Privacy Policy

Effective date: 12 July 2026 · Applies to: Obi beta builds distributed via Apple TestFlight

In this policy, terms such as "responsible party", "operator", "data subject", "personal information", "special personal information" and "processing" carry the meanings given to them in South Africa's Protection of Personal Information Act, 2013 (POPIA).

1. Who we are

Obi is made by Synqa Inc. ("Synqa", "we", "us"), a company incorporated under the Canada Business Corporations Act, with its registered office in North York, Ontario, Canada, and an operating presence in Cape Town, South Africa. Although Synqa is a Canadian company, Obi is built for South African schools, so this policy is written around POPIA.

Questions about this policy, or about anything you have sent to us directly, can be sent to Karl Lee at admin@synqa.ca. Under POPIA, the head of a responsible party is its Information Officer unless another person has been formally designated and registered with the Information Regulator. For the Obi beta, Karl Lee acts as Synqa's Information Officer and can be reached at the same address.

2. What Obi is, and who this policy covers

Obi is a classroom observation and assessment tool for foundation-phase teachers. It is used by teachers and school staff in their professional capacity. It is not directed at children, although the information a teacher records is about learners in their class.

The purpose of the information Obi handles is narrow and single: to help a teacher record and organise their own classroom observations, marks, and report comments for the learners in their class. Obi does not use the information for any other purpose, does not profile learners for Synqa's benefit, and does not sell or share information with third parties.

This policy covers the Obi beta app. It does not cover Apple's TestFlight service, which has its own terms and privacy policy.

Beta data rule: during the beta, testers are required to use fictional learner names or initials only, and must not enter real children's personal information. See the Terms of Use.

3. Information the app handles, on your device only

When you use Obi, the app stores the following in its private storage on your device:

• Class records you create: learner names, per-learner consent status, skill ratings, observation notes (text, date, subject, skill, achievement level), an optional need-to-know note per learner, entered marks (kept only for the current session), and report comments.
• Your profile: your name, school name, class, grade, and term, entered once at setup.
• App state: onboarding and setup progress, and dismissed suggestions.

The app does not collect or store: email addresses, passwords, phone numbers, location, device identifiers, or usage analytics.

Some of what a teacher may record can amount to special personal information or to a child's personal information under POPIA. Observation notes and the optional need-to-know note could, for example, touch on a learner's health, behaviour, or a referral. Because this information is sensitive, it is handled entirely on the device, it is never transmitted to Synqa, and the consent controls in section 7 are built specifically to protect it. During the beta, none of this information should be real (see the beta data rule in section 2).

Two features deserve precise description. Photos: you can attach a photo during capture, but the image itself is never saved by the app, only a marker that a photo was attached. Voice notes: when you tap the microphone, audio is recorded to a file on your device. That recording stays on your device, is never transcribed by any external service, and is never transmitted anywhere.

4. What Synqa receives: nothing

Obi has no backend. There is no sign-in and no account. The app makes no network requests, so nothing you enter is transmitted to Synqa or to anyone else by the app. Our App Store privacy declaration is accordingly "Data Not Collected."

The only information Synqa may receive in connection with the beta is what you choose to send us yourself (for example, feedback emails or TestFlight feedback), and crash reports provided through Apple's TestFlight, which Apple shares only if you opted in with Apple and which are governed by Apple's terms. Any feedback you send us is used only to fix and improve the app.

5. Where your data lives, and how it is protected

• All app data is stored in Obi's private container on your device, protected by your device's built-in encryption (Apple's Data Protection) while the device is locked. Obi does not add its own encryption layer on top, so your data is as secure as your device passcode.
• If you use iCloud or computer backups, your device includes Obi's data in your own backup (encrypted if you use iCloud, or if you enable encrypted local backups), under your own Apple ID. This backup is yours: Synqa has no access to it and no role in it. It is also your only protection against data loss, because Synqa holds no copy.
• Deleting the Obi app deletes all Obi data from your device. A copy may remain in your own device backup until that backup is replaced.

Because no learner information ever reaches Synqa, a security compromise of Synqa's systems cannot expose anything you enter into Obi. The security of the information therefore depends on the security of your device and your school's own device and backup practices. If a device is lost or compromised, that is handled under your school's information-security and incident processes, not by Synqa.

6. When information leaves your device

Only two ways, both requiring your deliberate action, and never automatically:

1. Sharing a learner's record (Settings, then Data): produces a plain-text summary handed to the iOS share sheet. You are warned before sharing that the record is personal information and should only go to destinations your school approves. The optional need-to-know note is never included in this summary.
2. Exporting an observation book as a PDF: generated entirely on your device and handed to the share sheet; the temporary file is deleted immediately after sharing.

Once you share an export, it is outside Obi's control and outside Synqa's control. Share only through channels your school approves.

