1. WHO ARE WE?
Diversit-e Smart Trade College (Pty) Ltd (Registration Number:2016/305525/07) (“we”; “us”, “our”), is an e-learning platform which coaches persons and start-ups on how to trade, how to manage risks and increase profits. Our e-learning courses include Forex Trading Education, Bitcoin, CFD, and Stock Market Trading.
We are committed to keeping the privacy and confidentiality of information provided to us by persons or organisations who use or visit this website, as well as all other websites and/or landing pages for which we are responsible (the “Website”).
Personal Information includes any information which relates to and renders it possible, to identify you as an identifiable living human being and/or where applicable an identifiable juristic person. This may include (without limitation) your
name, race, gender, identity number, registration number, email address, physical address, telephone number, location information, online indemnification such as the internet address of the domain from which you are visiting (i.e. your Internet Protocol address or IP address) or biometric data (“Personal Information”).
3. SCOPE OF POLICY
The primary object of this Policy is to inform you, being the person or organisation to
whom the Personal Information relates, as to (i) who is responsible for the processing, as well as the management and safeguarding of collected and/or processed Personal Information; ii) the manner in which your Personal Information may be processed pursuant to visiting or using our Website, products or services; (iii) the type of Personal Information we may process; (iv) other parties we may share the Personal Information we process with; (vi) your rights regarding the Personal Information; and (vii) security measures we employ to protect the Personal Information which we have processed.
4. WHO IS RESPONSIBLE FOR THE PROCESSING OF PERSONAL INFORMATION COLLECTED?
The Personal Information which we collect from you, is processed by us as defined in this Policy. This may include our employees, contracted third parties or authorised agents as we may be required to provide our employees, contracted third parties or authorised agents with access to your Personal Information in order to enable them to carry out our obligations to you. These employees contracted third parties or authorised agents are also required to comply with and uphold the applicable data protection laws and the terms of this Policy.
5. HOW DO WE PROCESS PERSONAL INFORMATION?
Information may be collected either through or by electronic means, which includes, without limitation, the use of our Website, electronic mail (e-mail), text, voice, sound or image messages, or through non-electronic means which includes, without limitation, the capturing of Personal Information on hard copy documents.
When using our Website your Personal Information may be collected either actively where you or your appointed agent provide us with certain Personal Information or inactively where we collect information from you that you have not actively provided. See below for a more detailed discussion.
a) Active Information Collection:
Active information collection refers to instances where we obtain information from you where you have directly provided us with Information, such as when you submit an enquiry in respect of a specific product or service, or when you subscribe to receiving marketing material from us. Throughout the use of our Website(s) or pursuant to providing you with the relevant products and/or services, we may request that you provide us with your Personal Information and views/ or opinion in the form of a questionnaire, such information being required to assist us to not only improve our products and services to our customers, but also ensure that our customers continue to experience products and services that are of exceptional value and quality. We may also use your information to provide you with electronic updates, alerts, and other information regarding our products and services.
b) Inactive Information Collection:
Inactive or passive Information collection refers to instances where we collect Information from you which you have not actively provided as contemplated above. To this end we may use technologies to passively collect information while you are visiting, accessing or using our Website or making use of our services or products. These technologies allow us to collect certain kinds of information which can perhaps not be linked to you as a person (i.e. non-personally identifiable information), such as your internet domain name, the type of web browser you use, the operating system you use, the date and time of your visit to our Website, the specific pages you may have visited, and the address of the website which you have visited prior to entering our Website.
Kindly note that we do not link this passively collected non-personally identifiable information with personally identifiable information you have actively provided elsewhere on our Website or at any of our physical locations and/or facilities. We reserve the right to share with third parties, including our business partners and advertisers, any anonymous aggregated non-personal information which we may have passively collected via our Website.
We may from time to time use the following technologies (without limitation) to collect information passively or inactively through our Website, namely:
(ii) Web Beacons:
We may include small graphic images called web beacons, also known as “Internet tags” or “clear gifs,” in our web pages and e-mail messages. Web beacons may be invisible to you, but any electronic image inserted into a web page or e-mail can act as a web beacon. We may use web beacons or similar technologies for a number of purposes, including, without limitation, to count the number of visitors to our Website, to monitor how users navigate the Website, to count how many e-mails that we sent were actually opened or to count how many particular articles or links were actually viewed.
(iii) Embedded Scripts:
An embedded script is programming code that is designed to collect information about your interactions with the relevant Website. It is temporarily downloaded onto your computer from our web server or a third party we may work with, is active only while you are connected to the relevant Website and is deleted or deactivated thereafter.
