This policy was last updated: 6 June 2021.
This Privacy Notice applies to E-Classroom (Pty) (Ltd), its associated websites and business units. Reference to “E-Classroom”, “website/s”, “we”, “our” or “us” in this Notice means E-Classroom (Pty) Ltd and any of its business units or websites. E-Classroom respects privacy and is committed to protecting visitors’ privacy to our services and website/s and seeks to employ best practice when collecting and processing personal information in line with data protection or privacy legislation.
E-Classroom undertakes to ensure that the use and processing of Personal Information is lawful, reasonable, and relevant to our business activities, with the essential goal of improving our offerings and services as well as your online experience.
Protection of Personal Information Act and Consumer Protection Act
If any part of this Privacy Notice is regulated by or subject to the Consumer Protection Act (“CPA”) or the Protection of Personal Information Act, No. 4 of 2013 (“POPIA”), it is not intended that any part of this Privacy Notice contravenes any provision of the Consumer Protection Act or POPIA.
Therefore, all provisions of this Privacy Notice must be treated as being qualified, to the extent necessary, to ensure that the provisions of the CPA and POPIA are complied with. No provisions of this Privacy Notice (or any contract governed by this Privacy Notice) does or purports to limit or exempt us (as the Responsible Party) or any person or entity (as the Operator) from any liability (including, without limitation, for any loss directly or indirectly attributable to our gross negligence or wilful default or that of any other person acting for or controlled by us) to the extent that the law does not allow such a limitation or exemption; requires you to assume risk or liability for the kind of liability or loss, to the extent that the law does not allow such an assumption of risk or liability; or limits or excludes any warranties or obligations which are implied into this Privacy Notice (or any contract governed by this Privacy Notice) by the CPA or POPIA (to the extent they are applicable) or which we give under the CPA or POPIA (to the extent they are applicable), to the extent that the law does not allow them to be limited or excluded.
How We Process Your Personal Information
“Personal Information” includes information about individuals and companies (including juristic persons, like trusts or companies) per the POPIA definition.
E-Classroom may collect, receive, record, organise, collate, store, update, process, analyse, collate, and share your Personal Information as set out in this Privacy Notice.
We process different kinds of Personal Information about you, such as your:
- Physical address
- Online username (only at registration)
- Date of birth
- Contact numbers
We may also collect limited Personal Information of minors (persons under the age of 18 years).
Types of Data
Transaction Data includes details about payments from and to you. Service Data contains information about your communication with E-Classroom. Technical Data includes your internet protocol (IP) address, browser version, type, data for logins, browser plug-in types and versions, time zone settings and location, operating platform, system, and alternative technology on the devices you use to visit the website. Usage Data keeps information regarding how you use our website/s as well as our offerings and services. Marketing and Communications Data contains your preferences in obtaining marketing from E-Classroom and our third parties, as well as your communication preferences. You may opt-out from receiving future promotional information or direct marketing at any time by contacting email@example.com
Links to Other Sites
Children under 18 require consent from a parent or legal guardian to use our website/s. The usage of our website by a child without the consent of a parent or legal guardian is forbidden.
E-Classroom may process, collect, store, or use aggregated anonymised data, including historical or statistical data in accordance with lawful processing. Aggregated Data can be obtained from your personal information but is not regarded as personal information because this data will not indirectly release your Persona Identifiable Information (PII). We may combine or connect Aggregated Data with your personal information to identify you directly or indirectly; however, we will use the combined data as personal information, which will be utilised under this Privacy Notice.
How Information Collected Is Used
We collect your personal information through direct or active interactions with you, automated or passive interactions with you, and from third parties. We may need you to present specific information to access certain areas of the website/s and allow us to supply certain services to you or conclude an agreement with us or fulfil our legal obligations. All personal information will be secured and treated with due care.
We also gather your information when you communicate directly with us, for example, via email, phone calls, forums, and site comments feedback forms. Should you correspond with us, we can save a record of that exchange. We also gather parts of your personal information from the devices you use to browse the website or view any network administered by E-Classroom using various technological means. The information we passively collect from your Access Device may include your Identity Data, Contract Data, Security Data, Technical Data, Usage Data, Marketing and Communications Data, and any other information you permit us to use to collect from your Access Device passively – all dependent on what you consent to via our Cookies Banner.
Personal information provided to E-Classroom by yourself shall only be utilised for the purposes communicated to you when the personal information is requested.
