This Privacy Policy explains how we collect, use, store, share and protect your personal information when you use the App. We process personal information in accordance with the Protection of Personal Information Act 4 of 2013 ("POPIA").
This Privacy Policy should be read together with our Terms of Use.
XP Labs Pty Ltd is the Responsible Party (data controller) for your personal information under POPIA.
For any POPIA-related queries, or to contact our Information Officer, email us at:
We collect only what we need to run the App and help you study. This includes:
Information you give us when you register or use the App:
Information generated as you use the App:
Information we collect automatically:
Payment information:
We collect personal information:
Under POPIA we may only process your information where we have lawful grounds. We rely on the following:
| Purpose | Legal basis under POPIA |
|---|---|
| Create and manage your account | Performance of our agreement with you |
| Give you access to purchased content | Performance of our agreement with you |
| Track and save your learning progress | Performance of our agreement / your consent |
| Process payments and prevent fraud | Performance of agreement / legitimate interest / legal obligation |
| Send service messages (e.g. receipts, important notices) | Performance of agreement / legitimate interest |
| Send reminders, streak nudges and marketing | Your consent (you may opt out at any time) |
| Improve the App and fix problems | Our legitimate interest |
| Comply with the law | Legal obligation |
We do not sell your personal information. We share it only with parties who help us operate the App, and only as far as needed:
Each provider is required to protect your information and use it only for the agreed purpose.
Some of our service providers (for example, cloud hosting and analytics) may store or process data outside South Africa. Where this happens, we take steps required by section 72 of POPIA to ensure your information receives an adequate level of protection, for example through contractual safeguards or by using providers in countries with comparable data protection laws. Our payment provider, PayFast, processes all payments within South Africa; we do not process cross-border payments.
We keep your personal information only for as long as:
When information is no longer needed, we delete or de-identify it. You can ask us to delete your account at any time (see section 9).
We apply reasonable technical and organisational measures as required by POPIA, including:
No system is perfectly secure. If a data breach occurs that risks your rights, we will notify you and the Information Regulator as required by POPIA.
You have the right to:
To exercise any right, contact us at hello@rideofpassage.co.za. We may need to verify your identity before acting on your request.
The K53 learner's licence may be applied for from the age of 17 in South Africa, so some of our users may be minors (under 18).
We will only send you marketing messages (such as study tips, offers and reminders) where you have agreed to receive them. You can opt out at any time via the App settings or the unsubscribe option in any message. Opting out of marketing does not stop important service messages (such as payment receipts or policy changes).
We may update this Privacy Policy from time to time. If we make material changes, we will notify you in the App or by email. The "Last updated" date at the top shows the latest version. Continued use of the App after changes means you accept the updated policy.
If you believe we have not handled your personal information properly, please contact us first so we can try to resolve it. You also have the right to complain to:
The Information Regulator (South Africa)
End of Privacy Policy.