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.
CityVarsity 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.
Where We Collect About You
Your data is collected where you visit our Site, www.cityvarsityonline.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):
- Subscribing to our services or publications
- Registering and/or participating in an enrolment for an online short learning programme
- Requesting and downloading marketing collateral
- Providing feedback or contacting us on the Contact Us page
- Alumni registered students
How we Use your Data
We utilise your data for the purpose we obtained it. These purposes include the following:
- Personal and Contact Details
- Sensitive Personal Data
- Technical Data
- 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.
Assisting with the targeting 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.
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.
This information could be collected directly from you through forms when you interact with on 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:
- Purchase history
- Contact preferences for marketing purposes
- 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.
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.
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.
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.
Where you have entered into contract with us, we may process your data. When enrolling for an online short learning programme with CityVarsity Online we bilaterally enter a contractual agreement.
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 two years.||To maintain contact with our students.|
|Cookies||Our Site for a duration of thirteen 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:
- 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.
- Website operators for registered user data located within the content management system (CMS) database.
- Lawyers, auditors, or insurers who provide consultancy, banking, legal, insurance, and accounting services.
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:
- Microsoft Azure
- Amazon Web Services
- Sage Accpac Accounting
- 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.
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 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 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:
- Essential cookies – used for intra Site tracking and continuity
- Preferences – storing preferences to enhance your experience like form details
- Statistics – web analytics to determine the popularity of our Site, e.g. Google Analytics
- 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.
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:
- Be notified that their data is being collected
- Their data has been accessed or acquired by an unauthorised person
- Know who holds their data
- Request correction, destruction/deletion of data
- Object (on reasonable grounds) relating to the processing of their data
Links & References to Us from Other Sites
Contact and Questions