Privacy and Information Use Policy
ABOUT THIS POLICY
This policy sets out the categories of personal information we may collect from you or other sources when you attend our online event (using the Flock Platform) or apply to enter into agreements with us as well as how we process that personal information.
We subscribe to the principles, outlined in Section 51 of the Electronic Communications and Transactions Act and POPI , which govern your right to having your personal information kept private. We briefly outline these principles below:
We shall only collect, collate, process and store ('use') your personal information with your written permission as set out in this policy, unless legally required to do so, and will only use such information for the lawful purpose for which it is required as set out in this policy.
We shall disclose in writing, upon request, the specific purpose for which we use, collect, and store your personal information. We will also keep a record of that personal information and the specific purpose for which we have used it.
We will not use your personal information for any purpose, other than that which we disclosed to you herein, unless you give us your express written permission to do so, or unless we are permitted/required to do so, by law.
Personal information will only be retained for as long as necessary for the purpose it was collected and in line with regulations governing the duration information should be kept.
If you have any questions about this policy or do not agree with it, please contact us directly at firstname.lastname@example.org
By entering into any agreement with us, or by applying to enter any such agreement, or by registering and attending our training sessions, you agree to the terms as set out in this policy.
We understand the value of your personal information and therefore will take all reasonable steps to protect your personal information from loss, misuse or unauthorised alteration, access, or disclosure by the following:-
We are legally obliged to provide adequate protection for the personal information we hold and to stop unauthorized access and use of personal information. We will, on an on-going basis, continue to review our security controls and related processes to ensure that your personal information remains secure. However, we do not make any warranties or representations that content shall be entirely safe or secure, however we are subject to POPI, with which we comply.
We make use of electronic and computer safeguards such as firewalls and data encryption.
We have physical and electronic access control to our buildings.
We only authorise access to information to those employees who require it to fulfil their designated responsibilities.
We are committed to appropriate technical and other security measures in line with acceptable industry standards to safeguard your information.
COLLECTING YOUR INFORMATION
“Personal information” (referred to herein, simply as “information”) includes any personal information as defined in POPI as information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person. Further to the POPI Act, we also consider all addresses, including residential, postal and email addresses and change of names, to be included in the definition.
We collect information about you as follows:
Information you provide to us through our applications or through the training registration process;
Information you provide through other communications with us;
From third party sources where allowed to do so in law.
When you attend our training sessions, we automatically receive and record information on our server logs from your browser which may from time to time, include your location, IP address, cookie information, and the page you requested.
This is statistical data about browsing actions and patterns and does not identify any individual at the time.
USE OF YOUR INFORMATION
Information we hold
We may for example collect and use the following information about you:
First name, Surname, Email address and Cell phone number;
Gender and Date of Birth;
School, City or Town;
User provided info such as favourite subjects
Educational identifying factors such as age or school grade;
IP address or cookie information;
Android ID of your device, device make and model, operating system, and version
Usage patterns, timing, and frequency.
and any other information which we reasonably need to perform our duties in pursuance of any agreement we may have with you, make decisions about you, or fulfill our regulatory or other business obligations.
SPECIAL PERSONAL INFORMATION
TNC does not intend to process any “special personal information” as defined in POPI, which includes for example political, religious or health-related information, and will only process special personal information with your consent or if otherwise allowed to do so in law.
INFORMATION WE SHARE
We will only share your information with third parties with your consent or if otherwise allowed to do so in law.
We have trusted relationships with selected third parties who perform services on our behalf.
All service providers are bound by contract to maintain the security of your personal information and to use it only as permitted by us.
We may share information about you:
with employees in accordance with their employment relationships with us;
with any firm, organisation or person we use to provide a service on our behalf;
with any firm, organisation or person who provides us with products or services, where applicable;
with any payment system we may use;
with regulatory and governmental authorities, ombudsmen, or other authorities, including tax authorities, where we are requested by them to do so; and
with any other third party if allowed to do so in law.
How we use your information
We undertake to only process your information insofar as it is adequate, relevant, and not excessive for the purposes set out below.
We will not on-sell your email address or profile picture or personal information.
We will use your information to:
perform our duties in pursuance of any agreement we may have with you;
operate and manage your agreement with us or correspondence you may have with us;
carry out, monitor and analyse our business;
contact you by email, SMS, letter, telephone or in any other way about our products and services as allowed for in law, unless you tell us that you prefer not to receive marketing communications;
to form a view of you as an individual and to identify, develop or improve products or services that may be of interest to you;
carry out market research, business and statistical analysis;
perform other administrative and operational purposes including the testing of systems;
trace your whereabouts, should it become reasonably necessary to do so;
recover any debt you owe us;
comply with our regulatory or other obligations;
carry out any other reasonable business operation considering our business and the relationship between the parties.
Note that, as permitted by the ECT Act, we may use personal information collected to compile profiles for statistical purposes. No information contained in the profiles or statistics will be able to be linked to any specific user.
Your information may also be used for other purposes for which you give your permission or where we are permitted to do so in law or it is in the public interest to disclose the information.
You may on reasonable grounds object to the processing of your personal information, after which we undertake not to continue to process such information, except as provided for in law.
ACCESS TO YOUR INFORMATION
You have a right to access certain personal records we hold about you. Requests can be made in writing by sending an email to TNC at email address email@example.com
We want to make sure that your information is accurate and up to date. You may ask us to correct or remove any information that you think is inaccurate and you can do so by sending us an e-mail to firstname.lastname@example.org.
OTHER IMPORTANT INFORMATION
We shall not run any third-party adverts or share any user data with any third party for purposes of advertising or direct marketing.
As a legally registered private company, this policy is governed and regulated by the laws of the Republic of South Africa.
Cross-Border Data Transfers
Due to the nature of our service offering, we may legally process or collect your data outside the Republic of South Africa and transfer same across borders.
We draw your attention to the fact that such country will not have identical data protection laws, which may be more or less restrictive than those of the Republic of South Africa.