Privacy Policy
Last updated 29 August 2026 · Version 1.0
This policy explains what Ellermon Holdings (Pty) Ltd does with personal information in the GradeLens app and on this website. It is written to be read, not to be survived. Where a section carries a specific legal meaning we say so plainly.
The short version. GradeLens holds information a guardian enters about their own children: names, dates of birth, grade, school and marks. It is stored in South Africa on Amazon Web Services (AWS), AWS Africa (Cape Town). We do not sell it, we do not use it for advertising, and there are no third-party analytics or tracking SDKs in the app. You can delete your account and everything in it from inside the app at any time.
Contents
1. Who we are
Ellermon Holdings (Pty) Ltd is the responsible party for the personal information described here — the term POPIA uses for what the GDPR calls a data controller. We decide why and how it is processed, and we are accountable for it.
- Registered name
- Ellermon Holdings (Pty) Ltd
- Registration number
- 2026/561599/07
- Registered office
- 4 Westminster Avenue
Bryanston
Johannesburg
Gauteng, 2191
South Africa - Information Officer
- Michael Ian Rolle, Director
- Privacy contact
- admin@ellermon.com
2. What we collect
We collect only what GradeLens needs to do its job. Nothing below is optional instrumentation added "in case it is useful later".
Your account
- Email address — used to identify your account and to sign you in.
- A unique account identifier issued by Amazon Cognito, our identity provider. This identifier, not your email, is what links your data together in our database.
- A display name, if you choose to set one.
- Your notification preferences — which of the four reminder types you want.
- Your achievement scale, if you adjust it away from the national default.
We never receive or store your password. Authentication is handled by Amazon Cognito and your password never reaches our systems.
Each learner you add
- First name and last name
- Date of birth
- School grade, from 1 to 12
- School name, which is optional
- A display colour
Schoolwork
- Subjects and terms you set up for each learner
- Assessment categories and their weightings
- Assessments — a name, a date, a subject, a category, and a mark out of 100 where one has been recorded
- Calendar events — a title, a date, an optional time, an optional note of up to 500 characters, and the kind of event it is
Technical information
- Server logs generated when the app talks to our API, containing the request, a timestamp, and your account identifier. These exist so we can find and fix faults and detect abuse.
- A device push token, if you turn notifications on, so a reminder can reach your device.
What we deliberately do not collect
- Location data of any kind
- Contacts, photos, camera, microphone, calendar or health data from your device
- Advertising identifiers, and we run no advertising SDKs
- Third-party analytics or behavioural tracking
- Payment or banking details — GradeLens takes no payments
- Race, religion, health, biometrics, political or trade union affiliation, or criminal history
3. Information about children
This is the part of the policy that matters most, so it is stated in full.
GradeLens exists to hold information about children — their names, dates of birth, schools and marks. Under section 34 of POPIA, personal information about a child is special personal information, and processing it is prohibited unless a specific exemption applies. We rely on section 35(1)(a): processing carried out with the prior consent of a competent person, meaning the child's parent, legal guardian, or someone else legally entitled to consent on the child's behalf.
In practical terms:
- Only adults hold accounts. Children do not sign up, sign in, or use GradeLens. The app is not directed at children and is not distributed as a children's app.
- You confirm you are entitled to enter the information. By adding a learner you confirm you are that child's parent or legal guardian, or that you are otherwise legally permitted to consent on their behalf. If that stops being true — for example following a change in custody — please delete that learner from your account.
- A child's information is used for nothing else. It is never used for advertising, profiling, marketing, model training, or any purpose beyond showing you your own child's progress.
- It is never sold or shared. There is no circumstance in which we sell or trade information about a child.
- Children have rights too. A child, or a competent person acting for them, may ask what we hold about that child, ask for it to be corrected, or ask for it to be deleted. See your rights.
- We collect the minimum. Date of birth is used to keep learners distinct and to sanity-check the grade; school is optional and can be left blank.
If you believe a child's information has been entered into GradeLens by someone with no right to do so, contact admin@ellermon.com immediately and we will investigate and, where appropriate, delete it. See our child safety standards.
4. Why we process it
| Purpose | Information used |
|---|---|
| Signing you in and keeping your account secure | Email address, account identifier |
| Showing your learners and their subjects | Learner details, subjects, terms, categories |
| Calculating averages and projecting a term mark | Assessments, marks, category weightings, achievement scale |
| Showing the family calendar | Events, assessment dates |
| Sending the reminders you asked for | Notification preferences, push token, assessment and event dates |
| Keeping the service running and diagnosing faults | Server logs |
| Detecting and preventing abuse of the service | Server logs, account identifier |
| Answering your support and privacy requests | Whatever you send us, plus your account record |
| Meeting our legal obligations | Whatever the specific obligation requires |
We do not use your information, or your children's, to train machine learning models.
5. Our lawful basis
Under POPIA we rely on:
- Consent (section 11(1)(a), and section 35(1)(a) for children's information) — you choose to create an account and to enter each learner's details.
- Performance of a contract (section 11(1)(b)) — we cannot provide GradeLens without processing what you enter into it.
