Prospen Africa is a training, development and consultancy company offering innovative educational solutions and related products and services across private and public sector organisations. This Privacy Policy explains what personal information we collect, how we use and protect it, with whom we share it, and what your rights are regarding your personal information.

Who We Are

We are a training, development and consultancy company that offers various services across different sectors, both in private and public organisations. We provide innovative educational solutions as well as related products and services.

Purpose

The purpose of this Privacy Policy is to explain what personal information we collect, how we use and protect such information, with whom we share such information, and what your rights are with regard to your personal information. This Privacy Policy applies to all jurisdictions where we do business and should be read together with any other privacy statement or notice we may provide on specific occasions. This Privacy Policy supplements, and does not override, any other such statements or notices.

Our Commitment to Privacy

We value and respect your right to privacy and the trust you place in us by giving us your (and/or your minor dependants') personal information. We strive to adhere to the provisions of the Protection of Personal Information Act ("POPIA") at all times. Should you have any concerns about how your personal information is being used, we will assist you in efficiently resolving such concerns.

What Personal Information Do We Collect?

This Privacy Policy relates to your personal information that we may collect and process by way of:

• Your general use of the websites, apps, online platforms, software and/or computer programs owned or controlled by us, or provided by a third party on our behalf ("Platform"); and/or
• Your commercial relationship with us; and/or
• Your communications with us.

By agreeing to this Privacy Policy, you represent that you are at least the age of majority, or that you have given us your consent to collect and process your minor dependant's personal information in accordance with this Privacy Policy. In the event we discover we have collected information from a child in a manner inconsistent with POPIA, we will either delete the information or immediately seek the consent of the parent/legal guardian. In this Privacy Policy, reference to "you" includes your minor dependant, and reference to "personal information" means information that could identify you and/or your minor dependants.

We may collect and process the following information (which may include personal information) about you and/or your minor dependant:

• Information that you provide by filling in forms on a Platform, including when registering to use a Platform, subscribing to or accessing our products and/or services, posting material, or requesting further services.
• Information that we may ask of you when you report a problem with our Platform, products and/or services.
• Records of correspondence between us, and information from reviews or surveys completed for research purposes.
• Details of transactions you carry out via our Platforms.
• Details of your visits to our Platforms (including traffic data, interactions, location data, weblog and other communication data) and the resources you access.
• Details provided by you of students or staff, which you agree we may process on your behalf to facilitate the delivery of services through our platforms or applications.
• Account Holder's Information: title, full names, surname, race, gender, contact details (including physical and postal address), e-mail, identity number, copy of identity document, and bank account details (if paying via debit order).

How Do We Collect Your Information?

The personal information that we collect and use may be provided to us in one or more of the instances below (this list is not exhaustive):

• On registration forms submitted regarding our Platforms, products and/or services.
• Through correspondence via e-mail, fax, telephone, post, our Platforms, and social media.
• When visiting our Platforms.
• When a third party delivers services to its clients using our platforms.
• When a third party requests us to deliver services to its clients or partners on its behalf.
• At social events, during office visits, via social media, and through our marketing services.
• Via any other third parties.

In most cases we explicitly request your consent to use your personal information; however, in some cases we may infer consent from your actions and/or behaviour, or may act on instruction of a third party who you have provided consent to. Where we act on instruction of a third party, we abide by all restrictions and confidentiality obligations stipulated by that party.

Collecting Information When You Register

We collect and use the personal information you provide when you complete and submit any registration or application form on our Platform, products and/or services.

Collecting Information When You Communicate With Us

We collect and use the personal information you provide when you communicate with us via social media, e-mail, fax, telephone, post, and our Platforms.

Collecting Information When You Use Our Platforms

We may use Cookies to manage your sessions and store preferences, tracking information, and language selection, whether or not you register with us. Cookies are small text files transferred by a web server to your hard drive and stored on your computer, collecting information such as the date and time of your visits, browsing history, preferences, and username.

Prospen Africa follows the standard procedure of using log files, which log visitors when they visit our websites. The information collected includes IP addresses, browser type, Internet Service Provider, date and time stamps, referring/exit pages, and possibly the number of clicks. This information is not linked to anything personally identifiable and is used for analysing trends, administering the site, tracking user movement, and gathering demographic information.

