S’gelaHub Data Processing Agreement (DPA)

Last Updated: March 2026

This Data Processing Agreement (“DPA”) governs how S’gelaHub processes personal data on behalf of partners such as schools.

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1. Parties

This Agreement is between:

S’gelaHub (Data Processor)
and
Partner (Data Controller)

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2. Purpose of Processing

S’gelaHub processes personal data to:

• provide educational services
• generate AI insights
• support learner progress tracking

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3. Types of Data Processed

Parent Data

• name
• contact details
• payment information

Learner Data

• name
• grade
• subject activity
• homework submissions

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4. Processing Activities

Data may be:

• collected
• stored
• analysed
• used to generate AI insights

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5. Data Security Measures

S’gelaHub implements:

• encryption
• secure hosting
• access controls
• regular system monitoring

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6. Sub-processors

S’gelaHub may use trusted third parties for:

• cloud hosting
• payment processing
• analytics services

All sub-processors must comply with data protection standards.

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7. Data Breach Notification

In the event of a data breach:

• S’gelaHub will notify the partner promptly
• steps will be taken to mitigate impact
• investigations will be conducted

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8. Data Subject Rights

S’gelaHub supports:

• data access requests
• correction requests
• deletion requests

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9. Data Retention

Data is retained only as long as necessary for:

• service delivery
• legal compliance

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10. Data Transfer

Data will not be transferred outside approved jurisdictions unless:

• adequate safeguards are in place

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11. Audit Rights

Partners may request reasonable audits to verify compliance.

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12. Termination

Upon termination:

• data may be deleted or returned
• systems access will be revoked

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13. Governing Law

This Agreement is governed by the laws of South Africa.