altair
Draft: this page is waiting for review by our attorney and may change. Highlighted items are still to be filled in.
Altair Privacy Notice
Altair by First Principles
Last updated: [PLACEHOLDER: date]
This notice explains how we collect, use, share and protect personal information about you and your child, as required by the Protection of Personal Information Act 4 of 2013 (POPIA). [VERIFY: POPIA section 18 — information to give when collecting]
[DECISION: Also publish a short, child-friendly version for children in Grades 1 to 12.]
1. Who we are
1.1 The responsible party is [ALTAIR ENTITY NAME] (Pty) Ltd, registration number [REG NO], of [ADDRESS] ("Altair", "we", "us").
1.2 Information officer: [NAME, EMAIL]. Contact the information officer about anything in this notice. [PLACEHOLDER: deputy information officer, if any]
1.3 Our PAIA manual, which explains how to request records, is available at [PLACEHOLDER: link]. [VERIFY: PAIA section 51 manual requirement]
2. Children's personal information
2.1 Altair is for children in Grades 1 to 12. Under POPIA, a "child" is anyone under 18. We may process a child's personal information only with the prior consent of a competent person — a parent or legal guardian — or on another ground allowed by POPIA [VERIFY: POPIA sections 34 and 35(1)].
2.2 That is why:
(a) only a parent or guardian aged 18 or older can open an account;
(b) children use Altair under the parent's account;
(c) we ask the parent to give consent when adding each child, using the Altair consent forms;
(d) we collect only what we need about children.
2.3 If we learn that we hold a child's information without a competent person's consent, we will delete it unless another lawful ground applies.
3. What information we collect
About your child
| Category | Examples | Where it comes from |
|---|---|---|
| Identity | First name, surname, age or grade band | You |
| Learning content | Typed worksheet answers, drawings on worksheets | Your child, in the app |
| Progress | Lessons completed, marks given by you, stars, progress charts | The app and you |
| Lab records | Centre attended, attendance, sign-in and sign-out | Altair or the partner centre |
| Health (optional) | Allergies, medical conditions, medication | You, only if you choose |
| Images (only with consent) | Photos or video at Labs | Altair or the partner centre |
About you (the parent or guardian)
| Category | Examples |
|---|---|
| Contact | Name, mobile number, email, relationship to child |
| Account | Login details, plan, settings, consents given |
| Emergency and collection | Names and numbers of emergency contacts and people allowed to collect your child |
| Billing | Plan, payment history, invoices. Card and bank details are handled by our payment provider, [PAYMENT PROVIDER]; we do not store full card details. |
| Communications | Messages with us, complaints, marketing choices |
| Technical | Device type, browser, IP address, app usage logs, cookies [DECISION: list analytics tools, if any] |
3.1 Special personal information. Health details are special personal information under POPIA [VERIFY: section 26]. We process them only with your consent [VERIFY: section 27(1)(a)], and only to keep your child safe at Labs.
3.2 Please do not let your child type their full name, school, address or other identifying details into worksheet answers or drawings.
4. Why we use it
We use personal information to:
(a) create and manage your account and your child's profile;
(b) deliver lessons, worksheets and videos, save your child's work, and show progress and stars;
(c) let you review and mark your child's work;
(d) enrol your child in Labs, take attendance, and keep children safe (emergency contacts, collection, allergies);
(e) bill you and process payments through [PAYMENT PROVIDER];
(f) answer questions, handle complaints and give support;
(g) send service messages, such as billing, Lab changes and safety notices;
(h) send marketing, only if you have consented (see clause 8);
(i) use photos or video, only for the uses you ticked on the photo/video consent form;
(j) improve the app and lessons [DECISION: using de-identified or aggregated data only?];
(k) meet our legal duties (for example, tax records) and protect our legal rights.
5. Our legal grounds
5.1 We rely on:
(a) consent of a competent person for children's information [VERIFY: section 35(1)(a)] and for health information;
(b) performing our contract with you, for your own information needed to run your subscription [VERIFY: section 11(1)(b)];
(c) legal obligations [VERIFY: section 11(1)(c)];
(d) legitimate interests, for example security and fraud prevention, where this does not override your rights [VERIFY: section 11(1)(f)].
5.2 Where we rely on consent, you can withdraw it at any time (clause 11). This does not affect processing before you withdrew it.
