Personal information should support the learning relationship—not become a product in its own right.

Internet Learning Solutions (Pty) Ltd is the responsible party for personal information collected through XVC-controlled websites, forms, learning routes, account systems, reports, subscriptions, support arrangements and Pedagogical Engineer administration.

This policy applies across the Xtreme Virtual Campus environment, including public XVC pages, learning-management and account systems, the Over-the-Shoulder AI Tutor, diagnostic activities, reports, XVC Club, PE Channels, Human Tutor Fallback arrangements, communication routes and related educational resources.

Information entered into an AI-supported service is transmitted to the platform and model providers required to generate a response. The way those providers store, retain or use information depends on the relevant service, account configuration and provider terms.

Internet Learning Solutions and a Pedagogical Engineer cannot view a learner’s private Over-the-Shoulder AI Tutor conversations unless the learner chooses to share them, for example through a screenshot. Conversation storage and deletion available within the learner’s account remain under the learner’s control, subject to the platform’s technical operation.

Internet Learning Solutions does not intentionally use private learner conversations to train AI models. Learners should nevertheless avoid entering unnecessary identifying, private or sensitive information because external processing is required to produce the response.

Some providers may process information outside South Africa. Internet Learning Solutions takes reasonable steps to use providers and arrangements that offer appropriate protection, while recognising that external systems remain subject to their own infrastructure and terms.

Internet Learning Solutions takes reasonable care to send learner reports only to parent-approved recipients using the contact details supplied for that purpose. A parent or legal guardian may add, change or withdraw an authorised report recipient by written email after reasonable verification.

Once a report has been delivered to an authorised recipient, its later storage, forwarding, printing, disclosure and device security fall outside Internet Learning Solutions’ direct control. Recipients are expected to protect the learner’s information and avoid unnecessary sharing.

WhatsApp is the preferred route for onboarding, service-related communication, account support and Human Tutor Fallback arrangements because it enables faster and more personal contact. It is not used for unsolicited promotional messaging.

Formal privacy requests should be made by email so that an appropriate written record is retained.

PE Channels stores operational and transaction information in a restricted SQLite database on the XVC server. Database records may include orders, buyer contact details, payment-verification results, transaction references, access vouchers, fulfilment history, download-use records, privacy actions and legal holds. Access is limited to authorised administrative functions and people whose role requires it.

Retention is managed by configurable rules rather than an indefinite “keep everything” approach. The current operational defaults are 30 days for pending or unpaid checkouts, 90 days for cancelled or abandoned checkouts, 90 days for raw PayFast notification content, 180 days for download-audit information and 365 days for completed-order contact information that is no longer required for ordinary fulfilment or support. A seven-day preview or grace period applies before an eligible automated action is carried out.

Completed financial and accounting records may be retained for at least five years, or longer where a tax, legal, audit, refund, fraud, safeguarding, dispute or enforcement requirement applies. Keeping the financial record does not mean that all buyer details must remain attached to it for the full period.

Where a record must remain but the person’s identity is no longer required, the system may anonymise or de-identify the operational information. This means removing or replacing identifying fields such as the buyer’s name, email address, phone number, learner name, country, time zone, payer email, source address or raw checkout payload while preserving the minimum non-identifying order, amount, product, status, date and accounting trail.

Automated retention processing is designed to run through a protected server-side scheduled task. Each run and each material privacy action is recorded in an administrative audit log. A legal hold prevents the relevant order and linked payment, voucher or download-audit information from being anonymised or deleted while the hold remains justified.

Authorised administrators may also apply lawful manual anonymisation or deletion actions. The system should not delete a record that remains subject to a legal hold or a required financial, legal, safety or dispute-retention obligation.

Backups may contain records that have since been anonymised or removed from the active database. Backups are protected, retained for continuity and disaster recovery, and should expire or be securely replaced according to the applicable backup schedule rather than being used as an ordinary source of restored personal information.

Downloaded XVC Pocket Practice files and other resources stored on a user’s device cannot be remotely deleted by Internet Learning Solutions.

An adult account holder, parent, legal guardian or authorised person may request access to, correction of or deletion of relevant personal information by emailing the Information Officer. Internet Learning Solutions may take reasonable steps to confirm identity, account ownership, guardianship or authority before acting.

Where deletion is appropriate, information will be deleted, de-identified or restricted as reasonably practicable. Some records may remain where continued retention is required or permitted by law, necessary for a lawful purpose, relevant to safeguarding, financial administration, an unresolved dispute or another legitimate obligation.

A person may withdraw optional marketing consent without losing ordinary educational access. XVC does not currently send unsolicited WhatsApp marketing. Service communications and parent-requested educational reports remain separate from optional marketing.

A person may also ask for an explanation of the categories of information held about an order, the purpose for which they are used, and whether a legal hold or statutory retention requirement prevents immediate deletion.

A deletion request does not always require the entire transaction record to disappear. Where a minimum financial, legal, fraud-prevention, safety or dispute record must remain, identifying operational fields may instead be anonymised, access may be restricted, and the reason for continued retention may be recorded.