Privacy Policy & Data Protection

Last Updated: October 1, 2026

1. Scope & Responsible Party

This Privacy Policy explains how Apex Learning KW (Pty) Ltd (CIPC Registration: 2026 / 262544 / 07), operating the platform apexlearningkw.com ("Apex Learning," "the Company," "we," "our," or "us"), collects, uses, stores, protects, and discloses personal information.

We process personal data in strict compliance with the Protection of Personal Information Act (POPIA No. 4 of 2013) of the Republic of South Africa, the Electronic Communications and Transactions Act (ECTA No. 25 of 2002), and the Data Protection & Privacy Regulations issued by the Kuwait Communication and Information Technology Regulatory Authority (CITRA) alongside Kuwait Law No. 20 of 2014 regarding Electronic Transactions.

2. Categories of Data Collected

We collect only the minimum personal information required to execute diagnostic match evaluations and manage educator listings:

Student & Parent Information: Submitter role, parent/guardian full name, student full name, student grade level, contact email, WhatsApp telephone number, preferred communication method, residential district/area within Kuwait, curriculum framework (e.g., American AP, British IGCSE/A-Level, IB, Kuwait National), subject challenges, and diagnostic learning notes.
Educator Information: Full name, contact email, WhatsApp telephone number, encrypted authentication credentials, CV/resume uploads, professional references, teaching history, subject competencies, hourly rate bounds (KD floor and target), delivery mode availability, and pedagogical archetype classifications.
Technical & Usage Data: Internet Protocol (IP) addresses, browser type, device information, and interaction timestamps captured during website access and form submissions.
Payment & Billing Data: All platform subscription transactions for educators are handled exclusively by our Merchant of Record, Lemon Squeezy. Apex Learning does not collect, process, or store credit card numbers, CVVs, or bank account credentials.

3. Purpose of Processing & Legal Basis

Personal information is processed strictly for the following operational purposes:

Evaluating student learning dimensions and cognitive roadblocks to introduce vetted, compatible academic specialists.
Brokering transparent hourly instructional rate expectations prior to direct communication exchange.
Vetting educator degrees, teaching histories, and institutional credentials.
Managing authenticated tutor dashboard access and active placement registry standing.
Responding directly to user inquiries submitted through our administrative channels.

4. The Blind-Matching Confidentiality Protocol

To eliminate commercial bias and protect user dignity, Apex Learning does not operate an open classifieds board:

No Public Classifieds Directory: Tutor biographies, personal contact information, and profiles are never indexed on public, searchable directories.
Controlled Information Release: Student and guardian phone numbers and email addresses are never accessible to educators browsing the platform. Contact information is only shared with an educator once both parties have explicitly agreed to the match and the brokered hourly rate.
Zero Commercial Data Selling: We do not sell, rent, monetize, or lease user data to third-party marketing brokers or advertisers under any circumstances.

5. Cross-Border Data Transfers (CITRA & POPIA Compliance)

Apex Learning operates across South African and Kuwaiti commercial spheres. Users in the State of Kuwait explicitly acknowledge and consent to the transmission, cloud processing, and storage of their information on secured cloud infrastructure located outside Kuwait (including Google Workspace / Google Apps Script infrastructure and Lemon Squeezy billing infrastructure) solely for matching delivery and payment handling.

6. Third-Party Service Providers

We share information strictly with verified cloud infrastructure providers operating under confidentiality obligations:

Google Workspace / Google Apps Script: Encrypted, serverless database and administrative storage.
Lemon Squeezy: Merchant of Record managing educator listing subscriptions, card processing, and billing compliance.

7. Data Retention & Security Measures

We maintain appropriate physical, electronic, and procedural safeguards, including 256-bit SSL/TLS transmission encryption. Records are retained only for as long as necessary to facilitate tutoring connections, service active educator subscriptions, or comply with statutory accounting and legal requirements.

8. Your Rights (POPIA & Kuwait DPPR)

Under applicable South African and Kuwaiti regulations, you have the right to:

Request confirmation and access to personal records held by the Company.
Request corrections or updates to inaccurate, outdated, or incomplete records.
Request the deletion or destruction of your diagnostic profile or tutor listing from our candidate pool.
Object to processing or withdraw consent at any time without penalty.

9. Contact the Information Officer

To exercise your data protection rights, request profile deletion, or submit privacy inquiries, please contact our administrative desk at:

Email: [email protected]
Legal Entity: Apex Learning KW (Pty) Ltd (Reg: 2026 / 262544 / 07)
Compliance Desk: Kuwait Decree Law 10/2026 & POPIA Framework