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Privacy Policy

USB Executive Development (Pty) Ltd. (“USB-ED”, “we”, or “us”) is committed to protecting your privacy as an individual, or that of the organisation you represent, in accordance with all laws, regulations that USB-ED is required to comply with (“Applicable Law”). This Privacy Policy (the “Privacy Policy”) sets out the basis on which any personal information we collect from you, or that you provide to us, will be collected, used, stored and disclosed by us when you visit and use www.usb-ed.com, partner and shareholder websites, 3rd party Service Providers, USB-ED’s remote learning and video conferencing environments, faculty management system, human capital and financial management platforms, Learner Management Systems (collectively, the “Websites”).

By submitting any personal information to USB-ED you provide consent to the processing of your personal information as set out in this Privacy Policy. By accessing, using and/or downloading any Content from the Websites in any way, you signify that you have read and agree to comply and be bound by the terms of this Privacy Policy. If you do not agree with this Privacy Policy, please do not continue to use the Websites.

How to Contact us:

If you have any comments or questions about this Privacy Policy please direct your enquiry to:

Deputy Information Officer: Ms. Auriel Bayard
Email: privacy@usb-ed.com

Types of Personal Information Collected

You, as the data subject, consent to the collection of information about you that is deemed necessary for our legitimate business interests, and may include the following: full name, address, email address, telephone number, gender, date of birth, ethnicity, disability, employment details, home language, government issued identifier, prior educational background information, physical address, geographic location, work experience, as well as non-personal information; records of correspondence or enquiries from you or anyone acting on your behalf; details of transactions you carry out with us; details of contracts, sales or leases you carry out with us; sensitive or special categories of personal information, including biometric information, such as images, fingerprints and voiceprints; consumer credit information at any credit bureau or third party.

Suppliers and Vendors:

In terms of USB-ED’s suppliers and vendors, in the course of our business agreement we may collect personal information about our suppliers and vendors as data subjects, to ensure that the business agreement and matters relating to the agreement can be fulfilled. We may also do due diligence on our suppliers and vendors to ensure that they meet the requirements set out in our procurement procedures. In the event that suppliers and/or vendors provide any personal information of other persons to us, such as employees or directors, it is warranted that the supplier / vendor is authorised to share this personal information with USB-ED for purposes of conducting legitimate business.

Information automatically collected

When you visit the Websites or interact with emails that we send to you, we may passively collect information from you and store that information on our server logs, including your internet protocol address (“IP address”), browser type, operating system, device identifier, device model, software version, or mobile or ISP carrier information. We use Cookies and other technologies to collect information about your visit to the Websites, Please see USB-ED’s Cookie Policy for details on how we use cookies.

Information collected from other sources

Where permitted by law, we collect or receive information about you from companies to whom you indicate that you would like to learn more about the Programme, companies that are our partners, or other entities within the Stellenbosch University umbrella or our partner companies (collectively “Other Sources”) in order to update or supplement the information that you provide or that we collect automatically. We may use this information to help us maintain the accuracy of the information we collect, to target our communications so that we can inform you of products, services or other offers that may be of interest to you, and for internal business analysis or other business purposes. We may combine the information we receive from and about you, via the Websites and from Other Sources to help us tailor our communications to you and to improve the Websites.

Failure to provide personal information

Failure to provide certain information may make it difficult or impossible for you to access some services through the Websites (for example, to register for and complete Programmes). You should ensure that personal information submitted to us is accurate and up-to-date.

Information of Children

We do not intend to collect and/or process any personal information of children under the age of 16, unless we make this clear.

Use of Personal Information Collected

We process personal information under the following legal bases:

  1. To fulfill a contract or take steps linked to a contract, including:

    1. providing our services to individuals and companies
    2. verifying your identity
    3. taking payments
    4. communicating with you.