We can make use of your personal information to supply our services:
- that you could buy from our website;
- to administer our various education packages;
- to comply with our statutory obligations as well as interacting with regulatory authorities;
- to conduct business case analysis to improve our service and/or provide new offerings;
- to maintain and make information accessible to you on the website/s;
- to supply you with marketing that is pertinent to you, or to information regarding our services and products;
- to retain and to keep you up to date, including our customer databases in terms of data accuracy;
- to initiate and confirm your Identity on the website/s;
- to determine and deal with technical problems, customer support questions and alternative user questions;
- to retain, administer, operate, develop, and secure the website/s and the execution and viability of the website/s;
- to preserve our rights in any litigation;
- to observe, stop or deal with alleged or actual fraud, security, or the abuse, incorrect or unauthorised use of the website/s and/or breach of this Privacy Notice or any of the terms and conditions that relate to the viewing of the website/s;
- to correspond with you and collect a record of our interactions with you and your interactions with us;
- to tell you about any changes to the website/s, the Privacy Notice, or other changes which we consider pertinent;
- to create/maintain user profiles to examine and differentiate how you as well as other viewers use the website/s, counting (without limitation) habits, preferences, click-patterns, times as well as frequency of use, demographics as well as trends;
- to examine and contrast the versions of Access Devices that you and alternate viewers use and where you use them; and
- for any separate reasons pertinent to our business pursuits if they follow the law and as consented by you.
We employ third-party companies and individuals due to the following reasons:
- to facilitate our Websites;
- to provide the service on our behalf;
- to perform Website-related services; or
- to assist us in analysing how our Website and Services are used.
These trusted 3rd party partners are:
E-Classroom will restrict its processing of your Personal Information to the original purposes for which it was collected unless we consider that it is required to be processed for another purpose. That purpose is adaptable with the initial purpose, but only with your additional consent to the initial purpose.
Sharing Your Personal Information
We will not intentionally disclose your Personal Information other than as set out in this Privacy Notice or without your permission. In the case where there is a suspicion of an unauthorised disclosure or a data breach, we will inform you immediately.
E-classroom may share your Personal Information under the following circumstances:
- to our advisors, agents, service providers, suppliers, and third-party suppliers or on terms which offer the same level of protection as this Privacy Notice;
- to our suppliers, employees, agents as well as service producers if and to the degree that they must acknowledge the information to provide the services for or to us for which they have been appointed, such as hosting, development and administration, technical and payment support and other support services relating to the website/s or the operation of the E-Classroom business.
- to impose or apply any different contract between us and you;
- to preserve our rights, safety, or property or that of our employees, customers and possible employees, contractors, candidates and prospective candidates, service providers, suppliers, agents as well as any alternative third party;
- to diminish any actual or reasonably recognised risk to us, our users, employees and possible employees, contractors, candidates and prospective candidates, agents or any other third party; and to government agencies, trades and alternate regulatory or self-regulatory organisation if needed to do so by law or if we reasonably accept that such activity is required to follow the law or any legal procedure;
- to save and preserve the rights, property or safety of E-Classroom, or our customers, employees and prospective employees, contractors, candidates and prospective candidates, service providers, suppliers, agents or any third party;
- to reveal, stop or handle actual or alleged fraud, security or technical problems or the abuse, incorrect or unauthorised use of the website and/or breach of this Privacy Notice; and
- to preserve the rights, property, or security of public citizens.
If you supply incorrect or misleading information regarding yourself, falsely identify yourself as another person, we may choose to divulge such information to the applicable regulatory authorities or commercial institutions.
How We Store Information Collected
Personal information is kept only if it is necessary to provide the services to you or as may be required in terms of legislation (including prescription periods), business requirements and whichever period is the longest. Personal information that you provided to us will be kept on our servers or those of our service providers in the form of a hard copy (at times), with reasonable safeguards in place to safeguard this information.
However, we also collaborate with third-party contractors, with some hosting and operating specific website attributes. If you sign up for news, alerts, data, announcements, marketing, or any other similar information for E-Classroom to email to you, we will hold your details on our customer database until you chose to unsubscribe from this service. We keep part of or all your personal information for as long as it is necessary to us to provide you with our offerings and services or as allowed by law or a commitment with you to stand by it; we may require it for legal reasons regarding our tasks and pursuits; we could need it for evidence reasons.
To decide the correct preservation time for individual information, we will contemplate, with other things, the amount, Identity and susceptibility of the individual information, the possible threat of damage from unapproved use or revealing of your individual information, the reasons for which we use your individual information and whether we can attain those aims through other methods. E-Classroom will always comply with applicable legal, regulatory, tax, accounting, or other requirements about retaining personal information.
