POPIA processing notice
Last updated 28 October 2026 · Version 1.2
This is the notice section 18 of the Protection of Personal Information Act 4 of 2013 ("POPIA") requires us to give you when we collect your personal information. It sits alongside our Privacy Policy, which covers the same ground in ordinary language; this page maps it to the Act.
1. The responsible party
- Responsible party
- Ellermon Holdings (Pty) Ltd
- Registration number
- 2026/561599/07
- Registered office
- 4A Westminster Avenue
Bryanston
Johannesburg
Gauteng, 2191
South Africa - Information Officer
- Michael Ian Rolle, Director
- admin@ellermon.com
Our Information Officer, registered with the Information Regulator, is appointed under section 55 of POPIA.
2. The information we collect, and from whom
| Data subject | Personal information | Source |
|---|---|---|
| Guardians (our users) | Email address, account identifier, display name, notification preferences, records of accepting the terms and confirming you are 18 or older, when the account was last used, support correspondence | Directly from you; if you use Sign in with Google, your name and email address come from Google |
| Learners (children) | First and last name, date of birth, school grade, school name, display colour, subjects, terms, assessment categories and weightings, assessments and marks, report marks, calendar events and notes, and the guardian's recorded consent for that learner. For a learner with their own account, also their email address and sign-in identifier, the guardians linked to them, and any request to delete their account with the guardian's decision | Entered or edited by the guardian; a learner with their own account may add and edit their own information, including assessments, marks and events, and if they use Sign in with Google their name and email address come from Google |
| Website visitors | IP address, in the standard server logs our web host keeps — used only to serve and protect the site, and retained for up to 90 days | The visitor's own request to the site, recorded by the host when it serves a page |
| Correspondents | Name, email address, and the contents of your message | Directly from you |
Providing this information is voluntary, but GradeLens cannot work without it. If you do not want to provide a learner's details, you cannot track that learner's marks — there is no version of the app that does the job without the data.
3. Special personal information: children
Under section 34 of POPIA, personal information about a child is special personal information and may not be processed unless an exemption in section 35 applies. We rely on section 35(1)(a): processing carried out with the prior consent of a competent person. The guardian who creates the account is that competent person. The app asks them to confirm this, by ticking a box, before each learner is added, and we record that confirmation and when it was given.
We process no other category of special personal information. We do not collect religious or philosophical beliefs, race or ethnic origin, trade union membership, political persuasion, health or sex life, biometric information, or criminal behaviour.
A child's information is used only to show their own guardian their own child's progress. It is never used for advertising, profiling, marketing, or training machine learning models, and it is never sold. See our child safety standards.
A learner may hold their own account. Under 18, the learner's parent or guardian is the competent person: they are emailed and must approve before the account can be used, we record their consent, and they have the final say over the learner's data, including whether it is deleted. A learner aged 18 or over is not a child under POPIA and consents for themselves. We ask for the learner's date of birth to tell these apart.
A guardian may also add a learner to their own account without the learner signing in, or invite a learner they have added to sign in with their own learner account. Every learner who uses the app signs in to their own account; no one signs in on another person's account. A learner can see and edit only their own subjects, terms, categories and weightings, report marks, assessments, calendar and events, and their own reminder and slip-alert settings, and can see the email addresses of the guardians linked to them. They cannot reach any other child's information or any guardian's account. A guardian linked to a learner can see and edit that learner's information, and either can end the link. These limits are enforced on our servers for every request.
4. Why we process it
To operate GradeLens: to authenticate you (and a learner signing in to their own account), store what you enter, calculate averages and projected term marks, show the family calendar, schedule the reminders you have asked for on your device, keep the service secure and available, record the consent you give, warn you before and then delete an account that has gone unused, answer your requests, and meet our legal obligations. The full breakdown is in the Privacy Policy.
5. Our lawful justification
- Section 11(1)(a) — your consent, and section 35(1)(a) for children's information
- Section 11(1)(b) — necessary to perform our contract with you
- Section 11(1)(c) — compliance with a legal obligation
- Section 11(1)(f) — our legitimate interests in a secure, working service
6. Recipients
We do not sell personal information and we do not share it for anyone else's marketing. It is shared only with the operators who run our infrastructure, each bound by contract to process it solely on our instructions and to secure it: Amazon Web Services (AWS) for hosting, identity and account emails, Google for Sign in with Google if you choose it, and Apple and Google for app distribution. We also disclose information where compelled by law. Full detail is in the Privacy Policy.
7. Cross-border transfers
Personal information is stored in the AWS Africa (Cape Town) region (af-south-1) — that is, in South Africa. We do not routinely transfer it out of the Republic.
Where a transfer does occur — Sign in with Google, if you choose it, and email correspondence with us — we rely on section 72, on the basis that the transfer is necessary to perform the contract with you, that you have consented, or that the recipient is subject to laws or binding rules providing an adequate level of protection. Neither involves your children's information. Account emails are sent from South Africa, and reminders are scheduled on your own device rather than sent through a push notification service.
8. Security safeguards
As section 19 requires, we secure the integrity and confidentiality of personal information through appropriate, reasonable technical and organisational measures: encryption in transit and at rest, a separate Amazon Cognito app client for learners so that each learner holds their own account, tokens kept in the platform's secure storage, per-request authorisation that confines a learner to their own records, least-privilege access to production systems, logging, and automated dependency auditing. Our operators are bound by section 21 written contracts. Details are in the Privacy Policy and on our security page.
9. Retention
As section 14 requires, we keep personal information only as long as we need it. Your data lives until you delete it or your account becomes inactive for 24 months. Deletion is completed within 30 days, backups roll over within 35 days, and logs are kept for up to 90 days. Before deleting an inactive account we email a warning and give at least 30 days to keep it. Invites, link codes and the consent and deletion links we email expire 7 days after they are sent and are then deleted automatically, and a minimal record that an account was deleted is kept for 3 years. The full table is in the Privacy Policy.
10. Your rights
Sections 23, 24 and 11(3) give you the right to:
- Be told whether we hold personal information about you, and to be given a copy
- Be told who has had access to it
- Have inaccurate, irrelevant, excessive, out of date, incomplete, misleading or unlawfully obtained information corrected or deleted
- Object, on reasonable grounds, to processing based on legitimate interests
- Object at any time to processing for direct marketing purposes
- Withdraw consent, without affecting processing that already lawfully occurred
- Not be subject to a decision based solely on automated processing that has legal consequences — we make no such decisions
- Complain to the Regulator, and to institute civil proceedings
To exercise any of these, see making a data request, or use the controls in the app.
11. Direct marketing
We do not send unsolicited electronic marketing. The only messages GradeLens sends are the reminders you switched on, and service messages such as a verification code, a warning that an unused account will be deleted, a security notice or a change to these policies — which section 69 does not treat as direct marketing. You can turn reminders off in the app at any time.
12. Complaints
Please raise a concern with our Information Officer first, at admin@ellermon.com. You are entitled to go straight to the Regulator instead.
- Regulator
- Information Regulator (South Africa)
- Address
- JD House, 27 Stiemens Street
Braamfontein, Johannesburg, 2001
P.O Box 31533, Braamfontein, Johannesburg, 2017 - POPIA complaints
- POPIAComplaints@inforegulator.org.za
- General enquiries
- inforeg@inforegulator.org.za
- Website
- https://inforegulator.org.za