Privacy Policy

Skulearn

Effective Date: 17 February 2026

Operator: Skulearn Pty Ltd | Reg. No. 2025/920955/07 | Skulearn.com Registered Address: 417 Pretorius Street, Arcadia, Pretoria, South Africa General Enquiries : hello@skulearn.com

Legal Notices: admin@skulearn.com

Governing Law: Republic of South Africa (see Clause 14 for cross-border users)

Applies To: All Users of Skulearn.com worldwide

Language: English. Translations are for convenience only; this English version prevails.

THIS PRIVACY POLICY FORMS PART OF SKULEARN'S GLOBAL TERMS OF SERVICE. BY USING THE PLATFORM YOU AGREE TO BE BOUND BY IT IN FULL.

1. INTRODUCTION

1.1 Skulearn Pty Ltd ("Skulearn", "we", "us", "our") is committed to protecting your personal information and respecting your privacy rights.

1.2 This Privacy Policy explains how we collect, use, store, share, and protect personal information when you access or use skulearn.com and the Skulearn Platform ("Platform"). It applies to all users of the Platform worldwide.

1.3 This Policy must be read alongside the Terms of Service, the Cookies Policy, and the Community Safety & Child Protection Policy.

1.4 By using the Platform, you acknowledge that you have read and understood this Policy. Where applicable law requires your consent, we will obtain it before processing your personal information.

2. WHO WE ARE - RESPONSIBLE PARTY / DATA CONTROLLER

Skulearn Pty Ltd

Registration No. 2025/920955/07 | skulearn.com

Registered Address: 417 Pretorius Street, Arcadia, Pretoria, South Africa

General Enquiries : hello@skulearn.com

Legal Notices: admin@skulearn.com

2.1 For users in the European Union or United Kingdom, Skulearn Pty Ltd acts as the Data Controller in respect of personal data processed through the Platform.

2.2 For users in South Africa, Skulearn Pty Ltd is the Responsible Party under the Protection of Personal Information Act 4 of 2013 (POPIA).

2.3 For users in other jurisdictions, Skulearn Pty Ltd is the equivalent data controller or responsible entity under applicable local law.

3. INFORMATION WE COLLECT

3.1 Information You Provide Directly

When you register for or use the Platform, we may collect:

Full name and display name
Date of birth
Email address
Phone number (where provided)
Country of residence
Parent or guardian details (for users under 18)
Account login credentials
Course progress, quiz responses, and assessment results
Community posts, comments, and uploaded content
Payment transaction confirmations (we do not store full card details - card data is handled by Paystack)
Coaching and counselling session booking details
Professional details provided by Coaches and Instructors during onboarding

3.2 Information Collected Automatically

When you use the Platform, we may automatically collect:

IP address
Device type, model, and operating system
Browser type and version
Country-level location data
Platform usage activity and navigation patterns
Game interaction and simulation data
Session duration and frequency
Cookie and tracking data (see Cookies Policy)

3.3 Information Relating to Minor Users

3.3.1 For users under 18, we apply enhanced data minimisation principles. We collect only data reasonably necessary for the Minor User to access and use the Platform.

3.3.2 We require verifiable parental or guardian consent before a Minor User may register.

3.3.3 We do not use Minor User data for commercial profiling, advertising, or any purpose beyond Platform delivery and safety.

3.3.4 Parents and guardians may request access to, correction of, or deletion of their child's personal data by contacting privacy@skulearn.com.

4. HOW WE USE YOUR INFORMATION

We process personal information for the following purposes:

To create and manage your Platform account
To provide access to courses, gamified features, and digital content
To issue certificates of completion
To process payments through Paystack
To facilitate coaching and counselling session bookings
To moderate community spaces and enforce the Terms of Service and Community Safety Policy
To send transactional communications (booking confirmations, payment receipts, account notices)
To send Platform updates and educational communications, where you have opted in
To improve Platform functionality, content, and user experience
To detect and prevent fraud, abuse, and security threats
To comply with our legal obligations in all jurisdictions in which we operate

5. LEGAL BASIS FOR PROCESSING

We rely on the following legal bases to process personal information:

5.1 Contractual necessity. Processing required to provide the Platform services you have requested, including account management, payment processing, and content delivery.

5.2 Consent. Where we rely on your consent (e.g. for non-essential cookies or marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing based on consent before withdrawal.

5.3 Legal obligation. Processing required to comply with applicable laws, including tax, financial reporting, and data protection obligations.

5.4 Legitimate interests. Processing for the purposes of fraud prevention, platform security, product improvement, and business administration, where those interests are not overridden by your rights.

5.5 Parental consent. For Minor Users, processing is based on verifiable parental or guardian consent in accordance with applicable child data protection law.

6. SHARING OF INFORMATION

We do not sell your personal information. We may share information with:

6.1 Payment processors. Paystack (Paystack Inc.) processes payment transactions. Paystack receives transaction data necessary to complete and verify payments. Paystack is subject to its own privacy policy and PCI-DSS obligations.