You have the ability to accept or decline the use of Cookies on the device accessing our Platforms. Declining Cookies may limit your access to certain features. We use cookies and other tools (such as web analytics tools and pixel tags) to automatically collect information including browser type, IP address, and hyperlinks clicked, for statistical and research purposes. This information does not identify an individual specifically.

We use comments and testimonials posted on our Platforms to improve our products and/or services. You are requested to continuously update your personal and contact details to enable us to improve the delivery of our products and services to you.

Collecting Information Where We Are a Third-Party Solutions Provider

The information collected by the Platform is provided by the source information provider (Second Party), and we cannot guarantee the security of information sent to us by that provider. The provider is responsible for using secure methods when sending confidential information to the Platform. Where a Second Party autonomously administrates users and controls access to personal information on platforms we provide, it shall assume all responsibility for compliance with applicable data protection legislation and confidentiality obligations.

Collecting Information at Social Events

Should we take photos at social events, these may be uploaded by our marketing team to our Platforms. By participating in a social event, you consent to your photo being taken and potentially uploaded to our Platforms. If you do not wish to have photos of you appear on our Platforms, please inform us in writing at admin@prospen.co.za.

Collecting Information via Third Parties

We may collect your personal information provided by third parties, as directed or instructed by you to that party. We will never exceed the mandate and purpose provided by the third party relating to the processing of your personal information.

Collecting Information via Third-Party Websites

Our Platform may link to other websites, or you may be referred to our Platforms through a link from another website. We have no control over the content or data collection practices of third-party websites and encourage you to read their privacy terms before disclosing personal information. We are not liable for personal information collected on third-party websites. This Privacy Policy covers only Cookies used by us, not any Cookies used by third parties.

Collecting Information When Visiting Our Offices

Upon arrival at any of our sites, you may be required to log your name, identity number, and vehicle registration number in our visitor book. This information is used for security and access control purposes only.

Collecting Information via Social Media

We may gather your personal information once you submit an enquiry or comment on our Platforms or any social media platform, or when you submit an inbox message. This information is used to assist us in resolving your query or responding to your comment.

Collecting Information via Our Marketing Services

We may follow up with clients who were previously registered with us to gather information as to why they are no longer registered. This information is used strictly for statistical purposes, and all clients have the option to opt out or refrain from answering any questions.

Children's Information

Protecting children online is a priority for us. We encourage parents and guardians to observe, participate in, and/or monitor and guide their children's online activity. Prospen Africa does not knowingly collect any personally identifiable information from children under the age of 13. If you believe your child has provided such information on our website, please contact us immediately and we will make every effort to promptly remove such information from our records.

What Do We Do With Your Personal Information?

We may use the information (including personal information) we hold about you in the following ways:

• To open your account with us.
• To provide you with information, products, or services you request from us, or which we feel may interest you, where you have consented to be contacted for such purposes.
• To keep records of information associated with the products and/or services for which you have registered.
• To respond to your queries, comments, and complaints.
• To ensure content from our Platforms is presented effectively for you and your device.
• To allow you to participate in interactive features of our products and/or services.
• To carry out and enforce any contracts that may form between us.
• To notify you about changes to our products and/or services.
• To send promotional information and announcements.

With Whom Do We Share Your Personal Information?

To enable us to deliver our products and/or services to you, your information is shared with our employees as well as third parties that assist us in delivering our products and services. Third parties we share information with on a regular basis include:

• SETAs (Sector Education and Training Authorities), learning centres, facilitators, moderators and assessors, academic assessment service providers, and other service providers linked to our products and/or services.
• Suppliers and contractors who assist us in providing our services and products.
• Warehousing, delivery, or courier services that enable us to deliver our products and/or services.
• Service providers who assist us in maintaining our IT infrastructure.
• Consultants and advisors, including legal advisors, business consultants, financial advisors, and auditors.
• Regulatory bodies and agencies to which we are required to provide information.
• Our shareholders and stakeholders.

In some instances, we may need to share your personal information with a third party to comply with a legal requirement, such as law enforcement or government authorities, or relevant examination boards. Should we share your personal information with a third party, such sharing is limited to the agreement between us and that third party, and we use commercially reasonable efforts to ensure your information remains confidential and secure.

