PRIVACY AND COOKIE NOTICE

Last updated: 7 September 2026 

1. Purpose and Scope 
This Privacy and Cookie Notice explains how Lourens Breytenbach collects, uses, stores, shares and protects personal information through LourensBreytenbach.com, SmartStudySystem.com and any related digital product, account area or application that links to this Notice. 
It is intended to provide transparent information under the Protection of Personal Information Act 4 of 2013 (“POPIA”) and other privacy laws that may apply. 

2. Responsible Party and Information Officer Contact 
The responsible party is: Lourens Breytenbach
Legal status: Individual / sole proprietor
Physical address: 2 König Avenue, Roodepoort, SA 1724
Telephone: +27 66 268 9778
Privacy and Information Officer email: info@smartstudysystem.com 

3. Personal Information We May Collect 
Depending on how you use the Platform, we may collect: 
  • Identity and contact information: name, email address, country and any contact details you choose to provide;
  • Order and subscription information: product purchased, order number, amount, currency, payment status, subscription status, renewal or cancellation status and limited billing information supplied by the merchant of record; 
  • Account and access information: account identifier, authentication status, access entitlements, login events and security records; 
  • Communication information: messages, support requests, survey responses and records of correspondence;
  • Marketing information: subscription source, email preferences, consent records, delivery status and engagement information supplied by the email service;
  • Technical information: IP address, browser type, device type, approximate location, timestamps, referring pages, error logs, security events and server records needed to operate and protect the Platform; and 
  • Information you choose to enter into a tool: responses needed to generate an educational result or recommendation. 
We do not receive or store your complete payment-card number. Payment information is handled by the merchant of record and its payment providers. At present, the Platform does not intentionally retain diagnostic quiz answers or create stored learner profiles in a central database. Where a tool processes answers temporarily to produce a result, the answers should not be linked to an identified teenager. If a future tool will store answers or profiles, a clear notice will be provided before that collection begins and this Notice will be updated. 

4. How We Collect Information 
Information may be collected: 

  • directly from the adult user when they register, purchase, subscribe, contact us or complete a form; 
  • from Lemon Squeezy or another merchant of record after a transaction; 
  • from Kit.com or another email-delivery service after an adult subscribes or interacts with an email; 
  • from hosting, authentication, security and technical service providers; and 
  • automatically through essential cookies, server logs and similar technologies. 
5. Why We Process Personal Information 
We process personal information only where there is an appropriate legal justification, including consent, performance of a contract, compliance with a legal obligation, protection of legitimate interests or another basis recognised by applicable law. 
We use information to: 
  • process and confirm registrations, purchases and subscriptions; 
  • provide accounts, downloads, membership access and customer support; 
  • authenticate users and protect accounts, products and systems; 
  • communicate about purchases, renewals, access, material service changes and security; 
  • send newsletters or promotional messages where permitted; 
  • maintain accurate transaction, consent and compliance records; 
  • diagnose technical faults, prevent fraud and improve reliability; 
  • understand aggregate use of products without creating advertising profiles; and 
  • establish, exercise or defend legal rights. 
Where information is required to complete a purchase, provide account access or meet a legal requirement, failure to provide it may mean that we cannot provide the requested service. 

6. Direct Marketing and Email 
Marketing email is sent only where permitted by law—for example, where an adult has consented or where a lawful existing-customer basis applies. 
Marketing consent is voluntary and must not be bundled into a purchase. You may unsubscribe at any time using the link in an email or by contacting info@smartstudysystem.com. Unsubscribing from marketing does not prevent service messages that are necessary for an active purchase, account or subscription. 
We may retain a minimal suppression record after an unsubscribe so that the address is not accidentally added to marketing again. 

7. Children’s and Teenagers’ Information 
Purchases, accounts and marketing sign-ups are for adults aged 18 or older. The Platform is designed so that teenagers can use appropriate educational resources without submitting their own name, email address or other identifying information. 
A parent, guardian or other legally competent adult should supervise a teenager’s use. Teenagers must not submit health information, emotional disclosures, school records, contact details or other sensitive information through a general form or educational tool. 
Technical data such as an IP address or security log may be processed automatically when a teenager uses a website or application. The responsible adult who permits that use consents, where legally required, to the minimum technical processing needed to provide and protect the service. If we learn that personal information was collected directly from a child without the authorisation required by law, we will take reasonable steps to delete or lawfully regularise it. 

