Privacy Policy

Last Updated On: 30 July 2026
Effective Date: 30 July 2026

We respect your privacy

Thanks for using our services. Our mission is to help learners excel in their education so they can fulfil their full potential in life. To do that, we need to collect, use and handle personal information about the people who use our websites, software and services (the "Services").

This policy explains what we collect, why, and what happens to it. It covers every entity in the global Reflective group:

EntityLocation & Details
Maths Pathway Pty LtdAustralia
Reflective Learning Education (Pty) LtdSouth Africa (trading as Reflective Learning; also the controller/processor for UK schools - see below)
1st Access Technologies (Pty) LtdSouth Africa
Reflective Learning Foundation NPCSouth Africa

We refer to these together as "Reflective," "we," "us" or "our." Most of this policy applies to everyone, everywhere. Where the rules genuinely differ by country, we've marked it clearly with a shaded box like the ones you'll see below.

This policy also includes our Website Privacy Policy & Terms of Use, further down the page.

The short version

We collect the information we need to run our Services well - things like names, contact details, and how you use the platform. We don't sell your data. We share it only with the partners who help us run the Services, with your school or organisation if that's who signed you up, or in anonymised/aggregated form for research and public-good insights. Where we store and access your data depends on where you're based.

What we collect

  • Contact details: name, address, phone number, email
  • Account details: sign-up information, two-factor authentication
  • For students: name, email, grade/class, and optionally gender and date of birth. Please note, we keep student data to the minimum needed to run the Services.
  • For teachers: name, email address, phone number, timetables
  • Assessment results and learning activity data (logins, test completion and marking, activity progress)
  • Enquiries and communications between us
  • Contacts you choose to share with us (e.g. to invite others or share reports)
  • Usage data (which features you use, how you use them)
  • Device data (IP address, browser/device type, device identifiers and, depending on your settings, location)
  • Payment information, for direct-to-consumer purchases
  • Cookies and similar technologies - see the Website section below

How we collect it

When you interact with us electronically or in person, when you access our website, and when we provide the Services to you.

Why we collect it

To provide, run, and improve the Services, and to let you know about things we think you'll find useful. We also use aggregated and anonymised data to give the broader education sector useful, high-level insights. This helps build a stronger education system, and it's done in a way that never identifies an individual learner or institution. If we ever want to use your information for something outside of this, we'll ask first.

Who we share it with

We do not sell your information to advertisers or anyone else. We use a small number of trusted service providers to help us run the Services, and the providers differ depending on which product you use:

THIS DIFFERS BY PRODUCT/COUNTRY

Maths Pathway (Australia) and Reflective Learning (South Africa and the UK) currently run on different technical infrastructure, so their service providers are different.

Maths Pathway (Australia):

  • Google Analytics (teacher usage data) - Google's privacy policy
  • Pipedrive (sales/support data) - Pipedrive's privacy policy
  • Instaclustr (24/7 infrastructure monitoring - ISO 27001 and SOC 2 Type II certified)

Reflective Learning (South Africa and the UK):

  • MongoDB Atlas (database hosting, Belgium - ISO 27001:2022 and SOC 2 Type II certified)
  • Google Firebase (user identity and authentication)
  • Sentry (error monitoring)
  • SendGrid/Twilio (email delivery)
  • Cloudflare (content delivery and network security)
  • SwarmCDN (content delivery)

In general:

  • Research institutions, for anonymised or aggregated learning data used in specific research projects (published results only ever show broad, aggregate figures, never individuals or institutions).
  • Other users, in limited ways - e.g. your name on a leaderboard, or basic details visible to others in your organisation.
  • Your school or organisation, if that's who set up your account - we assume they've secured any permissions needed, e.g. from parents or guardians.
  • Government bodies and the public, but only ever as aggregated data that can't be traced back to a person or institution.
  • Authorities, if we're reasonably required to by law, to prevent fraud, or to protect someone's safety or our legal rights.
  • A new owner, only if our business is merged with or acquired by another company.

Where your information is stored

Where we store your data depends on where you're based (see table below) and your device may also store some information locally.

Where you areWhere your data livesWho's responsible
AustraliaMicrosoft Azure - Australian regions onlyMaths Pathway Pty Ltd
South AfricaMongoDB Atlas, Belgium (EEA)Reflective Learning Education (Pty) Ltd
United KingdomMongoDB Atlas, Belgium (EEA) - same platform as South AfricaReflective Learning Education (Pty) Ltd

Who can access your information

THIS DIFFERS BY COUNTRY

Our own staff may access your information from Australia and South Africa to provide services and support. This includes UK users' data - Reflective Learning Education (Pty) Ltd, the entity responsible for the UK service, is based in South Africa, so day-to-day support of UK accounts is generally handled from there.

Our infrastructure partners provide 24/7 monitoring and may access data from wherever their support staff are working, which currently includes the USA, UK, EU, India, New Zealand and Australia.

How we protect it

We use current industry-standard security measures, including TLS (Transport Layer Security) encryption for data in transit.

Maths Pathway (Australia) holds current ISO 27001 certification for its information security management system. Its infrastructure partner, Instaclustr, is ISO 27001 and SOC 2 Type II certified.

Reflective Learning (South Africa and the UK) has an ISO 27001 programme in progress - formal certification has not yet been achieved. Its infrastructure partners, MongoDB Atlas and Google Cloud Platform, are independently ISO 27001 (and related) and SOC certified.

No system is completely secure. We can't guarantee absolute protection for anything you send us, but we take this seriously and keep our practices current.

How long we keep it

  • While your account is active, or as long as we need it to provide the Services
  • If you stop using the Services, we archive rather than delete student details
  • If you ask us to delete your account, we start deleting your personal information within 30 days (backups may take a little longer to clear)
  • General website visitor data (e.g. marketing, browsing) is kept for 90 days to 2 years after you stop engaging with us, or as long as needed for the purpose it was collected
  • We may keep anonymised, aggregated data indefinitely for research purposes, and we'll keep information longer where the law requires it or to resolve disputes

Your rights

Everywhere, you can generally ask to access, correct, or delete your personal data, and object to certain uses of it. The specific law and regulator depends on where you're based:

Where you areLawRegulator
AustraliaPrivacy Act 1988 (Cth)Office of the Australian Information Commissioner (OAIC)
South AfricaProtection of Personal Information Act (POPIA)The Information Regulator
United KingdomUK GDPR & Data Protection Act 2018Information Commissioner's Office (ICO)

To exercise any of these rights, email privacy@reflective.global.

Complaints

Email privacy@reflective.global. We take privacy complaints seriously and aim to respond promptly.

Changes to this policy

We may update this policy from time to time - we'll post the new version on our website. If a change meaningfully reduces your rights, we'll tell you directly, not just post it and hope you notice.

UK schools

If you're a school, teacher, parent or student in the United Kingdom, more detail on how we work specifically with UK schools is available at: [insert]

Website Privacy Policy & Terms of Use

This section covers Reflective's collection, use and disclosure of information gathered through our website. Using the website means you consent to this.

  • What we collect: Name, email, mobile number.
  • How we use it: Marketing/promotional communications, collecting customer feedback, support, administration, and targeted advertising. Anything beyond this, we'll ask first.
  • How we share it: We won't share your information with third parties without your consent, except: ad services, analytics providers, where the law requires it, to enforce our agreements, or to respond to claims that your use of the site violates someone else's rights. If our business is acquired or merged, your information transfers with it.
  • Cookies: See our Cookie Policy for details on tracking technologies and your choices.
  • Third-party links: Our site links to other websites we don't control or take responsibility for.
  • Questions or concerns: Email privacy@reflective.global.