- Legitimate interests (section 11(1)(f)) — keeping the service secure, available and free of abuse.
- Legal obligation (section 11(1)(c)) — where a law requires it.
If you are in the European Economic Area or the United Kingdom, the equivalent GDPR bases are Article 6(1)(a) consent, 6(1)(b) contract, 6(1)(f) legitimate interests and 6(1)(c) legal obligation, with Article 8 governing children's data.
You can withdraw consent at any time by deleting a learner or your whole account. Withdrawal does not undo processing that already lawfully happened.
6. Who we share it with
We do not sell personal information, and we never will. We do not share it for anyone else's marketing. We share it only with the service providers who run the infrastructure GradeLens sits on — operators in POPIA's terms, processors in the GDPR's — each bound to process it only on our instructions:
| Provider | What it does | Where |
|---|---|---|
| Amazon Web Services (AWS) | Hosts the application, database and stored files | AWS Africa (Cape Town) |
| Amazon Cognito (part of Amazon Web Services (AWS)) | Manages sign-in, passwords and session tokens | AWS Africa (Cape Town) |
| Apple and Google | Distribute the app and deliver push notifications to your device | Internationally |
We will also disclose information where we are legally obliged to — for example under a valid court order or a lawful request from a regulator — and where it is necessary to establish, exercise or defend a legal claim. If we are ever compelled to hand over information about you, we will tell you unless we are legally prohibited from doing so.
If Ellermon Holdings is ever sold or merged, personal information may transfer to the acquirer. We would notify you first, and the information would remain subject to a policy no less protective than this one.
7. Where it is stored
GradeLens data is stored in the AWS Africa (Cape Town) region (af-south-1). Your family's information is held in South Africa and is not routinely transferred outside the Republic.
Two limited exceptions involve information leaving the country. Push notifications are delivered through Apple's and Google's international networks — a notification contains only the short reminder text, never a mark. And if you email us, that message sits with our email provider. Where a transfer does occur we rely on section 72 of POPIA, which permits it with your consent, where it is necessary to perform our contract with you, or where the recipient is subject to comparable protection.
8. How long we keep it
| Information | Kept for |
|---|---|
| Your account and everything in it | Until you delete it, or until your account is inactive for 24 months |
| An archived learner | Until you delete that learner or your account |
| Data after you request deletion | Erased from live systems within 30 days |
| Encrypted backups | Rolling 35 days, then overwritten |
| Server logs | Up to 90 days |
| Support and privacy correspondence | Up to 3 years, so we have a record of what was asked and answered |
| Records we must keep by law | The period that law requires |
Before we delete an account for inactivity, we email the address on the account and give you at least 30 days to keep it.
9. How we protect it
- All traffic between the app and our servers is encrypted in transit using TLS.
- Data is encrypted at rest in our database and in backups.
- Sign-in uses the OAuth 2.0 authorisation code flow with PKCE. Tokens are held in the operating system's secure storage — Keychain on iOS, Keystore on Android — not in ordinary app storage.
- Every API request is authorised before it is served, and every request is checked to confirm the account making it owns the data it is asking for.
- Access to production systems is limited to the people who need it, and is logged.
- Dependencies are audited automatically and updated when vulnerabilities are published.
No system is perfectly secure, and we will not claim otherwise. What we commit to is applying appropriate, reasonable technical and organisational measures as section 19 of POPIA requires, and telling you promptly if something goes wrong.
10. Your rights
You have the right to:
- Be told what personal information we hold about you or your children
- Get a copy of it
- Correct anything inaccurate, and complete anything incomplete
- Delete information that is inaccurate, irrelevant, excessive, obtained unlawfully, or that we no longer have grounds to keep
- Object to processing based on legitimate interests, on reasonable grounds
- Withdraw consent at any time
- Not be subject to a decision made solely by automated means that has legal consequences for you — we make no such decisions
- Complain to the Information Regulator (South Africa)
Most of these you can exercise yourself inside the app: edit or delete a learner, or delete your entire account. For anything else, see making a data request. We respond within 30 days and we do not charge for a reasonable request.
If you are unhappy with how we handled your request you may complain to the Information Regulator (South Africa) — details on our POPIA page.
11. Security compromises
If personal information is accessed or acquired by anyone without authorisation, section 22 of POPIA requires us to notify both the Information Regulator (South Africa) and every affected person as soon as reasonably possible. We will tell you what happened, what information was involved, what we have done about it, and what you can do. We will not delay that notification to manage embarrassment.
12. Changes to this policy
When we change this policy we update the date at the top. If a change materially affects your rights or how we use your information, we will tell you in the app or by email before it takes effect, and where the law requires it we will ask for your consent again. Previous versions are available on request.
13. Contacting us
Our Information Officer is responsible for this policy and for your requests under it.
- Information Officer
- Michael Ian Rolle, Director
- admin@ellermon.com
- Post
- 4 Westminster Avenue
Bryanston
Johannesburg
Gauteng, 2191
South Africa - Response time
- Within 30 days