Last Updated: 27 December 2025
Effective Date: 1 January 2026
1. Introduction
Welcome to Primary Online Learner™ (“POL,” “we,” “us,” or “our”). We are committed to protecting the privacy and security of the personal information of our learners, applicants, and website visitors. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you interact with our services, including our online learning platform, scholarship applications, and website.
By submitting information to us via email (e.g., ceo@clad.co.zw), our online forms, or any other channel, you consent to the practices described in this policy.
2. Information We Collect
We may collect the following types of information:
A. Information You Provide Directly:
- Scholarship & Application Data: Name, date of birth, contact details (email, phone number, address), educational background, financial information, and personal statements submitted during the scholarship application process.
- Enrolment & Account Data: Information provided when registering for our programmes, including parent/guardian and learner details.
- Communication Data: Records of correspondence when you contact us via email, social media, or other methods.
- Technical Prerequisites Confirmation: Confirmation of access to a stable internet connection and suitable device.
B. Information Collected Automatically:
- Usage Data: When you visit our website or platform, we may collect data such as IP address, browser type, pages visited, time spent, and referring URLs.
- Cookies & Tracking Technologies: We may use cookies and similar technologies to enhance user experience and analyse trends. You can control cookie settings through your browser.
C. Information from Third Parties: We do not actively buy data, but may receive information from partners or educational institutions with your consent, where applicable.
3. How We Use Your Information
We use the collected information for the following legitimate business and educational purposes:
- To process, evaluate, and administer scholarship applications, including communication for interviews and notifications.
- To provide, manage, and improve our Cambridge Curriculum online learning services.
- To communicate with learners and parents/guardians regarding programmes, updates, and administrative notices.
- To ensure compliance with our Terms and Conditions and programme requirements.
- For internal analytical purposes to improve our services, website, and marketing strategies.
- To comply with legal obligations and protect the rights, property, or safety of POL, our users, or others.
4. Legal Basis for Processing (GDPR Compliance Note)
For users in regions governed by the General Data Protection Regulation (GDPR), our processing is based on:
- Performance of a Contract: To provide the educational services you enrol in.
- Legitimate Interests: For scholarship evaluations, communications, and service improvement.
- Consent: Where required by law, we will obtain explicit consent for specific processing activities (e.g., marketing emails).
- Legal Obligation: To comply with applicable laws.
5. How We Share and Disclose Information
We value your privacy and do not sell, trade, or rent your personal information to third parties for marketing purposes. We may share information only in the following circumstances:
- With Service Providers: Trusted third-party vendors who assist in operations (e.g., email service providers, cloud hosting, form processors) under strict confidentiality agreements.
- For Legal Reasons: If required by law, subpoena, or legal process, or to protect our rights, property, or safety.
- With Your Consent: When you have given explicit permission for a specific disclosure.
- Scholarship Announcements: With your prior consent, we may publicly announce the names of scholarship winners on our social media or website.
6. Data Security
We implement appropriate technical and organisational measures (including encryption, access controls, and secure servers) to protect your personal data from unauthorised access, alteration, disclosure, or destruction. However, no electronic transmission or storage method is 100% secure, and we cannot guarantee absolute security.
7. Data Retention
We retain personal information only for as long as necessary to fulfil the purposes outlined in this policy, unless a longer retention period is required or permitted by law.
- Scholarship Application Data: For unsuccessful applicants, data is typically retained for 12-24 months for record-keeping and potential future opportunities, unless deletion is requested.
- Learner Data: Retained for the duration of enrolment and a reasonable period thereafter for academic records and support.
- Marketing Data: Retained until consent is withdrawn or you opt-out.
8. Your Rights and Choices
Depending on your location, you may have the following rights regarding your personal data:
- Right to Access & Portability: Request a copy of the data we hold about you.
- Right to Rectification: Request correction of inaccurate or incomplete data.
- Right to Erasure (“Right to be Forgotten”): Request deletion of your data, subject to legal limits.
- Right to Restrict or Object to Processing: Object to certain uses of your data.
- Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time.
- Opt-Out of Communications: You can unsubscribe from marketing emails by using the link provided in the email.
To exercise these rights, please contact us at: privacy@clad.co.zw.
9. International Data Transfers
POL is based in Zimbabwe. If you are accessing our services from outside Zimbabwe, please note that your information may be transferred to, stored, and processed in Zimbabwe, where data protection laws may differ. By using our services, you consent to this transfer.
10. Children’s Privacy
Our services are directed at primary school-aged learners. We collect information about children only with explicit consent from a parent or legal guardian. If you believe we have collected a child’s information without proper consent, please contact us immediately so we can take appropriate action.
11. Third-Party Links
Our website or communications may contain links to third-party sites (e.g., Cambridge resources). This Privacy Policy does not apply to those sites. We encourage you to review the privacy policies of any third-party sites you visit.
12. Changes to This Privacy Policy
We may update this policy periodically to reflect changes in our practices or legal requirements. The updated version will be posted on our website with a revised “Last Updated” date. We encourage you to review this page regularly.
13. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Data Protection Officer at:
Primary Online Learner™ (POL)
Email: admin@clad.co.zw
Postal Address: 400 Engineering, Highfield, Harare
This policy is designed to be compliant with core principles of major privacy regulations like the GDPR and CalOPPA. For a legally binding policy, we recommend review by a legal professional in your jurisdiction.