- APPLICATION OF THIS POLICY
- WHAT IS PERSONAL INFORMATION?
Personal information refers to information about an identifiable person, such as your name and surname, gender, age, date of birth, contact details (phone number and email) and address, physical location, ID number and your image among other identifiers.
Other information which might be “personal” information may include:
- “device and device event information”: IP address, unique device identifier, the nature of the device which you used to access our site, the geographic location of your device, hardware model and settings, operating system details, browser type and version, browser language, system activity and crashes;
- “log information”: such as details of how, when and for how long you accessed and used our site and other site traffic and use information, landing pages, which pages you accessed and viewed, the amount of time spent and what you did on those pages, details about games you played, how you interacted with other site users, and exit pages;
- “location information”: We may use various technologies to determine your actual location, such as geographical data from your device (which is usually based on the GPS or IP location);
- “unique application numbers”: Certain services include a unique application number. This number and information about your installation (for example, the operating system type and application version number) may be sent to us when you install or uninstall such a service or when that service periodically contacts our servers, such as for automatic updates;
- “shared content”: Parts of the Services let you interact with other users or share content publicly, including by posting reviews on a course page, asking or answering questions, sending messages to students or instructors, or posting photos or other work you upload. Such shared content may be publicly viewable by others depending on where it is posted;
- “course data”: When you enrol in and take courses, we collect certain data including which courses, assignments and quizzes you’ve started and completed; your exchanges with the site, teaching and other students; and answers to questions, and other items submitted to satisfy course requirements.
When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, information about your participation in courses and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically collected information as “Device Information.”
We use tools like cookies, web beacons, analytics services, and advertising providers to gather the data listed above. Some of these tools offer you the ability to opt out of data collection.
We collect Device Information using some of the following data collection tools and technologies:
- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.
Additionally when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers, debit card numbers, PayPal, etc.), email address, and phone number. We refer to this information as “Order Information.”
- HOW DO WE USE YOUR PERSONAL INFORMATION?
We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to:
- Communicate with you;
- Screen our orders for potential risk or fraud; and
- When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).
- HOW WE COLLECT YOUR PERSONAL INFORMATION
We collect your personal information in four ways, namely
- actively from you;
- passively from your device when you use our platforms;
- passively from social networking sites (subject to your privacy settings); and
- passively from our affiliates and third-party service providers.
- ACTIVE COLLECTION OF PERSONAL INFORMATION
Some areas of our site may require you to submit certain information in order for you to register for certain services or benefit from specified features, such as when you register on our platforms, request to receive any newsletters or similar subscriptions or tips/pointers, or participate in a particular activity, such as a game, promotional competition or other promotion (collectively referred to as the “value added services”). If you contact us, we may keep a record of that correspondence.
If you want to take advantage of any of our site sharing features, we will ask you to set up an account and create a publicly visible profile, indicating, for example, your username, e-mail address and, if you so wish, your photo. Our site may also collect personal information from you by asking you specific questions and by permitting you to communicate directly with us, for example via e-mail, feedback forms, site comments and forums. In these situations, we will ask you for specific information; inform you at each information point what information is required and what information is optional; and indicate the consequences if you don't give us the relevant information. (You will generally need to provide us with the relevant information to take full advantage of our platform features.)
The information we may actively collect from you may include your:
- identifying information (e.g. your name, surname, username, unique identifier (if you have not chosen a username), gender, date of birth, profile picture and physical location); and/or
- contact details (e.g. e-mail address and phone number
- PASSIVE COLLECTION OF PERSONAL INFORMATION FROM YOUR DEVICE
We passively collect some of your personal information from the device which you use to access and navigate through our platform(s), using various technological means. One of the keyways in which we collect information passively is using server logs to collect and maintain log information.
- PASSIVE COLLECTION OF PERSONAL INFORMATION FROM SOCIAL NETWORKING SITES (WITH YOUR PERMISSION)
We may allow you to log onto our site, or create a profile on our site, by using Facebook Connect, Google or Yahoo.
By collecting information from social networking sites we enable you to enrich your profile on our site, your game-play and your social experience by enabling you to share your information (e.g. posts, photos, videos, contacts, etc) which is stored on that site without you having to actively give us all that information – all you need to do is login using your username and password and give us your permission to access and use that information.
There are two kinds of information which we collect from social networking sites, namely basic information, and extended information.
Basic information is information which you have put on a social networking site which you have made public in accordance with your privacy settings on the relevant social networking site.
This could include your name and surname, username or user-ID number, your profile picture or its URL, your e-mail address, the physical location of your device, your gender, your date of birth, and any other information which you have decided to share publicly (i.e. the information which you have put on your social networking site profile for anyone to see).
