Privacy Policy

Kleva App (“Kleva”, “we”, “us” or “our”) is a South African financial-literacy application. We help people learn about money through lessons, quizzes, streaks and leaderboards, and we may reward top performers with cash or voucher prizes. To do this, we need to collect and use some information about you. This policy explains, in plain language, what we collect, why we collect it, how we use and protect it, who we share it with, how long we keep it, the choices and controls you have, and your rights under the Protection of Personal Information Act 4 of 2013 (POPIA).

This policy also covers the requirements of the app stores we distribute through. Where you download Kleva from the Apple App Store or Google Play, the privacy rules of Apple and Google apply in addition to this policy and to POPIA. Where any app-store rule gives you a stronger protection than the law strictly requires, we apply that stronger protection.

We have tried to keep this policy clear and honest, because helping people understand money also means being straight with them about their information. Please read it together with our terms of use and any competition rules that apply. By creating an account and using Kleva, you confirm that you have read and understood this policy. If you do not agree with it, please do not use the app.

1. Who is responsible for your information

Under POPIA, the “responsible party” is the organisation that decides how and why your personal information is processed. For the Kleva app, that responsible party is Kleva. Our full contact details, and those of our Information Officer, are in section 18 at the end of this policy.

What “personal information” means. Personal information is any information that relates to and can identify you, such as your name, email address, phone number, or details about how you use the app. “Processing” simply means anything we do with that information collecting it, storing it, using it, sharing it, or deleting it.

2. The information we collect

We only collect information we actually need to run Kleva and give you a good, fair experience. Depending on how you use the app, this may include:

Device permissions. Kleva may ask your permission to send push notifications (for streak reminders and prize news) and, if you add a profile photo, to access your photos or camera. These permissions are optional, are only used for the purpose you grant them, and can be turned off at any time in your device settings. Kleva does not need or request your contacts, precise location, microphone or health data.

Special personal information. Some information is treated as especially sensitive under POPIA for example, information about your health, race, religion, or political views. Kleva does not ask for or need this kind of information, and we do not intend to collect it. Please do not send it to us.

Children. Kleva is designed for adults (18 and older), and both this policy and the app stores require an 18+ audience. We do not knowingly collect personal information from children under 18. If we learn that we have collected information from a child without proper consent, we will delete it promptly. If you are a parent or guardian and believe your child has given us information, please contact us using the details in section 18.

3. How we collect your information

We collect information in three main ways:

• Directly from you — when you create an account, complete lessons and quizzes, enter competitions, buy a subscription, claim a prize, set your preferences, or contact us.
• Automatically — when you use the app, our systems record technical and usage information such as device details, activity logs and, where used, cookies and similar identifiers.
• From third parties — for example, our payment or voucher partners may confirm that a payment succeeded, and if you sign in through another service (where offered, such as Apple or Google sign-in), that service may share basic details with us. We only accept information others are lawfully entitled to share.

4. Why we use your information, and our legal grounds

POPIA only allows us to use your information where we have a proper legal ground for doing so. Below is what we use your information for, and the ground we rely on in each case.

• To provide and manage the app — creating and running your account, delivering lessons and quizzes, saving your progress and giving you support. Ground: to carry out our agreement with you.
• To operate leaderboards and give rewards — showing rankings, running competitions and paying prizes. Ground: your consent to appear on public leaderboards, and to carry out the competition rules you agree to when you take part.
• To take payments and pay prizes — collecting subscription fees and paying out winnings safely. Ground: to carry out our agreement, and to meet our legal obligations.
• To keep Kleva safe and to improve it — preventing fraud, cheating and abuse, keeping accounts secure, fixing problems, and understanding how the app is used so we can make it better. Ground: our legitimate interests, weighed against your rights and interests.
• To communicate with you — sending you important service messages about your account, security or prizes, and — where you have agreed — marketing. Ground: to carry out our agreement, and your consent for direct marketing.
• To meet legal and regulatory duties — complying with POPIA, tax law, consumer-protection law, and other rules that apply to us. Ground: our legal obligations.

If we ever want to use your information for a genuinely new purpose that is not covered here or reasonably connected to it, we will update this policy and, where the law requires, ask for your consent first.

