Privacy Policy

Last Updated: May 2026

1. INTRODUCTION

Elite Remote Solutions (Pty) Ltd ("we", "us", "our") respects your privacy and is committed to protecting your personal information in accordance with the Protection of Personal Information Act, 2013 (POPIA) of South Africa.

This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you use the Elite Remote Learning application or website.

2. WHO WE ARE

• Company: Elite Remote Solutions (Pty) Ltd
• Trading as: Elite Remote Learning
• Registration: 2026/266812/07
• Founded by: Thaakirah Unwarsa
• Information Officer: Thaakirah Unwarsa
• Contact: info@eliteremotesolutions.com

3. INFORMATION WE COLLECT

3.1 Information You Provide

• Name and contact details (email, phone)
• Parent/guardian details (for users under 18)
• Each child profile's name, grade, and curriculum
• Login credentials (email and password)
• Photos and questions uploaded for homework help
• Communications with our support team

3.2 Information We Automatically Collect

• Usage data (subjects studied, time spent, features used)
• Device information (type, operating system, app version)
• IP address and approximate location
• Language preferences
• Crash reports and performance data

3.3 We Do NOT Collect

• Bank account details
• ID document copies
• Biometric data
• Medical or health information
• Card payment details (handled by Google Play)

4. HOW WE USE YOUR INFORMATION

• Provide the AI tutoring service
• Personalise learning for each child profile's grade and curriculum
• Process subscription payments via Google Play
• Send important account notifications
• Respond to support requests
• Improve the Service and AI accuracy
• Track learning progress for parent dashboards
• Detect fraud and ensure account security
• Comply with legal obligations

5. CHILDREN'S PRIVACY

• Parental/guardian consent is REQUIRED before account activation
• Parents provide verifiable contact details (email, phone)
• Email verification link sent to parent before account activation
• Parents can review, modify, or delete their child's data anytime
• NO direct marketing to children
• Account locked if parent withdraws consent
• Children's photos uploaded for homework are processed by AI then discarded

6. AI PROCESSING

Our AI tutor "Elite" is powered by industry-leading language model technology:

• Questions and homework photos are sent to our AI processing partners
• NO personally identifiable information is shared with AI services
• AI partners do NOT retain your queries for training
• Conversation history is stored on our SA servers, not with AI partners
• You can delete your conversation history anytime

7. PAYMENT DATA SECURITY

All payment processing is handled by Google Play Billing:

• We do NOT store, process, or transmit card details
• Google Play handles all card data with bank-level encryption
• Secure tokenization and fraud detection by Google
• We never see your card number

8. DATA SHARING

8.1 Service Providers

• Google Play: Payment processing
• Vultr: Hosting (encrypted server storage in Johannesburg)
• Google: Email service
• AI Technology Providers: Tutoring responses (anonymised queries only)

8.2 We NEVER:

• Sell your personal information to anyone
• Share data with marketing companies
• Allow third parties to track children
• Share data outside of South Africa without consent

9. DATA STORAGE AND SECURITY

• Data stored on encrypted servers in Johannesburg, South Africa
• All data transmission encrypted with TLS 1.3
• Passwords hashed using bcrypt (one-way encryption)
• Multi-factor authentication for admin access
• Regular security audits
• Daily encrypted backups
• Strict access controls
• Cyber liability insurance (active)

10. DATA RETENTION

• Account data: While subscription is active + 30 days after cancellation
• Payment records: 7 years (SARS tax compliance)
• Support communications: 2 years
• Usage analytics: Anonymised after 1 year
• Homework photos: Deleted after 30 days unless saved by user
• Children's data: Permanently deleted within 30 days of account deletion

11. YOUR RIGHTS UNDER POPIA

• Right to Access your personal information
• Right to Correction of inaccurate information
• Right to Deletion of your data
• Right to Object to certain processing
• Right to Withdraw Consent anytime
• Right to Data Portability
• Right to Lodge a Complaint with the Information Regulator

To exercise these rights, email: info@eliteremotesolutions.com

12. INFORMATION REGULATOR (SA)

If you believe your privacy rights have been violated, you can complain to:

• Information Regulator (South Africa)
• JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
• Email: inforeg@justice.gov.za
• Phone: +27 (0) 10 023 5200

13. COOKIES AND TRACKING

Our website uses minimal cookies for essential session management, security, and preference storage. We do NOT use advertising cookies, third-party tracking, or social media tracking pixels.

14. CHANGES TO THIS POLICY

• We may update this Privacy Policy from time to time
• Material changes communicated via email and in-app notification
• Updated date shown at the top of this policy
• 30-day notice for significant changes

15. SECURITY INCIDENT RESPONSE

• We will notify affected users within 72 hours of a data breach
• The Information Regulator will be notified as required by POPIA
• Detailed incident report provided
• Remediation actions communicated