Privacy Policy

1. Who we are

LearnSquad is a South African, monthly subscription-based digital education access platform owned by Randgo (Pty) Ltd.

LearnSquad provides subscription and access management. Partner colleges deliver learning, manage academic progress on their systems, and issue certificates.

Randgo (Pty) Ltd
8 Waterval Crescent South, Woodmead, Sandton, 2191
Email: support@learnsquad.co.za

2. Key POPIA terms and roles

Under POPIA:

• “Personal information” means information that identifies you or can reasonably be linked to you (directly or indirectly).
• “Responsible party” is the organisation that decides why and how personal information is processed.
• “Operator” is a  processes personal information for a responsible party under contract.

For the LearnSquad platform:

• Randgo (Pty) Ltd (LearnSquad) is the responsible par website/platform, subscription management, and user support.
• Partner colleges are generally separate responsible parties for the information they process on their own learning platforms (LMS), assessments, certificates, and academic administration.

This means your data may be processed under this policy (LearnSquad) and also under a partner college’s privacy policy when you use that partner’s platform.

3. Where this policy applies

This policy applies to personal information processed via:

• the LearnSquad website and platform;
• LearnSquad support channels (email/forms);
• LearnSquad subscription and billing workflows.

When you click “Start / Access course”, you may be redirected or handed over to a partner college platform. That partner college platform may have additional terms and privacy practices.

4. What information we collect

4.1 Information you provide to LearnSquad

• Account details: name, email address, mobile number, password (stored securely), basic preferences.
• Support and communications: content of messages you send to us, and records needed to resolve issues.
• Identity / verification details (only where required): e.g., South African ID or passport number where required for partner college administration and/or certificate issuance.

4.2 Subscription and billing information (subscription product)

To operate a month-to-month subscription fairly and securely, we process:

• subscription status (Active/Inactive), start/end dates and billing cycle metadata;
• billing references, invoice/receipt records, and payment confirmations;
• chargeback/fraud-prevention and reconciliation records.

Card details: If you pay by card, your full card number/CVV is processed by our payment provider, not stored by LearnSquad. We may receive limited metadata (e.g., payment reference, last 4 digits, expiry month/year) depending on the provider’s setup.

4.3 Information we receive from partner colleges (limited)

Depending on the partner arrangement, LearnSquad may receive limited information such as:

• activation confirmation (that you were provisioned/litform);
• completion status or outcomes only if provided by the partner for reporting/support purposes.

4.4 Information collected automatically (digital product)

• device and browser information;
• IP address and logs (including approximate location derived from IP);
• platform usage (pages visited, clicks, time spent, referral source);
• cookie identifiers (see Section 9).

5. Why we use your information (purposes)

We use personal information to:

• create and manage your account, authenticate access, and prevent unauthorised use;
• manage your subscription, billing status, and access enforcement while active;
• enable course access and share the minimum required data with partner colleges so they can deliver learning and, where applicable, issue certificates;
• provide user support and route queries correctly (platform/subscription vs academic delivery);
• send service messages (password resets, subscription notices, platform updates);
• improve product performance, stability, and user experience using analytics and diagnostics;
• comply with legal obligations and protect LearnSquad and users from misuse/fraud.

6. POPIA lawful grounds for processing

We process personal information only where, including where:

• it is necessary to perform a contract with you (e.g., providing subscription access you requested);
• you have given consent (e.g., optional marketing);
• processing is required by law; or
• processing is necessary for legitimate interests, balanced against your rights.

We follow POPIA’s minimality principle: we only process information that is adequate, relevant, and not excessive for the purpose. ([South Africa Government][1])

7. Direct marketing and communications (POPIA + consumer rules)

7.1 Marketing by email/SMS/WhatsApp/push

Direct marketing by electronic communication is prohibited unless:

• you have consented; or
• you are an existing customer and specific conditions are met (similar products/services + clear opt‑out each time). ([South Africa Government][1])

If we send direct marketing:

• every marketing message will identify the sender and include clear opt‑out/unsubscribe instructions. ([South Africa Government][1])
• you can opt out at any time, free of charge.

