Privacy Policy.
Last updated: 30 September 2026 · Version MENTOR-PRIV-2026-09-30 · In terms of the Protection of Personal Information Act 4 of 2013 (POPIA)
Summary: For learners, your school decides what is collected and how long it is kept — AOLC processes it on the school's instruction. We collect your name, email, school details, and grade to operate the AOLC Mentor service. Your chat messages and any files you upload are processed by our AI provider (Anthropic, or OpenAI as a standby) outside South Africa. If you speak a question instead of typing it, a recording of your voice is sent outside South Africa to be turned into text (Groq, or OpenAI as a standby); if Coal reads a reply aloud, only the text of that reply is sent (ElevenLabs, or OpenAI as a standby). If a learner's messages suggest they may be at risk, or they use abusive language, their teacher may get a short note saying what kind of thing happened — never the message itself. If a learner is stuck or asks for their teacher, the teacher may be told that the learner would like help, again without the message. When a teacher runs a lesson in the Mentor, we keep a short record of the learner's session, and for a PAT we keep the learner's journal, including any question asked in PAT mode and a shortened copy of the answer. A teacher who tries the demo gives us their contact details so that we can follow up; those go to AOLC's own ServiceDesk system. We use teacher contact details for marketing only if the teacher ticks the marketing box and confirms their email address. You may request deletion of your data at any time.
1. Who We Are (Responsible Party and Operator)
Your school is the responsible party in terms of POPIA for the personal information of its learners and staff processed through AOLC Mentor. AOLC (Pty) Ltd is the operator, which means we process that information on the school's written instruction and for no purpose of our own.
In practice this means:
- The school decides what is collected, who may see it, and how long it is kept. We act on that instruction.
- The school holds the relationship with parents and guardians, and obtains any consent required for a learner under 18.
- We keep a record of the school's confirmation that consent was obtained — who confirmed it, when, and against which version of this policy — and we make that record available to the school on request. It is the school's evidence, held by us.
- We do not use learner information for marketing, and we do not sell or share it.
Where there is no school — the public “Try it now” demonstration, and teachers who register directly — AOLC is the responsible party for the limited information described below. The demonstration does not ask a learner who they are. It keeps a short-lived record to enforce the demo limit (section 6), and a teacher who fills in the demo form gives us the details described in section 2a.
AOLC contact: systems@aolc.co.za · aolc.tech
For anything about a learner's information, contact the school first; we will answer the school.
2. What Personal Information We Collect
| Data | Who | Purpose |
|---|---|---|
| Full name, email address, password (hashed) | All users | Account authentication |
| School name, type, province, address, phone | Teachers | School registration; lead management |
| Principal name, number of learners | Teachers | Lead qualification for AOLC services |
| Grade (7 to 12) | Students | Tailoring AI responses to curriculum level |
| Chat messages, uploaded files and AI responses | All users | Generating tutoring responses (processed by our AI provider outside South Africa — see section 4) |
| A safeguarding note: what kind of concern it was (for example “abusive language aimed at someone”, or the Mentor's short reason for handing over to the teacher) and when — never the message itself | Students, only when needed | So that the learner's own teacher can check they are all right (see section 5) |
| A help request: that the learner would like their teacher's help, with the Mentor's short reason (for example “stuck twice on loops”) and when — never the message itself | Students, only when needed | So that the learner's own teacher can help them in the lesson (see section 5) |
| A lesson record, when your teacher runs a lesson in the Mentor: how many questions you used, the one-sentence wrap-up you wrote at the end, your exit-ticket answer and whether it was right, and whether you asked for your teacher (with the short reason you gave) | Students, in a teacher's lesson | So that your teacher can see how the lesson went and who needs help (see section 5) |
| A PAT journal: what you write in it, and any question you ask the Mentor in PAT mode together with a shortened copy of its answer | Students, for a PAT their teacher set | The evidence of how you did the task and used AI, which your teacher and the school's moderator may read (see section 5) |
| A recording of your voice, only if you choose to speak a question instead of typing it | All users | Turning what you said into text so the Mentor can answer it (sent outside South Africa for transcription, not stored by us — see section 4) |
| Name, email address, cell number, school, province and subject | Teachers who try the demo | Following up on that demo (see section 2a) |
| Marketing consent: whether you ticked the box, the exact wording and its version, and when | Teachers | POPIA-compliant record of consent |
| IP address, session data | All users | Security and rate limiting |
2a. Teacher demo details
Before the teacher demo we ask a teacher for their full name, email address, cell number, school name, province and the subject they teach, and whether they would like to receive product news. Learners are never asked for these details. AOLC is the responsible party for them.
- Why: so that AOLC can follow up on this demo with you. We use them for marketing only if you ticked the marketing box and then confirmed your email address. An unticked box is recorded as a “no”.
- Confirming your email address: we email you a 6-digit code and a one-tap link so that you can confirm the address is yours. The code is used only to confirm the address and is not used for marketing. The email may also tell you how to contact AOLC if you have a question, and a reply to it reaches AOLC; it contains no marketing. Whether the address has been confirmed is passed to our ServiceDesk system with your details.
