📖 Funda Flow Regulatory & Legal Notice

Legal Policies, Terms & Regulatory Documentation

Official Platform Terms, POPIA Notices, AI Disclosures, Library Rules, Commercial Policies & PAIA Manual

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💡 About Funda Flow

FUNDA FLOW (PTY) LTD (Enterprise Registration: 2026 / 622547 / 07) is a South African educational technology company providing curriculum-aligned artificial intelligence diagnostics, automated homework workflows, and classroom management tools across high school subjects.

Platform Scope & Mission

Aligned with the South African Department of Basic Education (DBE) Curriculum and Assessment Policy Statement (CAPS), Funda Flow provides educational diagnostic and curriculum-support services for school learners, including high-school learners (Grades 7–12), enabling them to submit photos of handwritten school work via WhatsApp or web dashboards to receive step-by-step diagnostic feedback, identified error misconceptions, and remedial practice tasks.

Audience & Institutional Tiers

1. Terms & Conditions

These Terms and Conditions govern access to and use of the Funda Flow web application (fundaflow.co.za) and the associated WhatsApp integration. By accessing the platform, you agree to these Terms.

1.1 Service Role & Access Boundaries

Users access Funda Flow under designated roles (Learner, Parent, Teacher, Tutor, HOD, Principal, Circuit Manager, District Manager, Admin). Access permissions are strictly partitioned: parents access only officially paired children; educators access assigned class rosters; and circuit/district managers access aggregated geographic analytics within their assigned educational jurisdiction.

1.2 Formative Diagnostic Role & No Academic Warranty

Important Notice on AI Assistance: Funda Flow provides supplementary formative diagnostic feedback and educational assistance. While designed around DBE CAPS rubrics, AI diagnostic outputs do not constitute official school marks, statutory matriculation certifications, or final academic determinations. Official academic assessments remain the responsibility of accredited educational institutions.

Funda Flow (PTY) LTD does not guarantee specific academic progression, admission outcomes, or examination results. Use of diagnostic feedback is at the user's educational discretion.

1.3 Acceptable Use & Upload Boundaries

Users may upload only relevant, legible educational materials (such as student notebook pages, worksheets, and formal assessment tasks). Users are strictly prohibited from:

Funda Flow reserves the right to suspend or terminate accounts that violate acceptable use standards.

1.4 Service Availability

The platform is provided on an "as is" and "as available" basis. While Funda Flow strives for continuous service availability, operations depend in part on third-party cloud hosting, cellular networks, and messaging APIs. Funda Flow is not liable for temporary service interruptions or network downtime.

1.5 Platform Intellectual Property

All software code, user interface designs, proprietary diagnostic algorithms, branding, logos, and platform documentation are the exclusive intellectual property of FUNDA FLOW (PTY) LTD.

2. Comprehensive Privacy Policy

Funda Flow is committed to lawful, transparent processing of personal information in accordance with the Protection of Personal Information Act (POPIA), Act 4 of 2013.

2.1 Responsible Party Information

Responsible Party: FUNDA FLOW (PTY) LTD (Reg: 2026 / 622547 / 07)
Registered Physical Address: 379, Vaalbank A, Mbibane, Mpumalanga, 0449
Designated Information Officer: Dumisa Harkkim Shongwe
Compliance & Data Protection Email: privacy@fundaflow.co.za