6.2 Cloud hosting and infrastructure providers. Platform data is hosted on third-party cloud infrastructure. These providers process data on our behalf and are bound by appropriate data processing agreements.

6.3 Coaches and Instructors. Limited booking and session information is shared with the relevant Coach or Instructor to enable service delivery. Coaches and Instructors are bound by confidentiality and data protection obligations under their agreements with Skulearn.

6.4 Analytics and performance providers. Anonymised and aggregated usage data may be shared with analytics providers to improve Platform performance.

6.5 Legal and regulatory authorities. We may disclose personal information to law enforcement, regulatory authorities, or courts where required to do so by applicable law, a binding court order, or a safeguarding obligation.

6.6 All third parties with whom we share personal information are required to implement appropriate technical and organisational safeguards.

7. CROSS-BORDER TRANSFERS

7.1 Skulearn operates as a global platform. Your personal information may be stored or processed in countries other than your country of residence, including South Africa, and countries in which our cloud infrastructure providers operate.

7.2 Where personal information is transferred across borders, we implement appropriate safeguards in accordance with applicable law, including:

Standard contractual clauses (for transfers from the EU/UK)
Adequacy assessments or equivalent mechanisms required under applicable data protection law
Contractual data processing obligations imposed on third-party recipients

7.3 Enhanced safeguards apply to cross-border transfers of Minor User personal information.

8. DATA RETENTION

8.1 We retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, including:

For the duration of your account and active use of the Platform
For such additional period as required to comply with applicable legal, tax, or regulatory obligations
For such period as required to resolve disputes or enforce our agreements

8.2 Inactive accounts may be anonymised or deleted after a reasonable period of inactivity, subject to any legal retention obligations.

8.3 Minor User data is subject to the same retention principles with enhanced review.

9. SECURITY

9.1 We implement appropriate technical and organisational security measures to protect personal information against unauthorised access, loss, misuse, disclosure, or alteration. These measures include encrypted connections (TLS/HTTPS), access control and rolebased permissions, secure server infrastructure, and regular security assessments.

9.2 No digital system is completely secure. While we take all reasonable precautions, we cannot guarantee the absolute security of information transmitted over the internet.

9.3 In the event of a personal data breach that poses a risk to users' rights, we will notify affected users and relevant regulatory authorities in accordance with applicable law and within legally required timeframes.

10. YOUR RIGHTS

Depending on your jurisdiction, you may have the following rights in relation to your personal information:

10.1 Access. The right to request a copy of the personal information we hold about you.

10.2 Correction. The right to request correction of inaccurate or incomplete personal information.

10.3 Deletion. The right to request deletion of your personal information, subject to legal retention obligations.

10.4 Restriction. The right to request restriction of processing in certain circumstances.

10.5 Portability. The right to receive your personal information in a structured, commonly used, and machine-readable format (where applicable under GDPR).

10.6 Objection. The right to object to processing based on legitimate interests or for direct marketing purposes.

10.7 Withdrawal of consent. The right to withdraw consent at any time where processing is based on consent, without affecting the lawfulness of prior processing.

10.8 Complaint. The right to lodge a complaint with the relevant supervisory authority in your jurisdiction - including the South African Information Regulator, the UK Information Commissioner's Office (ICO), or the relevant EU Data Protection Authority.

To exercise any of these rights, contact us at admin@skulearn.com. We will respond within the timeframe required by applicable law (generally 30 days).

11. AUTOMATED DECISION-MAKING

11.1 Skulearn's gamified life-path simulation generates automated scenario outcomes based on user inputs. These outcomes are fictional and educational in nature. They do not constitute decisions that produce legal, professional, or materially significant real-world effects on users.

11.2 Skulearn does not use automated decision-making that produces legally binding decisions about users without human oversight.

12. THIRD-PARTY LINKS

12.1 The Platform may contain links to third-party websites or services. Skulearn is not responsible for the privacy practices of third-party sites. Users should review the privacy policies of any third-party service they access.

13. GLOBAL LEGAL FRAMEWORK

Skulearn's privacy practices are designed to comply with applicable data protection law across all jurisdictions in which the Platform operates, including:

Protection of Personal Information Act 4 of 2013 - POPIA (South Africa)
General Data Protection Regulation 2016/679 - GDPR (European Union)
UK General Data Protection Regulation and Data Protection Act 2018 (United Kingdom)
Privacy Act 1988 and Australian Privacy Principles (Australia)
Personal Information Protection and Electronic Documents Act - PIPEDA (Canada)
Children's Online Privacy Protection Act - COPPA (United States, for Minor Users)
Equivalent applicable legislation in other operating jurisdictions

13.2 Where applicable law in a user's jurisdiction provides rights or protections beyond those described in this Policy, Skulearn will respect those rights and protections.

14. UPDATES TO THIS POLICY

14.1 We may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or Platform operations. Material updates will be communicated by email and/or via a notice on the Platform. The current version is always available at skulearn.com.

14.2 Continued use of the Platform following the publication of an updated Policy constitutes acceptance of the updated terms, to the extent permitted by applicable law.