- The 2027 pilot: if you register your school's interest in the 2027 pilot (on the demo form, or at the end of the demo), we record that you did and when, and pass it to our ServiceDesk system with your details so that AOLC can contact you about it. Registering interest does not guarantee a place.
- Where they go: the details are stored in the Mentor and sent to AOLC's own ServiceDesk system (servicedesk.aolc.tech), where they are recorded as a sales lead with a follow-up ticket. Both systems are run by AOLC (Pty) Ltd. We do not pass these details to any third party. If the first attempt to send them fails, the Mentor keeps trying until ServiceDesk confirms it has them.
- Your IP address is recorded when you submit the form, as evidence of when and from where you gave your details and your marketing choice. It is sent to ServiceDesk with your details, where it is kept with the record of your marketing consent if you gave one, and it is then removed from the Mentor. The Mentor keeps only a one-way hash of it.
- How long we keep them: for 24 months after our last contact with you, after which they are deleted automatically — or sooner, if you ask us to delete them.
- Stopping marketing: you can withdraw your marketing consent at any time — use the unsubscribe link in any marketing email, reply STOP to a WhatsApp message, or email systems@aolc.co.za. Withdrawing does not stop us following up on the demo you asked for unless you ask us to.
- Your rights: you may ask us for a copy of these details, to correct them, or to delete them from both the Mentor and ServiceDesk, and you may complain to the Information Regulator (see section 7).
3. How We Use Your Information
- Service delivery: Authenticating your account and providing the AI tutoring service.
- Curriculum personalisation: Using your grade to tailor AI responses to the correct CAPS level.
- Marketing (teachers only, with consent): Sending information about AOLC products, services, and educational resources, only to a teacher who ticked the marketing box and confirmed their email address. You may withdraw consent at any time by using the unsubscribe link in a marketing email, replying STOP to a WhatsApp message, or emailing systems@aolc.co.za.
- Lead management: School registration details, and the details a teacher gives before the demo (section 2a), are used internally by AOLC to follow up with schools about our services.
- Security: Preventing abuse, rate limiting, and protecting user accounts.
4. Third-Party Processing — Our AI and Voice Providers
Chat messages you send, and any files you upload, are transmitted to our AI provider to generate responses. Our AI provider is Anthropic (the Claude models). If Anthropic is unavailable, we may instead use OpenAI as a standby provider. Either provider processes this information as an operator on our behalf, and not for its own purposes.
With each message we also send your role (learner or teacher), your grade and the subject you are working in, and, for a learner, the names of topics not yet finished on your progress checklist, so that the answer suits your level. We do not send your name or your email address.
This means your messages and files are transferred to, and processed outside, South Africa. Each provider's handling of this information is described in its privacy policy: Anthropic and OpenAI.
Voice — speaking to Coal, and Coal speaking back
The Mentor can read replies aloud, and you can ask a question by speaking instead of typing. Both features use providers outside South Africa, and they send different things:
| Feature | Provider | What is sent |
|---|---|---|
| Coal reads a reply aloud | ElevenLabs (United States), or OpenAI as a standby | Only the text of the Mentor's own reply. Your question is not sent, no recording of you is sent, and your name, email and grade are not sent. |
| You speak a question | Groq (United States), or OpenAI as a standby | A recording of your voice, so that it can be turned into text. The recording is sent for transcription only; we do not store it. |
Speaking a question therefore sends a recording of your voice outside South Africa. If you would rather that did not happen, type your question instead — every part of the Mentor works by typing, and reading replies aloud does not send any recording of you. You can switch spoken replies off at any time under Access.
Previously, speaking a question used your web browser's own speech recognition. In Chrome and Edge that also sends the audio out of the country, to the browser's maker, under their terms rather than ours.
Do not include sensitive personal information (ID numbers, financial details, medical information) in chat messages, uploaded files, or spoken questions.
5. Children's Personal Information
Many users of this service are under 18 years of age. In terms of POPIA, the processing of a child's personal information requires the consent of a parent or guardian.
That consent is obtained by the school, not by AOLC. The school holds the relationship with the parent and is the responsible party. When a teacher approves a learner, the teacher confirms on the school's behalf that the necessary consent has been obtained, and we record that confirmation — who made it, when, and against which version of this policy — so that the school can produce it if it is ever asked to.
We collect the minimum from a learner (name, email and grade, and a safeguarding note or a help request only if one is needed), we do not use a learner's information for marketing, and we do not sell or share it.
Safeguarding notes — when a teacher is told
If a learner's messages suggest they may be at risk, or they use abusive language, their teacher may get a short note. This happens when the Mentor hands a learner over to their teacher because of a worry about their safety or wellbeing (for example because they seem upset, or mention bullying or harm), or when a message contains a slur, swearing aimed at someone, or a lot of strong language.
- What the note says: what kind of thing happened and when — for example “abusive language aimed at someone”, or the Mentor's short reason for handing over. It never contains the message itself, and the words the learner used are not kept anywhere. A slur is shown as “offensive language (possibly quoted)”, because a learner telling us what someone called them triggers it too.