5. Leaderboards, competitions and rewards

Leaderboards are part of what makes learning on Kleva fun and motivating, but they also mean showing some of your information to other users, so we want to be especially clear about them.

How ranking works

Leaderboards rank users on skill-based performance only for example quiz scores, streaks and lessons completed. Ranking is not based on chance or random draws. Where two users tie, we break the tie using an objective skill measure (such as who reached the score first or made fewer errors), not a lucky draw. Entry is free.

What is shown, and your choices

• On public leaderboards, other users may see your chosen display name or alias, your rank, and your score or progress not your email, phone number or contact details.
• You control the name shown. You may use a pseudonym instead of your real name, and you may ask to be left off public leaderboards entirely without losing access to the learning content.

Prizes

• If you win a cash or voucher prize, we collect only what we need to confirm you are eligible and to pay you, such as your name and banking or voucher-payout details. We use this information only to deliver your prize and to meet our record-keeping and tax obligations.
• Competitions are also governed by published competition rules, and consumer-protection law requires us to keep records of winners and how they were chosen. We keep those records for the required period.
• Cash and voucher prizes may have tax consequences for you, and in some cases, we may be required by law to report or withhold amounts. We will tell you if this applies. Rewards are prizes for learning performance they are never returns on money, guaranteed cash, or an investment.

6. Automated decisions and profiling

We want to be transparent about the automated processing behind Kleva, because leaderboards and streaks are calculated by our systems rather than by a person.

• Automatic scoring and ranking. Your quiz scores, streaks, progress and leaderboard position are calculated automatically by the app based on your own activity. This is a straightforward, rules-based calculation you earn points for what you do and it does not involve any hidden judgement about you as a person.
• No decisions with legal or similarly significant effects. We do not use automated processing to make decisions about you that have legal effects or similarly significant consequences (such as credit, employment or eligibility for financial products). Leaderboard ranking affects only your position in a learning game and your chance of winning a skill-based prize.
• Fairness and human review. If you believe an automated result for example a score, streak or ranking is wrong, you can contact us and ask a person to review it. We may also use automated tools to detect cheating or fraud; where such a tool flags your account, a person will review the matter before any significant action is taken, and you can give us your side.

7. Who we share your information with

We do not sell your personal information, and we do not share it for cross-context behavioural advertising. We share it only where it is necessary for the purposes in this policy, and only with parties who are required to protect it. These include:

• Service providers (“operators” under POPIA) — trusted companies that process information on our behalf and under our instructions, such as cloud hosting and storage, analytics, payment processing, voucher issuers, communication tools and customer-support platforms. They are bound by written agreements to keep your information secure and to use it only for the services they provide to us, and as the app stores require — to protect it to the same standard set out in this policy.
• Payment and payout partners — to collect subscription fees and pay prizes securely.
• Authorities, regulators and advisors where we are required to share information by law, regulation or a court order, or where it is needed to establish, exercise or defend a legal claim; and our professional advisors (such as lawyers and auditors) who are bound by confidentiality.
• In a business change if Kleva is involved in a merger, acquisition, restructuring or sale, information may be transferred as part of that deal, subject to this policy and applicable law.

8. Third-party services and SDKs in the app

Kleva relies on a small number of third-party tools built into the app to work properly. Each of these may process limited information as described in section 4, under the safeguards in section 7. The main categories are:

We keep this list of tool categories current, and we choose providers who commit to protecting your information to a standard consistent with POPIA and with the app-store rules. The specific providers we use, and their own privacy notices, are available on request using the details in section 18.

9. Tracking and advertising

Kleva does not track you across other companies’ apps and websites and does not use your information to build an advertising profile of you. Because of this, Kleva does not ask for permission to track you under Apple’s App Tracking Transparency, and does not share an advertising identifier with third parties for cross-app advertising under Google’s rules.

If this ever changes for example, if we introduce any advertising we will update this policy, ask for your permission where the law and the app stores require it, and give you a clear way to say no before any such tracking takes place.

10. Cookies and similar technologies

Like most digital services, Kleva uses cookies and similar technologies small data files, software development kits (SDKs) and identifiers stored on or read from your device in the app and on any related website. This section explains what they do and how you can control them.

