Privacy Policy
Effective date: 17 October 2026
Version: 1.0
We are reviewing this document with Zimbabwean legal advisers. Any changes will be published here with a new version number and effective date, with notice where it is required.
1. Who we are
Tendao is operated by Snaprise Investments (Private) Limited, registered in Zimbabwe, under the Companies and Other Business Entities Act [Chapter 24:31] under registration number 41932A0252025, with its business address at Calder Gardens, Unit 29, 87 Tongogara Avenue, Harare, Zimbabwe.
For privacy questions, contact privacy@tendao.co.zw. Our designated privacy contact is our Data Protection Officer. If a Data Protection Officer has been appointed, the officer’s contact details are privacy@tendao.co.zw, or by post to the address above.
This policy covers the Tendao website, enquiries and services operated by that entity. A school’s own privacy notice also applies to information the school determines how and why to process.
2. Our role and the school’s role
A data controller decides why and how personal information is processed. A processor handles information on a controller’s documented instructions.
| Context | Responsibility |
|---|---|
| Website enquiries, our business administration and our own legal obligations | Tendao is generally the controller for these purposes. |
| School pupil records, attendance, marks, assignments, fee records and school-directed communication | The school is generally the controller and Tendao generally acts as its processor under the school agreement. |
| AI used within an agreed school workflow | Roles depend on the actual workflow and providers; the school agreement and provider register identify them. |
| An external service you choose to visit, such as WhatsApp | That service may process information under its own terms and privacy notice. |
Roles depend on actual conduct, not a label alone. If Tendao determines a separate purpose, we must identify it and the relevant responsibilities before processing for that purpose.
A parent or pupil may need the school to decide a request concerning the school’s records. You may still contact Tendao; we will help route the request appropriately and handle our own responsibilities.
3. Information we handle
The information depends on how the school and user use the service.
| Category | Examples | Source |
|---|---|---|
| Enquiry information | Name, work contact, school, role, approximate enrolment and enquiry text | You or an authorised colleague |
| Account information | Name, role, school association, contact details and account settings | School administrator or user |
| Pupil and parent records | Pupil identifiers, class, subjects and verified parent or guardian relationships | School, parent or authorised user |
| Learning records | Attendance, assignments, submissions, marks, feedback, reports and schemes of work | Staff and pupils |
| Financial records | School fee charges, invoices, recorded payment method, receipts and balances | School bursar or authorised integration |
| Communications | School messages, recipient details and applicable delivery or interaction records | School and communication providers |
| AI interactions | Questions, uploaded working, responses and school context used by an enabled feature | User, school and approved AI workflow |
| Support information | Contact details, issue description and necessary diagnostic information | User, authorised school contact and support systems |
| Technical information | IP address, browser/device information, service events and security logs included in the verified processing inventory | Device or service operation |
Some educational, financial and other school information is sensitive under Zimbabwean law. Free text and uploaded files can also reveal sensitive information.
Do not send unnecessary health details, identity documents, passwords, bank-card security information or information about another person through a general enquiry or AI prompt.
Direct payment-provider processing, if offered, must be disclosed separately. A recorded payment method does not establish that Tendao receives full card details.
4. Why information is used
We use information for the following agreed purposes:
- Responding to enquiries and arranging relevant walkthroughs.
- Creating and maintaining authorised accounts.
- Providing the school workflows included in the agreement.
- Processing a school’s lawful instructions, including authorised communications.
- Providing enabled AI assistance within the approved school workflow.
- Resolving support requests and investigating faults.
- Protecting accounts, records and service integrity.
- Administering Tendao’s school subscriptions, invoices and legal obligations.
- Sending optional business updates to adults who choose to receive them.
- Meeting lawful requests and handling disputes.
We do not treat a privacy-policy acknowledgement as blanket permission for unrelated processing. We do not sell identifiable school information, use it for targeted advertising or use it to train general-purpose AI models.
We do not reuse identifiable pupil work or conversations for an independent product-development purpose merely because they were entered into Tendao.
5. Lawful grounds and choices
The responsible controller must identify a lawful ground for each purpose under applicable law, including the additional conditions relevant to sensitive information and children.