- Who sees it: only the learner's own teacher at their school — the teacher who approved them for that subject, or, if there is none, their other approved teachers. The teacher is emailed that there is a new note, but the email does not say who it is about or what it says. Every time a teacher opens or closes a note, we record it.
- What happens next is up to the teacher and the school, under the school's own safeguarding procedure. The note is a prompt for the teacher to check in, not a finding about the learner.
- How long it is kept: the school decides, like the rest of a learner's record (section 6).
Help requests — when a learner would like their teacher
If a learner is stuck, wants to go beyond the day's lesson, or asks for their teacher, the Mentor may let their teacher know that the learner would like help. This is a help request, not a safeguarding note: it says what the learner needs help with (the Mentor's short reason, for example “stuck twice on loops”) and when, never the message itself. Only the same teacher sees it, on their dashboard, and no email is sent about it. Opening and closing it is recorded, and the school decides how long it is kept, as for safeguarding notes.
Lessons and PAT journals
When your teacher runs a lesson in the Mentor, we keep a short record of your session in it: how many questions you used, the one sentence you wrote at the end about what you learned, your exit-ticket answer and whether it was right, and whether you asked for your teacher. Your teacher sees it for their own class. Your chat itself is not kept.
For a PAT your teacher set, we keep your PAT journal: what you write in it (your plan, what you checked and changed, how you used AI), and any question you ask the Mentor in PAT mode, with a shortened copy of its answer. The screen tells you when this is on. The journal is the evidence of how you did the work: your teacher and the school's moderator may read it, and you can print it. It cannot be edited, only added to — a correction is a new entry. The school decides how long it is kept (section 6).
6. Data Retention
For learners, the school's own retention schedule applies. As the school's operator we do not set a lifetime of our own and we do not delete a learner's record on our own initiative. The school instructs us, and we act on that instruction and record who gave it and when. Each school's operator agreement states its schedule; ask your school for it.
On request we will give the school a report of what we hold about its learners and how old each record is, so that it can instruct us accurately.
- Chat messages are held in your browser and in the server session for that visit only. They are not stored in our database — except a question asked in PAT mode, which is kept in your PAT journal with a shortened copy of the answer (section 5).
- Lesson records and PAT journals (section 5) are kept on the school's schedule, and a school's instruction to delete, anonymise or export a learner's record includes them.
- Safeguarding notes and help requests (section 5) are kept on the school's schedule, and a school's instruction to delete, anonymise or export a learner's record includes them.
- Your browser also keeps a copy of some things on the device you are using — see section 6a.
- Teacher and school accounts, where AOLC is the responsible party, are kept while the account is active and removed within 30 days of a deletion request, except where the law requires us to keep something.
- The “Try it now” demonstration keeps its chat for the visit only, like any other chat. The only records it leaves behind are the demo-limit record described below and, for a teacher, the demo details in section 2a.
- Teacher demo details are kept as described in section 2a.
Demo limit: when you try AOLC Mentor without an account, your browser is given a random device cookie (mentor_demo, which expires after 24 hours), and we keep a one-way hash of that cookie, of your IP address together with your browser's identification string, and of your IP address alone. We keep these only to limit a demo per device (normally 15 minutes, counted from the first question, or 10 questions; more at events AOLC exhibits at), with a looser daily limit per network. The record holds no IP address and nothing that names you. If a teacher has filled in the demo form on that device, the same record notes it, so that they are not asked again for 24 hours. A record is no longer used once it is 24 hours old, and is deleted automatically the next time the demo is used, or by a regular clean-up if it is not. AOLC's own presentation devices carry a separate cookie that exempts them from the limit; it holds no information about a person.
6a. What stays on the device you are using
The Mentor keeps some things in the browser itself so that it works offline and remembers where you were: your progress ticks, your accessibility settings, and any chats you chose to save.
On a shared computer — a school lab, a library, a borrowed phone — that information stays in that browser until it is removed. The next person to use the same browser profile could see it. Use Sign out and clear this device in the menu when you finish; it removes everything the Mentor has saved in that browser and signs you out.
A transcript you download of a spoken session is a file on your own device. Once you have saved it, it is outside our control.
7. Your Rights Under POPIA
You have the right to:
- Access the personal information we hold about you.
- Correct inaccurate personal information.
- Request deletion of your personal information.
- Object to the processing of your personal information for marketing.
- Withdraw consent to marketing at any time.
- Lodge a complaint with the Information Regulator of South Africa at justice.gov.za/inforeg.
To exercise any of these rights, contact us at systems@aolc.co.za.
8. Data Security
We implement reasonable technical and organisational measures to protect your personal information, including password hashing (bcrypt), HTTPS encryption, and access controls. No system is completely secure; we cannot guarantee absolute security.
9. Changes to This Policy
We may update this Privacy Policy from time to time. The "Last updated" date above will reflect any changes. Continued use of the Service after changes constitutes acceptance.
10. Contact the Information Officer
For any privacy-related queries or to exercise your POPIA rights:
AOLC (Pty) Ltd
Email: systems@aolc.co.za
Website: aolc.tech