This privacy notice aims to inform you about how we collect and process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information. It tells you about your privacy rights and how the law protects you.
We are committed to protecting your privacy and the confidentiality of your personal information. Our policy is not just an exercise in complying with the law, but a continuation of our respect for you and your personal information.
We undertake to preserve the confidentiality of all information you provide to us and hope that you reciprocate.
Our policy complies with the Protection of Personal Information Act 2013.
The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal information.
Except as set out below, we do not share, sell, or disclose to a third party, any information collected through our website.
1. Information Officer
We have appointed an Information Officer who is responsible for ensuring that our policy is followed.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our Information Officer, Mike Nicol, through the contact form on the website.
The Information Regulator in South Africa can be contacted at [email protected] or the website http://www.justice.gov.za/inforeg/ .
2. Information we process
We may collect, use, store and transfer different kinds of personal information about you. We have collated these into groups as follows:
Your identity includes information such as first name, last name, title, and other identifiable information that you may have provided at some time.
Your contact information includes information such as email address, telephone numbers and any other information you have given to us for the purpose of communication or meeting.
Technical information includes your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Your profile includes information such as your username and password.
Marketing information includes your preferences in receiving marketing from us; communication preferences; responses, and actions in relation to your use of our services.
We may aggregate anonymous information such as statistical or demographic data for any purpose. Anonymous information is information that does not identify you as an individual. Aggregated information may be derived from your personal information but is not considered personal information in law because it does not reveal your identity.
For example, we may aggregate profile information to assess interest in a product or service.
However, if we combine or connect aggregated data with your personal information so that it can identify you in any way, we treat the combined data as personal information, and it will be used in accordance with this privacy notice.
3. Special personal information
Special personal information is data about your race or ethnicity, religious or philosophical beliefs, sex life, political opinions, trade union membership, information about your health and biometric data. It also includes information about criminal convictions and offences.
We do not collect any special personal information about you.
4. If you do not provide personal information we need
Where we need to collect personal information by law, or under the terms of a contract, we have with you, and you fail to provide that information when requested, we may not be able to perform that contract. In that case, we may have to stop providing a service to you. If so, we will notify you of this at the time.
The bases on which we process information about you
5. Information we process because we have a contractual obligation with you
When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract, we must process the information you give us. Some of this information may be personal information.
We may use it in order to:
- verify your identity for security purposes
- sell products to you
- provide you with our services
- provide you with suggestions and advice on products, services and how to obtain the most from using our website
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
6. Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including our products and services, you provide your consent to us to process information that may be personal information.
If you have given us explicit permission to do so, we may from time to time, pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us through the website. However, if you do so, you may not be able to use our website or our services further.
7. Information we process for the purposes of legitimate interests
We may process the information on the basis there is a legitimate interest, either to you or to us, of doing so.
Where we process your information on this basis, we do after having given careful consideration to:
- whether the same objective could be achieved through other means
- whether processing (or not processing) might cause you harm
- whether you would expect us to process your information, and whether you would, in the round, consider it reasonable to do so
For example, we may process your information on this basis for the purposes of:
- record-keeping for the proper and necessary administration of our business
- responding to unsolicited communication from you to which we believe you would expect a response
- protecting and asserting the legal rights of any party
- insuring against or obtaining professional advice that is required to manage our business risk
- protecting your interests where we believe we have a duty to do so
8. Information we process because we have a legal obligation
Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorization such as a search warrant or court order.
This may include your personal information.
Specific uses of information you provide to us
9. Information provided on the understanding that it will be shared with a third party
Our website allows you to post information with a view to that information being read, copied, downloaded, or used by other people.
- posting a message on our forum
- tagging an image
- clicking on an icon next to another visitor’s message to convey your agreement, disagreement or thanks
In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it.
We do not specifically use this information except to allow it to be displayed or shared.
We do store it, and we reserve a right to use it in the future in any way we decide.
Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.
Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion, we may agree to your request to delete personal information that you have posted. You can make a request by contacting us through the WriteOnline webpage or through the Information Officer’s private email address.
10. Complaints regarding content on our website
Our website is a publishing medium. Anyone may register and then publish information about himself, herself or some other person.
We attempt to moderate user generated content, but we are not always able to do so as soon as that content is published.
You are requested to please be careful about disclosing personal information during your interactions on the chat-room forums during a course.
If you complain about any of the content on our website, we shall investigate your complaint.
If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.
Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.
If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.
11. Communicating with us
When you contact us, whether by telephone, through our website or by e-mail, we collect the information you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our business.
We keep personally identifiable information associated with your messages, such as your name and email address so as to be able to track our communications with you to provide a high-quality service.
When we receive a complaint, we record all the information you have given to us.
We use that information to resolve your complaint.
If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
Reasonable security safeguards have been implemented to protect the personal information you have supplied. Although WriteOnline cannot prevent all security threats, we have measures in place to minimise the threat to your privacy. The security of the website is regularly monitored for vulnerabilities and attacks.
13. Affiliate and business partner information
This is information given to us by you in your capacity as an affiliate of us or as a business partner.
The information is not used for any other purpose.
We undertake to preserve the confidentiality of the information and of the terms of our relationship.
We expect any affiliate or partner to agree to reciprocate this policy.
Use of information we collect through automated systems when you visit our website
Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalized experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
- to track how you use our website
- to record whether you have seen specific messages we display on our website
- to keep you signed in to our website
- to record your answers to surveys and questionnaires on our website while you complete them
- to record the conversation thread during a live chat with our support team
15. Personal identifiable information from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the information possibly could be used to identify you personally, even if you are not signed in to our website.
16. Our use of re-marketing
Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve you an advert for our products or services when you visit some other website.
We distribute a newsletter via Mailchimp. You can unsubscribe from the newsletter at any time.
Disclosure and sharing of your information
17. Information we obtain from third parties
Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive information that is indirectly made up from your personal information from third parties whose services we use.
No such information is personally identifiable to you.
18. Third-party advertising on our website
Third parties may advertise on our website. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on our website.
We do not have control over these technologies or the information that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.
19. Information may be processed outside South Africa
Our websites are hosted in the United States of America.
We may also use outsourced services in countries outside South Africa from time to time in other aspects of our business.
Accordingly, information obtained within South Africa or any other country could be processed outside South Africa.
For example, some of the software our website uses may have been developed in the United States of America or Australia.
Control over your own information
20. Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes.
21. Access to your personal information
At any time you may review or update personally identifiable information that we hold about you, by signing in to your account on our website.
To obtain a copy of any information that is not provided on our website you should contact us to make that request.
After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
22. Removal of your information
If you wish us to remove personally identifiable information from our website, you should contact us to make your request.
This may limit the service we can provide to you.
23. Verification of your information
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
24. Use of website by children
We do not sell products or provide services for purchase by children, nor do we market to children.
If you are under 18, you may use our website only with consent from a parent or guardian
We collect information about all users of and visitors to these areas regardless of age, and we anticipate that some of those users and visitors will be children.
Such child users and visitors will inevitably visit other parts of the website and will be subject to whatever on-site marketing they find, wherever they visit.
25. Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or another trust mark in your browser’s URL bar or toolbar.
26. How you can complain
If a dispute is not settled, then we hope you will agree to attempt to resolve it by engaging in good faith with us in the process of mediation or arbitration.
27. Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
- to provide you with the services you have requested;
- to comply with other law, including for the period demanded by our tax authorities;
- to support a claim or defence in court.
28. Compliance with the law
However, ultimately it is your choice as to whether you wish to use our website.
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.