2.2 Categories of Personal Information Ingested & Processed

Data Category Specific Data Fields Processed Technical Purpose & Processing Workflow
Learner Profiles Full name, email, WhatsApp phone number, grade level, gender, learning target bio, preferred language, learner group, school reference, class section, parent link code. Account authentication, class enrollment, diagnostic progress tracking, parent pairing, and regional reporting.
Parent Profiles Auth identifier (UUID), full name, email address, role, linked learner records. Parental monitoring, roadblock notifications, report cards, and study credit sponsorship.
Educator & Staff Profiles Role (Teacher, Tutor, HOD, Principal, Circuit/District Manager), school/jurisdiction ID, teaching subjects, teaching grades, tutor bio, rate structures, available hours. Classroom administration, task assignment, lesson plan generation, and geographic curriculum oversight.
Handwritten Work & Submissions Raw photos of handwritten notebook pages/worksheets, camera captures, OCR text, student calculation steps, assigned task IDs, submission timestamps. AI diagnostic evaluation, method/accuracy marking, error identification, teacher marksheets, and longitudinal academic records.
Diagnostic Marks & Results Mastery scores, method marks (M), accuracy marks (A), consistent accuracy marks (CA), specific error classifications, formative feedback text. Formative feedback generation, teacher item analysis sheets, parent alerts, and remedial intervention.
AI Mini-Lessons & Misconceptions Learner ID, submission ID, subject, targeted misconception, progressive 3-step question schemas, hints, and completion status. Targeted remediation for learners scoring below 50% on assessments to address specific conceptual errors.
Educator Content & Library Lesson plan titles, ATP references, grade levels, subjects, formatted HTML content, task question text, teacher memorandums, author ID. Classroom task delivery, lesson planning, and voluntary sharing via the community Lesson Plan Library.
Peer Challenges & Leaderboards Challenge UUID, 3-letter pseudonymous player tag (e.g., "SIY"), score, question count, completion time in seconds. Gamified peer revision challenges via shared links without displaying full learner names on scoreboards.
Financial & Transaction Data Learner ID, transaction amount (ZAR), requested credit count, transaction status, proof of payment slip URLs, administrative credit adjustments. Credit allocation, payment verification, financial audit compliance, and reconciliation ledger records.
Transient Session State Temporary WhatsApp conversation states, phone number keys, pending task payloads. Asynchronous message routing and interactive bot navigation (stored in temporary cache with automatic 1-hour expiration).

2.3 Lawful Grounds for Processing Personal Information

Funda Flow processes personal information under the following statutory grounds in terms of Section 11 of POPIA [LEGAL VERIFICATION REQUIRED: Legal counsel confirmation of specific processing ground applications]:

2.4 Role-Based Data Access Matrix

Information Asset Learner Linked Parent Class Teacher School HOD / Principal Circuit / District Manager Public / Unauthenticated
Learner Profile Full (Own) Full (Linked child) Class Scope School Scope Aggregated Only No Access
Raw Worksheet Photos Full (Own) Full (Linked child) Class Scope School Scope No Access No Access
Diagnostic Marks & Feedback Full (Own) Full (Linked child) Class Scope School Scope Aggregated Reports No Access
AI Remedial Mini-Lessons Full (Own) Full (Linked child) Class Scope School Scope Aggregated Reports No Access
Item Analysis Sheets (Excel) No Access No Access Class Scope School Scope District Overview No Access
Task Memorandums No Access No Access Authorized Scope Authorized Scope Authorized Scope No Access
Public Lesson Plan Library View Only View Only View / Publish View / Publish View / Publish View Only (Search)
Peer Challenge Arena 3-Letter Tag 3-Letter Tag 3-Letter Tag 3-Letter Tag 3-Letter Tag 3-Letter Tag Only
Financial / Proof of Payment Own Records Own Records No Access No Access No Access No Access

2.5 Data Subject Rights under POPIA

Under Sections 23 to 25 of POPIA, data subjects (or their competent persons) have the right to:

3. Children's Privacy & Parental Consent Notice

Protection of Children's Personal Information (POPIA Sections 34 & 35): POPIA prohibits the processing of personal information concerning children (individuals under 18 years) unless authorized by a competent person (such as a parent, legal guardian, or an authorized educational institution acting with institutional authority) or permitted by law.

3.1 Account Creation & Onboarding Pathways

Funda Flow provides educational diagnostic services for school learners, including high-school learners. Onboarding operates through several distinct pathways:

  1. Learner Direct Registration: When a learner registers directly, the platform assigns a unique 6-character parent_link_code to facilitate pairing with a parent or guardian.
  2. Parent-Created Accounts: Parents or legal guardians may register directly and link their child's profile to their parental dashboard.
  3. School / Educator-Assisted Onboarding: Where educational accounts are managed via school partnerships or class join codes, the school warrants that it operates under institutional authority to process educational records strictly for curriculum support and academic assessment [LEGAL VERIFICATION REQUIRED: Legal confirmation of school institutional onboarding authority].