Your choices. You can manage cookies and similar technologies through your device or app settings, and where we ask for consent (for example for analytics or marketing), you can give or withdraw it at any time. Turning off non-essential cookies will not stop you using the core learning features, though some parts of the app may work less smoothly.

11. Marketing communications

We will only send you direct electronic marketing (such as promotional emails or push notifications) where you have agreed to receive it, or where the law otherwise allows it for existing users. You are always in control:

• Every marketing message includes a simple way to opt out, such as an unsubscribe link or a setting in the app.
• You can change your marketing preferences at any time in the app or by contacting us.
• Opting out of marketing does not stop essential service messages — for example, messages about your account, security, a prize you have won, or important changes to the app or this policy.

12. Sending information outside South Africa

Some of the service providers we use may store or process information on servers outside South Africa. When your personal information is transferred across borders, POPIA requires us to make sure it is properly protected. We do this by working with providers who are subject to laws that offer comparable protection, or by putting appropriate contractual safeguards in place that require them to protect your information to a standard consistent with POPIA.

13. How we keep your information safe

We take the security of your information seriously and apply reasonable technical and organisational measures to protect it against loss, damage, and unauthorised access, use or disclosure. These measures include:

• Encrypting information in transit between your device and our systems;
• Storing passwords in a secure, hashed form rather than as plain text;
• Limiting access to personal information to people who need it to do their work, under confidentiality obligations;
• Using access controls, monitoring and reputable service providers; and
• Reviewing our security practices from time to time.

No system can ever be completely secure, and you also play a part please keep your password confidential and let us know immediately if you think your account has been compromised. If a security breach happens that creates a real risk of harm to you, we will notify you and the Information Regulator as required by POPIA.

14. How long we keep your information

We keep your personal information only for as long as we need it for the purposes set out in this policy, or for as long as the law requires. In practice:

• Account and learning data — kept while your account is active, and for a reasonable period afterwards in case you return or in case we need it for legitimate business or legal reasons.
• Payment, prize and tax records — kept for the periods required by financial, consumer-protection and tax legislation, which may be several years.
• Support and communication records — kept for as long as needed to handle your query and for a reasonable period afterwards.

When we no longer need your information, we securely delete it or make it anonymous so it can no longer be linked to you.

15. Deleting your account and your data

You can delete your Kleva account and personal information at any time, directly from within the app. Because you can create your account inside the app, both Apple and Google require us to give you a way to delete it inside the app too and we do.

To delete your account:

• In the app: open Settings, then Account, then “Delete account”, and follow the steps. You may need to confirm your identity first.
• Or contact us: email hello@klevaapp.com and we will action your request.

When you delete your account, we delete or anonymise the personal information linked to it, except where we are legally required to keep certain records for a limited time for example, payment, prize and tax records, or information we must retain to prevent fraud or to resolve a dispute. We will keep only what the law requires, for only as long as it requires, and then delete it. If you would like a copy of your data before you delete your account, ask us first using the details in section 18.

16. Your rights under POPIA

POPIA gives you a number of rights over your personal information. Subject to the conditions in the Act, you have the right to:

To exercise any of these rights, contact us using the details in section 18. We will respond within a reasonable time and in line with POPIA. To protect your privacy, we may first need to verify your identity, and in some cases the law allows us to decline a request if so, we will explain why. Exercising these rights is free, although we may charge a reasonable fee for additional copies where the law permits.

17. Changes to this policy

We may update this policy from time to time to reflect changes to the app, our practices, the app stores’ rules, or the law. When we do, we will post the updated version in the app and change the “last updated” date at the top. If the changes are significant, we will take reasonable steps to bring them to your attention, for example through a notice in the app. Please check this policy from time to time so you stay informed.

18. How to contact us

If you have any questions, requests or complaints about your privacy or this policy, please contact us:

Information Regulator (South Africa). You also have the right to complain directly to the Information Regulator if you believe we have not handled your personal information lawfully. The Regulator’s current contact details and complaint process are available on its official website.

Apple and Google. Your use of the app is also subject to the privacy practices of the app store you downloaded it from. You can review Apple’s and Google’s own privacy information through their respective app-store and account settings.