Privacy Policy

We collect and use the following information to provide, improve, and protect our Services:

• Account information.
  We may collect and associate with your account the information you provide to us when you do things such as sign up for your account, purchase products and services, and set up two-factor authentication.
  • Student details are kept to a minimum and used specifically to enable the Services to take place. This could include name, email address, grade and class, gender (optional), and date of birth (optional).
  • Teacher details may include name, email address, and phone number.
  • Direct-to-consumer student details may include phone number and payment information.

• Contacts.
  You may choose to give us access to specific contacts to make it easy for you to do things like sharing learner reports and inviting others to use the Services. If you do, we’ll store those contacts on our servers.

• Usage information.
  We collect information related to how you use the Services, including actions you take in your account (for example, which features you use, how long you are on pages). We use this information to improve our Services, develop new services and features, provide industry insights, and protect Reflective Learning users.

• Device information.
  We also collect information from and about the devices you use to access the Services. This includes things like IP addresses, the type of browser and device you use, and identifiers associated with your devices. Your devices (depending on their settings) may also transmit location information to the Services.

• Cookies and other technologies.
  We may use technologies like cookies to provide, improve, and protect our Services. For example, cookies help us with things like remembering your username for your next visit, understanding how you are interacting with our Services, and improving them based on that information.

• Service messages.
  In order to serve you best, we may from time to time send you messages that report about usage and guide you to make full use of the Services. If you receive a message and no longer wish to be contacted by Reflective Learning, you can unsubscribe yourself from the list or request to be removed.

• Bases for processing your data.
  We collect and use the personal data described above in order to provide you with the Services in a reliable and secure manner. We also collect and use personal data for our legitimate business needs and to provide high-level, aggregated and anonymous insights to the education industry. By releasing these educational insights, we help to build a stronger education system which benefits us all. We will only do this in a way that protects the identities of the individual learners and institutions. To the extent we process your personal data for other purposes, we ask for your consent in advance or require that our partners obtain such consent.

We may share information as discussed below, but we won’t sell it to advertisers or other third parties.

• Others working for and with Reflective Learning.
  Reflective Learning uses certain trusted third parties (for example, providers of customer support and IT services) to help us provide, improve, protect, and promote our Services. These third parties will access your information only to perform tasks on our behalf in compliance with this Privacy Policy, and we’ll remain responsible for their handling of your information as per our instructions.

• Other users.
  Our Services may display information like your name to other users in places, for example on leaderboards. When you register your Reflective Learning account with an email address on a domain owned by your employer or organisation, we may help educational institutions and administrators find you and your team by making some of your basic information visible to other users on the same domain. Certain features let you make information available to others, like the Observer Account.

• Other applications.
  We may also give third-party providers access to your information and account to serve you in using the Services, for example, via Reflective Learning APIs. At no time will contact details be shared with third parties for advertising purposes.

• Reflective Learning educational institutions.
  If you are an educational institution or any other organisation creating, or requesting the creation of, accounts on behalf of others, it is assumed that you have sought the relevant permissions required to do so including those of parents or guardians.
• Government educational entities and the general public.
  We believe in providing insights to the broader education industry (such as government or the general public) so that they may be empowered to improve the system as a whole to the benefit of all. However, we will not compromise by infringing on the privacy of individuals or specific institutions in order to do so. As such, these views will only be of aggregated data with specific use to that governmental role such as school quintile, grades levels, public/independent schools, associated choice of intervention, and location as classified by the relevant educational departments.

• Law & Order and the Public Interest.
  We may disclose your information to third parties if we determine that such disclosure is reasonably necessary to: (a) comply with any applicable law, regulation, legal process, or appropriate government request; (b) protect any person from death or serious bodily injury; (c) prevent fraud or abuse of Reflective Learning or our users; (d) protect Reflective Learning’s rights, property, safety, or interest; or (e) perform a task carried out in the public interest.

• Stewardship of your data is critical to us and a responsibility that we embrace.
  We believe that your data should receive the same legal protections regardless of whether it’s stored on our Services or on your home computer’s hard drive. We’ll abide by the following principles when receiving, scrutinising, and responding to government requests (outside of that explained above) for your data:

• Be transparent,
• Fight blanket requests,
• Protect all users, and
• Provide trusted services.

• User Controls.
  You can access, amend, and download personal information by logging into your Reflective Learning account and going to your account profile page or contacting us directly.
• Levelled User Access.
  The level of detail shown to a user is dependent on the role of an individual within an education institution. This is restricted to what is reasonably required to execute that role well.

• Retention.
  When you sign up for an account with us, we’ll retain information you store on our Services for as long as your account is in existence or as long as we need it to provide you the Services. Should you stop using the Services, the student details will be archived. Should you require the deletion of your account details, we will initiate the deletion of personal information within 30 days. But please note: (1) there might be some latency in deleting this information from our servers and back-up storage; (2) we will retain essential, non-personal data to preserve the integrity of aggregated research-related data sets such as answers to questions or software usage trends; and (3) we will retain this information if necessary, to comply with our legal obligations, resolve disputes, or enforce our agreements.

