Beetl is the trading name of Hambrockedugroup (Pty) Ltd, registration 2022/738383/07. Business address: 134 Nicolette Street, Pretoria 0184, South Africa. For privacy enquiries, rights requests and appeals contact Heinzhambrock@gmail.com. For security and support enquiries contact hello@beetl.net. Information Officer: Heinz Hambrock, hello@beetl.net. EU and UK representatives, if required: [COUNSEL: assess applicability and insert appointed representative details or approved explanation].

Beetl determines how it handles website enquiries, business relationships, account administration, billing, platform security and legal obligations. For content, learning records and other personal information that your organisation puts into its workspace, your organisation generally determines the purposes and Beetl processes under its instructions. If your organisation is itself a processor, the ultimate controller may be another organisation. Contact your organisation for workplace, training or publication decisions. We assist it with applicable requests and remain responsible for our own processing.

We obtain information from you, your organisation, its authorised administrators and integrations, service interactions and providers delivering requested functions. This includes:

Identity and access: name, email, authentication credentials in protected form, account identifiers, invitations, memberships, roles, identity-provider subject information, sessions and legal-version acknowledgements. Workspace content: articles and versions, comments, files, images, source/import metadata, search requests, questions and feedback. Content may identify employees, contractors, customers or other people named by the organisation. Learning: assignments, enrolments, attendance/progress events, assessment attempts and responses, results, submitted evidence, certificates, due dates and authorised learning-system transfers. Your organisation determines who may inspect these records and how it uses them; Beetl's certificate is not a guarantee of professional accreditation or employee suitability. AI features: submitted questions/instructions, selected source excerpts, relevant context and feature-specific generated drafts, provenance, outcomes and feedback. Some grounded-answer interaction records omit generated answers, while other features intentionally store generated drafts. There is no blanket promise that all AI inputs/outputs are never stored. Operations and relationships: support messages, business and billing contacts, plan/usage records, delivery events, bounded audit/security records, device/browser/request metadata and cookie choices. Infrastructure may process IP addresses and user-agent information; privacy-reduced analytics does not mean infrastructure sees no IP address. Legal handling: copyright notices/counter-notices, signatures, contact details, material locations, relevant evidence and correspondence. Required details may be sent to the affected parties; this is not an anonymous channel.

We do not need children's information, sensitive/regulated records, passwords in content, payment-card details in support, or unnecessary identity documents. Account users must be adults. Customers must not knowingly upload children's data or prohibited sensitive data. Reports of such data are reviewed for access restriction and appropriate deletion or legal handling.

For Beetl's controller processing, the proposed EU/UK bases below are subject to counsel confirming the precise activity and relationship. Under South African and US law we apply the corresponding applicable grounds and obligations; these bases are not a claim that EU law applies to every person.

Contracting with an individual business subscriber. Purpose: Set up, supply and administer their ordered service. Proposed basis where GDPR applies: Contract necessity.

Employee/business contact account administration and support. Purpose: Operate the employer's service and answer requests. Proposed basis where GDPR applies: Legitimate interests in providing a secure business service; contract only where the individual is actually party to it.

Security, abuse prevention and service diagnostics. Purpose: Protect users/content, investigate faults and misuse. Proposed basis where GDPR applies: Legitimate interests in safe, reliable operation; legal obligation where a specific duty applies.

Invoices, statutory accounting and lawful disclosures. Purpose: Collect agreed fees and comply with applicable law. Proposed basis where GDPR applies: Contract where applicable; legal obligations for required records/disclosure.

Legal acceptance and dispute handling. Purpose: Record agreements and establish/defend legal claims. Proposed basis where GDPR applies: Legitimate interests; legal obligations where applicable.

Optional browsing/search analytics. Purpose: Measure use and improve content/service. Proposed basis where GDPR applies: Consent for the optional tracking described below; any separate non-tracking service diagnostics remain purpose-limited.

Optional marketing, if introduced. Purpose: Send promotional messages. Proposed basis where GDPR applies: Only the separately reviewed permission/basis and opt-out required for the recipient/market; promotional campaigns currently blocked.

Customer-controlled workspace and learning processing follows the customer's documented purposes and lawful bases under the DPA. Merely accepting Beetl's terms does not provide employee consent. We assess legitimate interests against individual rights and provide information about the relevant assessment on request, subject to lawful confidentiality limits.

Core identity/access data is necessary to provide an account; refusing it prevents account operation. Optional analytics and optional feedback are not a condition of core access. Workspace content and learning submissions required by your organisation depend on its rules; it should explain the consequences of not supplying them.

We disclose information to authorised recipients only for the relevant purpose: workspace administrators and members under their permissions; hosting, database, storage, email and enabled AI providers; approved support personnel/advisers; and authorities or parties to legal proceedings where lawfully required. Publicly published content is accessible to its intended public audience and may be indexed or copied by others. Your organisation controls publication; deletion from Beetl cannot guarantee removal of lawful independent copies.