3.2 Recording Account & Linkage Events

The platform records account creation timestamps, linked phone numbers, and parent pairing linkages as recorded system events. These technical records document account association within the platform.

3.3 Parental Oversight & Consent Withdrawal

Parents and legal guardians paired with a learner account have the right to:

4. AI Diagnostic Processing & Responsible AI Notice

Funda Flow employs multimodal artificial intelligence to evaluate handwritten school work and provide automated formative feedback.

4.1 Scope of AI Inputs

To generate diagnostic reports, the AI processing pipeline receives:

4.2 Scope of AI Outputs

The AI generates structured diagnostic outputs, including:

4.3 POPIA Section 71 & Human-in-the-Loop Safeguards

Formative Decision Support: AI diagnostic evaluations on Funda Flow function as formative educational aids. Formal academic determinations, grade promotions, official term marks, and institutional academic decisions remain subject to human educator review and authority.

Educators retain the technical capability and institutional responsibility to review, modify, or override AI-generated marks before compiling official school records.

5. User-Generated Content & Funda Flow Library Policy

Funda Flow distinguishes between public community teaching resources and private learner educational records.

5.1 Educator-Created Lesson Plans & Library License

Educators who author and contribute CAPS-aligned lesson plans to the shared Funda Flow Library retain copyright in their original educational content. By voluntarily submitting content to the public Library, the educator grants Funda Flow a non-exclusive, worldwide, royalty-free license limited to:

Educators may edit or delete their contributed lesson plans from the Library at any time through their dashboard.

5.2 Learner Work — Private Educational Vault

Learner handwritten worksheet photos, submitted answers, diagnostic marks, and remedial mini-lessons are private educational records. Learner work is NEVER published to public library collections or indexed for public search.

5.3 Peer Challenge Pseudonymity

Participation in multiplayer revision challenges displays only the participant's chosen 3-letter uppercase player tag (e.g., "TAG") alongside their challenge score and time taken. Full learner profile details are not exposed on public challenge scoreboards.

5.4 Memorandum Access Protection

Formal assessment memorandums uploaded by teachers are technically masked from learner view. Memorandums are accessible only to verified educators and authorized school leadership within their jurisdiction.

5.5 Copyright & Takedown Procedure

If you believe that any material published on the Funda Flow Library infringes your copyright, please submit a written takedown notice to privacy@fundaflow.co.za including: (a) identification of the copyrighted work, (b) URL/location of the infringing material, and (c) your contact information. Funda Flow will promptly investigate and remove infringing content where verified.

6. Third-Party Service Providers & Cross-Border Data Transfers

To operate our cloud infrastructure, authentication, messaging, and AI diagnostic capabilities, Funda Flow engages professional third-party service providers (operators).

6.1 Cloud Infrastructure & Third-Party Services

Operator / Provider Category Primary Service Function Data Processed by Operator Contractual / Security Baseline
Supabase Inc.
[PROVIDER VERIFICATION REQUIRED: Confirm eu-west-2 project region]
Managed PostgreSQL database, user authentication, and secure object storage buckets (math_submission_portal deployed on Supabase infrastructure in West Europe / London, eu-west-2). User account records, encrypted password hashes, submission metadata, worksheet images, transaction logs. Encrypted storage (AES-256 at rest) and secure transit protocols (TLS); binding Data Processing Addenda (DPAs) [PROVIDER VERIFICATION REQUIRED].
Google LLC (Gemini API)
[PROVIDER VERIFICATION REQUIRED]
Multimodal AI vision, OCR text extraction, and diagnostic feedback generation. Worksheet image buffers, grade level, CAPS subject/topic context, rubric guidelines. Enterprise API service terms; data submitted via API is processed for response generation under terms that prohibit foundation model training on customer data [PROVIDER VERIFICATION REQUIRED].
Meta Platforms Ireland Ltd (WhatsApp Cloud API)
[PROVIDER VERIFICATION REQUIRED]
Inbound webhook processing and outbound WhatsApp messaging. User phone numbers, chat messages, menu button interactions. WhatsApp Business terms and data protection addenda; transport layer security.
Redis / In-Memory Cache
[PROVIDER VERIFICATION REQUIRED]
Background job queuing (BullMQ) and temporary session state caching. Transient phone session state, queue identifiers (auto-expiring within 1 hour). Encrypted in-memory caching with strict key TTL expiration policies.