Around the world.
To provide you with the Services, we may store, process, and transmit information in the Republic of Ireland (where our servers are based), South Africa and locations around the world – including those outside your country. Information may also be stored locally on the devices you use to access the Services.

Changes.
We may revise this Privacy Policy from time to time, and will post the most current version on our website. If a revision meaningfully reduces your rights, we will notify you.

Your Right to Control and Access Your Information.
You have control over your personal information and how it is collected, used, and shared. For example, you have a right to change or correct personal data. You can manage your account and the content contained in it, as well as edit some of your personal data, through your account profile page.

Contact.
Your personal information is controlled by Reflective Learning (Pty) Ltd. Have questions or concerns about Reflective Learning, our Services, and privacy? Contact us at info@reflectivelearning.co.za.

This Website Privacy Policy & Terms of Use describes the policies of Reflective Learning Education (Pty) Ltd, 13 Boundary Road, Western Cape 7700, South Africa, on the collection, use and disclosure of your information that we collect when you use our website (the “Service”). By accessing or using the Service, you are consenting to the collection, use and disclosure of your information in accordance with this Website Privacy Policy & Terms of Use. If you do not consent to the same, please do not access or use the Service.

We may modify this Website Privacy Policy & Terms of Use at any time without any prior notice to you and will post the revised Website Privacy Policy & Terms of Use on the Service. The revised Policy will be effective 180 days from when the revised Policy is posted in the Service and your continued access or use of the Service after such time will constitute your acceptance of the revised Website Privacy Policy & Terms of Use. We therefore recommend that you periodically review this page.

Information We Collect:
We will collect and process the following personal information about you:

1. Name
2. Email
3. Mobile

How We Use Your Information:
We will use the information that we collect about you for the following purposes:

1. Marketing/ Promotional
2. Customer feedback collection
3. Support
4. Administration info
5. Targeted advertising

If we want to use your information for any other purpose, we will ask you for consent and will use your information only on receiving your consent and then, only for the purpose(s) for which grant consent unless we are required to do otherwise by law.

How We Share Your Information:
We will not transfer your personal information to any third party without seeking your consent, except in limited circumstances as described below:

1. Ad service
2. Analytics

We require such third parties to use the personal information we transfer to them only for the purpose for which it was transferred and not to retain it for longer than is required for fulfilling the said purpose. We may also disclose your personal information for the following:

1. to comply with applicable law, regulation, court order or other legal process;
2. to enforce your agreements with us, including this Website Privacy Policy & Terms of Use; or
3. to respond to claims that your use of the Service violates any third-party rights. If the Service or our company is merged or acquired with another company, your information will be one of the assets that is transferred to the new owner.

Retention Of Your Information:
We will retain your personal information with us for 90 days to 2 years after users terminate their accounts or for as long as we need it to fulfill the purposes for which it was collected as detailed in this Website Privacy Policy & Terms of Use. We may need to retain certain information for longer periods such as record-keeping/reporting in accordance with applicable law or for other legitimate reasons like enforcement of legal rights, fraud prevention, etc. Residual anonymous information and aggregate information, neither of which identifies you (directly or indirectly), may be stored indefinitely.

Your Rights:
Depending on the law that applies, you may have a right to access and rectify or erase your personal data or receive a copy of your personal data, restrict or object to the active processing of your data, ask us to share (port) your personal information to another entity, withdraw any consent you provided to us to process your data, a right to lodge a complaint with a statutory authority and such other rights as may be relevant under applicable laws. To exercise these rights, you can write to us at privacy@reflective.global. We will respond to your request in accordance with applicable law. You may opt-out of direct marketing communications or the profiling we carry out for marketing purposes by writing to us at privacy@reflective.global. Do note that if you do not allow us to collect or process the required personal information or withdraw the consent to process the same for the required purposes, you may not be able to access or use the services for which your information was sought.

Cookies Etc.:
To learn more about how we use these and your choices in relation to these tracking technologies, please refer to our Cookie Policy.

Security:
The security of your information is important to us and we will use reasonable security measures to prevent the loss, misuse or unauthorized alteration of your information under our control. However, given the inherent risks, we cannot guarantee absolute security and consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk.

Third Party Links & Use Of Your Information:
Our Service may contain links to other websites that are not operated by us. This Website Privacy Policy & Terms of Use does not address the privacy policy and other practices of any third parties, including any third party operating any website or service that may be accessible via a link on the Service. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Grievance / Data Protection Officer:
If you have any queries or concerns about the processing of your information that is available with us, you may email our Grievance Officer at Reflective Learning Education (Pty) Ltd, email: privacy@reflective.global. We will address your concerns in accordance with applicable law.