Privacy Policy

Reflective Learning Privacy Policy
Posted: 12 April 2019
Effective: 12 April 2019

Thanks for using Reflective Learning! Our mission is to help learners excel in their education so that they fulfil their full potential in life. As part of our work, we need to collect, use, and handle the personal information of learners using our websites, software, and services (“Services”).

What & Why

We collect and use the following information to provide, improve, and protect our Services:

  • Account information.
    We collect, and associate with your account, the information you provide to us when you do things such as sign up for your account, purchase products and services, and set up two-factor authentication (like your name, email address, phone number, payment info, and physical address).
  • Contacts.
    You may choose to give us access to your contacts to make it easy for you to do things like sharing learner reports and inviting others to use the Services. If you do, we’ll store those contacts on our servers.
  • Usage information.
    We collect information related to how you use the Services, including actions you take in your account. We use this information to improve our Services, develop new services and features, provide industry insights, and protect Reflective Learning users.
  • Device information.
    We also collect information from and about the devices you use to access the Services. This includes things like IP addresses, the type of browser and device you use, the web page you visited before coming to our sites, and identifiers associated with your devices. Your devices (depending on their settings) may also transmit location information to the Services.
  • Cookies and other technologies.
    We may use technologies like cookies to provide, improve, protect, and promote our Services. For example, cookies help us with things like remembering your username for your next visit, understanding how you are interacting with our Services, and improving them based on that information.
  • Marketing.
    In order to serve you best, we will, from time to time, send you messages about services that may assist you and your learner(s) further. Users who receive these marketing materials can opt out at any time. If you do not want to receive marketing materials from us, simply click the ‘unsubscribe’ link in any email or change the relevant setting in your profile. We sometimes contact people who do not already have a Reflective Learning account. If you receive an email and no longer wish to be contacted by Reflective Learning, you can unsubscribe and remove yourself from our contact list via the message itself.
  • Bases for processing your data.
    We collect and use the personal data described above in order to provide you with the Services in a reliable and secure manner. We also collect and use personal data for our legitimate business needs and to provide insights to the education industry. By releasing aggregated educational research findings, we help to build a stronger education system which benefits us all. We will only do this in a way that protects the identities of the individual learners and institutions. To the extent we process your personal data for other purposes, we ask for your consent in advance or require that our partners obtain such consent.

With Whom

We may share information as discussed below, but we won’t sell it to advertisers or other third parties.

  • Others working for and with Reflective Learning.
    Reflective Learning uses certain trusted third parties (for example, providers of customer support and IT services) to help us provide, improve, protect, and promote our Services. These third parties will access your information only to perform tasks on our behalf in compliance with this Privacy Policy, and we’ll remain responsible for their handling of your information as per our instructions.
  • Other users.
    Our Services may display information like your name, profile picture, device, and email address to other users in places like your user profile. When you register your Reflective Learning account with an email address on a domain owned by your employer or organisation, we may help educational institutions and administrators find you and your team by making some of your basic information visible to other users on the same domain. Certain features let you make information available to others.
  • Other applications.
    You can also give third-party providers access to your information and account, for example, via Reflective Learning APIs. Just remember that their use of your information will be governed by their privacy policies and terms.
  • Reflective Learning affiliates.
    If you are an educational institution or any other organisation creating, or requesting the creation of, accounts on behalf of others, it is assumed that you have sought the relevant permissions required to do so including those of parents or guardians. If you are a user through an affiliate of Reflective Learning, your information may be accessible to their administrators and other team members. While we try by all means to ensure that our affiliates adhere to similar standards of privacy regarding your data, we cannot guarantee this. Please refer to their privacy policies.
  • Government educational entities and the general public.
    We believe in providing industry insights to government decision-makers and the general public so that they may be empowered to improve the system as a whole to the benefit of all. However, we will not compromise by infringing on the privacy of individuals or specific institutions in order to do so. As such, these views will only be of aggregated data with specific use to that governmental role such as school quintile, grades levels, public/independent schools, associated choice of intervention, and location as classified by the relevant educational departments.
  • Law & Order and the Public Interest.
    We may disclose your information to third parties if we determine that such disclosure is reasonably necessary to: (a) comply with any applicable law, regulation, legal process, or appropriate government request; (b) protect any person from death or serious bodily injury; (c) prevent fraud or abuse of Reflective Learning or our users; (d) protect Reflective Learning’s rights, property, safety, or interest; or (e) perform a task carried out in the public interest.
  • Stewardship of your data is critical to us and a responsibility that we embrace.
    We believe that your data should receive the same legal protections regardless of whether it’s stored on our Services or on your home computer’s hard drive. We’ll abide by the following principles when receiving, scrutinising, and responding to government requests (outside of that explained above) for your data:
    • Be transparent,
    • Fight blanket requests,
    • Protect all users, and
    • Provide trusted services.


