Privacy Policy


The purpose of this Privacy Policy (“Policy”) is to verbalise our commitment to protecting your privacy and being in compliance with all relevant regulation and legislation, including the Protection of Personal Information Act 4 of 2013 (POPI) and the Consumer Protection Act 68 of 2008 (CPA) for the people of South Africa.

Introduction

This Policy describes how we collect, use, store, process, and share your information in relation to this website. This Policy covers our treatment of information that is gathered by this website, including personally identifiable information or personal. This Policy does not apply to information collected by third-party websites or services.

Damelin Online (“We”) are committed to protecting and respecting your privacy. We encourage you to read these terms and conditions carefully that you are aware of our practices and your right. This Policy is a ruling in conjunction and in cooperation with other website (“Site”) Terms and Conditions or any other documentation and/or rulings published.

When engaging with Damelin Online, our Site, you are subject to our Terms & Conditions. Prior to registering and enrolling with Damelin Online for an online short learning programme, we encourage you to read this Privacy Policy prior to participating in an enrolment.

Where We Collect About You

Your data is collected where you visit our Site, www.damelinonline.co.za, and where you engage with and Site functionality requesting personal data.

We use different methods to collect data, such as (but not limited to):

  1. Subscribing to our services or publications
  2. Registering and/or participating in an enrolment for an online short learning programme
  3. Requesting and downloading marketing collateral
  4. Providing feedback or contacting us on the Contact Us page
  5. Alumni registered students

How We Use Your Data

We utilise your data for the purpose we obtained it. These purposes include the following:

  1. Personal and Contact Details
  2. Sensitive Personal Data
  3. Technical Data
  4. Personal & Contact Details

In order to efficiently and effectively service you with our products and/or services, we collect and use your details in this context. We may also use your details for sending you updates in relation to the product and/or service you engaged us with. This may include to contact you for marketing and advertising in relation to campaigns you have shown an interest in. Such data could also be used to compile user profiles used in the context of campaigns.

Personal Data (Sensitive)

In order to design a target audience and provide feedback for our marketing campaigns, user profiles are constructed using sensitive personal data.

Technical Data

Assisting with the targeting of our Site, products, and marketing campaigns, communications and advertisements, technical data are collected by third parties such as Facebook and Google. We use the collected metrics in order to derive insights into our user’s interest.

Profiling

User interest insights help us cater our products, services, and marketing more precisely. Through the collection of Technical Data, we construct profiles in correlation with user personas to enable decisions (that include automated decision making) so that interests or categories of interests are better allocated to particular individuals or groups of individuals.

COLLECTED INFORMATION

Personal Details

This information could be collected directly from you through forms when you interact with our Site. It could also be collected directly as research, performed by us, or inferred from your browsing history, as collected by Technical Data.

The data we collect may include:

  1. Name
  2. Country/location
  3. Gender
  4. Race
  5. Purchase history
  6. Contact preferences for marketing purposes
  7. Personal Data (Sensitive/Special Category)

Data collected directly from you through forms, or when you participate with our Site or through our digital marketing campaigns, which are sensitive or special nature are retained in some cases. This will be used with your explicit consent.

Technical Data

Data, other than that collected from our Site, may also be collected. This may include log files, such as browser cookies, as you interact with your Site in order to support your website experience and interactions with us. This information could include data on your IP Address, Location, device identifiers and information on links that you click on or content that you view.

Basis of Information Collection

We conform to laws, rules, and regulations when using your personal data. We may use your personal data in a few situations.

Consent

By participating in our Site, you agree explicitly that we may obtain your data. Your personal details may be collected during your participation with our Site, products, and/or services. When you opt into receiving marketing communications, you provide us with consent to use your personal data. It may also entail the deposit of a website cookie that might collect Technical Data from your device. We only collect Personal Data (Sensitive) with your explicit consent. You consequently also reserve the right to withdraw such consent by contacting us or opting out with a relative unsubscribe link, as described in the Legal Rights section.

Legitimate Interest

In order to improve our business, we may engage you in a direct marketing where we contact you in the online short learning programme of our mutual business activities or engage you in researching our target audience for marketing campaigns. However, your interests and fundamental rights are not subordinate to our interests.

Contractual

Where you have entered into contract with us, we may process your data. When enrolling for an online short learning programme with Damelin Online, we bilaterally enter a contractual agreement.

Legal Obligations

We are bound by superior legal structures, e.g. South African Revenue Services, to retain records. Our obligation is to retain relevant data for tax purposes.