7.2 Service messages vs marketing

Even if you opt out of marketing, we may still send service/transactional messages (e.g., password reset, billing notices, access status) because they are necessary to deliver the service.

• Note (subscription compliance): Cancellation rights, billing rules, cooling‑off (where applicable), and refund rules are explained in the LearnSquad Terms / Subscription Terms (not this Privacy Policy). South African e‑commerce rules can include cooling‑off rights for certain electronic transactions. ([South Africa Government][3])

8. When we share your information

We do not sell or rent your personal information.

We may share information with:

• Partner colleges for learner administration, course delivery, and certificate issuance (minimum necessary);
• Operators/service providers that host or support LearnSquad (e.g., hosting, email delivery, analytics, support tooling) under appropriate POPIA-aligned contracts;
• Payment providers to process subscription payments and manage fraud/chargebacks;
• regulators, courts, or law enforcement where required by law.

We may share aggregated/de-identified insights (that do not identify individuals) for reporting on platform performance and outcomes.

9. Cookies and analytics (digital product)

We use cookies and similar technologies to:

• keep you signed in during sessions;
• remember preferences;
• understand platform usage and improve performance.

Where cookies or tracking technologies are not strictly necessary (e.g., certain analytics/marketing cookies), we will use appropriate notice and consent mechanisms consistent with POPIA-aligned best practice.

You can manage cookies via your browser settings. Disabling cookies may reduce functionality.

10. International data transfers (POPIA s72)

If we transfer personal information outside South Africa (for example, where infrastructure or service providers are based abroad), we will do so only where POPIA’s cross-border requirements are met (e.g., adequate protection, binding agreements, consent, or contractual necessity). ([South Africa Government][1])

11. Security safeguards and breach notification

We use reasonable technical and organisational measures to protect personal information (access controls, encryption in transit, least-privilege access, secure hosting, monitoring).

POPIA requires responsible parties to secure integrity and confidentiality of personal information. ([South Africa Government][2])

If there are reasonable grounds to believe personal information was accessed or acquired by an unauthorised person, we will notify:

• the Information Regulator, and
• affected people (unless they cannot be identified),

as soon as reasonably possible, in line with POPIA. ([South Africa Government][1])

12. Retention of information

We keep personal information only as long as necessary for the purposes in this policy, including:

• while your account is active;
• as needed to provide support and manage disputes;
• as required by law.

Subscription and financial records: certain billing/tax/accounting records may need to be kept for longer periods under South African record-keeping rules (often 5–7 years depending on the type of record and the entity), after which they are securely deleted or de-identified.

13. Children (under 18)

POPIA places specific restrictions on processing a child’s personal information. A responsible party may not process a child’s personal information unless an applicable legal basis applies (commonly prior consent by a competent person). ([South Africa Government][1])

LearnSquad is intended primarily for adults. If we learn that we have collected personal information of a child without a valid basis, we will take steps to delete it or obtain the required authorisation/consent, as appropriate.

14. Your rights under POPIA

You may request to:

• access your personal information;
• correct inaccurate, incomplete, or outdated information;
• object to certain processing where applicable;
• withdraw consent where processing is based on consent (e.g., marketing);
• request deletion where appropriate and lawful;
• lodge a complaint with the Information Regulator.

We may require proof of identity before acting on certain requests.

15. Contact and complaints

POPIA / privacy requests (Randgo Information Officer):
Email: support@learnsquad.co.za

Information Regulator (South Africa):
General enquiries: enquiries@inforegulator.org.za
Telephone: 010 023 5200 / 0800 017 160
Address: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg. ([Inforegulator][4])

16. Changes to this policy

We may update this Privacy Policy from time to time. If changes are material, we will notify you via the platform and/or email. The latest version will always be made available on our website/platform.