  • User Controls.
    You can access, amend, download, and delete your personal information by logging into your Reflective Learning account and going to your account profile page or contacting us directly.
  • Levelled User Access.
    The level of detail required by a user is dependent on the role of an individual within an education institution, education department or affiliate organisation. This is restricted to what is reasonably required to execute that role well. For example, a school teacher would reasonably expect to see the detailed results for every learner in their class. However, external government officials would not need to see identifiable individual learner results.
  • Retention.
    When you sign up for an account with us, we’ll retain information you store on our Services for as long as your account is in existence or as long as we need it to provide you the Services. If you delete your account, we will initiate deletion of this information within 30 days. But please note: (1) there might be some latency in deleting this information from our servers and back-up storage; (2) we will retain essential data to preserve the integrity of aggregated research-related data sets such as answers to questions or software usage trends; and (3) we will retain this information if necessary, to comply with our legal obligations, resolve disputes, or enforce our agreements.


Around the world.

To provide you with the Services, we may store, process, and transmit information in South Africa and locations around the world—including those outside your country. Information may also be stored locally on the devices you use to access the Services.


We may revise this Privacy Policy from time to time, and will post the most current version on our website. If a revision meaningfully reduces your rights, we will notify you.

Your Right to Control and Access Your Information.

You have control over your personal information and how it is collected, used, and shared. For example, you have a right to change or correct personal data. You can manage your account and the content contained in it, as well as edit some of your personal data, through your account profile page.


Your personal information is controlled by Reflective Learning (Pty) Ltd. Have questions or concerns about Reflective Learning, our Services, and privacy? Contact us at [email protected]

Terms of Service

Reflective Learning Terms of Service
Posted: 12 April 2019
Effective: 12 April 2019

Thanks for using Reflective Learning! These terms of service (“Terms”) cover your use and access to our services, client software and websites ("Services"). Your agreement is with Reflective Learning (Pty) Ltd. Our Privacy Policy explains how we collect and use your information while our Acceptable Use Policy outlines your responsibilities when using our Services. By using our Services, you’re agreeing to be bound by these Terms, our Privacy Policy, and Acceptable Use Policy. If you’re using our Services for an organisation, you’re agreeing to these Terms on behalf of that organisation.

Your permissions

We need your permission to do things like retaining your information, backing it up, and sharing it when you ask us to. These and other features may require our systems to access, store, and scan your data. You give us permission to do those things, and this permission extends to our affiliates and trusted third parties we work with.

  • Your Responsibilities.
    You’re responsible for your conduct and must comply with our Terms and Acceptable Use Policy. Content in the Services may be protected by others’ intellectual property rights. Please don’t copy, upload, download, or share content unless you have the right to do so.
  • Contacts.
    You may choose to give us access to your contacts to make it easy for you to do things like sharing learner reports and inviting others to use the Services. If you do, we’ll store those contacts on our servers.
  • Review of conduct and compliance.
    We may review your conduct and content for compliance with these Terms. With that said, we have no obligation to do so. We aren’t responsible for the content people post and share via the Services.
  • Help us keep you informed and information protected.
    Safeguard your password to the Services, and keep your account information current. Don’t share your account credentials or give others access to your account.
  • Age of digital consent.
    You may use our Services only as permitted by applicable law, including export control laws and regulations. Finally, to consent to use our Services, you must be of legal age of consent in your country of origin. If you don’t meet these age requirements, you may not use the Services unless your parent or guardian has given permission to do so. If you have access to our Services through a third-party organisation, it is their responsibility to obtain such consent. When an organisation provides us with your details or signs you up for our Services, we will automatically assume that consent has been obtained. We accept no liability if this process has not been followed through on by the relevant third-party organisation.


