PRIVACY POLICY

EFFECTIVE UPON 10 MARCH 2023

PLEASE ENSURE THAT YOU READ THIS POLICY BEFORE USING OUR SERVICES.

Our website and/or our services are provided on the basis that you have read and agreed to the terms of this privacy policy. We reserve the right to modify this privacy policy at any time, so please review it frequently.

  1. SCOPE

This policy explains how we obtain, use and disclose your personal information, in accordance with the requirements of the Protection of Personal Information Act (the “Act”).

It applies to all personal information (as defined below) which we may collect and process (more on this below).

  1. WHO IS THE RESPONSIBLE PARTY OF THE INFORMATION?

We are Mind Growth Masters of Cottage 6 Klipper Close, 9e Klipper Rd, Rondebosch, Cape Town, 7750 and the designated information officer is Sarah Hallas who can be contacted on sarah@mindgrowthmasters.com or on +27 82 808 4530.

Should you contact us in relation to this policy, including amending any of your personal information, withdrawing consent to processing of information or a query as to what personal information we hold, you must do so in writing and we may require a copy of your ID or other proof that you are who you say you are and that your request is valid.

  1. WHAT IS PERSONAL INFORMATION?
  • Personal information is any information relating to an identifiable, living individual or business. It includes, but is not limited to:
  • Identifiers such as: a name, identity number, staff number, account number, tax number, physical address or any other “assignment” to the person used to identify them.
  • Demographic information such as: race; gender; sex; pregnancy; marital status; national, ethnic or social origin; colour; sexual orientation; age; physical or mental health or well-being; disability; religion; conscience; belief; culture; language and birth.
  • Financial information such as: bank and other account numbers; bank statements; salary information; financial statements.
  • Usernames and passwords.
  • Background information such as: education; financial, employment, medical or criminal history.
  • Biometric information: this refers to techniques of identification that is based on physical, physiological or behavioural characterisation such as blood typing, fingerprinting, DNA analysis, retinal scanning and voice recognition.
  • A person’s personal opinions, views and preferences.
  • Correspondence sent by the person that is of a private or confidential nature and any further correspondence that would reveal the contents of the original correspondence.
  • Views or opinions about a person (such as interview notes and preferences).
  • The following personal information may be processed by us for legitimate reasons:
  • Company information of our clients in order to conclude a contract with them and to provide our services effectively.
  • Employee details including personal information identified above and, specifically, job descriptors, roles, salaries and remuneration packages, grievances and labour disputes.
  • Training and test results.
  • Details of the services we provide you.
  • Email addresses.
  1. WHERE DO WE GET YOUR PERSONAL INFORMATION FROM?

Personal information is obtained in the following ways:

  • Information provided by you directly through: email correspondence; the completion of forms; use of our services ; telephone calls or otherwise supplying us with information.
  • Information collected when you visit our website or connect with us, which may be processed without you supplying it and may occur through technologies such as:
    • Cookies: These are small bits of data which is stored by the server on the device used to browse the website. The cookie records the user’s preferences and actions which enables the web application to create an experience tailor made for that user. The cookie will record and store information such as items purchased, links clicked and pages visited.
    • Online Analytics: these are web analytics services provided by companies such as Google. The Online Analytics will use tracking technology to establish website activity. The duration of your visit, pages visited per session and bounce rate of the user is recorded. The information is used to establish the effectiveness of marketing, design and functionality of the website as it is an accurate reflection of user behaviour.
    • Log Files: information such as your IP address, information concerning your computer’s operating system, language settings, your browser and the website from which you visited us may be recorded when you visit the website. The information is used to establish website trends and make necessary changes.
    • Information from third parties: we may receive information that is publicly or commercially available.
  1. HOW DO WE PROCESS YOUR PERSONAL INFORMATION?
    • Processing is defined as any operation or activity or any set of operations, whether or not by automatic means, concerning personal information, including:
    • The collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use;
    • Dissemination by means of transmission, distribution or making available in any other form;
    • Merging, linking, as well as restriction, degradation, erasure or destruction of information.
      • We process your information in the following ways:
        • Collection, receipt and/or recordal of personal information.
        • Storage of information where necessary.
        • Information is updated as required.
        • Information is modified when necessary.
        • Information is shared with third parties such as service providers or where legally required.
        1. WHAT ARE THE REASONS FOR THE PROCESSING OF YOUR PERSONAL INFORMATION?
      • Your personal information is processed if it is in your legitimate interest or our legitimate interest and, specifically, for the following reasons:
      • To provide you with our services.
      • To manage your account or relationship and to comply with your instruction or requests.
      • To manage our contractual relationship with you.
      • To respond to queries, requests or comments made by you.
      • To analyse and improve the functioning of our website.
      • To process payments, accounting, auditing and delivery of our services.
      • To comply with legal obligations and legislation.
      • To comply with an order of court.
      • To detect and prevent fraud.
      • To provide you with administrative information such as changes to terms and conditions.
      • To conduct market research and provide you with information about our services from time to time via email, telephone or other means.
      • To enhance, improve or modify our current services.
      • DISCLOSURE OF PERSONAL INFORMATION
      • Comply with legislative requirements
      • Comply with an order of court
      • Protect our rights.

 

      1. RETENTION OF PERSONAL INFORMATION

We may retain personal information records indefinitely, but at least for the period required by law or otherwise for as long as we need to. Retaining a history of what services we have provided to you and what you, your business and/or your employees are about is useful in order for us to continue to provide you with an effective service.

Should you wish to object to the permanent retention of your personal information, it will be retained for the period prescribed by law. You can request to have your information deleted. However, we may not be able to comply with your request if we are under a legal obligation to retain the information. In some cases we may choose to retain certain information in anonymised or aggregated form.

 

      1. RIGHT TO ACCESS, RECTIFICATION AND DELETION OF PERSONAL INFORMATION
        • You have the right to request access to your personal information retained by us for purposes of correcting information and deleting incorrect personal information. It is requested that you ensure that all personal information held by us is complete, accurate and current.
      • You also have the right to:
        • ask what personal information we have about you,
        • ask what personal information was sent to our suppliers, service providers, or any other third party,
        • ask us to update, correct, or delete any out-of-date or incorrect personal information we have about you,
        • unsubscribe from any direct marketing communications we may send you,
        • object to the processing of your personal information, and
        • lodge a complaint about our practices with the Information Regulator.
      1. RIGHT TO WITHDRAW CONSENT AND OBJECT TO THE PROCESSING OF DATA OBJECTION

If you have consented to the processing of personal information which is being processed by us, you have the right to withdraw such consent. You have the right to object to the processing of personal information on reasonable grounds. Should you wish to withdraw your consent or object to the processing of your personal information, you may submit the objection or withdrawal to the Information Officer at clare@tacticalhrsolutions.co.za.

      1. RIGHT TO LODGE A COMPLAINT

Should you feel that the processing of your data is done in a manner which does not comply with the Act, you may lodge a complaint with the Information Regulator using the following details: Information Regulator (South Africa) Email: complaints.IR@justice.gov.za

      1. SECURITY SAFEGUARDS

We will take the necessary precautions to secure the integrity and confidentiality of personal information in our possession or under our control by taking appropriate and reasonable technical and organisational measures to prevent the loss, damage, destruction and unauthorised access and processing of personal information. We regularly monitor our systems for possible vulnerabilities and security breaches, but no system is perfect, and we cannot guarantee that we will never experience a breach of any of our physical, technical or managerial safeguards. If something should happen, we have taken steps to minimise the threat to your privacy. We will let you know of any breaches which affect your personal information and inform you how you can help minimise the impact. If you suspect that we (or you) have had a security breach, please notify us immediately by sending an email to sarah@mindgrowthmasters.com.