6. Who we share it with
6.1 Operators. We use service providers who process information on our behalf, under written contracts that require them to keep it confidential and secure [VERIFY: POPIA sections 20 and 21]:
| Service | Provider |
|---|---|
| Cloud hosting and database | [PLACEHOLDER: hosting provider and region] |
| Payments | [PAYMENT PROVIDER] |
| [PLACEHOLDER: email provider] | |
| WhatsApp messaging | [PLACEHOLDER: WhatsApp Business provider] |
| SMS | [PLACEHOLDER: SMS provider] |
| Video hosting | [PLACEHOLDER, if used] |
| Analytics | [PLACEHOLDER, if used] |
6.2 Partner tuition centres. If your child attends a Lab, the partner centre receives what it needs to run the Lab safely: your child's name, attendance, emergency contacts, collection list and (if given) medical details. The centre acts as our operator for this information. [DECISION: In the licence model, if the centre bills you directly, it also becomes responsible for its own billing records — attorney to confirm wording.]
6.3 Others, only where needed. Emergency services or medical staff in an emergency; professional advisers; authorities where the law requires it; a buyer of our business (who must keep this notice's protections).
6.4 We do not sell personal information. We do not share it with others for their own marketing.
7. Transfers outside South Africa
7.1 Some of our operators (for example, cloud hosting, email and WhatsApp) may store or process information outside South Africa.
7.2 We only transfer information if the recipient is bound by law, binding corporate rules or a contract giving protection substantially similar to POPIA, or another ground in POPIA section 72 applies [VERIFY: section 72(1)].
7.3 [PLACEHOLDER: countries or regions where data may be stored.]
8. Marketing
8.1 We send marketing by WhatsApp, email or SMS only if you have consented on our marketing consent form, or as otherwise allowed by POPIA section 69 [VERIFY].
8.2 Every marketing message has a free and simple way to opt out.
8.3 We never send marketing to children.
9. How long we keep it
We keep information only as long as needed for the purpose, or as the law requires [VERIFY: POPIA section 14]. [DECISION: confirm all periods.]
| Information | Retention |
|---|---|
| Child's work and progress | While the account is active, plus [DECISION: 12] months after cancellation (so you can return), then deleted |
| Account and contact details | While active, plus [DECISION: 12] months |
| Billing and tax records | [VERIFY: 5 years — Tax Administration Act / Companies Act] |
| Medical details for Labs | While your child is enrolled in Labs, then deleted within [DECISION: 30] days |
| Incident and safeguarding records | [DECISION: Attorney to advise — likely until the child turns 21 or longer, because claims by minors prescribe later] |
| Photos and video | Until consent is withdrawn, or [DECISION: 3] years, whichever is sooner |
| Marketing choices | While you are a customer, and a record of opt-outs for as long as needed to respect them |
After that, we delete information or make it de-identified.
10. How we keep it safe
10.1 We take reasonable technical and organisational steps to protect information [VERIFY: POPIA section 19], including [DECISION: confirm actual measures]:
(a) encryption in transit and at rest;
(b) access limited to staff who need it, with strong passwords and two-factor authentication;
(c) separate, stricter access to children's medical information;
(d) staff and facilitator confidentiality and safeguarding training;
(e) written security requirements for operators and partner centres.
10.2 If we have reason to believe personal information has been accessed or acquired by an unauthorised person, we will notify the Information Regulator and affected families as soon as reasonably possible [VERIFY: POPIA section 22].
11. Your rights
You (and, through you, your child) have the right to:
(a) know whether we hold personal information and access it [VERIFY: section 23];
(b) ask us to correct or delete information that is wrong, out of date, excessive or unlawfully held [VERIFY: section 24];
(c) object to processing based on legitimate interests [VERIFY: section 11(3)];
(d) withdraw consent at any time, including for photos, medical information and marketing;
(e) opt out of marketing;
(f) complain to the Information Regulator [VERIFY: section 74].
To use these rights, contact our information officer at [NAME, EMAIL]. We may need to confirm your identity. We will respond within [DECISION: 30 days] [VERIFY: PAIA timelines for access requests]. Withdrawing consent for your child's core information means we can no longer provide the app for that child.
12. Cookies and app tracking
[DECISION: Describe cookies and analytics, if used. Recommended: essential cookies only for children's areas; no third-party advertising trackers.]
13. The Information Regulator
If you are not satisfied with how we handle your information, you may complain to:
Information Regulator (South Africa) [VERIFY all details before publishing]
- Address: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191
- Phone: 010 023 5200
- Email (general enquiries): enquiries@inforegulator.org.za
- Email (POPIA complaints): [PLACEHOLDER: verify current complaints address]
- Website: https://inforegulator.org.za
14. Changes to this notice
We may update this notice. We will tell you about important changes by email, WhatsApp or in the app before they take effect. If a change needs new consent, we will ask for it.
Questions: hello@altairkids.com