iRainbow Privacy Policy

Last updated: 11 March 2026

This Privacy Policy explains how Ecigus Proprietary Limited (registration number 2012/149413/07), trading as iRainbow Education (“iRainbow”, “we”, “us”, “our”) collects, uses, stores, shares, and protects personal information when you use our website, web platform, offline software, learner profiles, AI features, teacher features, support channels, and related services.

This Privacy Policy should be read together with our Terms and Conditions and any additional product-specific terms, promotional terms, or written package terms that apply to your use of iRainbow.

1. Who we are

Entity: Ecigus Proprietary Limited
Trading name: iRainbow Education
Address: H. Santos Building, 30 Arena Cl, Bruma, Johannesburg, 2026, South Africa
Email: admin@irainbow.co.za
Website: irainbow.co.za
Platform: app.irainbow.co.za and any related iRainbow digital service, including offline versions, downloadable software, support channels, and web-based services

2. Scope of this Privacy Policy

This Privacy Policy applies to personal information processed by iRainbow in connection with:

• our website and landing pages

• our web app and browser-based platform

• our offline or downloadable versions

• learner, parent, and teacher accounts

• SAS Teachers sign-up and educator memberships

• AI features, including iRainbow Buddy and similar tools

• customer support via email, WhatsApp, telephone, forms, or in-app communication

• billing, payment, onboarding, promotions, and guarantee claims

• reporting, diagnostics, analytics, and account management

By using iRainbow, creating an account, purchasing a package, or submitting personal information to us, you acknowledge this Privacy Policy.

3. Important note about children

Because iRainbow is used by learners, including minors, we take children’s personal information seriously.

Where required by law, a parent, guardian, school, or authorised educator must provide the necessary consent or authority before a child’s personal information is submitted to or processed through iRainbow.

If you create a learner profile, upload a report, submit a child’s name or grade details, or otherwise provide information about a child, you confirm that you are legally authorised to do so.

4. What personal information we collect

Depending on how you interact with iRainbow, we may collect the following categories of personal information:

4.1 Parent, guardian, customer, and account holder information

• full name

• surname

• email address

• mobile number

• billing address

• login credentials

• account ID or customer reference

• communication preferences

• records of your consents, requests, complaints, or support interactions

4.2 Learner information

• learner name or nickname

• grade

• subject selections

• language preferences

• age or date of birth where needed

• school name where provided

• learner profile data

• activity history

• progress, performance, diagnostic, and report data

• worksheet completion, assessment results, and usage patterns

4.3 Teacher and educator information

• teacher or educator name

• email address

• phone number

• SAS Teachers membership details

• profile allocation details

• support requests

• information submitted to create or manage learner profiles

4.4 Payment and transaction information

• package purchased

• subscription type

• amount paid

• currency

• payment date

• transaction reference

• recurring billing information

• promotions, discounts, or vouchers applied

• payment status

• limited payment details received from payment processors

We do not necessarily store full bank card details ourselves where payments are processed by third-party payment providers.

4.5 Device, technical, and usage information

• IP address

• browser type

• operating system

• device type

• device identifiers where applicable

• app or platform version

• login times

• crash logs

• connection information

• referral URLs

• cookies and similar technologies

• general usage analytics and engagement patterns

4.6 AI interaction data

If you use AI features, we may collect:

• prompts or questions submitted

• responses generated

• related learner or subject context

• screen context or assignment context where available

• safety and moderation signals

• feedback about AI responses

4.7 Support and communication records

• emails

• WhatsApp messages

• call notes

• chatbot messages

• complaint records

• onboarding replies

• guarantee claim submissions

• screenshots, attachments, and supporting documents sent to us

4.8 School and academic documents

Where you submit them, we may collect:

• school reports

• before-and-after reports for guarantee claims

• proof of grade or school

• evidence of usage or academic performance

• proof of household size or number of children where needed for extra profiles

4.9 Marketing and lead information

• enquiry forms

• landing page submissions

• campaign source

• affiliate or referral source

• ad engagement

• webinar or event registration data

• mall sign-up details

• free trial or demo application details

5. How we collect personal information

We collect personal information in the following ways:

• directly from you when you sign up, purchase, contact us, or create profiles

• when you use our website, platform, offline version, or support channels

• when a parent, guardian, school, educator, or authorised third party submits information to us

• from payment processors and service providers involved in billing or onboarding

• from cookies, analytics, and similar technologies

• from public sources where you have made information public

• from partners, affiliates, schools, or teacher programmes where permitted by law and relevant to service delivery

6. Why we process personal information

We process personal information for one or more of the following purposes:

• to create and manage accounts

• to activate subscriptions, memberships, lifetime packages, and educator plans

• to create and manage learner profiles

• to deliver educational content and platform functionality

• to provide offline and web-based access

• to personalise content by grade, subject, or learner needs

• to generate learner, parent, and teacher reports

• to enable AI features and respond to learner questions

• to provide customer support and troubleshooting

• to process payments, renewals, upgrades, and billing

• to verify eligibility for promotions, profile increases, or guarantee claims

• to improve the platform, content, user experience, and AI performance

• to monitor abuse, fraud, profile misuse, payment risk, or security concerns

• to communicate with users about onboarding, updates, payments, support, or service notices

• to send direct marketing where permitted by law or where consent has been given

• to comply with legal, regulatory, tax, accounting, and record-keeping obligations

• to establish, exercise, or defend legal rights

7. Legal basis for processing

Where required by applicable law, we process personal information on one or more of the following legal bases:

• your consent

• the performance of a contract or steps taken before entering into a contract

• compliance with legal obligations

• our legitimate business interests, including service improvement, fraud prevention, security, customer support, and internal analytics

• a child’s parent, guardian, school, or authorised educator providing the required authority or consent

• any other lawful basis permitted under applicable law, including POPIA

8. Children’s personal information

8.1 We may process children’s personal information to provide iRainbow services to learners.

8.2 We only do so where we believe there is lawful authority or consent to do so, including from a parent, legal guardian, school, or authorised educator where required.

8.3 Parents and guardians are responsible for ensuring that the information they provide about a child is accurate and that they are authorised to provide it.

8.4 If a teacher, school, tutor, or educator provides learner data, they confirm that they have the necessary authority and that their use of iRainbow complies with applicable law and any school policies.

8.5 If you believe a child’s information has been submitted without proper authority, contact us immediately at admin@irainbow.co.za.

9. AI features and automated processing

9.1 iRainbow may use AI features to support learning, generate explanations, provide assistance, personalise recommendations, or improve platform functionality.

9.2 When you use AI features, prompts, context, usage data, and outputs may be processed by iRainbow and by approved service providers acting on our behalf.

9.3 We may review AI interactions for:

• service delivery

• safety

• abuse prevention

• debugging

• product improvement

• quality assurance

• training internal support processes

9.4 AI features are designed to support learning, not replace parental supervision, teacher judgment, or professional advice.

9.5 iRainbow does not use solely automated decision-making to make legal or similarly significant decisions about users in the ordinary course of providing the platform. However, automated systems may be used to generate recommendations, flag risk, personalise content, detect misuse, or support internal decision-making.

10. Who we share personal information with

We may share personal information only where reasonably necessary, lawful, and proportionate, including with:

• payment processors

• cloud hosting and storage providers

• analytics providers

• communication service providers such as email, messaging, SMS, or WhatsApp tools

• AI and automation service providers

• software vendors and integration partners

• customer support providers

• accountants, auditors, insurers, lawyers, and other professional advisers

• regulators, courts, law enforcement, or public authorities where required by law

• buyers, investors, or transaction counterparties in connection with a sale, restructure, merger, or transfer of the business, subject to confidentiality and legal safeguards

• schools, parents, guardians, or educators where this is part of the service relationship and lawful to do so

We do not sell personal information as a standalone data product.

11. International and cross-border transfers

Because digital services often rely on global providers, some personal information may be stored in or accessed from countries outside South Africa.

Where we transfer personal information across borders, we take reasonable steps to ensure that appropriate safeguards are in place, including contractual protections and lawful transfer mechanisms where required.

By using iRainbow, you acknowledge that cross-border processing may occur in connection with cloud hosting, analytics, AI features, support systems, communications, and payment infrastructure.