  2. To conduct USB-ED’s business and pursue our legitimate interests in marketing our business, ensuring that we conduct our business in line with our objectives, improving and developing our products and services, and keeping our records accurate and up to date. This includes:

    1. using your information to provide products and services you have requested and responding to any comments or complaints you may send us;
    2. assessing and dealing with complaints and requests;
    3. personalising your experience on the Websites and in any Programme in which you choose to enrol and to help us to better respond to your individual needs;
    4. targeting advertising to groups of individuals with similar interests or characteristics through services offered by third party Service Providers
    5. developing new products or services or conducting analyses to enhance current products and services
    6. reviewing the usage and operations of the Websites and analysing and improving the Websites
    7. conducting market research and providing you with information about USB-ED’s products or services from time to time via email, telephone or other means (for example, events);
    8. protecting the security and functionality of the Websites, including using personal information you provide to investigate any complaints received from you or from others about our Websites or our products and services.

  3. To protect the security and functionality of the Websites. This includes:

    1. if you provide a credit or debit card as payment, using third parties to check the validity of the sort code or routing number, account number and card number you submit in order to prevent fraud
    2. monitoring customer accounts to prevent, investigate and/or report fraud, misrepresentation, security incidents or crime, in accordance with Applicable law.

  4. Where you give us consent. This includes:

    1. where consent is required by Applicable Law, sending you direct marketing in relation to our relevant products and services, or other products and services provided by USB-ED, its partner companies and affiliate entities within the Stellenbosch University umbrella;
    2. on other occasions where we ask you for consent, using the data for the purpose which we explain at that time.

  5. For purposes which are required by law. This includes:

    1. in response to requests by government or law enforcement authorities conducting an investigation;
    2. using personal information in connection with legal claims, compliance, regulatory and investigative purposes as necessary, including disclosure of such information in connection with legal process or litigation.

  6. For reasons not described in this Privacy Policy where the reason is compatible with the purpose for which we originally collected your information and where such use is lawful.

Use of de-identified, aggregate or anonymized information

We use de-identified aggregate information to help us analyze the use of the Websites. Where permitted by law, this Privacy Policy does not limit our use or disclosure of de-identified, aggregate information, and we reserve the right to use and disclose such information to our partners, advertisers, and other third parties at our discretion.

Disclosure of Personal Information

USB-ED shares your information with other entities or individuals in the following circumstances:

  1. Learning Partners: We may share your information with the relevant learning partner or in-country orgabisation with which we collaborate on Programmes (“Learning Partner”) in order to process your information, track your participation in the Programme, and/or fulfill our contracted responsibilities to the Learning Partner. Once we share your personal information with the Learning Partner, USB-ED does not maintain control over the Learning Partner’s use of your personal information. We may also share de-identified, aggregate information with the Learning Partner for their own research and analytics purposes. The Learning Partner’s use of your information is subject to its own privacy policy.
  2. Stellenbosch University: Where you have expressed interest and given your consent, we share your information with our major shareholder, Stellenbsoch University, to provide you with information about other educational / development programmes and/or opportunities
  3. Third Party Service Providers: We share your information with third parties that provide business, professional, or technical support functions for us. In particular, we use third-party providers for website hosting, maintenance, marketing services, courier services, certification services, business operations, payment services, and identity verification services (“Service Providers”). These Service Providers are only given access to your information to the extent necessary to process your information and/or provide services to USB-ED, and they are prohibited from using or sharing your information for any other purposes. Where permitted by law, USB-ED discloses limited information about you to Service Providers to serve relevant advertising on third party platforms to you or to other audiences.
  4. Third Parties and International transfers: We may transfer your information to another of USB-ED’s entities, a learning partner or third party who carries on business in another country, including one which may not have data privacy laws similar to those of the Republic. If this happens, we will ensure that anyone to whom we pass your information agrees to treat your information with the same level of protection as if we were dealing with it. If you do not wish us to disclose this information to third parties, please reach out to us. We may, however, not be able to provide products or services to you if you do not agree with such disclosure.
  5. Your employer / our client: We share your information with your employer, in the event that the employer is paying for your Programme (“Your Employer / Our Client”). Information disclosed in this case shall include Programme performance information, unless otherwise expressly agreed in writing with USB-ED.
  6. Legal matters; safety: We access or share your information to satisfy any applicable law, regulation, legal process, or governmental request; in connection with an investigation on matters related to public safety; as permitted by law; or otherwise as required by law. We may disclose your information to protect the security of the Programme, the Websites, servers, network systems, and databases.
  7. Fraud; security: We access and disclose your information to detect, prevent, or otherwise address fraud, security or other technical issues.
  8. Consent; other: We share information with third parties when we have your consent, or otherwise as described to you at the point of information gathering.
  9. Sale or transfer of business or assets: USB-ED may sell or purchase assets during the normal course of our business. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties. Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use your information in a manner that is consistent with this Privacy Policy.

