Privacy Policy

Digital Frontiers

1. Introduction
2. What information do we collect?
3. Cookies and Third-Party Technologies
4. Who Do We Use Your Information?
5. Who Do We Disclose This Information To?
6. Our Processing Principles
7. User Rights
8. Processing Your Data Outside South Africa
9. Use Of the Website By Children
10. Questions or Concerns About this Policy

1. Introduction

This is the privacy policy of Digital Frontiers NPC (registration number 2017/127296/08), a non-profit company registered in the Republic of South Africa, with its registered office being at office no.3, Watershed, 17 Dock Road, V&A Waterfront, Cape Town, 8002 (“Privacy Policy”).

We are committed to protecting the privacy, accuracy and reliability of all personal information and to safeguarding such information from loss, misuse, unathorised access, disclosure, alteration and destruction in accordance with applicable data protection laws, including the Protection of Personal Information Act (No. 4 of 2013) (“POPI“) and, where applicable, the General Data Protection Regulation (EU 2016/679) (“GDPR“), which includes the retained EU law version of GDPR as it forms part of the law of the United Kingdom, and any other applicable data protection legislation and/or regulation (collectively, the “Data Protection Laws“). For the purposes of GDPR, we are, in different instances, a data controller and a data processor, respectively.

This Privacy Policy sets out the basis on which we process personal information about you when you visit our websites (https://digitalfrontiersinstitute.org/ and https://gateway.academy/), access our online campus platform(s) (each, our “Website”), or otherwise contact us and/or use our services (together, our “Services”).

By making use of any of our Services, you agree to be bound by this Privacy Policy. If you do not accept or understand this Policy for any reason you should stop using our Services immediately.

Questions, comments and complaints about our data practices can be submitted to our information officer:

2. What Information Do We Collect?

We process your personal information only where we have a lawful basis to do so. Accordingly, we will only process your personal data where:

• You provide consent for us to do so (which consent can be freely withdrawn at any time by you)
• It is necessary for us to perform any contractual obligations to you

• We have a legitimate interest in processing the information in order to provide our Services, and/or for our legitimate business purposes, for example, to communicate with you, to use data for analytics purposes, to combat fraud)
• We are under a legal obligation to do so
• In order to establish, exercise or defend our legal rights.
• To protect the rights, property or personal safety of another student and/or any member of the public.

We may collect information submitted by you, for example, when you complete a survey or application form, submit information to us through the Website, or when you contact us. The information we collect may include personal information about you, such as your name and contact details (or other information that can be used to identify you), or non-personally identifiable information (anonymous data). When you submit information to us, you consent, in each instance, to us using same. This consent may be withdrawn at any time, except where we are required to continue to use such information in order to perform our contractual obligations to you, or where such information is needed for our legitimate business interests.

By transmitting personal information to us belonging to a third party, you warrant that you have the requisite authority for us to process such information. You must notify us immediately if any consent has not been obtained or if it is withdrawn. You indemnify us to the fullest extent permitted by law for any loss which may occur as a result of you disclosing personal information to us without the requisite authority.

When you visit the Website or receive correspondence from us, we may passively process information from you, including, your IP address, what browser software and operating system you are using, and your ISP carrier information. You can control the technologies we use by utilising the settings in your browser or third-party tools, however, refusing or deleting some cookies may make it impossible for us to provide our Services to you, and may limit your access to certain functions. You can read more about our policies relating to automated collections below.

We don’t collect financial/credit card information. At the point of making payment via our Website, you will be transferred to a secure page belonging to Paygate or Paypal. That page may be dressed in our “livery”, but it is not controlled by us. Our staff and contractors never have access to it.

You may also choose to submit personal information to us via other methods, including, but not limited to: (i) in response to marketing or other communications, (ii) through social media or online forums, (iii) through participation in an offer, program or promotion, or (iv) in connection with an actual or prospective business relationship with us.

3. Cookies and Third-Party Technologies

“Cookies” are small files stored on your computer during your use of the Website and which contain data about your use of the Website. We may use session Cookies (which expire when you close your browser) or persistent Cookies (which stay on your computer until you delete them) to understand more about your activity on the Website or on other websites, including for:

• Authenticating users
• Remembering preferences and settings
• Determining the popularity of Website content
• Delivering and measuring the effectiveness of advertising campaigns

• Analysing site traffic and trends
• Operating our content management system
• Enhancing security.
• Recording that a user has viewed a webcast. It collects information in an anonymous form. This Cookie expires when you close your browser.
• Recording your activity during a webcast. This Cookie will record an anonymous ID for each user, but it will not use the information for any other purpose. This Cookie will last for three months, following which it deletes automatically.

• Enabling you to watch videos we have placed on YouTube. YouTube will not store personally identifiable Cookie information if you use YouTube’s privacy-enhanced mode.

We also use Cookies and other technologies to collect information about your visit to the Website, such as the date and time of your visit, the information you searched to find the Website, or your activity on the Website.

You may adjust your browser or operating system settings to limit or to decline or delete Cookies, but this may affect your use of certain areas of the Website. Check the settings menu of your browser or operating system to learn how to change your tracking settings or Cookie preferences. On your mobile device, you can adjust your privacy and advertising settings to limit your tracking for advertising or control whether you receive more relevant advertising.