Protecting Your Information
We aim to save the individual information we keep up to date, thorough and precise. We strive to guarantee the safety of individual information we keep by taking appropriate actions to stop the demolition, illegal access, and loss of individual information. Any settlement of data integrity or privacy will be communicated to you via email. Regardless of taking the beforementioned procedures when preparing individual information, we do not promise that your information is entirely safe however we will seek to achieve the following 5 key objectives:
- Protection – Of individual information so that only authorised users have access to it.
- Compliance – With the regulatory requirements of the act
- Security – Improve security through continuous education and awareness.
- Confidentiality – To ensure that sensitive information remains private.
- Auditing – Regular monitoring of security relevant events
Under specific conditions, you have the right to data protection laws regarding your individual information. You have the right to ask for your personal information (also known as a “data subject access request”).
This Allows You To:
Receive a copy of the personal information that we have about you. We may refuse your request for access or disclosure of your personal information if any of the grounds permitted in law apply.
Request correction of the personal information that we hold about you. This enables you to ensure that any incomplete or inaccurate data that we hold about you is corrected. Upon receipt of your request, we will correct or complete your personal information as soon as reasonably possible.
Request erasure of your data. This enables you to request that we delete or remove personal information where there is no lawful basis for us to continue to process or retain it. We may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
Withdraw consent at any time where we are relying on consent to process your personal information. Please note that we may continue to process your personal information in certain instances where we are not relying on your consent.
Right to object
You have a right to object under applicable data protection or privacy legislation, at any time, from our processing or using your personal information, and we may no longer process your personal information. Should you require to exercise your right to object, you should inform us that you do not want us to process your personal information.
If you require E-Classroom to delete or update your information about you, please contact firstname.lastname@example.org.
Please be advised that we may refuse to delete some of your information if we are required by law to retain it or if we need it to protect our rights.
You will only receive direct marketing from us if you have consented. You can opt out of direct marketing communications at any time.
Direct Marketing and Opting Out
If you are an existing member, we may communicate with you based on your selected preferences when registering/signing up for our product/s. This may include contact telephonically, email, SMS, social media, or other channels about products and services that may interest you.
At the point we collect information from you, you will be asked to consent to us using or disclosing your personal information for purposes other than those that are expressly stated in this policy. For example, you may be asked to opt-in to receive further information or communications from our advertisers or agencies.
You can “opt out” from receiving communications from us or from third parties that send communications to you in accordance with this policy. In such cases, you can opt out by using the unsubscribe option in the emails or newsletters sent by us.
You may also opt-out from receiving any direct marketing or promotional information by requesting us via email to desist from sending any direct marketing communications to you by contacting us via email@example.com
Please note that you may continue to receive communications from us that are not marketing related by essential to our offerings and service to you.
Retention and Destruction of Information
Personal information that E-Classroom collects from you is kept and processed for the purposes it was collected and is not retained longer than required by relevant applicable laws.
E-Classroom may retain your information after closing your account to comply with any legal obligations or resolve disputes, maintain security, prevent fraud and abuse, enforce our agreement, or fulfil your request to “unsubscribe” from further communication from us.
After your account has been closed, we may retain anonymised information using techniques that do not permit your re-identification. If none of those above scenarios is required, E-Classroom will permanently delete your details after the purpose of collecting the information has expired.
To the maximum extent possible, South African law applies to this Privacy Notice. If any provision of this Privacy Notice is found to be illegal, void, or unenforceable due to applicable law or by order of a court of competent jurisdiction, it shall be deemed deleted, and the continuation in full force and effect of the remainder of the provisions will not be prejudiced.
Changes to Our Statement
We may amend this statement from time to time, and all amendments we make to our Privacy Notice will be updated on this page.
If you have questions about this Privacy Statement or wish to exercise your rights in terms of access to, correction, or deletion of your information, please contact us to attempt to resolve your query.
Our Information Officer contact details are:
Address: 5 Noordhoek Road, Noordhoek, Cape Town
Information Regulator (South Africa)
Should you believe that we have utilised information contrary to applicable law, you undertake to first attempt to resolve any concerns with us. If you are not satisfied with such process, you have the right to lodge a complaint with the Information Regulator of South Africa.
The Information Regulator’s contact details are:
Address: JD house, 27 Stiemens Street, Braamfontein, Johannesburg