(iv) Mobile Device Identifiers:
Certain mobile service providers uniquely identify mobile devices and we or our third-party service providers may receive such device information if you access our Website through mobile devices. Certain features of the relevant Website may require collection of mobile phone numbers and we may associate that phone number with the mobile device identifiers. Additionally, some mobile phone service providers operate systems that pinpoint the physical location of devices that use their service. Depending on the provider, we and our third-party service providers may receive this information. If we associate any such passively-collected information with your Personal Information, we will treat the combined information as Personal Information as contemplated in this Policy.
6. THE TYPE OF INFORMATION WE PROCESS
The information we collect about you and how we collect it may vary depending on
the products and services that you use and subscribe to, how you have used the Website, products and services, and how you have interacted with us even if you aren’t a customer. With your permission or consent and/or as permitted by law, we may also collect information about you from other organisations or third parties, these include fraud-prevention agencies, business directories, and credit bureaus or reference agencies.
By using our Website, engaging with us or by making use of our products and/or services we will be collecting the following information from you:
· Your name, date of birth, home language, address, contact number and email address.
· Your account information
· Your preferences for particular products, services when you tell us what they are – or when we assume what they are, depending on how you use our products and services.
· Your contact with us – such as notes or recordings of a call to our contact centre, an email or letter you send to us or other records of any contact you have with us.
· We will also get information on how you use our products and services, such as:
– Record of learning activities to help us serve you better;
– The level of service you receive – for example, network faults and other network events which may affect our network services;
– the phone numbers/ e-mail address that you contact us or send messages from;
– The date, time and length of the calls and messages you send or receive through our network, and your approximate location at the time these communications take place;
– Your website browsing information (which includes information about the website you visit), and about how you use our Website on your mobile devices or a PC; and
– The date, time and length of your internet browsing, and your approximate location at the time of browsing.
7. USE AND ANALYSIS OF PERSONAL INFORMATION
All Personal Information which may be collected from you, will only be processed in
accordance with this Policy or as specifically disclosed to you and/or brought to your attention, at the time you provide the information. We will be entitled to lawfully process your Personal Information and to disclose such Personal Information to any employees, contracted third parties or authorised agents or representatives, as well as trade partners to facilitate the procurement of products and / or services which you may have requested.
We will not sell, transfer, share, or otherwise permit access to your Personal Information with any third parties other than as described in this Policy. Please note that we reserve the right to transfer, or otherwise share without restriction aggregated, de-identified, and other non-personally identifiable information as
contemplated in this Policy.
We further reserve the right to use or disclose your Personal Information provided by you through, or by means of, our Website or the use of our products and/or services
as may be required from time to time so as to respond to your requests, comply with applicable laws, regulations, legal processes, and law enforcement inquiries, as required by litigation, to take precautions against liability, and protect the security and integrity of our Website and the safety of its users.
Access to Personal Information classified as “Confidential” or “Restricted” shall be
limited to authorised persons who in the fulfilment of their obligations require such access.
We will store your information for as long as a required to keep such information by law. If there is no legal requirement, we will only store it for as long as we need it.
In supplementation of the above, we may use and analyse your information to:
o Process the goods and services you have bought from us, and keep you updated with your order progress.
o Keep you informed generally about new products and services (unless you choose not to receive our marketing messages).
o Provide the relevant service or product to you. This includes services that use information about where you are when using your mobile equipment (location information) and to contact you with messages about changes to the service or product.
o Bill you for using our products or services, or to take the appropriate amount of credit from you.
o To administer this Website and help us improve our services.
o Respond to any questions or concerns you may have about using our network, products or services.
o Protect our network and manage the volume of calls, texts and other use of our network. For example, we identify peak periods of use so we can try and ensure the network can handle the volume at those times.
o Understand how you use and interact with our Website, products and services. That way, we can develop more interesting and relevant products and services, as well as personalising the products and services we offer you.
o Carry out research and statistical analysis including to monitor how you use our Website, products and services on an anonymous or personal basis.
o Prevent and detect fraud or other crimes, recover debts or trace those who owe us money.
8. SHARING OF YOUR PERSONAL INFORMATION
We may share, transfer or disclose the information in our databases and server logs to comply with a legal requirement, for the administration of justice, interacting with
anti-fraud databases, to protect your vital interests, to protect the security or integrity of our databases or this website, to take precautions against legal liability, or in the event of our involvement on a stock exchange, sale, merger, reorganisation, dissolution, disposal of all or part of our assets or similar event. We will inform you of any such transfer or disclosure if we are required to do so by law.
Where appropriate, before disclosing personal information to a third party, we
contractually require the third party to take adequate precautions to protect that data and to comply with applicable law.
We may share information about you with:
o Partners contracted third parties or authorised agents involved in delivering the products and services you have ordered or used.
o Partners or authorised agents that conduct network performance and customer satisfaction surveys and any other surveys related to the products or services provided to you.
o Where applicable, credit reference, fraud prevention or business scoring agencies, or other credit scoring agencies.
o Debt collection agencies or other debt recovery organisations.
o Law enforcement agencies, regulatory organisations, courts or other public authorities if we are required to do so by law.
o if it is reasonable for the purpose of protecting us against fraud, defending our rights or property, or to protect the interests of our customers.
o In the event of a merger/acquisition or company reorganisation, your personal information may be part of the transferred assets and are likely to be disclosed to the new company.