Some of our Services may allow you to download client software (“Software”) which may update automatically. So long as you comply with these Terms, we give you a limited, nonexclusive, non-transferable, revocable license to use the Software, solely to access the Services. To the extent any component of the Software may be offered under an open source licence, we’ll make that license available to you and the provisions of that license may expressly override some of these Terms. Unless the following restrictions are prohibited by law, you agree not to reverse engineer or decompile the Services, attempt to do so, or assist anyone in doing so.

Beta Services

We sometimes release products and features that we are still testing and evaluating. Those Services have been marked beta, preview, early access, or evaluation (or with words or phrases with similar meanings) and may not be as reliable as Reflective Learning’s other services, so please keep that in mind.

Our Stuff

The Services are protected by copyright, trademark, and other South African and foreign laws. These Terms don’t grant you any right, title, or interest in the Services, others’ content in the Services, Reflective Learning trademarks, logos and other brand features. We welcome feedback, but note that we may use comments or suggestions without any obligation to you.

  • Copyright.
    We respect the intellectual property of others and ask that you do the same. We respond to notices of alleged copyright infringement if they comply with the law, and such notices should be reported to us directly by emailing [email protected]

Paid Accounts


It is free to register an account with Reflective Learning. To access our Services, you may be required to pay an annual subscription fee or once-off payments depending on the Service chosen. Any membership will be valid for one year from your date of payment and will allow you to use our services as much as you like. You will be reminded to extend this membership beyond its expiry which can be done by purchasing a new licence. Physical products will accrue relevant delivery charges. Please note that we do not deliver outside of South Africa.

No Refunds.

You may cancel your Reflective Learning account at any time, however refunds are only issued if required by law.


We may change the Reflective Learning fees, but will give you advance notice of these changes via a message to the email address associated with your account.

Reflective Learning School or Enterprise

  • Email Address.
    If you sign up for a Reflective Learning account with an email address provisioned by your organisation, your organisation may be able to block your use of Reflective Learning (unless you associate your Reflective Learning account with a personal email address).
  • Using Reflective Learning School or Enterprise.
    If you join using a Reflective Learning School or Enterprise account, you must use it in compliance with your organisation's terms and policies. Please note that Reflective Learning School or Enterprise accounts are subject to your organisation's control. Your administrators may be able to access, disclose, restrict, or remove information in or from your Reflective Learning team account. They may also be able to restrict or terminate your access to a Reflective Learning account. If you convert an existing Reflective Learning account into part of a Reflective Learning School or Enterprise account, your administrators may prevent you from later disassociating your account.


You’re free to stop using our Services at any time. We reserve the right to suspend or terminate your access to the Services with notice to you if:

  • you’re in breach of these Terms,
  • you’re using the Services in a manner that would cause a real risk of harm or loss to us or other users, or
  • you don’t have a paid account.

We’ll provide you with reasonable advance notice via the email address associated with your account to remedy the activity that prompted us to contact you. If after such notice you fail to take the steps we ask of you, we’ll terminate or suspend your access to the Services.

We won’t provide notice before termination where:

  • you’re in material breach of these Terms,
  • doing so would cause us legal liability or compromise our ability to provide the Services to our other users,
  • we have decided to revoke access for demo purposes,
  • we're prohibited from doing so by law.

Discontinuation of Services

We may decide to discontinue the Services in response to unforeseen circumstances beyond Reflective Learning’s control or to comply with a legal requirement. If we do so, we’ll give you reasonable prior notice.

Services “AS IS”

We strive to provide great Services, but there are certain things that we can't guarantee. To the fullest extent permitted by law, Reflective Learning and its affiliates, suppliers and distributors make no warranties, either express or implied, about the services. The services are provided "AS IS."

