PRIVACY POLICY (GDPR + POPIA)
LearnerLens Profile –
Privacy Policy
Last updated: 17 April 2026
Information Officer: Lizaan Fourie
Organisation: LearnerLens
Registration Number: 2026-008937
Email: learnerlensprofile@gmail.com
1. Who we are
LearnerLens Profile (“LearnerLens”, “we”, “us” or “our”) provides non-diagnostic educational learning support profiles, roadmaps and related digital resources. We are based in Bethlehem, Free State, South Africa and operate online through www.learnerlens.co.
2. What we collect
We may collect:
- Identity/contact details: name, email address, country/region
- Learner information: age range, grade/year, learning preferences, observations and reflections provided in questionnaires
- Order data: purchase details, selected add-ons (payments processed by payment providers; we do not store full card details)
- Technical data: device/browser information, IP address (where provided by platforms), cookies/analytics (if enabled)
- For POPIA purposes, LearnerLens Profile is the responsible party for the personal information described in this policy. The head of the private body is Lizaan Fourie, who acts as the Information Officer for the business. Privacy and POPIA requests may be sent to learnerlensprofile@gmail.com.
- Depending on the service requested, we may collect identity and contact details, parent or guardian details, learner details, questionnaire answers, observations, reflections, uploaded supporting information, order information, support communications, and technical information such as browser type, cookies, analytics, IP address and device information where those are made available by the website or service providers.
3. How we use information
We use your information to:
- generate your LearnerLens Profile and selected add-ons
- deliver reports by email or download
- provide customer support
- improve questionnaire clarity and product quality (using aggregated, non-identifying insights)
- comply with legal obligations (records, accounting)
- We use personal information to provide the purchased LearnerLens service, prepare and deliver the requested report or add-on, communicate with you about intake, delivery, support or clarification, improve the quality and reliability of our workflows in a lawful and proportionate way, maintain records, prevent misuse or fraud, and comply with legal, accounting and tax obligations.
4. Legal bases
We process personal data based on:
- Contract: to deliver the product you purchased
- Consent: where you voluntarily provide optional information
- Legitimate interests: improving service quality and preventing misuse/fraud
- Legal obligations: accounting, tax, and compliance requirements
- We process personal information on one or more lawful bases depending on the context, including performance of a contract where processing is necessary to deliver a purchased service, consent where information is voluntarily provided or optional processing is agreed to, legitimate interests where reasonably necessary to improve service quality, security and administration, and legal obligations where records must be kept or compliance duties apply.
5. Sensitive information
We do not request medical diagnoses. If you voluntarily submit sensitive personal information, you consent to our processing of it solely for creating your report. We recommend keeping details practical and non-clinical.
LearnerLens is designed to support learners, including minors. Where the learner is under 18, the intake must be completed by a parent, legal guardian or another competent person with lawful authority to act for that learner. By using the service for a minor, you confirm that you have authority to provide the child’s personal information and to request the service. LearnerLens does not knowingly market directly to children or invite children to purchase services on their own.
6. Sharing your information
We do not sell your personal information. We may share limited data with:
- website and form providers (e.g., Wix, Jotform)
- payment processors to complete transactions
- email delivery providers (if used) to send your reports
- service contractors assisting with operations (bound by confidentiality)
We only share what is necessary to deliver the service. LearnerLens is non-diagnostic and does not require medical diagnoses as a standard part of the service. However, parents or customers may voluntarily submit information that could be sensitive or special personal information. If you provide this kind of information, you consent to our processing of it only to the extent reasonably necessary to prepare, quality-check and deliver your requested service, and you should keep that information practical, relevant and as limited as possible.
We do not sell personal information. We may share personal information, only where reasonably necessary, with trusted operators and service providers who help us run the website, collect intake submissions, process payments, send emails, store files, support internal workflows, or provide technical infrastructure. These operators process information on our instructions and are required to use appropriate safeguards.
7. International data transfers
Because we serve customers globally, data may be processed in countries other than yours depending on platform hosting locations. We take reasonable steps to ensure providers use appropriate safeguards.
Because some service providers may host or process data outside South Africa, personal information may be stored or processed in other countries. Where cross-border processing is reasonably necessary, we take practical steps to ensure appropriate safeguards are in place or that another lawful transfer ground applies. By using our service and submitting information online, you acknowledge that limited cross-border processing may occur.
8.1 Data retention
8.2 Security
We keep questionnaire submissions, working files and delivered reports for as long as reasonably necessary to provide support, handle follow-up questions, maintain records and comply with legal or business obligations. As a practical default, LearnerLens aims to keep customer files for up to 12 months after delivery unless a longer period is reasonably necessary for support, record-keeping, accounting, legal compliance or security purposes. After that period, information may be deleted or de-identified where appropriate.
We use reasonable administrative, technical and organisational safeguards to protect personal information against loss, misuse, unauthorised access, disclosure, alteration or destruction. No internet-based service is entirely risk free, but we take practical measures to reduce risk and work with providers that use appropriate security controls.
Our website may use cookies or similar technologies to support site functionality, improve user experience and understand website traffic. Where required, we will provide a cookie notice or consent mechanism. You can also manage many cookie preferences through your browser settings.
9. Your rights
Depending on your jurisdiction, you may request:
- access to your data
- correction of inaccurate data
- deletion (where legally allowed)
- restriction/objection to processing
- portability of your information
Subject to applicable law, you may request access to the personal information we hold about you, request correction or deletion of inaccurate or unnecessary information, object to certain processing, request portability where applicable, or ask us to explain our processing practices. To make a request, email learnerlensprofile@gmail.com with enough detail for us to identify your request and verify your authority.
If you believe your personal information has been handled unlawfully, please contact us first so we can try to resolve the matter. You also have the right to lodge a complaint with the Information Regulator (South Africa).
Privacy, POPIA and PAIA requests: learnerlensprofile@gmail.com
Our PAIA Manual is available on our website. It explains the types of records held by LearnerLens, which records may be automatically available, and how a requester may ask for access to records under PAIA.
We may update this Privacy Policy from time to time. The version posted on our website applies.
For learners under 18, submissions must be completed by a parent/guardian or with parent/guardian permission. We do not knowingly market directly to children under 13.
10. Children’s privacy
11. Security
We use reasonable administrative and technical measures to protect your information. No method of transmission or storage is 100% secure, but we work to minimise risk.
12. Cookies and analytics
If analytics/cookies are enabled on our site, we may use them to understand traffic and improve user experience. You can manage cookies via your browser settings and any cookie banner we provide.
13. Policy
-We may update this Privacy Policy from time to time. The version posted on our Website applies.
-Our PAIA Manual will be made available through the website footer and on request. It explains the types of records held by LearnerLens Profile, which records may be automatically available, and how a requester may ask for access to records under PAIA.
-If you believe your personal information has been handled unlawfully, please contact us first so we can try to resolve the matter. You also have the right to lodge a complaint with the Information Regulator (South Africa).
Privacy & POPIA requests: learnerlensprofile@gmail.com