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Privacy Policy

Effective date: 1 June 2026  ·  Last updated: 1 June 2026  ·  Responsible party: Vuhosi Capital (Pty) Ltd  ·  Contact: privacy@vuhosicapital.online

Plain-language summary: Zande is a management platform for ECD (Early Childhood Development) centres. We collect two types of information: (1) account information about centre operators who sign up to use Zande, and (2) personal information about learners and parents that is entered by centre operators into the system. ECD centres are legally responsible for the learner and parent data they collect. We process that data on their behalf. We do not sell any personal information to anyone.

1. Who we are

Zande is operated by Vuhosi Capital (Pty) Ltd, a company registered in South Africa ("Zande", "we", "us", "our"). Our registered office is in Hazyview, Mpumalanga, South Africa.

This Privacy Policy explains how we collect, use, store, and protect personal information in connection with the Zande platform. It applies to:

  • ECD centre operators who create a Zande account ("Centre Operators");
  • Parents and guardians who submit enrolment applications through a centre's Zande enrolment portal ("Parents");
  • Learners (children) whose information is recorded in Zande by Centre Operators or Parents.

2. Applicable law

We comply with the Protection of Personal Information Act 4 of 2013 (POPIA), which is the primary data protection law in South Africa. Where applicable, we also comply with the European Union's General Data Protection Regulation (GDPR) for users in the EEA, and the California Consumer Privacy Act (CCPA) for California residents.

South Africa's Information Regulator enforces POPIA. Their contact details are: inforeg.org.za | enquiries@inforeg.org.za | +27 10 023 5200.

3. The two types of personal information we hold

3.1 Centre Operator account data (Zande is the Responsible Party)

When you register a Zande account, we collect and are directly responsible for:

InformationWhy we collect itRetention
Centre name, email address, phone numberCreate and manage your account; communicate with you about the serviceDuration of account + 3 years after closure
Password (stored as a one-way cryptographic hash — we cannot read it)Account authenticationDuration of account
Centre details: physical address, province, EMIS number, registration statusAppear on fee statements and DOE registers; required for service functionalityDuration of account + 3 years
Banking details: bank name, account number, branch codePrinted on PDF fee statements sent to parents; we do not process payments or debit your accountDuration of account + 3 years
Centre logo (if uploaded)Branding on fee statements and enrolment portalDuration of account

3.2 Learner and parent data (ECD Centre is the Responsible Party)

Centre Operators enter personal information about their learners and parents into Zande. In this context:

  • The ECD centre operator is the Responsible Party under POPIA — they are legally responsible for ensuring they have lawful grounds to collect and process this information, including obtaining consent from parents/guardians.
  • Zande (Vuhosi Capital) is the Operator — we process this data only on the instructions of the Centre Operator and do not use it for any other purpose.

Learner and parent data collected includes:

CategoryFields
Child identityFull name, date of birth, gender, home language, SA ID or birth certificate number
Child enrolmentAge group / class, start date, site/branch, attendance records (daily present/absent/late)
Child health information (Special Personal Information — POPIA Section 26)Medical conditions, allergies, dietary needs, chronic medication, doctor/clinic name, medical aid details
Parent / GuardianFull name, phone number, SA ID number (optional)
Emergency contactName and phone number
Financial recordsMonthly fee amount, payment date, payment method, payment notes, waived fee records

Children's data — POPIA Section 57: Learner records contain personal information of children, which is a specially protected category under POPIA. ECD Centre Operators must obtain the written consent of a parent or legal guardian before entering a child's personal information into Zande. The online enrolment portal includes an explicit consent step for this purpose. Centre Operators who manually add learner records confirm by using the service that they have obtained the required parental consent.

4. How we use personal information

4.1 Centre Operator data

  • Provide and operate the Zande platform
  • Send service-related communications (billing, security, platform updates)
  • Respond to support requests
  • Enforce our Terms of Service
  • Comply with legal obligations

4.2 Learner and parent data

  • Render the Zande platform features (fee tracking, attendance, DOE registers, PDF statements, enrolment management) on behalf of the Centre Operator
  • Generate PDF fee statements addressed to parents
  • Populate DOE attendance registers in the format required by the Department of Basic Education
  • We do not use learner or parent data for any purpose beyond providing the service to the Centre Operator
  • We do not analyse, profile, or sell learner or parent data

5. Legal basis for processing

DataLegal basis (POPIA)
Centre Operator account dataProcessing necessary for the performance of a contract (the Zande subscription agreement)
Learner identity, enrolment, and financial dataConsent of parent/guardian (obtained by the Centre Operator); performance of contract between centre and parent
Child health informationExplicit consent of parent/guardian (required by POPIA Section 26 for special personal information)
Attendance recordsLegitimate interest of the ECD centre in meeting DOE regulatory reporting obligations; consent

6. Sharing of personal information

We do not sell personal information. We share personal information only in the following limited circumstances:

  • VPS hosting provider: Zande data is hosted on a Virtual Private Server. The hosting provider has access to server infrastructure only and does not process personal information in any meaningful sense.
  • Legal compliance: We will disclose personal information if required to do so by law, court order, or a lawful request by a South African government authority.
  • Business transfer: If Vuhosi Capital is sold or merged, personal information may be transferred to the acquiring entity, who will be bound by this Privacy Policy.

