Privacy Policy
Last updated: 20 September 2026
This Privacy Policy explains how SP Leaders (Pvt) Ltd of 62/13 Udumulla Road, Battaramulla, a company incorporated under the Companies Act No. 7 of 2007 of Sri Lanka, trading under the brand and website "MurphyLearn" ("MurphyLearn", "we", "us"), collects, uses, shares, and protects personal data when you use the MurphyLearn website and platform (the "Platform").
This Policy forms part of, and should be read together with, our Terms of Use. Capitalised terms not defined here have the meaning given in the Terms of Use.
1. Who This Policy Applies To
MurphyLearn is used by Students (including students under 18), Parents/Guardians, Tutors/Teachers, and Schools/Institutions. This Policy applies to personal data we collect from or about all of these users.
If you are a parent or guardian, this Policy explains what we collect about your child, how you can see it, and how you can request its correction or deletion — see Section 8.
2. Information We Collect
2.1 Information you give us directly
- Account information: name, date of birth or age band (where collected), email address, phone number, school/grade or exam stream, and account type (Student, Parent, Tutor, School).
- Uploaded content: photographed or scanned answer scripts, written responses, and any other material you upload for marking, feedback, or practice purposes.
- Payment information: billing name and contact details. We do not collect or store your full card number — payment card and bank transfer details are collected and processed directly by our payment gateway, PayHere, under its own privacy and security terms. We also store payment tokens supplied by the processor, card-expiry information where supplied, and transaction records to administer subscriptions, process authorised payments and handle payment disputes.
- Communications: messages you send to our support team, survey responses, or feedback you provide.
2.2 Information collected automatically
- Usage data: pages and features accessed, questions attempted, time spent, marks and scores, login times, and general activity patterns on the Platform.
- Device and technical data: IP address, browser type, device type, and operating system, collected for security, troubleshooting, and analytics purposes.
- Cookies and similar technologies: we and our marketing/analytics partners (which may include Google, Meta/Facebook, and TikTok, used for advertising and site analytics as described in Section 5) use cookies and pixels to remember your preferences, understand how the Platform is used, and measure the effectiveness of our marketing campaigns. You can control cookies through your browser settings; disabling some cookies may affect Platform functionality.
2.3 Information shared through linked accounts
When a Student account is linked to a Parent, Tutor, Teacher or School account, the linked account may access learning-progress information according to its role and the permissions associated with the link. This may include scores, recent attempts, subject performance, study activity and exam-readiness indicators.
Parent Guide. Where this feature is available, linked parents or guardians may receive AI-generated guidance based on additional learning summaries, including estimated topic mastery, patterns of mistakes, confidence compared with answer accuracy, revision activity and the frequency of AI tutor use. These summaries do not give parents access to the student's private AI tutor chat history. AI processing is described in Section 4.
Email summaries and your choices. Linked parents or teachers may enable weekly progress emails. Students can stop these emails independently of allowing access within the Platform, and can revoke parent or teacher monitoring links through their family settings.
Revoking a link stops new access to learning records through that link. It does not recall emails already delivered or automatically erase previously generated reports or Parent Guide conversations. Your rights concerning retained personal data are described in Section 9.
3. How We Use Information
We use personal data to:
- Create and administer accounts, and authenticate logins;
- Provide the core Platform features: practice exams, Upload & Mark, progress tracking, and dashboards visible to linked accounts;
- Process payments and manage subscriptions;
- Communicate with you about your account, service updates, or support requests;
- Improve and develop the Platform, including analysing aggregate usage trends;
- Detect, prevent, and address fraud, abuse, or security issues;
- Market our services to prospective users (e.g., through Facebook, Google, or TikTok advertising), where you have not opted out and in line with applicable advertising and data protection rules;
- Comply with legal obligations.
We do not sell your personal data to third parties.
4. AI-Assisted Learning and Support
MurphyLearn uses AI services to support learning and provide features such as automated marking and feedback, explanations, tutoring, personalised study recommendations, voice-based coaching, guidance for linked parents or guardians, and assistance with using the Platform.
Depending on the features available and those you use, we may process your answers, messages, uploaded documents, voice inputs and transcripts, relevant learning and activity information, and information shared through linked accounts. We use this information to generate responses, assess answers, provide relevant guidance and maintain continuity within AI-assisted interactions.
We use different third-party AI providers and related processing services for these purposes. Information relevant to the feature is transmitted through their APIs for processing on our behalf. Where a feature involves document retrieval or saved conversation memory, documents or interaction information may also be stored to support that feature, subject to the retention arrangements described in this Policy.
We do not use uploaded content to train or fine-tune general-purpose AI models. We may use learning-performance data to evaluate and improve MurphyLearn's educational features and models, subject to the safeguards and legal basis applicable to that processing. We require AI service providers to process information we submit under contractual terms that prohibit its use to train or improve their general-purpose models.
AI-generated marks, feedback, explanations and recommendations may contain errors. They are intended to support learning and should not be treated as official examination results or a substitute for appropriate human judgment. See Section 4.2 of our Terms of Use.
