1. Introduction
After Matric (“the App”) is operated by Private Club App (Pty) Ltd (“we”, “us”, “our”), a company registered in the Republic of South Africa.
We are committed to protecting your personal information in compliance with the Protection of Personal Information Act, 2013 (POPIA) and other applicable South African legislation.
This Privacy Policy explains what personal information we collect, why we collect it, how we use and protect it, and what rights you have regarding your data.
2. Responsible Party
For the purposes of POPIA, the responsible party for your personal information is:
3. Personal Information We Collect
We collect the following categories of personal information:
| Category | Data | Purpose |
|---|
| Identity | Name (display name) | Personalise your experience |
| Contact | Email address | Account authentication, notifications |
| Location | Province of residence | Region-relevant recommendations |
| Academic | Matric year, matric status, subjects, marks | Career guidance, APS calculation |
| Preferences | Interests, life situation | AI-personalised plans |
| Usage | Study session data (duration, subjects) | Progress tracking, insights |
| Profile | Profile image (optional) | Account personalisation |
| Device | Study preferences via iCloud key-value store | Sync settings across your devices |
| Subscription | Subscription status, expiry date | Feature access management |
| Financial Goals | Savings goals, target amounts, income entries | Personal savings tracking |
| Deadlines | Personal deadlines (title, date, category, notes) | Deadline tracking and reminders |
| AI Content | Career summary, personalised action plan | Display your generated career guidance |
3.1 Information We Do Not Collect
- We do not collect phone numbers.
- We do not collect precise geolocation or GPS data.
- We do not collect financial or payment information — all payments are processed by Apple.
- We do not use cookies or web-based tracking technologies within the App.
4. How We Use Your Information
We process your personal information for the following purposes:
- Account creation and authentication — to create your account and verify your identity via Sign in with Apple or Sign in with Google.
- Personalised career recommendations — to generate AI-powered study plans and career guidance tailored to your profile. This involves sending your academic profile and interests to a third-party AI service (Google Gemini) — see Section 6.1 for full details.
- Study progress tracking — to record study sessions, streaks, and provide insights on your study habits.
- Deadline management — to help you track university, bursary, and personal deadlines.
- Device sync — to sync your study preferences (timer settings, goals) across your Apple devices via iCloud.
- App improvement — to understand usage patterns and improve functionality and user experience.
- Notifications — to send study reminders and deadline alerts (with your consent).
5. Legal Basis for Processing (POPIA)
We process your personal information based on the following lawful grounds under POPIA:
- Consent (Section 11(1)(a)) — You provide consent when you create an account and accept these terms. You may withdraw consent at any time by deleting your account.
- Contract (Section 11(1)(b)) — Processing is necessary to provide the services you have signed up for (e.g., generating your personalised plan).
- Legitimate interest (Section 11(1)(f)) — We have a legitimate interest in improving the App and understanding usage patterns, provided this does not override your rights.
6. Data Sharing & Third Parties
We do not sell your personal data to any third party.
We share limited data with the following service providers, solely to operate the App:
| Provider | Purpose | Data Shared |
|---|
| Supabase (cloud infrastructure) | Authentication, database storage | Account data, academic data, study data |
| Google Gemini AI | Career plan and study plan generation | Province, matric year, matric status, subjects, marks, interests, life situation |
| Apple | Authentication, payments, push notifications | Email (via Sign in with Apple), subscription status |
| Google | Authentication | Email (via Sign in with Google) |
| Apple iCloud | Settings sync | Study preferences only (stored on your own iCloud) |
All service providers are contractually required to protect your data and may only use it for the purposes described above.
6.1 AI Data Processing
To generate your personalised career plan, the App sends the following personal information to Google Gemini AI (operated by Google LLC):
- Your province of residence
- Matric year and matric status (e.g., current Grade 12 or post-matric)
- Your school subjects and marks
- Your selected interests
- Your life situation responses (e.g., financial situation, study preferences, goals)
This data is sent solely to generate your personalised plan and is not used by Google to train AI models. Your name and email address are not sent to the AI service. The AI processes your academic profile to produce career recommendations and a 12-month action plan, which is then stored in your account.
By using the plan generation feature, you consent to this data being processed by Google Gemini AI. If you do not wish for your data to be processed by a third-party AI service, you may choose not to generate a plan.
6.2 Cross-Border Data Transfers
Some of our service providers, including Google, operate outside of South Africa. Where your data is transferred internationally, we ensure that adequate safeguards are in place as required by POPIA Section 72, including contractual obligations to protect your data to a standard equivalent to South African law.
7. Data Storage & Security
- Your data is stored using industry-standard cloud infrastructure with encryption in transit (TLS/HTTPS) and encryption at rest.
- Authentication uses secure protocols including PKCE (Proof Key for Code Exchange) and SHA-256 cryptographic nonces.
- Access to your data is restricted to authorised systems and personnel only.
- We conduct regular security reviews to identify and address potential vulnerabilities.
8. Data Retention
- We retain your personal information for as long as your account is active.
- Upon account deletion, all personal data is permanently and irreversibly deleted from our systems. This includes your profile, academic records, study data, plans, interests, and any associated content.
- Cached data on your device (such as study preferences) is also cleared during account deletion.
- We do not retain anonymised or aggregated data after account deletion.
9. Your Rights Under POPIA
As a data subject under POPIA, you have the following rights:
- Right of access — You may request confirmation of whether we hold your personal information and request a copy of it.
- Right to correction — You may request that we correct or update inaccurate personal information. You can also update most information directly in the App's profile settings.
- Right to deletion — You may request the deletion of your personal information. You can delete your account directly in the App's Settings, which permanently removes all your data.
- Right to object — You may object to the processing of your personal information on reasonable grounds.
- Right to withdraw consent — You may withdraw your consent to data processing at any time by deleting your account.
- Right to lodge a complaint — You have the right to lodge a complaint with the Information Regulator (South Africa) if you believe your personal information has been mishandled.
To exercise any of these rights, contact us at aftermatric@privateclubsa.co.za. We will respond to your request within 30 days.
9.1 Information Regulator
If you are not satisfied with our response, you may contact the Information Regulator:
10. Children's Privacy
- The App is designed for users aged 16 years and older.
- Users under 18 must have parental or legal guardian consent to use the App. We request age confirmation during the account setup process.
- We do not knowingly collect personal information from children under 16. If we become aware that we have collected data from a child under 16 without appropriate consent, we will delete that information promptly.
11. Push Notifications
- The App may send push notifications for study reminders and deadline alerts.
- You will be asked for permission before any notifications are sent.
- You can enable or disable study reminders at any time in the App's Settings, or manage notification permissions in your device's Settings.
12. Changes to This Policy
- We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law.
- Users will be notified of material changes via the App or by email.
- The “Effective Date” at the top of this page indicates when the policy was last updated.
- Continued use of the App after changes are posted constitutes acceptance of the revised Privacy Policy.
13. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us at:
Email: aftermatric@privateclubsa.co.za
Entity: Private Club App (Pty) Ltd