We do not share learner or parent data with third parties for marketing, advertising, research, or any purpose other than operating the Zande platform.

7. Data retention

  • Active accounts: All data is retained for the duration of the Centre Operator's active subscription.
  • After account closure: Centre Operator account data is retained for 3 years after account closure for legal and audit purposes, then permanently deleted.
  • Learner and parent data: Retained for the duration of the active account. On account closure, the Centre Operator may request an export of all learner data within 30 days. After 30 days post-closure, all learner and parent data is permanently deleted from our servers.
  • Inactive learner records: Deactivated (not deleted) learner records within an active account are retained until the Centre Operator chooses to delete them or the account closes.

8. Security measures

We implement the following technical and organisational measures to protect personal information:

  • All passwords are hashed using industry-standard PBKDF2-SHA256 — we cannot recover or read your password
  • All data in transit is encrypted using TLS 1.2 or higher (HTTPS)
  • Session tokens are cryptographically random, stored with HttpOnly and SameSite=Lax cookie flags
  • Each ECD centre's data is stored in a separate isolated database — one centre cannot access another's data
  • CSRF (Cross-Site Request Forgery) tokens protect all data-changing actions
  • File uploads are validated for content type before storage
  • Rate limiting protects login and enrolment endpoints against brute force and spam
  • Access to the server is restricted to authorised personnel via SSH key authentication

No system is 100% secure. In the event of a data breach that poses a risk to data subjects, we will notify the South African Information Regulator within 72 hours and affected parties as soon as reasonably practicable, as required by POPIA Section 22.

9. Your rights as a data subject

Under POPIA, you have the following rights regarding your personal information:

RightWhat it meansHow to exercise it
Right of accessRequest a copy of personal information we hold about youEmail privacy@vuhosicapital.online
Right to correctionRequest correction of inaccurate or incomplete informationCentre Operators: edit directly in Zande. Parents: contact your ECD centre.
Right to deletionRequest deletion of your personal informationEmail privacy@vuhosicapital.online — we will action within 30 days
Right to objectObject to processing of your personal information in certain circumstancesEmail privacy@vuhosicapital.online
Right to data portabilityReceive your data in a structured, machine-readable formatCentre Operators: contact support for a full data export
Right to lodge a complaintComplain to the Information Regulator if you believe your rights have been violatedinforeg.org.za | enquiries@inforeg.org.za

Note for parents and learners: Learner records are controlled by the ECD centre, not by Zande directly. To access, correct, or delete your child's records, contact the centre operator in the first instance. If the centre does not respond, contact us at privacy@vuhosicapital.online and we will assist.

10. Cookies and tracking

Zande uses only a single session cookie to keep you logged in. This cookie is:

  • Strictly necessary for the platform to function — it cannot be declined if you use the platform
  • HttpOnly (cannot be accessed by JavaScript)
  • Not used for advertising, tracking, or analytics
  • Deleted when you log out or when your browser session ends (unless "remember me" is set)

We do not use Google Analytics, Facebook Pixel, or any third-party tracking scripts. We do not place advertising cookies.

11. International transfers

Zande data is hosted on a VPS server located in South Africa or within a jurisdiction with adequate data protection standards. We do not intentionally transfer personal information outside South Africa to countries that do not provide adequate protection. If this changes, we will update this policy and comply with POPIA Section 72 transfer requirements.

12. Children's privacy — additional protections

Zande processes personal information of children as part of its core function (ECD learner management). We take the following additional measures:

  • The online enrolment portal requires explicit parental/guardian consent before an application is submitted
  • Centre Operators using Zande agree, as part of our Terms of Service, that they have obtained required parental consent before entering child data
  • Health information (medical conditions, medication, allergies) is treated as special personal information under POPIA Section 26 and Section 57
  • Children's data is never used for advertising, profiling, or any purpose beyond the ECD management functions
  • Zande does not allow anyone under 18 to create an account — accounts are for ECD centre operators only

13. CCPA notice (California residents)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA). We do not sell personal information. California residents may exercise the same access, deletion, and portability rights described in Section 9. To exercise these rights, email privacy@vuhosicapital.online with the subject line "CCPA Request".

14. Changes to this policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify Centre Operators by email and update the "Last updated" date at the top of this page. Continued use of Zande after the effective date of an updated policy constitutes acceptance of the changes.

15. Contact us

For any privacy-related questions, requests, or complaints:

  • Email: privacy@vuhosicapital.online
  • Postal: Vuhosi Capital (Pty) Ltd, Hazyview, Mpumalanga, South Africa
  • Response time: We will acknowledge your request within 3 business days and resolve it within 30 days

If you are not satisfied with our response, you may contact the Information Regulator of South Africa at inforeg.org.za.

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