Privacy Policy

Adcam Advertising (Pty) Ltd, a company incorporated in the Republic of South Africa, is the responsible party for the personal information described here.

• Information officer: privacy@k53examiner.co.za
• General support: support@k53examiner.co.za

We apply the eight conditions for lawful processing: accountability, processing limitation, purpose specification, further processing limitation, information quality, openness, security safeguards, and data subject participation. We collect the minimum information needed to run the App and use it only for the purposes set out below.

• Account information — email address, password (stored hashed by our authentication provider, and never visible to us), display name, and the basic profile Google returns if you sign in with Google.
• Cellphone number — if you register or sign in with your cellphone number, we store that number so we can identify your account and send you a one-time sign-in code by SMS through our SMS provider, Twilio. We do not use your number for marketing without your consent.
• Profile and preferences — the licence code you study for, your daily goal, and app settings.
• Study and performance data — the questions you answer, whether each answer was correct, quiz and mock-exam sessions, scores, timings, mastery progress and bookmarks.
• Problem reports — the message you write, the screen you were on, your browser and screen size, and the screenshot the App captures when you submit a report.
• Advertising interaction data — when you tap an advertising banner we record the banner, the date and time, the screen you were on, a coarse device category (phone, tablet or desktop) and your account identifier.
• Technical and log data — information our hosting and database providers generate to run and secure the service, such as request logs and error reports.
• Acceptance records — the version of the Terms and this Policy you accepted, when, and the browser used.

We do not ask for your ID number, physical address, biometric data or payment card details, and we do not knowingly collect special personal information as defined in POPIA.

• To provide the App — creating and securing your account, saving progress across devices, calculating readiness and statistics. Basis: necessary to perform the agreement between us (section 11(1)(b)).
• To support and improve — answering support requests, fixing bugs reported through the App and improving content quality. Basis: legitimate interests (section 11(1)(f)) and performance of the agreement.
• To run advertising — counting ad taps, reporting performance to advertisers, billing them and detecting fraudulent or automated clicks. Basis: legitimate interests in funding a free service, and your consent given when you accept these documents.
• To comply with the law — keeping records we are legally required to keep and responding to lawful requests. Basis: legal obligation (section 11(1)(c)).

We do not sell your personal information. We do not build advertising profiles about you, and advertisers receive aggregated counts, not your identity or study data.

We share personal information only with operators who process it on our written instruction and are bound to keep it confidential and secure (section 21):

• our cloud hosting, database, storage and authentication provider, which runs the App and stores your account and study data;
• our email delivery provider, for account and password emails;
• Twilio, our SMS provider, for one-time sign-in codes sent to your cellphone number;
• error-monitoring and analytics tooling used to keep the App working.

We may also disclose information where the law requires it, to protect our rights, or as part of a merger or sale of the business, in which case this Policy continues to apply until you are notified otherwise.

Our providers may store or process data on servers outside South Africa. We only use providers that are subject to laws, binding agreements or corporate rules giving substantially similar protection to POPIA, and that place equivalent obligations on any onward transfer. By accepting this Policy you also consent to such transfers.

• Account, profile and study data — for as long as your account is open.
• Problem reports and screenshots — up to 12 months after the report is closed.
• Ad interaction records — up to 24 months, for advertiser reporting, billing and fraud investigation.
• Acceptance records — for as long as your account is open and for 5 years afterwards, as proof of consent.

When you delete your account, your profile, answers, sessions, bookmarks and reports are permanently deleted. De-identified or aggregated statistics that cannot identify you may be retained.

Access to the App requires authentication, and database row-level security rules ensure you can only read and write your own records. Traffic is encrypted in transit, uploaded files are served through expiring signed links, and administrative access is limited to authorised personnel. No system is perfectly secure, so please use a strong, unique password and sign out on shared devices.

If personal information is accessed or acquired by an unauthorised person, we will notify the Information Regulator and affected users as soon as reasonably possible after establishing the extent of the compromise, and will explain what happened and what you can do to protect yourself.

You have the right to:

• ask whether we hold personal information about you and request a copy of it;
• ask us to correct or update inaccurate information;
• ask us to delete information that is inaccurate, irrelevant, excessive, out of date or obtained unlawfully, or delete your whole account yourself from Profile → Delete account;
• object, on reasonable grounds, to processing based on legitimate interests, including our ad interaction logging;
• withdraw consent where processing is based on consent; and
• lodge a complaint with the Information Regulator.

To exercise a right, email privacy@k53examiner.co.za. We may ask you to verify your identity, and will respond within a reasonable time. Access requests are handled in terms of the Promotion of Access to Information Act 2 of 2000; the prescribed fee may apply to copies. Withdrawing consent to ad interaction logging means we can no longer offer you the free, ad-supported App.

We send you service and account emails that are necessary to run the App. We do not send electronic direct marketing without your prior consent or unless you are an existing customer of a similar product, and every marketing message includes an opt-out. Advertising banners inside the App are not personalised to you.

We use browser storage and cookies that are strictly necessary to keep you signed in, to remember your settings, and to let the App work offline as an installed app. We do not use third-party advertising cookies or cross-site tracking pixels. Clearing this storage signs you out.

Two further categories are optional and are only used if you agree to them when you register: usage measurement (which screens are opened and for how long, so we can improve the App) and advertising records (which advert was displayed or tapped, for advertiser reporting).

You may refuse both and still use every part of the App. If you refuse, adverts are still displayed, but no usage or advertising records are kept about you. We store your answer against your account together with the date and the version of these terms, so it applies on every device you sign in on.

The App is intended for learner-licence candidates aged 16 and above. If you are under 18, a parent or legal guardian must consent to your use of the App and to this processing, as required by section 35 of POPIA. If we learn that we hold a child's information without the necessary consent, we will delete it.

Readiness scores and mastery tracking are calculated automatically from your own answers to help you study. These calculations do not have legal consequences for you and are not used to make decisions about you outside the App.

If you are not satisfied with how we handle your personal information, you may complain to the Information Regulator (South Africa):

• JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
• Complaints: POPIAComplaints@inforegulator.org.za
• General enquiries: enquiries@inforegulator.org.za
• Website: https://inforegulator.org.za

We update this Policy as the App changes and show the new date and version at the top. Where a change is material, we will ask you to accept the updated documents in the App before you continue. Questions go to privacy@k53examiner.co.za.