4. How We Use Your Information

We may use your information for the following purposes:

• To provide our Services
• To personalise your use of the Website
• To develop new services or to conduct analysis of our Services
• To review usage and operation of the Website
• To contact you

• Marketing (although you will always be able to opt out of receiving such marketing correspondence)
• Providing you with course information
• Responding to your queries
• Other legitimate business purposes
• Verifying your identity

We may also use your non-personally identifiable information in an anonymous manner to analyse the use of our Services.

5. Who Do We Disclose Your Information To?

• To donors and/or funders

We may share your information with donors and/or funders in order to generate reports on pass/fail rates and for statistical reasons, to analyse participation. The information we provide in this regard will not be personally identifiable information.

• Service providers, affiliates and related entities

We may share your information with these parties to render the Services, and/or otherwise for our internal administration purposes, including to provide us with business, professional, or technical support. These persons will only be provided with access to your personal information to the extent necessary, and they may not use or share your personal information for any other purposes.

• Legal obligations

We may process your personal information in any manner necessary in order to comply with any law, regulation legal process or governmental request. We may also access and/or disclose your personal information if it is necessary for an investigation relating to public safety, or as otherwise required by law.

• Security

We may process your personal information to protect the security of the Website, our servers, network systems, and databases. We may also disclose your personal information as necessary where there has been a violation of any legal document or contract related to the Website, or the rights of any third party.

• Fraud

We may access and disclose your information in order to combat fraud.

• Non-personally identifiable or anonymised data

We may also use and share non-personally identifiable, aggregate or anonymous information, provided it can no longer be linked to you.

6. Our Processing Principles

We are committed to protecting your personal information. We maintain appropriate procedures to safeguard and secure your personal information and to prevent unauthorised access of your personal information. The accuracy, safety, and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Website, you are responsible for keeping this password confidential. Even though we do our best to protect your information, the transmission of information via the internet is not completely secure, and we cannot guarantee our security measures. We are not responsible for any unauthorised access to or acquisition of your information.

We will only retain personal information for as long as is necessary for the purposes for which it is obtained, unless otherwise permitted by law, or requested by you.

To ensure that your personal information is processed correctly and with a suitable level of privacy, we have adopted the following processing principles:

• Personal information is processed in a manner that is lawful, fair and transparent
• Personal information is collected only for specified, explicit and legitimate purposes (and not further processed in a manner that is incompatible with those purposes)

• Personal information is adequate, relevant and is limited to what is necessary in relation to the purposes for which it is processed
• Personal information is accurate and kept up to date, and inaccurate or incomplete personal information will be rectified, erased or further processing suspended
• Personal information is processed in a manner that ensures appropriate security of the personal information

7. User Rights

You have the following rights:

• Right of access – to request a copy of the personal information that we hold about you.
• Right of rectification – to correct data that we hold about you that is inaccurate or incomplete. Failure to provide updated information may make it difficult or impossible for you to access certain Services (for example, to course registration). You will need to ensure your personal information is accurate and up-to-date.
• Right to be forgotten – to ask for the data we hold about you to be erased from our records, in certain circumstances.
• Right to restriction of processing – to restrict processing of your information in certain circumstances.
• Right of portability – to have the data we hold about you transferred to another organisation.

• Right to object – to object to certain types of processing such as direct marketing.
• Right to object – to object to the automated processing or profiling.
• Right to judicial review – you have the right to complain to a relevant authority regarding the use of your personal information by us.
• Right to withdraw consent – you have the right to withdraw your consent to us processing your personal information, by contacting our information officer.

You will not generally have to pay a fee to access your personal information or to exercise any of your other rights in terms of this Privacy Policy. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

To better safeguard your information, we will take reasonable steps to verify your identity before granting access or making corrections to your information.

8. Processing Your Data Outside South Africa

Personal information obtained within South Africa may be processed outside South Africa and personal information obtained in any other country may be processed within or outside that country. We shall ensure that our host providers are subject to laws, or policies, which uphold principles for the reasonable processing of information substantially similar to POPI to ensure adequate protection of any such information.

We shall ensure that any personal information belonging to a resident of the European Union (“EU Personal Data“) shall be processed in accordance with GDPR. This envisages, inter alia, that the EU Personal information shall be:

• processed lawfully fairly and in a transparent manner;

• accurate and, where necessary, kept up to date;
• kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal information are processed;
• processed in a manner that ensures appropriate security of personal information, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

9. Use of the Website by children

No person under the age of 18 should submit any personal information to us or use the Services without their legal guardian’s consent and supervision. We do not market to, nor do we sell products or services for purchase to anyone under the age of 18. Accordingly, we do not knowingly process any personal information belonging to minors.

10. Questions or Concerns About This Policy

If you would like to exercise any of your rights in respect of your personal information or have any queries or complaints on how we have handled your personal information, please contact us via our information officer so we can investigate the matter. You also have the right to lodge a complaint with the relevant regulatory body which, for the purposes of POPI, is the Information Regulator. The Information Regulator can be contacted by email: complaints.IR@justice.gov.za or inforeg@justice.gov.za.

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