Duration of Retention

The data context, sensitivity, quantity, risk level for harm if lost or accessed by unauthorised sources, the context and purpose of the data all play a role in the duration of retention.

Table 1 Data Retention Guide

Data Nature Type Duration Justification
Personal Data Student: over contractual period, 5 years for tax purposes and 15 years for academic. Adequately service the student active and alumni engagement for service and marketing.

Keeping academic records for transcript and reference purposes.

Purchase History Retained for Student: over contractual period, for business relations and 5 years for tax purposes. To manage the customer/supplier relationship and suggest new products or services.
Contact Details; Contact Preferences Retained for Student: over contractual period, for business relations and an additional 2 years. To maintain contact with our students.
Cookies Our Site for a duration of 13 months maximum. Monitor of our website and to track the user’s interests.

Disclosure of Information

We may share your personal data with the parties set out below for the purposes outlined above. This may also include storage, for the administration of relevant contracts, the targeting of appropriate advertisements, and for our legal obligations.

These parties can include:

  1. Our partner advertising firms who make use of personas for marketing campaign purposes but does not include the distribution and/or use of personal/sensitive data.
  2. Website operators for registered user data located within the content management system (CMS) database.
  3. Lawyers, auditors, or insurers who provide consultancy, banking, legal, insurance, and accounting services.

Database Providers

We make use of service providers to render functionality such as our Site, the Learning Management System, and the Student Information System. These service providers can be local, i.e. in the Republic of South Africa, the United States of America, or the European Union.

These may include:

  1. Microsoft Azure
  2. Amazon Web Services
  3. MailChimp
  4. Sage Accpac Accounting
  5. Other Disclosures

Legally, we may also be required to share information with other service providing parties such as:

Public authorities who make lawful requests for the disclosure of information for meeting tax, security, and law enforcement requirements.

If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms of Use or Student Terms and Conditions and other agreements; or to protect the rights, property, or safety of UNi4 Online, our customers, or others.

This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

We might disclose your personal information to third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them.

If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.

Personal Data Transfer Safeguards

We assure the transfer of data between parties that those endpoints conform to agreements that they have adequate safeguards in place and that they won’t transfer data to any third party until arrangements are verified.

Cookies

Cookies are used to personalise your visits to this site, keep track of your preferences and learn about the way you use the site. Typically, these contain two pieces of information: a site name and unique user ID. All information these cookies collect is aggregated and anonymous. Cookies are essential to the effective operation of our website. Cookies make the interaction between you and the website faster and easier.

Cookies may also be set by the website you are visiting (first-party cookies) or they may be set by other websites who run content on the page you are viewing (third-party cookies).

We will generally collect information through the following types of cookies:

  1. Essential cookies – used for intra Site tracking and continuity
  2. Preferences – storing preferences to enhance your experience like form details
  3. Statistics – web analytics to determine the popularity of our Site, e.g. Google Analytics
  4. Marketing – collects viewing interests and displays advertisements that are relevant to the visitor

Cookies enable IP address, device identifiers, login data, browser type, version, time-zone, location browser plugin types, versions, operating system, and platform statistics. You can opt out of cookies as our Site should provide you with an upfront choice.

Legal Rights

Under the POPI act, everyone has the right to privacy that includes protection against the unlawful collection, retention, dissemination, and use of personal information.

According to the Rights of data subjects (POPI Act 4 of 2013 in the Government Gazette, 26 November 2013) chapter 2 paragraph 5, a person has the right to:

  1. Be notified that their data is being collected
  2. Their data has been accessed or acquired by an unauthorised person
  3. Know who holds their data
  4. Request correction, destruction/deletion of data
  5. Object (on reasonable grounds) relating to the processing of their data

Links & References to Us from Other Sites

Our Site contains links to other websites. You may also see links to our Site or information about us on third-party websites. If you follow a link to any of these websites or see information relating to us on those third-party websites, please note that these websites have their own privacy policies. We do not accept any responsibility or liability for these policies. This Privacy Policy only applies to our Site so when you access links to other websites, you should read their own privacy policies before continuing to browse them.

Changes to the Privacy Policy

We keep our Privacy Policy under regular review. If we change our Privacy Policy, we will post the changes on this page and place notices on other pages of the Site. We will make you aware of the information we collect and how we use it and, where appropriate, we will notify you by email.

Contact and Questions

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to operations@uni4online.co.za.