8. Sharing with Operators and Service Providers 
We do not sell personal information. Information may be shared only as reasonably necessary with trusted providers that perform functions such as: 
  • payment, tax, receipt, refund and subscription administration, including Lemon Squeezy; 
  • email delivery and subscriber management, including Kit; 
  • website and file hosting; ·
  • account authentication and access control; 
  • security, technical support and error diagnosis; 
  • professional advice, accounting or legal compliance; and 
  • regulators, law-enforcement bodies or courts where disclosure is lawfully required. 
These providers may act as independent responsible parties/controllers or as operators/processors acting on instructions. Their own privacy notices apply when they determine how they process information. We do not permit a provider to use customer information for our own third-party advertising profiles. 

9. International Processing and Transfers 
The Platform is operated from South Africa, but some service providers may process or store information in other countries. Those countries may have different privacy laws. Where POPIA applies, a transfer outside South Africa will be made only where an appropriate basis under section 72 exists, such as adequate legal or contractual protection, a binding agreement, consent where appropriate, or another lawful basis. Where another privacy law applies, additional transfer safeguards will be used where required. 

10. Retention 
We keep personal information only for as long as reasonably necessary for the purpose for which it was collected, including to provide an active service, comply with tax and record-keeping duties, resolve disputes, prevent fraud and establish or defend legal claims. 

In general: 
  • account and access information is kept while an account or entitlement remains active and for a reasonable period afterwards; 
  • transaction records are kept for the period required by tax, accounting, consumer and legal obligations; 
  • marketing information is kept until consent is withdrawn, the purpose ends or continued processing is no longer lawful, subject to a minimal suppression record; 
  • support correspondence is kept for a reasonable period based on the nature of the request; and 
  • technical and security logs are kept only for the period reasonably required for reliability, fraud prevention and security. Information may be retained longer where law requires it or where preservation is necessary for a current dispute or investigation. 
Information that no longer needs to be retained will be deleted, destroyed, de-identified or restricted as appropriate. 

11. Cookies, Local Storage and Embedded Content 
The Platform may use cookies, local storage or similar technology that is strictly necessary to provide login, security, preferences, checkout or other requested functions. 
The Platform does not currently use cookies to build third-party advertising profiles. If analytics, advertising pixels or other non-essential tracking are introduced, this Notice and the consent controls will be updated before that use begins where required. 
Embedded content, such as a YouTube video or an external checkout, may allow the third-party provider to set cookies or collect technical information when the content loads or is used. Where required, non-essential embedded content will be blocked until the user chooses to activate it. You may also open third-party content directly, in which case that provider’s privacy notice applies. 
Browser controls can be used to block or delete cookies, although blocking essential technology may prevent account, checkout or other features from working. 

12. Security and Data Breaches 
We use reasonable technical and organisational safeguards appropriate to the nature of the information and the risks involved. These may include access controls, secure service providers, authentication protections, software updates, backups and limiting the information collected. No online system can be guaranteed completely secure. If there are reasonable grounds to believe that personal information has been accessed or acquired by an unauthorised person, we will investigate and notify the Information Regulator and affected people as required by POPIA and other applicable law. 

13. Your Rights 
Subject to applicable law and appropriate identity verification, you may have the right to: 

  • ask whether we hold personal information about you; 
  • request access to that information; 
  • ask for inaccurate, irrelevant, excessive, outdated, incomplete, misleading or unlawfully obtained information to be corrected or deleted;
  • request deletion or destruction where retention is no longer authorised; 
  • object to certain processing; 
  • withdraw consent where processing is based on consent; 
  • unsubscribe from direct marketing; 
  • complain to the Information Regulator or another competent privacy authority; and 
  • obtain other rights available under the privacy law applicable to you. 
Requests may be sent to info@smartstudysystem.com. We may request reasonable proof of identity and may retain information that we are legally required or entitled to keep. 
South African data subjects may lodge a complaint with the Information Regulator (South Africa) through https://inforegulator.org.za/complaints/. 

14. Automated Processing 
Educational tools may automatically calculate a score, category or suggested next step from answers supplied by the user. These outputs are informational and self-directed. They are not used to make decisions that produce legal or similarly significant effects, and they should not be treated as clinical or formal educational assessments. 

15. Third-Party Websites 
This Notice does not control how an external website or service independently collects and uses information. Review the privacy notice presented by the relevant payment provider, email provider, authentication provider, embedded-media service or linked website. 

16. Changes to This Notice 
We may update this Notice when our practices, providers, products or legal obligations change. The current version will be posted with a revised date. Where a change materially affects how existing personal information is used, additional notice or consent will be provided where required. 

17. Contact 
Privacy questions, objections and rights requests may be sent to: 
Lourens Breytenbach
Privacy and Information Officer email: info@smartstudysystem.com
Telephone: +27 66 268 9778
Address: 2 König Avenue, Roodepoort, SA 1724
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