Retention of Personal Information

We may retain your personal information indefinitely, unless you object, in which case we will only retain it if we are permitted or required to do so in terms of Applicable Laws. However, as a general rule, we will retain your information in accordance with retention periods set out in Applicable Laws, unless we need to retain it for longer for a lawful purpose. (For example, for the purposes of complaints handling, legal processes and proceedings.)

Access to, correction and deletion of Personal Information

If you are enrolled in a Programme, you may access and/or update your personal information via your user profile on our Learner Management System or your subscription preferences on www.usb-ed.com.

In some instances, you may request details of personal information which we hold about you under the Promotion of Access to Information Act, 2000 (“PAIA”). You may request the correction of personal information USB-ED holds about you. Please ensure that the information we hold about you is complete, accurate and up to date. You have a right in certain circumstances to request the destruction or deletion of and, where applicable, to obtain restriction on the processing of personal information held about you. You have a right to object on reasonable grounds to the processing of your personal information where the processing is carried out in order to protect our legitimate interests or your legitimate interests, unless the law provides for such processing.

Our use of certain personal information is necessary for us to provide information to you about the Programme or to provide services to you through the Websites or otherwise. If you choose not to provide this personal information or request that USB-ED delete or restrict the processing of this personal information, you may not be able to participate in the Programme, and we may not be able to provide you with other services, including those provided through the Websites or advertised about the Programme.

Personal Information security and Indemnity

We are committed to protecting the security of your information. We are taking reasonable technical and operational measures to prevent unauthorised access to and disclosure of your personal information, as well as to maintain its accuracy, and to safeguard appropriate use thereof. However, we do not guarantee that your information shall be 100% secure. It is important that you take all necessary and appropriate steps to protect your personal information yourself (for example, by ensuring that all passwords and access codes are kept secure). USB-ED will not be held responsible for any unauthorized access to or acquisition of your information.

Publicly Available Content

Any information you may disclose through the Websites, such as on message boards, in chat rooms, or on other public areas, such as on webinars / virtual learning sessions that you may attend about the Programmes, may be viewed by others, such as your fellow participants and facilitators. Please exercise caution when disclosing personal information in these public areas. If you do not want USB-ED to store metadata associated with your content, please remove the metadata before uploading your content.

Third-Party Content

The Websites may also offer you the ability to interact with content provided by third parties not affiliated with USB-ED (“Third-Party Content”). Third-Party Content linked to or embedded on the Websites is governed by the privacy policies of those third parties. Your use of Third-Party Content is subject to each site’s privacy policy, which may be different from ours. We have no control over the information that is collected, stored, or used by Third-Party Content.

Amendments to this Privacy Policy

We may amend this Statement from time to time for any of the following reasons:

  1. to provide for the introduction of new systems, methods of operation, services, products, property offerings or facilities;
  2. to comply with changes to any legal or regulatory requirement;
  3. to ensure that our Privacy Policy is clearer and more favourable to you;
  4. to rectify any mistake that may be discovered from time to time; and/or
  5. for any other reason which USB-ED, in its sole discretion, may deem reasonable or necessary.

USB-ED will take reasonable steps to notify you of such an amendment, including publication on our website. It is your responsibility to check the website often.

Complaints:

Should you believe that USB-ED has utilised your personal information contrary to Applicable Laws, you undertake to first attempt to resolve any concerns with USB-ED:

Name of Private Body: USB Executive Development (Pty) Ltd
Deputy Information Officer: Ms. Auriel Bayard
Email: privacy@usb-ed.com
Postal address: PO Box 610, Bellville, 7535, Cape Town, South Africa

If you are not satisfied with such process, you may have the right to lodge a complaint with the Information Regulator, as follows:

Email: inforeg@justice.gov.za
Tel: +27 (0)12 406 4818

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