Contents

  1. Who We Are
  2. Data We Collect
  3. Why We Process Your Data
  4. Lawful Basis (GDPR) & Justification (POPIA)
  5. Third Parties & Data Sharing
  6. International Data Transfers
  7. Data Retention
  8. Cookies & Tracking
  9. Your Rights
  10. Security
  11. Children
  12. Changes to This Policy
  13. Contact & DPO
South African Users: Scholar Africa complies with the Protection of Personal Information Act 4 of 2013 (POPIA). You have rights to access, correct, and delete your personal information. The Information Regulator of South Africa can be contacted at inforeg@justice.gov.za.

1. Who We Are

Scholar Africa is a scholarship discovery and matching platform operated by Vyoma AI Studios. Our platform helps African students find and apply for scholarships worldwide.

Responsible Party / Data Controller: Vyoma AI Studios, operating Scholar Africa at https://scholar.africa.

Data Protection Contact: emailsuryateja.m@gmail.com (acting DPO)

For POPIA purposes, Scholar Africa acts as a responsible party as defined in section 1 of POPIA. For GDPR purposes (EU/EEA users), Scholar Africa acts as a data controller.

2. Data We Collect

2.1 Information You Provide

Data CategorySpecific FieldsWhen Collected
IdentityFirst name, last nameRegistration
ContactEmail addressRegistration
Academic ProfileField of study, academic level (undergraduate/masters/PhD/postdoc), GPA, nationality, country of residenceProfile setup
PreferencesPreferred study destinations, financial need indicatorProfile setup
AuthenticationPassword hash (if email sign-up), Google OAuth tokens (if Google sign-in)Registration
Application ActivityScholarships saved, applied, exploring; application status notesPlatform use
DocumentsAny documents uploaded during scholarship application trackingApplication workflow

2.2 Information Collected Automatically

DataPurposeConsent Required?
IP address (hashed for analytics)Security, fraud preventionNo (legitimate interest)
Browser type, OSCompatibilityNo (essential)
Pages visited, clicks (via GA4)Platform improvementYes (analytics cookie consent)
Session tokensKeeping you logged inNo (essential)
Cookie consent recordCompliance proofNo (legal obligation)

2.3 Special Categories

We do not intentionally collect special-category data (race, health, religion, etc.). Nationality is collected solely for scholarship eligibility matching and is not processed for any discriminatory purpose.

3. Why We Process Your Data

We do not use your data for automated decision-making that produces legal or similarly significant effects on you.

4. Lawful Basis (GDPR) & Justification (POPIA)

Processing ActivityGDPR Lawful BasisPOPIA Justification
Core service, account, matchingContract (Art. 6(1)(b))Contract performance (s. 11(1)(a))
Analytics cookies, marketing emailsConsent (Art. 6(1)(a))Consent (s. 11(1)(a))
Security / fraud preventionLegitimate interest (Art. 6(1)(f))Legitimate interest (s. 11(1)(f))
Legal compliance, audit logsLegal obligation (Art. 6(1)(c))Legal obligation (s. 11(1)(c))

5. Third Parties & Data Sharing

Third PartyRoleData SharedPrivacy Policy
Google Analytics 4Analytics processorAnonymised usage data, hashed IPgoogle.com/privacy
Google OAuth (Sign in with Google)Authentication providerEmail, name, Google profile IDgoogle.com/privacy
Gmail SMTP (via Google)Email deliveryRecipient email, email contentgoogle.com/privacy
Anthropic (Claude API)AI processing (if used for matching)Academic profile data submitted for AI processinganthropic.com/privacy
HostingerWeb hosting / infrastructureAll data stored on Hostinger servershostinger.com/privacy

We do not sell, rent, or trade your personal information to any third party for their own marketing purposes.

We may disclose data to law enforcement or regulatory authorities if required by law, a court order, or to protect the rights and safety of users or others.

6. International Data Transfers

Scholar Africa is hosted in Europe (Hostinger). However, some processors operate outside South Africa and the European Economic Area:

For South African users: transfers outside South Africa are made in compliance with POPIA section 72, which permits transfers where the recipient country provides adequate data protection or where we have implemented appropriate safeguards.

For EU/EEA users: we rely on Standard Contractual Clauses (SCCs) for transfers to the US.

7. Data Retention

Data CategoryRetention PeriodBasis
Account & profile data3 years after last login, then anonymisedLegitimate interest / contract
Application tracking data3 years after account deletionAudit / legal records
Email logs12 months rollingOperational / compliance
Cookie consent records5 yearsLegal obligation (proof of consent)
Security / audit logs5 yearsLegal obligation
Data subject requests5 years from completionLegal obligation

When your account is deleted, personal fields are anonymised (name replaced with "[Deleted User]", email with a hash) rather than hard-deleted, to preserve scholarship application audit integrity. You may request confirmation of this process.

8. Cookies & Tracking

CategoryCookies UsedPurposeCan Opt Out?
Essentialps_session, oauth_state, sa_cookie_consentLogin sessions, CSRF security, consent recordNo — required for the site to function
Analytics_ga, _ga_*, _gid (Google Analytics 4)Page views, user journey, feature usage. IP anonymised.Yes — via cookie banner
MarketingNone currentlyNot in use at this timeN/A

Our cookie banner appears on first visit. You can change your cookie preferences at any time from the "Cookie Preferences" link in the footer.

9. Your Rights

Under POPIA (for South African users) and GDPR (for EU/EEA users), you have the following rights:

To exercise your rights, use the Data Request Portal (when logged in) or email us directly.

Submit a data request:
In-app: scholar.africa/data-request
Email: emailsuryateja.m@gmail.com
We respond to all requests within 30 days (POPIA: 30 days; GDPR: 1 month).

10. Security

We implement appropriate technical and organisational measures to protect your personal information:

In the event of a data breach that poses a risk to your rights and freedoms, we will notify the South African Information Regulator within 72 hours and notify affected users without undue delay, as required by POPIA section 22.

11. Children

Scholar Africa is not directed at children under 18. We do not knowingly collect personal information from anyone under 18 years of age. If you believe we have inadvertently collected data from a minor, please contact us immediately and we will delete it.

12. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will:

Your continued use of Scholar Africa after a policy change constitutes acceptance of the revised policy. If you disagree with changes, you may request account deletion before the effective date.

13. Contact & Data Protection Officer

Data Protection Contact (acting DPO):
Vyoma AI Studios / Scholar Africa
Email: emailsuryateja.m@gmail.com

South African Information Regulator:
Website: inforegulator.org.za
Email: inforeg@justice.gov.za
Tel: 012 406 4818

Response time: We aim to respond to all data subject requests within 30 days.