Legal Document

Privacy Policy

Effective: 1 March 2026 Last updated: 17 May 2026 Jurisdiction: South Africa Governing law: POPIA Act 4 of 2013

Important: ChromeWatch processes the personal information of students, including children under 18. We take this responsibility seriously. This policy explains exactly what we collect, why, and how it is protected under South Africa's Protection of Personal Information Act (POPIA).

01

Who We Are

ChromeWatch is a SaaS platform operated by ChromeWatch, a South African technology platform. ChromeWatch provides centralised web browsing monitoring for schools and educational institutions that manage Google Workspace for Education environments.

In this policy, "ChromeWatch", "we", "us", and "our" refer to ChromeWatch and its operating team. "You" refers to the school, IT administrator, teacher, or parent using the platform, and by extension the students whose data is processed through it.

Operator (Data Processor)

ChromeWatch

admin@chromewatch.co.za

chromewatch.co.za

Platform

ChromeWatch

chromewatch.co.za

South Africa

02

What This Policy Covers

This Privacy Policy applies to all personal information processed by the ChromeWatch platform, including:

This policy does not cover websites or services operated by third parties, including Google (whose services are used for authentication). Please refer to Google's own Privacy Policy for information on how Google handles your data.

03

What Data We Collect

ChromeWatch collects two categories of data:

3.1 — Student Browsing Data (via the Chrome extension)

Data pointDescriptionExample
URLThe full web address of each page visitedhttps://example.com/page
Page titleThe title of the visited page as shown in the browser tabChapter 4 — Science Notes
TimestampThe date and time the page was visited2026-03-01 09:14:32
Google account emailThe school-issued Google Workspace email of the signed-in studentadmin@chromewatch.co.za

ChromeWatch does not collect passwords, page content, keystrokes, screenshots, location data, or any information beyond the four fields listed above. See section 3.3 for DNS data collected separately where the ChromeWatch DNS resolver is deployed.

3.2 — Staff Authentication Data (for dashboard access)

Data pointDescription
Google account emailThe email address of the school staff member used to log into the ChromeWatch dashboard via Google OAuth
Session tokenA temporary session token stored in the browser to keep staff logged in. Automatically cleared on logout or session expiry.

No passwords are stored by ChromeWatch. All authentication is handled by Google OAuth 2.0.

3.3 — Network DNS Query Data (where DNS resolver is deployed)

Where a school deploys the ChromeWatch DNS resolver on their network, ChromeWatch additionally collects DNS query data from devices on that network. This data is collected at the network level and is not tied to a Google account — it is recorded per source IP address. Linking a DNS event to a specific student requires correlation with the school's own DHCP or device management records, which ChromeWatch does not hold.

Data pointDescriptionExample
TimestampThe date and time of the DNS query2026-05-17 09:14:32
Source IP addressThe local network IP address of the device that made the query192.168.1.45
Domain queriedThe hostname the device looked upexample.com
Query typeThe DNS record type requestedA, AAAA
CategoryAn automatically assigned content category for the domainEducation, Social Media
Client domainThe school domain the query is associated withschool.co.za

DNS data captures queries from any device on the school network using the ChromeWatch DNS resolver — including school-managed Chromebooks, staff devices, BYOD phones, tablets, and network-connected equipment. It does not capture page content, URLs, search terms, or any payload beyond the domain name queried. DNS data is accessible to school IT administrators and principals only — it is not accessible via the parent portal.

04

Why We Collect It

ChromeWatch collects and processes browsing data for the following specific, lawful purposes only:

ChromeWatch data is never used for advertising, profiling, or any commercial purpose beyond the school monitoring service described above. We do not sell, rent, or share student data with any third party for commercial purposes.

05

Our Role Under POPIA

South Africa's Protection of Personal Information Act (POPIA) distinguishes between two roles in any data processing relationship:

RoleWhoResponsibility
Responsible PartyThe SchoolThe school determines the purpose of monitoring, obtains parental consent, and is accountable to parents and the Information Regulator for the lawful use of ChromeWatch.
OperatorChromeWatchChromeWatch processes data on the school's behalf, under a written Data Processing Agreement, and may not use the data for any purpose beyond what the school has authorised.

Each school that uses ChromeWatch must sign a Data Processing Agreement (DPA) with ChromeWatch before any data is collected. This is a legal prerequisite under Section 21 of POPIA.

06

Legal Basis for Processing

ChromeWatch operates under the Acceptable Use Policy (AUP) signed by parents each year. By signing the AUP, parents acknowledge and consent to the monitoring of browsing activity on school-managed devices. This annual consent forms the lawful basis for processing under POPIA.

07

How We Store & Protect Data

ChromeWatch implements the following technical and organisational security measures in compliance with Section 19 of POPIA:

08

How Long We Keep Data

In accordance with Section 14 of POPIA, personal information is not kept for longer than is necessary for the purpose for which it was collected.

Data typeRetention periodHow it is deleted
Student browsing data90 days from collectionAutomated deletion by the ChromeWatch server
Network DNS query data90 days from collectionAutomated deletion by the ChromeWatch server
Staff session tokensDuration of the browser sessionCleared on logout or session expiry
Authorised user recordsDuration of the school's subscriptionDeleted when the school's account is closed

On cancellation of a school's subscription, all associated data is permanently deleted within 30 days. Schools may request a full data export before cancellation at no charge.

09

Who Can Access the Data

Access to student browsing data is strictly limited to the following authorised parties:

Network DNS query data is accessible to school IT administrators and principals only. It is not accessible via the parent portal, as DNS data is recorded per device IP address rather than per named student account.

No student data is accessible to any other school, third party, advertiser, or external organisation under any circumstances.

10

Children's Data

ChromeWatch is designed specifically for educational environments where the majority of data subjects are children under the age of 18. We recognise that children's personal information carries the highest level of protection under POPIA (Sections 34 and 35), and we apply additional safeguards accordingly.

ChromeWatch does not collect names, ID numbers, physical addresses, photographs, biometric data, or any other special personal information as defined by POPIA. The only personal identifier collected is the student's school-issued Google Workspace email address.

11

Your Rights Under POPIA

POPIA grants data subjects — and parents or guardians acting on behalf of children — the following rights:

Right of Access

Request a copy of the personal information ChromeWatch holds about your child.

Right to Correction

Request that inaccurate or incomplete personal information be corrected or updated.

Right to Deletion

Request deletion of your child's personal information, subject to any legal retention obligations.

Right to Object

Withdraw consent or object to the processing of your child's personal information at any time.

Right to Complain

Lodge a complaint with the Information Regulator of South Africa if you believe your rights have been violated.

Right to Security

Expect that your child's data is protected with appropriate technical and organisational security measures.

To exercise any of these rights, contact your school's IT administrator in the first instance. For matters unresolved at school level, contact ChromeWatch at admin@chromewatch.co.za.

Information Regulator of South Africa: justice.gov.za/inforegadmin@chromewatch.co.za

12

Data Breaches

In the event of a security compromise affecting personal information, ChromeWatch will:

Schools, as Responsible Parties, are required under POPIA to notify the Information Regulator and affected parents or students within a reasonable time after becoming aware of a breach.

13

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in the ChromeWatch platform, applicable law, or our data practices. When we make material changes, we will:

Continued use of ChromeWatch after the effective date of any changes constitutes acceptance of the updated policy. Schools who do not accept the updated terms may cancel their subscription and receive a full data export in accordance with Section 8 of this policy.

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