We do not sell your personal information. However, should we enter into a sale or business agreement, merger, consolidation, change in control, re-organisation, or liquidation of all or part of our business, the purchaser will be bound to the same terms and conditions that apply to us regarding your personal information, unless otherwise advised.

Sending Personal Information Outside of South Africa

We may transfer your personal information outside of South Africa. Where this occurs, we ensure compliance with the Chapter 9 provisions of POPIA.

How Long Do We Keep Your Personal Information?

Your personal information will be retained, in a secure manner, for as long as is required to achieve the purpose for which it was collected. Personal information, registration information, assessment and curriculum information, and all financial information will be kept for the duration of your relationship with us, and for a period of five years after termination thereof, or as long as stipulated by applicable statute or law.

How Do We Keep Your Personal Information Confidential and Secure?

We take all commercially reasonable measures to ensure the confidentiality and integrity of your personal information, and require any third party that handles your information on our behalf to do the same. These measures include:

• Appointing an Information Officer and Deputy Information Officers to monitor compliance with data security and privacy legislation.
• Conducting regular risk assessments to identify physical and/or technological risks to your personal information.
• Restricting access to your personal information to authorised employees and third parties.
• Requiring third parties to undertake confidentiality and data protection obligations before receiving any personal information.
• Using encryption when transmitting confidential, personal information.
• Implementing regular employee training on information security and privacy policies and procedures.

We cannot guarantee the security of information sent to us; you are responsible for using secure methods when sending confidential information to us.

Prospen Africa only collects personal information when you provide it voluntarily. Collected information is stored in databases with strictly controlled access, made available only to those who need it in the course of their duties. Personal information you submit when registering on our Platforms may be protected by a unique customer password and user ID — you should never disclose your password to anyone, and you should always log off after each session.

While we strive to use commercially acceptable means to protect your personal information, no method of electronic transmission or storage is completely secure, and we cannot guarantee its security. You acknowledge and agree that we assume no liability regarding the theft, loss, alteration, or misuse of personal or other information, including information provided to third parties or other users, or the failure of a third party to abide by the agreement between us and that party.

Marketing of Our Products or Services

We may contact you regarding our products, services, and events that may be of interest to you, provided you have given consent, or have previously requested a similar product or service, or made an enquiry regarding another product or service. You may request to "opt out" of such communication at any time. Any direct marketing communication we send will provide the information and means necessary to opt out of receiving such information in future.

Keeping Your Data Up to Date and Accurate

It is important that we have up-to-date and accurate records of your personal information. You may update your information by contacting the relevant department and following the required procedures put in place to effect the change of your information.

Your Rights and Who to Contact

You have the right to:

• Know what personal information we have about you.
• Request that we correct or update your personal information on our records.
• Report any misuse of your personal information.

Should you wish to revoke any consent pertaining to your personal information, or request that we remove and/or delete your personal information entirely, you may contact us telephonically or notify us in writing. Please note that revoking consent may prevent us from providing or rendering our products or services to you or your minor dependant.

You can contact us in the following ways:

• Submit a query online, clearly setting out your concern or request, to: admin@prospen.co.za
• To assist us in dealing with your request, please provide your full name and ID number, or the full name of the account holder. To guard against fraudulent requests, we may require further information to verify your identity and the authenticity of the request.
• We will endeavour to respond to your request within a reasonable time, and may charge an appropriate fee for the cost of fulfilling your request (e.g. photocopying and postage), to the extent permitted by applicable law.

If you do not agree to this Privacy Policy, you may not access or otherwise use our Platforms.

Changes to This Policy

We may change this Privacy Policy from time to time by posting an updated version on our Platforms.

Consent

By agreeing to this Privacy Policy, you represent that you are at least the age of majority, or that you have given your consent to allow any of your minor dependants to use our Platforms.

By using our Platform or registering with us as a client, you consent to the collection, storage, and use of the personal information you provide in accordance with this Privacy Policy, including any updates you may provide. This consent extends to our right to collect, store, and use the personal information you provide in respect of your minor dependant. In this regard, you warrant that you are legally competent to consent to any action or decision taken in respect of any matter arising from your use of our services.