Important: ChilledTutor LMS provides privacy-conscious technical controls, but each customer organisation remains responsible for its own lawful processing, policies, retention rules, user access and regulatory obligations.
Introduction
ChilledTutor LMS respects privacy and is committed to protecting personal information in accordance with the Protection of Personal Information Act 4 of 2013 (POPIA) and other applicable South African laws.
This policy explains how personal information may be collected, used, stored, shared and protected when you use the ChilledTutor LMS website, platform and related services.
Who this policy applies to
This policy applies to people who interact with ChilledTutor LMS, including learners, students, facilitators, lecturers, assessors, moderators, administrators, training-provider staff, corporate users, prospective customers and website visitors.
Our role under POPIA
When Zenotha IT Solutions is the Responsible Party
Zenotha IT Solutions may determine the purpose and means of processing personal information for activities such as customer enquiries, demonstrations, subscriptions, billing, account administration, technical support, platform security and our own legal obligations.
When Zenotha IT Solutions acts as an Operator
Where a training provider, college, employer or other organisation uses ChilledTutor LMS to manage its own learners, staff and training records, that organisation generally determines why the information is processed. In those circumstances the organisation is generally the Responsible Party and Zenotha IT Solutions processes information on its authorised instructions as an Operator.
If you use ChilledTutor through your employer, college or training provider, some privacy requests may need to be submitted to that organisation first.
Personal information we may process
Identity & contact
Names, ID or passport details, learner numbers, email addresses, telephone numbers, addresses and profile information.
Learning records
Qualifications, courses, Unit Standards, enrolments, attendance, results, competency outcomes, progress and certificates.
Documents & evidence
CVs, qualifications, proof of address, IDs, PoE files, assignments, practical evidence and supporting training records.
Staff information
Professional qualifications, accreditation details, roles, programme assignments, assessment and moderation activities.
Account & security
User roles, account status, authentication records, login history, permissions, sessions, security events and audit logs.
Communications
Support requests, emails, contact forms, WhatsApp communications, service enquiries and system notifications.
Special personal information and children
Customer organisations may, where legally authorised and necessary for their programmes, process special personal information or information relating to children. The customer organisation is responsible for establishing the required lawful authority, consent or competent-person authorisation where applicable.
How we collect personal information
Information may be collected directly from you, from an authorised organisation, during account registration or enrolment, through assessment and attendance workflows, when documents are uploaded, when virtual sessions are attended, when support is requested, or through legitimate security and system logs.
Why we process personal information
- Creating and maintaining accounts, workspaces and learner profiles.
- Managing enrolments, qualifications, courses, Unit Standards and learning content.
- Delivering assessments, attendance, PoE, moderation, certificates and training records.
- Providing virtual learning, document management, reports, analytics and audit records.
- Managing customer subscriptions, billing, enquiries and technical support.
- Protecting the platform, investigating misuse and meeting contractual or legal obligations.
Depending on the circumstances, processing may be based on consent, a contract, a legal obligation, a legitimate interest, an authorised public-law function or another basis permitted by law. Where consent is the basis, it may be withdrawn subject to legal and contractual limitations.
Security, incidents and retention
ChilledTutor LMS uses reasonable technical and organisational safeguards designed to protect personal information against loss, unlawful access, unauthorised alteration or disclosure. Controls may include authentication, password hashing, role-based permissions, tenant separation, access-controlled private files, logging, audit trails, backups and security maintenance.
No internet-connected system can guarantee absolute security. Where a suspected compromise occurs, the incident will be handled in accordance with applicable law and the relevant roles of the Responsible Party and Operator.
Information is retained only for as long as reasonably necessary for service delivery, training and academic records, contractual requirements, legal obligations, dispute resolution, audit trails or legitimate business requirements. Customer organisations may apply their own lawful retention schedules to the records they control.
Your privacy rights
Subject to applicable law, you may request confirmation of whether personal information is held about you, request access, ask for inaccurate information to be corrected, request deletion or destruction where permitted, object to certain processing, withdraw consent where applicable, and object to direct marketing.
We may need to verify your identity before completing a privacy request. If your information is controlled by your employer, training provider or college, the request may need to be directed to that organisation.
Contact, privacy requests and complaints
ChilledTutor privacy enquiries
Contact the Zenotha IT Solutions privacy team / Information Officer function for questions or privacy requests.
info@zenotha.co.za 067 205 8371Information Regulator (South Africa)
Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191.
POPIAComplaints@inforegulator.org.za 010 023 5200 ยท Toll Free 0800 017 160Changes to this policy
This policy may be updated to reflect changes to the platform, business operations, legal requirements, integrations or security practices. The latest version will be published on this page with its effective date.