6.2 POPIA Section 72 Cross-Border Data Transfer Framework

In compliance with Section 72 of POPIA, personal data transferred across borders (including to cloud servers located in the European Union and the United States) is protected through [LEGAL VERIFICATION REQUIRED: Legal verification of Section 72 contractual transfer instruments]:

7. Data Retention, Deletion & Security Breach Notice

7.1 Operational, Financial & Tax Record Retention Schedule

Funda Flow retains company, educational, financial, and tax records for the periods required by applicable South African legislation and current operational schedules:

Record Category Retention Period Statutory / Operational Authority
Active User Profiles Duration of active enrollment + 12 months Operational baseline for longitudinal academic tracking until account closure.
Handwritten Worksheet Images 24 months Operational period supporting term moderation and longitudinal error analysis.
AI Mini-Lessons & Diagnostic Logs 24 months (linked to submission records) Tracking remedial mastery across academic school terms.
Company & Financial Ledger Records At least 7 years The Companies Act, No. 71 of 2008 (Section 24), or for any longer period required by applicable law.
Tax-Related Records & Invoices Generally 5 years (with statutory extensions) The Tax Administration Act, No. 28 of 2011 (with longer retention where an audit, dispute, or objection is outstanding).
Transient WhatsApp Session State 1 hour (3,600 seconds) Automatic key expiration in temporary cache for interactive bot navigation.
Security & Audit Logs 12 months Threat detection, access monitoring, and operational security verification.

7.2 Account Deletion Protocol

Users (or linked parents/guardians for minor accounts) may request full account deletion at any time by contacting our compliance team at privacy@fundaflow.co.za. Upon verified request, personal identifiers and active submission records are removed from active databases, subject only to legally required financial audit records.

7.3 Security Compromise Notification (POPIA Section 22)

Funda Flow maintains administrative, technical, and physical safeguards (including Row Level Security, API authentication tokens, and encryption) to protect personal information. In the event of reasonable grounds to believe that personal information has been accessed or acquired by an unauthorized person, Funda Flow will notify the Information Regulator of South Africa and affected data subjects in accordance with Section 22 of POPIA.

8. Commercial Terms, Refunds & Cancellation Policy

This section outlines the commercial terms governing AI study credits, tutor subscriptions, and institutional licenses in accordance with the Consumer Protection Act (CPA), Act 68 of 2008 and the Electronic Communications and Transactions Act (ECTA), Act 25 of 2002.

8.1 Clear Pricing Schedule

Learners & Parents

Free / Pay-As-You-Go
  • Basic web dashboard access is free
  • AI Credits in flexible bundles via EFT/Card
  • Diagnostic homework marking & mini-lessons

Independent Tutors

R300 / month
  • Tutor directory profile listing
  • High-volume worksheet diagnostics
  • Exportable diagnostic PDF reports

Schools & Institutions

R2,000 / month
  • Or R20,000 / year annual license
  • School-wide teacher & learner access
  • Automated CAPS Item Analysis Excel export

Corporate CSI Sponsors

R100,000+
  • Sponsor learner blocks with study credits
  • SED compliance impact reporting
  • Institutional pass rate monitoring

8.2 ECTA Section 43 Supplier Disclosures

In terms of Section 43 of the ECTA, Funda Flow provides the following commercial disclosures:

8.3 Digital Services, Performance and Cooling-Off Rights (ECTA & CPA)

Electronic transactions with Funda Flow are subject to applicable consumer protections under South African law, including the Electronic Communications and Transactions Act, 25 of 2002 (ECTA), and the Consumer Protection Act, 68 of 2008 (CPA).