For Tendao’s own processing, the assessed grounds are:
| Purpose | Assessed lawful ground or permission |
|---|---|
| Enquiry response and requested walkthrough | Your consent, which the Act allows to be implied when an adult contacts us about Tendao (section 10(1) and (2)) |
| Business account and subscription administration | The consent of the school’s authorised representative in entering the agreement, and our legitimate interests in running it (sections 10(2) and 10(3)(e)) |
| Necessary service security and misuse investigation | Our legitimate interests in keeping Tendao and schools’ records secure, and preserving evidence of an offence where one is suspected (sections 10(3)(e) and 10(3)(a)) |
| Accounting, legal obligations and lawful requests | Compliance with a legal obligation, such as keeping tax records under the Income Tax Act and the Value Added Tax Act (section 10(3)(b)) |
| Optional marketing to adult business contacts | Specific opt-in, subject to the applicable rules |
| Non-essential website technologies | Not applicable: this website sets none |
For school-directed processing, the school identifies and records the ground in its notices and processing arrangements. Tendao must follow lawful documented instructions and cannot rely on an invalid school instruction to justify processing.
Where consent is the ground, it must meet the applicable standard and may be withdrawn. Withdrawal does not automatically erase records that must lawfully be retained or invalidate earlier lawful processing. We or the school will explain the consequences for the affected feature and any available alternative.
6. Children and guardian involvement
Tendao is used by schools that hold records of children. The commercial subscription is arranged with an authorised adult school representative, not with a child.
The school must give understandable information to parents, guardians and pupils, verify the relevant authority and obtain and record written parent or guardian consent where required before children’s information is processed. Any exception must have a documented legal basis and satisfy any required regulatory steps.
Optional AI tutoring and optional marketing permissions must not be hidden within a general acknowledgement. The current advertised pupil tutoring range is Form 1 to Upper 6, subject to school enablement and the required authority.
We do not offer targeted advertising to pupils. We do not authorise solely automated decisions affecting children’s rights.
7. AI information
When an approved AI feature is used, relevant prompts, attachments and limited school context are processed by our AI provider, Anthropic, in the United States. Anthropic acts on our instructions under its commercial terms and does not use this information to train its models. The AI features stay off until the school’s administrator switches them on.
Teachers and school administrators can review pupil-tutor conversations as described in the enabled product. Conversations should not be treated as private from the school, or as continuously monitored by a person.
The provider register and school processing agreement must identify the actual provider, purpose, processing locations, retention and model-training restrictions. These details are not established merely by describing the feature as “AI.”
AI output can be wrong. The school and teacher remain responsible for appropriate human review of consequential decisions and suggested marks. See how the AI help works.
8. Who may receive information
Information is shared only for an identified, lawful purpose with an appropriate recipient. Depending on the workflow, recipients may include:
- Authorised users at the same school, according to their roles and verified relationships.
- Approved hosting, storage, communications, support and AI providers.
- Tendao personnel or contractors who need access for an authorised service task and are bound by confidentiality duties.
- Professional advisers where necessary for an identified business or legal matter.
- A regulator, court or other body where disclosure is legally required or otherwise lawfully justified.
- A successor organisation in a lawful business transfer, subject to appropriate safeguards, notice and existing restrictions on school information.
A business transfer does not itself permit incompatible reuse of pupil information. Cross-school disclosure is not authorised merely because both schools use Tendao.
9. Processing locations and international transfers
Primary application and database locations: Amazon Web Services, Cape Town region (af-south-1), South Africa.
File and backup locations: Amazon Web Services, Cape Town region (af-south-1), South Africa.
Support-access locations: Zimbabwe.
Some providers process information outside South Africa and Zimbabwe: Anthropic in the United States for enabled AI features, and the SMS and WhatsApp providers a school switches on for messages to parents, including Meta for WhatsApp. Transfers out of Zimbabwe are made under sections 28 and 29 of the Cyber and Data Protection Act.
We assess international processing before enabling it and put the required legal, contractual and technical protections in place. The school and Tendao must complete applicable notification or authorisation steps, including additional requirements relevant to children’s information.
A statement that a provider is “global” does not replace location information. Acceptance of these terms is not blanket consent to transfer information to any country.