Limitation of Liability

We won’t exclude or limit our liability to you where it would be illegal to do so—this includes any liability for Reflective Learning’s or its affiliates’ fraud or fraudulent misrepresentation in providing the services. In countries where the following types of exclusions aren’t allowed, we're responsible to you only for losses and damages that are a reasonably foreseeable result of our failure to use reasonable care and skill or our breach of our contract with you. In countries where exclusions or limitations of liability are allowed, Reflective Learning, its affiliates, suppliers or distributors won’t be liable for:

  • Any indirect, special, incidental, punitive, exemplary, or consequential damages, or
  • Any loss of use, data, business, or profits, regardless of legal theory.
  • These exclusions or limitations will apply regardless of whether or not Reflective Learning or any of its affiliates has been warned of the possibility of such damages.

If you use the services for any commercial, business, or re-sale purpose, Reflective Learning, its affiliates, suppliers or distributors will have no liability to you for any loss of profit, loss of business, business interruption, or loss of business opportunity. Reflective Learning and its affiliates aren’t responsible for the conduct, whether online or offline, of any user of the services.

Other than for the types of liability we cannot limit by law, we limit our liability to you to 100% of any amount you've paid under your current service plan or product with Reflective Learning.

Resolving Disputes

Let’s try to sort things out first. We want to address your concerns without needing a formal legal case. Before filing a claim against Reflective Learning, you agree to try to resolve the dispute informally by contacting [email protected] We’ll try to resolve the dispute informally by contacting you via email. If a dispute is not resolved within 15 working days of submission, you or Reflective Learning may bring a formal proceeding.

Entire Agreement

These Terms constitute the entire agreement between you and Reflective Learning with respect to the subject matter of these Terms, and supersede and replace any other prior or contemporaneous agreements, or terms and conditions applicable to the subject matter of these Terms. These Terms create no third-party beneficiary rights.

Waiver, Severability & Assignment

Reflective Learning’s failure to enforce a provision is not a waiver of its right to do so later. If a provision is found unenforceable, the remaining provisions of the Terms will remain in full effect and an enforceable term will be substituted reflecting our intent as closely as possible. You may not assign any of your rights under these Terms, and any such attempt will be void. Reflective Learning may assign its rights to any of its affiliates or subsidiaries, or to any successor in interest of any business associated with the Services.


We may revise these Terms from time to time to better reflect:

  • changes to the law,
  • new regulatory requirements, or
  • improvements or enhancements made to our Services.

If an update affects your use of the Services or your legal rights as a user of our Services, we’ll notify you prior to the update's effective date by sending an email to the email address associated with your account or via an in-product notification. These updated terms will be effective no less than 30 days from when we notify you. If you don’t agree to the updates we make, please cancel your account before they become effective. By continuing to use or access the Services after the updates come into effect, you agree to be bound by the revised Terms.

Acceptable Use Policy

Reflective Learning is used by many individuals, schools and organisations, and we're proud of the trust placed in us. In exchange, we trust you to use our services responsibly.

You agree not to misuse the Reflective Learning services ("Services") or help anyone else to do so. For example, you must not even try to do any of the following in connection with the Services:

  • probe, scan, or test the vulnerability of any system or network;
  • breach or otherwise circumvent any security or authentication measures;
  • access, tamper with, or use non-public areas or parts of the Services, or shared areas of the Services you haven't been invited to;
  • interfere with or disrupt any user, host, or network, for example by sending a virus, overloading, flooding, spamming, or mail-bombing any part of the Services;
  • access, search, or create accounts for the Services by any means other than our publicly supported interfaces (for example, "scraping" or creating accounts in bulk);
  • send unsolicited communications, promotions or advertisements, or spam;
  • send altered, deceptive or false source-identifying information, including "spoofing" or "phishing";
  • promote or advertise products or services other than your own without appropriate authorisation;
  • abuse referrals or promotions to get more services than deserved;
  • circumvent service limits;
  • sell the Services unless specifically authorised to do so;
  • harass or abuse Reflective Learning personnel or representatives or agents performing services on behalf of Reflective Learning;
  • violate the privacy or infringe the rights of others.