Privacy Notice

Privacy Notice for MindSprout

Welcome to MindSprout, a digital education platform provided by Phauwe Digital (Registration Number: 2024/102605/07). We are committed to protecting your privacy and complying with the Protection of Personal Information Act (POPIA) and other applicable data protection laws. This Privacy Notice explains how we collect, use, store, and protect your personal information when you use our mobile applications (iOS and Android).

Last Updated: November 7, 2025

1. Information We Collect

We collect the following types of information to provide and improve our services:

1.1 Personal Information You Provide

  • Name and surname
  • Email address
  • Cell phone number
  • Grade level and curriculum information (for students)
  • Profile picture (optional)
  • Account credentials (when registering directly with us)

1.2 Information from Third-Party Sign-In Services

When you sign in using Google or Apple, we receive:

  • Your name
  • Email address
  • Profile picture (if available)
  • Unique identifier from the third-party service

1.3 Subscription and Payment Information

  • Subscription status and history
  • In-app purchase receipts (processed through Google Play Store and Apple App Store)
  • Transaction identifiers

Note: We do not store your credit card or payment details. All payments are processed securely by Google Play Store and Apple App Store.

1.4 Usage and Device Information

  • Device type and operating system
  • App version
  • Device tokens (for push notifications via Firebase Cloud Messaging)
  • Curriculum progress and teaching plan interactions
  • Notification preferences
  • IP address and general location (country/city level)

2. How We Use Your Information

We use your personal information for the following purposes:

  • To create and manage your account
  • To provide access to curriculum content and teaching plans aligned with South African CAPS (Curriculum and Assessment Policy Statement)
  • To process and manage your subscription
  • To send you relevant notifications about teaching plans and updates
  • To provide customer support
  • To improve our services and develop new features
  • To comply with legal obligations, including tax and financial record-keeping requirements
  • To prevent fraud and ensure platform security
  • To communicate important updates about our services

3. Legal Basis for Processing (POPIA Compliance)

Under POPIA, we process your personal information based on the following lawful grounds:

  • Consent: You provide explicit consent when creating an account and accepting this Privacy Notice
  • Contractual Necessity: Processing is necessary to provide our services under our Terms of Service
  • Legal Obligation: We retain certain transaction records to comply with South African tax laws and financial regulations
  • Legitimate Interest: We process data to improve our services, prevent fraud, and ensure platform security

4. Parental Consent and Children’s Privacy

MindSprout provides educational content for children aged 6-18 (Grades R-12). We take children’s privacy seriously:

  • For users under the age of 18, we require parental or guardian consent before creating an account
  • Parents/guardians can request access to, correction of, or deletion of their child’s personal information
  • We do not knowingly collect unnecessary personal information from children
  • We limit data collection to what is essential for providing educational services
  • Parents/guardians have the right to revoke consent at any time

If you are a parent or guardian and believe your child is using our services without your consent, please contact us immediately at info@phauwedigital.co.za

5. Sharing Your Information

We do not sell your personal information to third parties. We only share your information with:

5.1 Service Providers

  • Firebase Cloud Messaging (Google): For sending push notifications about teaching plans and updates
  • Google Play Store and Apple App Store: For processing in-app purchases and subscription management
  • Google and Apple OAuth: For secure authentication when you choose to sign in with these services

5.2 Legal Requirements

We may disclose your information if required by law, court order, or government regulation, or to:

  • Comply with legal processes
  • Enforce our Terms of Service
  • Protect the rights, property, or safety of Phauwe Digital, our users, or the public
  • Prevent fraud or security threats

6. Data Security

We implement appropriate technical and organizational measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction:

  • Secure data transmission using encryption (HTTPS/TLS)
  • Secure authentication mechanisms including OAuth 2.0
  • Regular security assessments and updates
  • Access controls limiting who can access personal information
  • Secure cloud infrastructure
  • Hashed device fingerprints for fraud prevention

While we strive to protect your information, no method of transmission over the internet is 100% secure. We cannot guarantee absolute security but continually work to improve our security measures.

7. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Notice:

  • Active Accounts: Your data is retained while your account is active
  • Account Deletion: When you request account deletion, personal information is permanently deleted within 2 business days
  • Legal Records: We retain transaction history and subscription records for 7 years to comply with South African tax and financial regulations (even after account deletion)
  • Data Export Files: Exported data files are automatically deleted after 30 days

8. Your Rights Under POPIA

As a South African data subject, you have the following rights:

  • Right to Access: Request a copy of the personal information we hold about you
  • Right to Correction: Request correction of inaccurate or incomplete information
  • Right to Deletion: Request deletion of your personal information (subject to legal retention requirements)
  • Right to Objection: Object to certain types of processing
  • Right to Restriction: Request that we limit how we use your information
  • Right to Data Portability: Receive your data in a structured, machine-readable format
  • Right to Withdraw Consent: Withdraw consent at any time (where consent is the basis for processing)

How to Exercise Your Rights

You can exercise your rights by:

  • Using the in-app data request features (available in Profile → Privacy Settings)
  • Contacting us at info@phauwedigital.co.za

We will respond to your request within 30 days as required by POPIA.

9. Data Export and Deletion

9.1 Export Your Data

You can request a complete export of your personal data at any time through the app:

  • Go to Profile → Export My Data
  • You will receive an email when your data is ready to download
  • Download links expire after 2 days for security reasons

9.2 Delete Your Account

To permanently delete your account:

  • Go to Profile → Delete My Account
  • Confirm your decision
  • Your personal data will be permanently deleted within 2 business days
  • Transaction records will be retained for legal compliance but will be anonymized

10. Push Notifications

We use Firebase Cloud Messaging to send you notifications about:

  • Weekly teaching plans (sent on Sundays)
  • Important curriculum updates
  • Subscription reminders
  • Account security alerts

You can manage your notification preferences:

  • Through your device settings
  • By contacting us at info@phauwedigital.co.za

Opting out of notifications will not affect your ability to use the app, but you may miss important curriculum updates.

11. Third-Party Services

Our app integrates with third-party services that have their own privacy policies:

  • Google Services (Firebase, OAuth, Play Store): https://policies.google.com/privacy
  • Apple Services (Sign In with Apple, App Store): https://www.apple.com/legal/privacy/

We encourage you to review their privacy policies. We are not responsible for the privacy practices of these third-party services.

12. International Data Transfers

Your information is primarily stored and processed in South Africa. However, some of our service providers (such as Firebase/Google and Apple) may process data in other countries. When data is transferred internationally, we ensure appropriate safeguards are in place to protect your information in accordance with POPIA requirements.

13. Changes to This Privacy Notice

We may update this Privacy Notice from time to time to reflect changes in our practices or legal requirements. When we make significant changes:

  • We will update the “Last Updated” date at the top of this notice
  • We will notify you through the app or by email
  • Continued use of the app after changes constitutes acceptance of the updated Privacy Notice

We encourage you to review this Privacy Notice periodically to stay informed about how we protect your information.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Notice or our data practices, please contact us:

Phauwe Digital
Registration Number: 2024/102605/07
Email: info@phauwedigital.co.za
Location: South Africa
Website: https://mindsprout.phauwedigital.co.za

For data protection inquiries specifically, please use the subject line “Privacy Inquiry” to ensure your request is handled promptly.

15. Information Regulator

If you believe we have not adequately addressed your privacy concerns, you have the right to lodge a complaint with the Information Regulator of South Africa:

Information Regulator (South Africa)
JD House, 27 Stiemens Street
Braamfontein, Johannesburg, 2001
P.O Box 31533, Braamfontein, Johannesburg, 2017
Email: inforeg@justice.gov.za
Website: https://www.justice.gov.za/inforeg/

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