The approved public provider register will identify actual vendors, purposes, processing countries and transfer safeguards: [CONFIRM: final public register URL after provider approval]. Optional customer connectors, identity providers and learning destinations may handle information under their own terms/notices; the customer chooses and authorises them. We do not sell personal information, share it for cross-context behavioural advertising or use workspace content for advertising under the proposed launch scope.

Enabled AI may transmit questions and selected content/context to the approved model provider. We do not authorise training a general-purpose model on customer content. Provider retention, abuse monitoring, support access and countries depend on the approved contract/configuration; no zero-retention or regional-processing assurance is made without evidence. The approved register and AI notice must disclose those facts before enablement. Users should not submit prohibited information in questions.

When a purchase is processed through Paddle, the Paddle entity identified at checkout acts as merchant of record and a separate controller for payment, tax, fraud-prevention and required transaction records under its own Privacy Policy. Payment details are entered into Paddle checkout. Beetl receives the billing contacts, customer and subscription identifiers, plan and payment status, invoice information and masked payment-method details needed to administer the workspace, such as card brand, last four digits and expiry date, not full card numbers or card security codes. Contact Paddle for its payment-data practices and Beetl for the billing records Beetl handles.

Information may be processed where approved providers and authorised personnel operate, including South African operator access and the countries in the completed provider schedule. Proposed Frankfurt hosting and an R2 Western Europe location selection do not establish all processing/backup countries. Before publication insert the verified destinations, lawful transfer grounds and means to obtain a copy of safeguards: [CONFIRM: final destinations, safeguards and privacy contact process]. Where needed, contractual safeguards may include applicable EU SCCs and UK transfer instruments together with appropriate assessments; these must actually be executed. We do not claim South Africa has EU/UK adequacy merely because Beetl is based there.

We retain information only for the relevant purpose, customer instructions and applicable legal obligations. Proposed production limits must match verified configuration before this notice is used. The detailed retention schedule distinguishes current code from unapproved targets.

Sign-in sessions are configured to expire after seven days. Workspace retention defaults are 365 days for optional analytics, 730 days for article feedback and 90 days for stored AI questions; authorised owners can change those retention settings. These defaults do not establish a fixed deletion deadline for every copy or data category. Generated content and provenance follow their feature/content lifecycle, not necessarily the question period. Learning responses, evidence and certificates have distinct rules; an advertised generic progress period is not a guarantee of complete learning-record erasure. Customer content/versions normally remain for the workspace lifecycle until deletion. Article soft deletion has a 30-day recovery period.

The proposed production policy is a 30-day offboarding/export opportunity, active deletion within 30 days after confirmed deletion and backup expiry within 90 days after active deletion, subject to earlier legal requirements. Operational support, security logs, legal case records and statutory records require the approved category-specific periods in the schedule before publication: [CONFIRM: final periods and legal bases]. Restricted legal retention is isolated and used only for the retained purpose. Restored backups have outstanding deletions reapplied. We may keep genuinely anonymised statistics that no longer identify a person.

Cookie preferences control optional browsing/search analytics separately from terms acceptance. You can change or withdraw them through Cookie preferences; withdrawal stops subsequent optional collection and does not itself delete existing records. Choices apply per browser/hostname, including customer Reader domains. Essential security/service storage remains necessary. No session replay or optional advertising SDK is part of the proposed launch.

Depending on applicable law and context, you may request access/confirmation, correction, deletion, restriction, portability, objection or withdrawal of consent, and exercise applicable US rights including an appeal of a denied request. For direct marketing, you may object or unsubscribe without charge. You will not receive unlawful discrimination for exercising rights. An authorised agent may act where law permits; we verify authority and identity proportionately and avoid requesting unnecessary documents. We respond within the applicable legal period, explain permitted extensions or refusals and provide an appeal route where required. Send privacy requests and appeals to Heinzhambrock@gmail.com. Rights are not absolute and lawful retention/exemptions may apply.

For organisation-controlled data we refer the request to the relevant controller and assist it; this does not prevent you contacting us about our own processing. Workplace administrators may access your activity and learning records under their permissions. Ask your organisation how this affects employment decisions, retention and any employee consultation obligations.

You may complain directly to the South African Information Regulator, the UK ICO, your competent EU supervisory authority or the relevant US authority as applicable; contacting Beetl first is optional. The approved notice will link to the current authority contact pages. We do not use solely automated decisions about individuals with legal or similarly significant effects under the proposed scope. AI and assessment outputs require human review; a customer's separate use of records for employment decisions is governed by its own duties.

We use access controls, tenant isolation and other verified safeguards described in the approved security schedule. No online service is perfectly secure. Report suspected compromise to hello@beetl.net. We publish material changes with a new date/version and appropriate notice. Account acknowledgement records notice delivery and, separately, terms acceptance; it does not make optional processing compulsory or waive your rights.