We will access your basic information from a social networking site only:
- when you log on to a social networking site from our site or if you select the “keep me logged in” function;
- with your permission; and
- in line with your privacy settings on the relevant social networking site.
Extended information is information which you have put on a social networking site over and above the basic information. This could include your additional identifying information and contact details, biographical information, educational history, personal preferences, religion, your “friends” or contacts on the social networking site, your “likes” and “dislikes”, information you have “shared”, your recommendations to your friends or other social networking site contacts, your game scores and rankings, and any other information which you have put on, or actions you have done, on a social networking site, and any other information which you permit us, from time to time, to passively collect from a social networking site.
You can decide the layers of extended information which you want to share with us and manage it either through our site or the relevant social networking site (e.g. you might decide, depending on your personal preferences, to allow us to post on your wall when you complete a course or to send a notification to your social network friends on your behalf. We may offer you the ability to import your address book contacts or to manually enter third parties' contact details to populate your invite list on our site (“your contacts”). You may authorise us to send your communications to your contacts on your behalf (e.g. to send your contact an e-mail or notification from you or on your behalf inviting him/her to join you on a course).
Each application on our site will have its own default privacy setting. You can manage your settings at the time of giving us your permission or at any time thereafter by clicking on ”My Profile” on the applicable platform, or in any other manner which we make available from time to time. Your permission will expire if you do not access our site for a period of 60 continuous days. If it expires, you will need to refresh it when you next log in to our site. Additionally, we reserve the right to shut down your profile if you do not access/use the site within a 3-month period.
We only receive information from social networking sites – we do not give them access to any of your personal information.
- PASSIVE COLLECTION OF PERSONAL INFORMATION FROM OUR AFFILIATES AND THIRD-PARTY SERVICE PROVIDERS
We collect some personal information passively from our affiliates and third-party service providers, purely to supplement information which you have already agreed to give us, to supplement your user profile on our site to assist us with enhancing your user experience.
- WHY WE COLLECT YOUR PERSONAL INFORMATION AND HOW WE USE IT
We use the information we collect to provide, maintain, and improve our services, to develop new ones, and to protect us, our services, and our users. We constantly strive to improve our users' experience, and so we also use the information we collect to offer you information and content which is more appropriately tailored for you.
We may collect and use your personal information to:
- establish and verify your identity;
- to create your user account and ensure that it doesn't duplicate an existing user account on our site and allow use of our site, products and services;
- maintain and update our databases;
- communicate with you in various ways (determined by you in your privacy settings), such as e-mail, post, telephonically, SMS notifications, instant messaging or other notifications to your device (e.g. on-screen pop-up messages);
- personalise your User experience and enhancing our ability to recommend relevant content
- enable user to user communications;
- request feedback on our site, products, and servers, address any issues and liaise with users in that regard;
- keep a record of our communications with you and your communications with us;
- fulfil any contractual obligations we may have to you or any third party;
- provide you with value added services;
- to identify and inform you of points of interest or goods and services of interest near to your location, using your location information;
- improve the content of our site and our products and services;
- allow you to participate in any interactive features and sharing features that may be active on our site;
- combine your personal information from a social networking site with the information on our site to streamline and complete our records and to make it easier for you to share content with people you know;
- improve your user experience and the overall quality of our services;
- customise our site to your preferences and tailor information and content for you to ensure that it is presented in the most effective manner for you and for your device;
- inform you of facts relating to your access to and use of our site;
- inform you about our products and services which we think may interest you (if you have consented to this);
- inform you about competitions, promotions, and special offers from us (if you have consented to this);
- carry out marketing, product research and development;
- to tailor general advertising on our platforms more appropriately for user groups;
- to compile and use statistical information about you and other users and their access to and use of our site, browsing habits, click-patterns, preferences, demographics etc which we may use to develop, provide and improve our platforms and our products and services, including recommendations to users and tailoring information and content for users;
- to compile, use, disclose and trade with non-personal statistical information about our users and their access to and use of our site, browsing habits, click-patterns, preferences, demographics etc. which we and our advertisers may use to develop, provide and improve our platforms and our products and services, including targeted advertising to user groups. Please note that the information referred to in this paragraph is aggregate information about our users which has de-identified users' personal information such that it cannot be linked back to identify you. We will not disclose your identifiable personal information to anyone without your express permission;
- diagnose and deal with technical issues and customer support queries and other user queries, such as problems with our server, determine the optimal and fastest route for your device to use in connecting with our site, and administer, maintain and secure our platforms;
- comply with the law or with any legal process; and
- other activities not specifically mentioned which are lawful, reasonable, relevant to our business activities, and the minimum necessary and adequate for us to provide our platforms, and our products and services.
