This manual sets out how trading as Learna™ processes personal information under the Protection of Personal Information Act 4 of 2013 and Regulation 4 of the POPIA Regulations. It must be read with the Privacy Policy and the PAIA Manual.
1. Responsible party
Trading as Learna™
Registration number:
Physical address: Ashley Drive, Gillitts, Durban, KwaZulu-Natal, 3610, South Africa
Email: hello@learna.co.za
2. Information Officer and Deputy
The Information Officer of a private body is the head of the body (section 1 of PAIA read with section 55 of POPIA), unless another person is designated. The Information Officer and any Deputy Information Officer must be registered with the Regulator before taking up their duties (section 55(2)).
Information Officer: Trevor Roberts
Email: info@learna.co.za
Telephone: +27832731489
Deputy Information Officer:
Email:
Telephone:
See the Information Officer page for duties and how to make a request.
3. Duties of the Information Officer
Section 55(1) of POPIA requires the Information Officer to:
- encourage compliance by the body with the conditions for the lawful processing of personal information;
- deal with requests made to the body pursuant to POPIA;
- work with the Regulator in relation to investigations under Chapter 6; and
- otherwise ensure compliance by the body with POPIA.
Regulation 4 additionally requires the Information Officer to ensure that:
- a compliance framework is developed, implemented, monitored and maintained;
- a personal information impact assessment is done so that adequate measures exist to comply with the conditions for lawful processing;
- a manual is developed, monitored, maintained and made available as prescribed in section 51 of PAIA;
- internal measures are developed together with adequate systems to process requests for information or access thereto; and
- internal awareness sessions are conducted regarding the provisions of POPIA, the Regulations, codes of conduct and information obtained from the Regulator.
4. Conditions for lawful processing
Personal information is processed in line with the eight conditions in Chapter 3 of POPIA:
- Accountability — the responsible party ensures the conditions are complied with.
- Processing limitation — processing is lawful, reasonable and only as much as is needed. Children’s information is processed with the parent or guardian as competent person.
- Purpose specification — collected for a specific, explicitly defined and lawful purpose (subscriptions, Campus access, Teacher Directory, billing, safety, legal duties).
- Further processing limitation — further processing is compatible with the original purpose.
- Information quality — reasonably practicable steps to ensure information is complete, accurate, not misleading and updated.
- Openness — this manual, the Privacy Policy and the PAIA Manual document processing; data subjects are informed as required by section 18.
- Security safeguards — reasonable technical and organisational measures; operators bound by contract; security compromises handled under section 22.
- Data subject participation — access, correction and related rights under sections 23–25.
5. Purpose of processing
To conclude and perform family and teacher subscription contracts; create and manage learner logins; operate Campus and courses; list verified teachers; process payments through PayFast; prevent fraud and protect children; meet tax, CPA, ECTA, PAIA and POPIA duties; and, where consent is given, send optional marketing.
6. Categories of data subjects and personal information
Parents and customers — names, contact details, billing address, subscription status, WhatsApp if provided.
Learners — first name, grade, username, parent email, Campus activity.
Teachers — identity, contact, qualifications, SACE, police-clearance status, listing content.
Visitors — IP address, device and cookie data.
Suppliers and personnel — as applicable.
7. Recipients and operators
Hosting and infrastructure providers; email providers; FluentCommunity; PayFast; professional advisers; the Regulator, SARS or a court where required by law. Campus posts are visible only to members of the relevant space.
8. Transborder flows
Operators may process information outside the Republic. Transfers are undertaken in accordance with section 72 of POPIA.
9. Retention and deletion
Records are kept while the account is active and thereafter for as long as tax, POPIA, CPA or dispute purposes require, then deleted or de-identified where reasonably practicable.
10. Security compromises
Where there are reasonable grounds to believe that personal information has been accessed or acquired by an unauthorised person, the Information Officer will notify the Regulator and the affected data subject as required by section 22 of POPIA.
11. Data subject rights and forms
A data subject may request confirmation whether we hold their information and may request a copy (section 23); request correction or deletion (section 24); object to processing (section 11(3)); and withdraw consent where processing is consent-based. Prescribed POPIA forms include:
- Form 1 — Objection to processing
- Form 2 — Request for correction or deletion / destruction of a record
- Form 4 — Consent for processing for direct marketing by electronic communication
Forms are available from the Regulator and from the Information Officer. Use info@learna.co.za.
12. Complaints
If you are not satisfied, you may lodge a complaint with the Information Regulator (POPIAComplaints@inforegulator.org.za) or seek court relief. See inforegulator.org.za.