Privacy Policy

Last updated: 24 March 2026

1. Introduction

This Privacy Policy explains how TenuTech (Pty) Ltd ("TenuTech", "we", "us", or "our") collects, uses, stores, and protects personal information through the SkillTracer platform, including our web application and mobile application (collectively, the "Platform").

We are committed to protecting your privacy in accordance with the Protection of Personal Information Act, 2013 (POPIA) of South Africa, the General Data Protection Regulation (GDPR) where applicable, and other relevant data protection legislation.

By accessing or using the Platform, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with this policy, please discontinue use of the Platform immediately.

2. Information We Collect

We collect and process the following categories of personal information:

2.1 Information You Provide Directly

  • Account and identity data: Full name, email address, phone number, date of birth, and profile photograph.
  • Role-specific data: Information relevant to your role on the Platform (e.g., athlete, coach, manager, or parent/guardian), including organisational affiliations and qualifications.
  • Performance and assessment data: Scores, assessment results, skill evaluations, and related performance metrics submitted or generated through the Platform.
  • Uploaded content: Documents, profile pictures, certificates, and any other files you upload to the Platform.
  • Communication data: Messages, feedback, and correspondence sent through the Platform or to our support channels.

2.2 Information Collected Automatically

  • Device and usage data: IP address, browser type and version, operating system, device identifiers, pages visited, time spent on pages, and referral URLs.
  • Location data: Approximate geographic location derived from your IP address or, where you have granted permission, precise location data from your mobile device. Location data is used for proximity calculations and to deliver location-relevant services.
  • Cookies and similar technologies: We use cookies, session tokens, and similar tracking technologies to maintain your session, remember preferences, and analyse Platform usage. Please refer to Section 9 for further details.

2.3 Information from Third Parties

  • Verification services: We may receive identity verification data from third-party providers to confirm user identities.
  • Google services: Where you authenticate using Google, we receive basic profile information in accordance with your Google account settings.
  • WhatsApp (Meta): Where you interact with the Platform via WhatsApp, we may receive your phone number and message content in accordance with Meta's data policies.
3. How We Use Your Information

We process your personal information for the following purposes:

  • Service delivery: To provide, operate, and maintain the Platform, including user authentication, role-based access, and account management.
  • Performance tracking and analytics: To generate scores, assessments, skill analyses, and reporting dashboards for users and their organisations.
  • AI-powered features: To provide automated analysis, scoring, and personalised recommendations using artificial intelligence and machine learning technologies. AI-generated outputs are intended to supplement, not replace, human decision-making.
  • Location-based services: To calculate proximity between users, facilities, and opportunities, and to deliver geographically relevant content.
  • Communications: To send service-related notifications, updates, and administrative messages via email, SMS, push notifications, or WhatsApp.
  • Safety and security: To detect, prevent, and investigate fraud, unauthorised access, and other malicious activity.
  • Improvement and development: To analyse usage patterns, conduct research, and improve the functionality and user experience of the Platform.
  • Legal compliance: To comply with applicable laws, regulations, and legal processes.
4. Legal Basis for Processing

We process your personal information on the following legal grounds:

  • Consent: Where you have provided explicit consent for a specific purpose (e.g., opting in to location tracking or marketing communications).
  • Contractual necessity: Where processing is necessary for the performance of a contract to which you are a party, including the provision of Platform services.
  • Legitimate interest: Where processing is necessary for our legitimate interests, such as improving the Platform, ensuring security, and conducting analytics, provided these interests do not override your rights.
  • Legal obligation: Where processing is necessary to comply with a legal obligation to which we are subject.
5. Third-Party Services and Data Sharing

We do not sell your personal information. We may share your information with the following categories of third parties, strictly to the extent necessary for the stated purposes:

  • Cloud infrastructure and hosting providers: For secure data storage and Platform hosting.
  • WhatsApp / Meta: To facilitate messaging and notifications where you have opted in to WhatsApp-based communications.
  • Google services: For authentication (Google Sign-In), analytics, cloud services, and mapping/location features.
  • Identity verification providers: To verify user identities where required.
  • Analytics providers: To help us understand Platform usage and improve our services.
  • Organisational administrators: Where you are associated with an organisation (e.g., a school, sports club, or enterprise), authorised administrators within that organisation may access your performance data and profile information as necessary for their legitimate administrative purposes.
  • Legal and regulatory authorities: Where required by law, court order, or regulatory obligation.

All third-party service providers are contractually required to process personal information in accordance with applicable data protection laws and solely for the purposes specified by TenuTech.

6. Data Retention

We retain your personal information only for as long as is necessary to fulfil the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements.

  • Active accounts: Your data is retained for the duration of your account's active status on the Platform.
  • Inactive accounts: Accounts that have been inactive for a period exceeding twenty-four (24) months may be flagged for deletion, subject to prior notification.
  • Post-deletion: Upon account deletion, personal data is permanently removed within ninety (90) days, except where retention is required by law or for the resolution of disputes.
  • Anonymised data: We may retain anonymised or aggregated data indefinitely for analytics and research purposes, provided such data cannot be used to identify you.
7. Your Rights

Under POPIA, GDPR, and other applicable data protection legislation, you have the following rights in relation to your personal information:

  • Right of access: You may request confirmation of whether we hold personal information about you and, if so, request a copy of that information.
  • Right to rectification: You may request correction of inaccurate or incomplete personal information.
  • Right to erasure: You may request the deletion of your personal information, subject to any legal obligations requiring retention.
  • Right to restrict processing: You may request that we limit the processing of your personal information in certain circumstances.
  • Right to data portability: You may request to receive your personal information in a structured, commonly used, machine-readable format.
  • Right to object: You may object to the processing of your personal information where processing is based on legitimate interests or direct marketing.
  • Right to withdraw consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.
  • Right to lodge a complaint: You may lodge a complaint with the Information Regulator of South Africa or the relevant supervisory authority in your jurisdiction.

To exercise any of these rights, please contact us at support@skilltracer.com. We will respond to your request within thirty (30) days.

8. International Data Transfers

Your personal information may be transferred to, and processed in, countries other than South Africa where our hosting providers and third-party service providers operate. Where such transfers occur, we ensure that appropriate safeguards are in place in accordance with Section 72 of POPIA and, where applicable, Chapter V of the GDPR, including standard contractual clauses or equivalent protective measures.

9. Cookies and Tracking Technologies

The Platform uses cookies and similar technologies to:

  • Essential cookies: Maintain your session, authenticate your identity, and ensure the secure operation of the Platform.
  • Functional cookies: Remember your preferences, language settings, and display options.
  • Analytics cookies: Collect anonymised usage data to help us understand how the Platform is used and to identify areas for improvement.

You may control cookie settings through your browser preferences. Disabling essential cookies may impair the functionality of the Platform.

10. Children's Privacy

The Platform may be used by individuals under the age of eighteen (18), including athletes and learners. Where a user is a minor, we require the consent of a parent or legal guardian for the collection and processing of their personal information, in accordance with Section 35 of POPIA. Parents and guardians may exercise the rights described in Section 7 on behalf of their children.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. The "Last updated" date at the top of this page indicates when this policy was most recently revised. We will notify you of material changes through the Platform or by email. Continued use of the Platform following such notification constitutes acceptance of the updated policy.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact us:

You may also lodge a complaint with the Information Regulator of South Africa at inforegulator.org.za.