7. Consent controls built into the app

Each learner has a consent status that you control. This reflects a POPIA reality: processing a child's personal information, and processing special personal information, is restricted, and generally depends on the consent of a competent person (a parent or guardian) obtained by the school, or another lawful basis. Obi does not manage that underlying consent between the school and parents; it gives the teacher a switch that respects it.

While consent is not recorded for a learner, the app pauses all processing of that learner's information: observation capture, group sessions, marks entry, report drafting, and AI suggestions are all blocked with a visible notice until consent is recorded.

Two things deliberately continue to work regardless of consent status, because they are data-subject rights, not further processing: producing a learner's record on request (so a parent or guardian can receive it) and deleting a learner's record. Consent status is never printed in the class observation book. A learner without recorded consent simply appears with blank cells, so their status is not disclosed to anyone who sees the document.

8. AI features

Obi shows suggestions (for example, practice nudges and draft report comments) generated on your device from your own entries. No information is sent to any AI service. Every suggestion cites the evidence it came from and is yours to accept, edit, or dismiss.

These suggestions are decision support, not decisions. Nothing Obi suggests is ever sent to parents or anyone else automatically, and no suggestion is applied to a learner without a teacher choosing it. In POPIA terms, Obi does not subject any learner to a decision based solely on automated processing that produces legal consequences or similarly significantly affects them: a teacher is always in the loop and remains responsible for any assessment, mark, or report they produce. Suggestions are not permanent labels on a child.

9. Roles under POPIA, and children's information

Obi is a tool teachers use to record information about learners under the school's authority and the school's existing consent arrangements with parents and guardians. In POPIA terms, for information recorded in Obi during the beta, the school remains the responsible party for learner information, and the teacher processes it on the school's behalf.

Because Synqa operates no server for Obi and cannot receive, hold, or access any information you enter, our position is that Synqa does not act as a responsible party or as an operator for that information under POPIA during this beta. Synqa is a Canadian company with a South African operation; this policy and this position are drawn up on the basis that no learner information reaches Synqa and that the beta uses fictional data only. Both are characterisations subject to the professional legal review this policy will receive before publication.

Processing children's information and special personal information is subject to specific POPIA protections (including the restrictions in sections 26, 27, 34 and 35 of the Act). The controls in sections 3 and 7 are designed with those protections in mind, and the beta data rule in section 2 means, in practice, that no real learner information should exist in Obi during the beta at all.

This picture changes when Obi adds a server (see section 13). At that point Synqa expects to become an operator for the schools that use Obi, which will require a written operator agreement under section 21 of POPIA, appropriate security safeguards under section 19, and, because Synqa is a Canadian company, attention to the cross-border transfer rules in section 72. None of that applies to this on-device beta, but it is flagged here for transparency.

10. Your rights, and how to exercise them

POPIA gives data subjects rights including access to their personal information, correction or deletion of it, the right to object to processing in certain circumstances, the right not to be subject to a decision based solely on automated processing (see section 8), and the right to complain to the Information Regulator.

Because Synqa holds no personal information from the app, requests about learner records (access, correction, deletion, objection) are fulfilled on the device, by the teacher or school: Obi provides a per-learner export for access requests and a per-learner delete that permanently removes the learner's record and everything derived from it (report comments, marks, suggestions, and drafts). A parent or guardian who wants to exercise a learner's rights should approach the school, which holds and controls the information.

For anything you have sent to Synqa directly (for example, feedback emails), contact Karl Lee at admin@synqa.ca to access or delete it.

You also have the right to complain to the Information Regulator (South Africa):

11. Retention

Records stay on your device until you delete them (per learner, via reset, or by deleting the app). Nothing expires automatically in the beta. Your school's record-keeping obligations, including any statutory retention periods that apply to learner assessment records, govern how long you should retain observation records and when you should delete them. Synqa holds no copy and applies no retention period of its own, because it holds nothing.

12. Device permissions

• Microphone: requested only when you tap the microphone button, never at launch. When you record a voice note, the audio is captured on your device; it is never transcribed by an external service and never leaves the device.
• Camera and photo library: requested only if you attach evidence photos (the image itself is not stored by the app).
• Obi requests no location, contacts, or background permissions.

13. Changes to this policy

The app will change during the beta. In particular, a future version will add accounts and synchronisation to a server hosted in South Africa. That version will not ship under this policy. Before it ships, we will publish a revised policy, put the required operator agreement and security and cross-border measures in place (see section 9), and complete the required privacy review. The fictional-data rule stays in force until all of that is done. Beta testers are notified of policy changes via TestFlight build notes and the in-app legal page.

14. Contact

Synqa Inc. · registered office 2544 Weston Road, Unit 907, North York, Ontario, M9N 2A6, Canada · operating in Cape Town, South Africa

Contact and Information Officer for the Obi beta: Karl Lee, admin@synqa.ca