, except where the law requires us to keep something.
- The “Try it now” demonstration keeps nothing. It ends with the visit.
6a. What stays on the device you are using
The Mentor keeps some things in the browser itself so that it works offline and remembers where you were: your progress ticks, your accessibility settings, and any chats you chose to save.
On a shared computer — a school lab, a library, a borrowed phone — that information stays in that browser until it is removed. The next person to use the same browser profile could see it. Use Sign out and clear this device in the menu when you finish; it removes everything the Mentor has saved in that browser and signs you out.
A transcript you download of a spoken session is a file on your own device. Once you have saved it, it is outside our control.
7. Your Rights Under POPIA
You have the right to:
- Access the personal information we hold about you.
- Correct inaccurate personal information.
- Request deletion of your personal information.
- Object to the processing of your personal information for marketing.
- Withdraw consent to marketing at any time.
- Lodge a complaint with the Information Regulator of South Africa at justice.gov.za/inforeg.
To exercise any of these rights, contact us at systems@aolc.co.za.
8. Data Security
We implement reasonable technical and organisational measures to protect your personal information, including password hashing (bcrypt), HTTPS encryption, and access controls. No system is completely secure; we cannot guarantee absolute security.
9. Changes to This Policy
We may update this Privacy Policy from time to time. The "Last updated" date above will reflect any changes. Continued use of the Service after changes constitutes acceptance.
10. Contact the Information Officer
For any privacy-related queries or to exercise your POPIA rights:
AOLC (Pty) Ltd
Email: systems@aolc.co.za
Website: aolc.tech