9. PLACE WHERE PERSONAL INFORMATION WILL BE KEPT
All Personal Information provided to us will be stored on our secure servers located in South Africa, however, we may elect to store data at a destination outside of South Africa in which event we will only transfer your Personal Information to facilities or parties outside South Africa where such transfer is compliant with applicable data protection laws and regulations.
10. DATA SECURITY
We are committed to implementing leading data security safeguards to protect your
personal information from unauthorised access, accidental loss, disclosure or destruction.
If we have a contract with another organisation to provide us with services or a service on our behalf to process your personal information, we will ensure that your
information is protected and that they only process your information in the way we have authorised them to. These organisations will not be entitled to use your personal information for their own purposes.
Unfortunately, the transmission of information via the internet is not completely secure. Whilst we have taken all appropriate, reasonable, technical, organisational and reasonable measures to secure the integrity and confidentiality of the Personal Information in our possession, in order to guard against the loss of, damage to or unauthorised destruction of Personal Information and unlawful access to or processing of Personal Information, we do not guarantee that our security system is 100% secure or error-free. Therefore, we do not guarantee the security or accuracy of the information (whether it be Personal Information or not) which we collect from you and process in accordance with this Policy.
We will never ask for your secure personal or account information by unsolicited means of communication. You are responsible for keeping your personal and account information secure and not sharing it with others.
11. UNAUTHOIRSED ACCESS TO YOUR INFORMATION
Despite the security measures we have in place to protect your personal information (firewalls, password access and encryption methods ) you acknowledge that it may be accessed by unauthorised third party, e.g. as a result of an illegal activity.
You acknowledge that any transmission of Personal Information will be solely at your own risk. Once we have received your Personal Information, we will use strict procedures and security features to try to prevent unauthorised access to it. We shall not be however be held responsible for, and by accepting the terms and conditions to which this Policy relates, you agree to indemnify us and hold us harmless for any security breaches which may potentially expose the Personal Information in our possession to unauthorised access and or the unlawful processing of such Personal Information by any third party.
12. LINKS TO OTHER WEBSITES
On our Website you may see references or links to websites that are owned and/or managed by third parties which third parties are unrelated to us (“Third Party Websites”) and which Third Party Websites are specifically excluded from this Policy.
We shall bear no responsibility or liability for the products offered, services rendered or content provided through or by means of any Third Party Websites. We therefore make no warranties or representations whatsoever regarding the products offered or services rendered by any third party or the content or activities of any Third Party Websites which may be accessed or used through or by means of our Website and/or their associated services.
13. GOVERNING LAW
The laws of the Republic of South Africa will govern any dispute or claim arising out of or relating to your use of this Website, products or services.
14. YOUR RIGHTS
We are committed to processing Personal information in a manner that is consistent with applicable data protection laws. Below we set out details on how you can exercise your rights. Please note, that same is not intended to be a closed list and that you are advised to consult the relevant legislation or take legal advice in respect of your rights and entitlements under the applicable data protection laws, should you so desire.
Right to correct personal information
Upon request, having provided adequate proof of identity, you have the right to have information held about you corrected if it is not accurate. In order to request a correction, please contact us by emailing email@example.com.
Right to access personal information
You have the right to make a request for a copy of the personal information that we have about you. Having provided adequate proof of identity, you have the right to request that we to conﬁrm, whether or not the responsible party holds Personal Information about you, as the data subject and request from a responsible party the record or a description of the Personal Information about you held by the responsible party.
Right to Opt-Out
If you no longer want to receive marketing messages from us, please contact us by emailing firstname.lastname@example.org and you will be ‘opted out’.
If you choose to unsubscribe or opt out, we will hold your contact details on file, this is so that we do not contact you if your details are subsequently provided to us by a third party.
Right to object to use of personal information
In certain circumstances, you have the right, to object or withdraw consent to our processing your Personal Information. Please contact us by emailing email@example.com and a member of our dedicated team will respond to you.
How to lodge a complaint
Should you believe that we have used your Personal Information contrary to applicable law, you undertake to first attempt to resolve any concerns with us directly. If you are not satisfied with such process, you have the right to lodge a complaint with the Information Regulator, once the Protection of Personal Information Act, No. 4 of 2013, is in full force and effect.
15. CHANGES TO THIS POLICY
Kindly take note that we reserve the right to change this Policy at any time and in our sole discretion. In the event that that Policy is changed the new policy will be made available on our Website. Should you have any queries in connection with this Policy, please contact us by emailing firstname.lastname@example.org