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Privacy Policy

How we collect, process and protect personal data under the GDPR and South Africa's POPIA.

Last updated: 2026-08-11

1. Data controller

DL Integrated Services (Pty) Ltd, owner Daniel Ludik, 100 Harrison Drive, Unit 51, Glen Hills, 4051 Durban North, South Africa.

Email: daniel@dlintegratedservices.com

2. Personal data we collect and why

Account data (email address, name): to create and secure your account, sign you in, send password and verification emails, and send service messages about your account.

Profile details (company name, job role, industry, learning goal, language level, profile picture): to tailor exercises, speaking tasks and learning paths to your working context. These details are optional.

Voice recordings and the transcripts, pronunciation and error analyses derived from them: used solely to give you immediate feedback on pronunciation, grammar and word choice and to show your progress. Recordings are never used to train public AI models and are never shown to company administrators.

Learning and progress data (completed lessons, scores, test attempts, vocabulary journal, homework, streaks, certificates): to save where you are, suggest the next suitable content, and issue certificates.

AI coach chat history: to continue a conversation within an exercise and let you review your past sessions.

Payment and billing data (subscription status, invoice numbers, payment provider identifiers): to provide paid access, issue invoices and meet tax obligations. Card details are handled exclusively by Lemon Squeezy and never reach our systems.

Technical usage data (last activity timestamp, active session identifier): to operate the platform securely, limit concurrent sign-ins, and identify inactive accounts under our retention schedule.

Consent records (timestamp, privacy policy and terms version, user ID): to meet our accountability obligations under the GDPR and POPIA.

We do no advertising tracking and no marketing profiling. We do not collect data that does not serve one of the purposes listed above.

3. Purpose of processing

Delivering and operating the learning platform, including personalised exercises and feedback.

Billing your subscription and meeting statutory record-keeping obligations.

Communicating with you about your account, support requests and service notices.

Security, abuse prevention, and proof of the consent you have given.

4. Legal basis (GDPR)

Account, learning, recording and billing data: performance of a contract and pre-contractual steps (Art. 6(1)(b) GDPR).

Optional profile details and personalisation: consent (Art. 6(1)(a) GDPR), withdrawable at any time with future effect.

Security, abuse prevention and session limiting: legitimate interests (Art. 6(1)(f) GDPR).

Billing records and consent logs: legal obligation (Art. 6(1)(c) GDPR).

5. POPIA (South Africa)

Because DL Integrated Services is registered in South Africa, we also comply with the Protection of Personal Information Act 4 of 2013 (POPIA).

POPIA protects personal information through principles of lawful processing, minimality, purpose specification, further processing limitation, information quality, security safeguards and accountability.

6. Information officer (POPIA)

Information Officer: Daniel Ludik

Email: daniel@dlintegratedservices.com

Organisation: DL Integrated Services (Pty) Ltd, registered in South Africa (registration number 2026/288043/07).

7. Lawful processing under POPIA

Personal information is processed on the basis of contractual necessity, the legitimate interests of the responsible party, legal obligations, or a valid consent of the data subject where required.

8. Third-party processors

Supabase — database, authentication and data storage.

Lemon Squeezy — payment processing.

Resend — transactional email delivery.

We have entered into Data Processing Agreements incorporating Standard Contractual Clauses with Supabase, Lemon Squeezy, and Resend to ensure appropriate safeguards for any processing of personal information outside South Africa.

9. Data retention

Account data and learning progress are stored for the duration of the contract and then deleted or anonymised, unless statutory retention obligations apply.

Inactive accounts: if an account has no activity for 12 months we flag it as dormant and email you a warning. If it remains inactive for a further 30 days, the personal content (recordings, transcripts, analyses, chat history, progress data) is deleted and the remaining account record is anonymised.

You can delete your voice recordings and analyses yourself at any time in account settings.

Billing records are retained for 5 years from the end of the relevant tax/financial year, in accordance with the South African Tax Administration Act.

10. Your rights under GDPR and POPIA

You have the right to access, correction, deletion, restriction of processing, and data portability.

Self-service: under "Settings → Privacy and my data" you can see which categories of data we hold about you, download all of your data as a JSON file, and delete your account together with the associated personal data.

Under POPIA you may also object to the processing of your personal information and request that we stop processing it, unless a legal basis requires continued processing.

You also have the right to lodge a complaint with a competent supervisory authority or with the South African Information Regulator.

11. Security and data breaches

We implement appropriate technical and organisational security measures to protect personal information against unauthorised access, loss or destruction.

If a data breach is likely to result in a risk to your rights and freedoms, we will notify you and the relevant supervisory authorities without undue delay where required by law.

12. Classroom data vs. company dashboard data

Answers submitted in online classrooms are individually attributable and visible to the teacher running the session.

Company administrators only see aggregated, anonymised metrics in the company dashboard — never individual exercise content, recordings, transcripts or specific mistakes.

13. Consent and changes to this policy

When you register you explicitly agree to this privacy policy and our terms; the timestamp, version and your user ID are stored as an auditable consent record.

If the purposes described here change, we ask you to consent again the next time you open the application rather than replacing the policy silently. The version in force is shown by the "last updated" date at the top of this page.