ECTA section 44 generally provides a seven-day cancellation period for qualifying services, subject to the exclusions contained in section 42(2). These exclusions include circumstances where services commenced with the consumer's consent before the expiry of the applicable cooling-off period.

Where a Funda Flow service is made available or commenced immediately following the user's express request or consent, the applicability of any statutory cooling-off exclusion will depend on the circumstances of the particular transaction and the service provided.

Nothing in these Terms is intended to exclude or limit any consumer right that cannot lawfully be excluded or limited under applicable South African law [LEGAL VERIFICATION REQUIRED: Professional legal confirmation of transaction-specific cooling-off application].

8.4 Technical Errors & Duplicate Payment Reversals

8.5 Direct Marketing & Communications (POPIA Section 69)

Funda Flow distinguishes between essential transactional service communications (e.g. marking results, roadblock alerts, password resets) and promotional direct marketing:

9. PAIA Manual (Section 51 of PAIA)

This section constitutes the Manual for FUNDA FLOW (PTY) LTD as a private body in accordance with Section 51 of the Promotion of Access to Information Act (PAIA), Act 2 of 2000.

9.1 Information Officer Details

Designated Information Officer Dumisa Harkkim Shongwe
Information Regulator Reg. No. [LEGAL VERIFICATION REQUIRED: Official registration number with Information Regulator]
Physical Address 379, Vaalbank A, Mbibane, Mpumalanga, 0449
Postal Address 379, Vaalbank A, Mbibane, Mpumalanga, 0449
Telephone Number 0825715549
PAIA & Compliance Email privacy@fundaflow.co.za

9.2 South African Human Rights Commission / Information Regulator Guide

The Information Regulator has compiled a guide in each official language containing information on how to exercise rights under PAIA. The guide is available from the Information Regulator (inforegulator.org.za).

9.3 Records Held by Funda Flow

Funda Flow maintains the following categories of records:

9.4 Procedure for Requesting Access to Records (PAIA Section 53)

  1. A requester must complete the prescribed Form 2 (available on the Information Regulator website) and submit it to the Information Officer.
  2. The request must provide sufficient detail to enable the Information Officer to identify the requested record and the requester.
  3. The requester must indicate which form of access is required and identify the right they seek to exercise or protect.
  4. The prescribed request fee must be paid before the request is processed (unless the requester is legally exempt).
  5. The Information Officer will decide on the request within 30 days of receipt, unless an extension is applicable under PAIA.

9.5 Grounds for Refusal of Access

Funda Flow may refuse access to records under Chapter 4 of PAIA on mandatory grounds, including the protection of commercial information of a third party, protection of confidential information, protection of personal privacy of an individual, and protection of the safety of individuals or property.

10. Business & Regulatory Contact Details

If you have any questions regarding these policies, need technical support, or wish to submit a POPIA or PAIA inquiry, please contact us:

🏢 Registered Entity FUNDA FLOW (PTY) LTD
📄 Enterprise / Registration No. 2026 / 622547 / 07
🌐 Official Website https://fundaflow.co.za
📧 Compliance & Legal Inquiries privacy@fundaflow.co.za
📱 Phone / WhatsApp 0825715549
📍 Registered Address 379, Vaalbank A, Mbibane, Mpumalanga, 0449
⏰ Operating Hours Mon – Fri: 08:00 – 17:00 (SAST)

Information Regulator of South Africa

Data subjects may lodge complaints regarding personal information processing or PAIA access requests with the Information Regulator:

🏛️ Regulatory Authority The Information Regulator (South Africa)
📧 POPIA Complaints Email POPIAComplaints@inforegulator.org.za
📧 PAIA Complaints Email PAIAComplaints@inforegulator.org.za