10. Retention
Information is kept for the relevant purpose and applicable legal requirements, rather than indefinitely.
| Category | Retention rule |
|---|---|
| Unconverted enquiries and walkthrough requests | 12 months after our last contact |
| Tendao’s subscription, billing and legal records | 6 years after the end of the tax period they relate to, as the Income Tax Act and the Value Added Tax Act require |
| Active school operational records | School’s approved schedule: kept for as long as the school’s subscription is active, unless the school instructs otherwise; a pupil’s records are not deleted when they leave a class or the school |
| Pupil-tutor and other AI interaction records | Kept with the school’s records for as long as its subscription is active, including provider copies |
| Security and activity logs | 12 months |
| Support tickets and attachments | 24 months after the request is closed |
| Marketing preferences and minimal suppression records | Until you withdraw permission; after that, only the contact detail needed to keep you off our lists |
| Active records after school service ends | Export window 90 days; active deletion within 30 days after that window ends, or earlier on a lawful school instruction, except identified lawful retention |
| Residual backups | Expire within 35 days under the verified schedule |
The school may have separate legal duties to retain educational or financial records. Closing a user’s account or leaving a school does not automatically erase those records.
A necessary legal hold may pause deletion for an identified record. Access and use remain restricted. We explain the applicable basis and limits when responding to a request.
11. Security and incidents
We use appropriate organisational and technical measures for the actual risks. Our verified public summary is set out on Your school’s data.
No online service can remove every risk. Users should protect their accounts and report suspected exposure promptly through security@tendao.co.zw.
When a personal-information incident occurs, we assess it, take containment steps and make the notifications required of us, including notifying POTRAZ within 24 hours as section 19 of the Cyber and Data Protection Act requires. Where acting as processor, we notify the school’s designated contact without undue delay and cooperate so that the school can meet its own obligations. We do not wait for a complete investigation before providing available initial information.
We do not claim independent certification, a particular encryption standard, constant human monitoring or a specific uptime level unless it is expressly documented.
12. Rights and requests
Depending on the information and applicable law, you may ask to:
- Be told how your information is used.
- Access your information.
- Correct false or misleading information.
- Object to processing where the law provides that right.
- Request deletion where the applicable conditions are met.
- Withdraw consent for processing that relies on consent.
- Stop optional Tendao marketing.
Contact privacy@tendao.co.zw to make a request.
We may need proportionate information to verify identity and authority. Do not email a full identity document unless we explain why it is necessary and provide a suitable method.
Requests involving school records may require a decision by the school. We assist with the relevant steps. We will not disclose another person’s information simply because it appears in the same document.
If a request cannot be met in full, the responsible party should explain the lawful reason and available options within applicable time limits. This policy does not promise an unconditional right to erase required records or a universal right to data portability.
13. Cookies, optional updates and external links
This website does not use analytics, advertising or tracking cookies. If that changes, we will say which technologies are used and offer a choice before any optional ones are set.
Optional Tendao marketing is separate from operational school communication. You can withdraw optional marketing permission without using the school’s messaging preferences as a substitute.
If you choose to use WhatsApp or another external service, its own policies may also apply. We do not control that service merely because our website links to it.
14. Complaints
Contact privacy@tendao.co.zw with a concern about Tendao’s processing. You may contact the school’s privacy representative about school-controlled records.
You may also complain directly to the relevant regulator. In Zimbabwe, the designated Data Protection Authority is POTRAZ. Use its official website for current complaint channels.
You do not have to give up a regulatory complaint or another lawful remedy to contact us first.
15. Changes and contact
We update the version and effective date when this policy changes. Material changes will be communicated in an appropriate way. A new purpose requiring consent or other authority will be addressed before processing for that purpose.
Privacy contact: our Data Protection Officer
Email: privacy@tendao.co.zw
Address: Calder Gardens, Unit 29, 87 Tongogara Avenue, Harare, Zimbabwe
Tendao is provided by Snaprise Investments (Private) Limited, company number 41932A0252025, Calder Gardens, Unit 29, 87 Tongogara Avenue, Harare, Zimbabwe. See also our Terms of Service and Privacy Policy.