12. Cookies and similar technologies

We use cookies, pixels, tags, local storage, analytics tools, and similar technologies to:

• keep users logged in

• remember preferences

• understand traffic and usage

• measure campaign performance

• improve functionality

• personalise content and marketing

• maintain security and system performance

These technologies may include:

• necessary cookies

• functionality cookies

• analytics cookies

• performance cookies

• advertising or retargeting technologies where applicable

You can usually manage cookie preferences through your browser settings. If you block cookies, some platform functions may not work correctly.

13. Direct marketing

We may send you marketing communications about iRainbow products, offers, services, events, or updates where:

• you have consented,

• you are an existing customer and the communication is permitted by law, or

• we otherwise have a lawful basis to do so.

You can opt out of direct marketing at any time by using the unsubscribe option where available or by contacting us at admin@irainbow.co.za.

Even if you opt out of marketing, we may still send you service-related communications such as billing notices, support messages, account alerts, or important legal or operational notices.

14. Data retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including:

• maintaining active accounts and learner profiles

• delivering services and support

• handling billing, disputes, and refunds

• complying with tax, accounting, and legal obligations

• resolving complaints or claims

• preventing fraud and abuse

• maintaining internal business records

• preserving de-identified or aggregated analytics

Where lawful and appropriate, we may delete, anonymise, or de-identify personal information when it is no longer needed.

15. Security

We take reasonable technical, administrative, and organisational measures to protect personal information against loss, misuse, unauthorised access, disclosure, alteration, or destruction.

These measures may include:

• access controls

• password protections

• role-based permissions

• encryption or secure transmission tools where appropriate

• provider due diligence

• audit and monitoring processes

• internal process controls

However, no online system is completely secure. You are responsible for protecting your own login credentials and for using secure communication methods when sharing sensitive information with us.

16. Your rights

Subject to applicable law, you may have the right to:

• access personal information we hold about you

• request correction of inaccurate or incomplete personal information

• request deletion of personal information in certain circumstances

• object to certain processing

• request restriction of processing in certain circumstances

• withdraw consent where processing is based on consent

• opt out of direct marketing

• request a copy of certain personal information

• complain to the relevant regulator

If you want to exercise any of these rights, contact us at admin@irainbow.co.za.

We may ask you to verify your identity before acting on a request, and we may refuse or limit a request where the law allows us to do so.

17. Complaints and regulator

If you have a privacy complaint or concern, please contact us first at:

admin@irainbow.co.za

If you are not satisfied, you may lodge a complaint with the South African Information Regulator. Your current privacy policy already lists the Information Regulator and its Pretoria contact details.

18. Third-party websites and services

Our website, platform, or communications may contain links to third-party websites, plugins, services, payment pages, app tools, or social media platforms.

We do not control all third-party privacy practices and are not responsible for how third parties collect or use personal information once you leave our controlled environment.

You should review the privacy policies of third-party services you use.

19. Account, household, and teacher-specific privacy points

19.1 Household memberships

Where a household membership covers multiple children, we may process learner profile data for each child linked to that household account.

If a parent asks for more than 5 profiles, we may request proof reasonably necessary to verify entitlement.

19.2 SAS Teachers and educator memberships

Where a teacher or educator signs up through SAS Teachers or a similar programme, we may process teacher account information and learner profile information linked to that membership.

Teachers may only submit learner data they are authorised to submit.

If a teacher requests more than the included profile allocation, we may process supporting details needed to assess and administer that request.

20. Guarantee claims and supporting documents

If you submit a money-back guarantee or success guarantee claim, we may process:

• usage records

• learner reports

• before-and-after academic evidence

• subject and grade information

• correspondence and claim notes

• payment information necessary to process an approved refund

We use this information to assess claim eligibility, prevent abuse, and keep proper business and legal records.

21. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in:

• law or regulation

• product features

• AI functionality

• support channels

• subscriptions or business operations

• security and processing practices

If we make a material change, we may notify users through the website, platform, email, or another appropriate channel.

The updated version becomes effective on the date stated at the top of the Privacy Policy.

22. Contact us

For privacy questions, requests, corrections, complaints, or objections, contact:

iRainbow Education
Ecigus Proprietary Limited
H. Santos Building, 30 Arena Cl, Bruma, Johannesburg, 2026, South Africa
Email: admin@irainbow.co.za