We will get your permission before collecting or using your personal information for any other purpose.
- YOUR RIGHTS AS A DATA SUBJECT
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you. Access to this information may be subject to an administrative fee if your request is manifestly unfounded, excessive, or repetitive.
- Right of accuracy – you have a right to insist that we correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply you have a right to restrict the processing of your data.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation or provided to you in a machine-readable word format.
- Right to object – you have the right to object or remove your consent for certain types of processing such as direct marketing.
- Right to object to automated processing, including automated profiling unless such profiling is necessary to conclude a contract, or the performance required by a contract between us and you – and we apply suitable measures to safeguard your personal information.
- You have the right to complain if you have cause to be concerned about the way we capture, treat, or process your personal information.
In order to verify your identity should you request a copy of your data or information about your data, we may ask for a copy of your passport, driving licence, national identity card or birth certificate.
- COMPULSORY AND OPTIONAL INFORMATION AND CONSEQUENCES OF NOT SHARING IT WITH US
Only the following information is compulsory: Your name, surname, registered e-mail address or mobile number. All other information is optional. If you do not agree to share your compulsory information with us, then you will not be able to make full use of the features that are offered to registered users. If you do not agree to share your optional information with us, then you may not be able to enjoy all sites’ features and functionality.
- DISCLOSURE OF YOUR PERSONAL INFORMATION
We may disclose or share your personal information to or with:
- our affiliates;
- our employees, contractors and agents if and to the extent that they need to know that information in order to process it for us and to provide services for or to us, such as site hosting, development and administration, technical support, financial services such as processing of payments, delivery services, marketing services (only in respect of our site, products and services) and other support services;
- in order to protect our rights, property, or safety or that of our customers, employees, contractors, agents and any other third party;
- in order to mitigate any actual or reasonably perceived risk to us, our customers, employees, contractors, agents or any other third party;
- any third party who acquires (or proposes to acquire) ownership or control of our assets, shares or management, or that of our affiliates, and our site, whether by sale, merger, acquisition or otherwise, and to any third party from who we acquire (or propose to acquire) ownership or control of assets, shares or management, whether by purchase, merger, acquisition or otherwise;
- governmental agencies, exchanges and other regulatory or self-regulatory bodies if we are required to do so by law or if we reasonably believe that such action is necessary to:
- comply with the law or with any legal process;
- protect and defend the rights, property or safety of us, our affiliates or our customers, employees, contractors, and agents or any third party;
- protect the rights, property or safety of members of the public (if you provide false or deceptive information about yourself or misrepresent yourself as being someone else, we may proactively disclose such information to the appropriate regulatory bodies and/or commercial entities).
We may use your personal information to compile profiles for statistical purposes and may freely trade with such profiles and statistical data, provided that the profiles or statistical data cannot be linked back to you by a third party.
We will get your permission before disclosing your personal information to any third party for any other purpose.
When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information.
- SHARING YOUR PERSONAL INFORMATION
We share your Personal Information with third parties to help us use your Personal Information, as described above.
We also use Google Analytics to help us understand how our customers use the Site--you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/
You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout
Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
- POLICY CONCERNING CHILDREN
We recognize the privacy interests of children and encourage parents and guardians to take an active role in their children’s online activities and interests. Children under 18 (or under 16 in the European Economic Area) should not use the Services unsupervised or without the relevant consent from a parent or guardian. If we learn that we have collected personal data from a child under those ages, we will take reasonable steps to delete it.
Parents who believe that BABH may have collected personal data from a child under those ages can submit a request that it be removed to firstname.lastname@example.org
- BEHAVIOURAL ADVERTISING & DIRECT MARKETING
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you.
When you register on our site you may choose whether to receive marketing communications from us. You may also manage it in your privacy settings on our site. You may refuse to accept, require us to discontinue, or pre-emptively block any approach or communications from us if that approach or communication is primarily for the purpose of direct marketing (“marketing preference”).
You may opt out of receiving direct marketing communications from us:
- at the time of registering on our site by ticking the relevant “opt-out” box; and
- at any time by requesting us (in any manner, whether telephonically, electronically, in writing or in person) to desist from initiating any direct marketing to you.
If you have opted out in accordance with the above, we will:
- send you written (which may include electronic writing) confirmation of receipt of the opt-out request; and
- not send you any further direct marketing communications.