5. Who We Share Information With
We share personal data only as needed to operate the Platform:
- Linked accounts: as described in Section 2.3, with Parent, Tutor, or School accounts a Student account is linked to.
- Payment processor: PayHere, to process subscription payments.
- AI and related service providers: to provide AI-assisted learning, marking, tutoring, voice processing, document retrieval and support features, as described in Section 4.
- Hosting and infrastructure providers: to store data and run the Platform securely.
- Analytics and advertising partners: Google, Meta/Facebook, and TikTok, for site analytics and advertising, where cookies/pixels are active (see Section 2.2).
- Professional advisers and authorities: where necessary to comply with law, respond to legal process, or protect our rights, safety, or property, or that of our users.
- Business transfers: if MurphyLearn is involved in a merger, acquisition, or asset sale, personal data may be transferred as part of that transaction, subject to this Policy or a policy offering at least equivalent protections.
We require third parties who process personal data on our behalf to protect it and use it only for the purposes we specify.
6. International Data Transfers
Some of our service providers (including our AI provider and certain hosting or analytics services) may process personal data on servers located outside Sri Lanka. Where this occurs, we take reasonable steps to ensure the data continues to be protected in a manner consistent with this Policy.
7. Data Retention
While your account remains open. We retain your account information, learning records and full chat history to provide the Platform, preserve your learning history and maintain continuity in your conversations, subject to your rights described in Section 9.
When you close your account. We disable access to the account and remove identifying account information. We queue private uploaded files for deletion from our active systems and relevant service providers. This work may finish through a background process rather than immediately. If a provider mapping is incomplete or a retained publication may contain identifying material, we keep the minimum operational evidence needed to investigate and mark the item for restricted review rather than claiming it has been deleted.
We retain structured learning records, including attempts and scores, and may retain learning and interaction records for statistical analysis, such as assessing question difficulty, identifying common mistakes and improving educational content. We remove direct account identifiers and apply deterministic automated redaction to retained free text. Automated redaction may not remove every identifying reference and does not make retained records anonymous. Where retained information can still identify an individual, we continue to treat it as personal data and apply the protections and retention requirements described in this Policy.
Educational content you have published or contributed for use by others, such as question papers and their associated materials, may remain available under MurphyLearn's management after your account is closed. Account closure does not automatically remove that published content. Identifiers embedded in published file keys, provider metadata or document bytes may require restricted review because changing them can alter the publication.
Certain records may be retained where necessary to meet legal or accounting obligations, prevent fraud, resolve disputes or establish legal claims. Backup copies are handled under our backup retention arrangements and are not used to restore a closed account's sign-in access.
Account closure is separate from a legally valid erasure request. It does not limit your right to request erasure of personal data under applicable law, and any request remains subject to applicable legal retention requirements and rights exceptions. You may make such a request using the contact details in Section 13.
8. Children's Data & Parental Rights
MurphyLearn is designed with school-age users in mind, and Student accounts may be created by users under 18 as described in our Terms of Use.
- Students under 18 must have their parent's or legal guardian's permission to use the Platform. Our Terms require anyone purchasing a subscription for a student under 18 to be their parent or legal guardian, or to act with their permission. We do not separately verify parental permission at registration or the payer's relationship to the student.
- A parent or guardian may, at any time, contact us at learn@murphylearn.com to: request a copy of the personal data we hold about their child; request correction of inaccurate data; request deletion of their child's account and associated data; or object to further processing.
- We will take reasonable steps to verify that a person making such a request is the child's parent or guardian before acting on it.
9. Your Rights
Subject to applicable law, you (or, for a minor, their parent/guardian) may have the right to:
- Access the personal data we hold about you;
- Request correction of inaccurate or incomplete data;
- Request deletion of your data, subject to any legal retention requirements;
- Object to or request restriction of certain processing (e.g., marketing);
- Request a copy of your data in a portable format, where technically feasible;
- Withdraw consent where processing is based on consent, without affecting processing carried out before withdrawal.
To exercise any of these rights, contact us using the details in Section 13. We will respond within a reasonable time.
A note on Sri Lanka's Personal Data Protection Act
We handle personal data in accordance with applicable Sri Lankan data protection law.
10. Data Security
We use reasonable technical and organisational measures — including access controls, encryption in transit, and restricted internal access — to protect personal data against unauthorised access, loss, or misuse. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
If you believe your account has been compromised, contact us immediately at learn@murphylearn.com.
11. Marketing Communications
If you receive marketing communications from us, you may opt out at any time by using the unsubscribe link in the communication or by contacting us directly. Opting out of marketing does not affect service-related communications (e.g., billing notices, account security alerts) necessary for operating your account.
12. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes in accordance with the notice arrangements in Section 13.1 of our Terms of Use. The "Last updated" date at the top of this Policy shows when it was last revised.
13. Contact Us
Questions about this Privacy Policy, or requests relating to your data or a minor's data (access, correction, deletion), can be sent to:
SP Leaders (Pvt) Ltd 62/13 Udumulla Road, Battaramulla learn@murphylearn.com +94 76 471 8778
14. Governing Law
This Policy is governed by the laws of Sri Lanka.