You may (in terms of the Consumer Protection Act, 2008) register a pre-emptive block against direct marketing communications. If you do so, we will not send you direct marketing communications unless you have expressly consented to receiving direct marketing communications from us.
We will not send you direct marketing communications at home at any period during which it is prohibited by law to do so unless you have expressly or implicitly requested or agreed otherwise.
All information you provide to us is stored on our secure servers or those of our trusted partner services.
We implement appropriate, generally accepted technical and organisational measures to protect your personal data against unauthorised or unlawful processing, accidental loss, destruction, or damage, including encryption where appropriate.
Unfortunately, the transmission of information via the Internet is not completely secure. We will do our best to protect your personal information, but we cannot guarantee 100% security of your data transmitted to our servers using the internet and any transmission is at your own risk.
We take reasonable technical and organisational measures to secure the integrity of information we collect about you, using accepted technological standards to –
- prevent unauthorised access to or disclosure of your personal information; and
- protect your personal information from misuse, loss, alteration, or destruction.
- We require you to enter a password when logging in to our site.
- Where we allocate you or replace a password which enables you to access certain parts of our site, we will do so in an automated manner and we do not store it. You are responsible for keeping your password confidential. Please notify us immediately and change your password if you become aware that your password has or may have become compromised or accessed by an unauthorised person.
- From time to time we review our information collection, storage and processing practices, including physical security measures, to keep up to date with best practice.
- The BABH site and marketing automation platform maintain a backup for operational and safety purposes.
- LINKING TO THIRD PARTY SITES
We are not responsible for the privacy practices of a third-party site to which there may be a link on our site or to which you may log in from our site (e.g. integrated social networking services).
In certain instances, we may give you the option to manage some of your privacy settings on integrated social networking sites from our sites (e.g. to enable you to determine which of your personal information you would like to share via our site).
- CHANGES TO THIS POLICY
This privacy notice gives effect to many of our responsibilities as a responsible party or a data controller in terms of the applicable legislation in the respective countries where we operate.
If you have a concern about the way we are handling your information, for example if you feel we:
- are unlawfully processing your personal information;
- are not keeping your personal information secure;
- are misusing of your personal information;
- are keeping personal information about you for longer than is necessary;
- hold inaccurate personal information about you;
- have disclosed personal information about you;
- have collected personal information for one reason and is using it for something else; or
- have accessed your personal information without your authorisation.
If you have any queries or questions regarding your personal information or how we process it, please email us on email@example.com to log a query. This email address is actively monitored, and we endeavour to respond to all requests within 1 month.
If possible, please supply all or any of the following information to assist us in the process:
- Full name of the person lodging the compliant;
- Contact details such as email address and telephone number;
- How the personal data was collected (if known);
- All necessary information (such as your account number and what you think we have done wrong);
- The timeframe over which the suspected wrongdoing occurred (if known); and/or
- Any evidence in support of the complaint.
Top of Form
While we try to respond as promptly as possible, resolution times will vary depending on the nature of the complaint. We will liaise with our relevant departments to investigate your complaint. You will be notified of the outcome of your complaint as well as any action taken. If you are unhappy with how your complaint was handled, or the outcome of your complaint, then you may appeal, by contacting our Data Privacy Officer on firstname.lastname@example.org
If you remain unhappy after the appeals process you may forward your complaint to the Information Regulator:
or the Information Regulator (South Africa):
316 Thabo Sehume Street,
Tel: 012 406 4818
Fax: 086 500 3351
More information can be found at http://www.justice.gov.za/inforeg/
- ABUSIVE, PERSISTENT OR VEXATIOUS CORRESPONDENCE AND COMPLAINTS
For the purposes of lodging complaints, it is the complaint which must be vexatious and not the individual making the complaint. While we differentiate between people who make numerous complaints because they think things have gone wrong and people who are simply being difficult, we do understand that sometimes complainants act in distress, and we will make reasonable allowance for that. We may decide not to attend to the complaint based on one or more of the following reasons:
- Persisting in a complaint after being advised that there are insufficient or no grounds for your complaint or that we are not the appropriate body.
- Refusing to co-operate with the complaints process, without good reason, but still wanting your complaint to be resolved, including a failure or refusal to specify the grounds of a complaint despite offers of assistance.
- Changing the basis of the complaint as inquiries of a complaint despite offers of assistance, changing the basis of the complaint as inquiries are made and introducing trivial or irrelevant new information and expecting this to be considered and commented on.
- Submitting repeat complaints, after the complaint procedure has been completed essentially about the same issues, with additions/variations which the Complainant then insists on being treated as new complaints and put through the full complaint procedure again.