Date of Last Review: 19 July 2022
Page:
KolabEduTech (Pty) Ltd
Reg: 2020/258885/07
Directors: Nikole Montano
44 8th Avenue
Parktown North
2193
PRIVACY POLICY
Table of Contents
Scope and Content .............................................................................................................................................................................. 1
Who This Policy Applies To ............................................................................................................................................................... 1
Your Consent ...................................................................................................................................................................................... 1
Interpretation ....................................................................................................................................................................................... 1
Definitions .......................................................................................................................................................................................... 1
Collection of Content .......................................................................................................................................................................... 2
How Information Is Used .................................................................................................................................................................... 5
Our Lawful Basis ................................................................................................................................................................................ 7
Disclosure ........................................................................................................................................................................................... 7
Access, Correction, Deletion and Opting Out ..................................................................................................................................... 7
Tracking Technologies and Cookies ................................................................................................................................................... 8
Retention of Your Personal Data ........................................................................................................................................................ 8
Security of Your Personal Data .......................................................................................................................................................... 8
Transfer of Your Personal Data .......................................................................................................................................................... 8
Third Parties and Links To Other Websites ........................................................................................................................................ 8
Changes To This Privacy Policy ....................................................................................................................................................... 10
Contact Us ........................................................................................................................................................................................ 10
Date of Last Review: 19 July 2022
Page 1
44 8th Avenue
Parktown North
2193
KolabEduTech (Pty) Ltd
Reg: 2020/258885/07
Directors: Nikole Montano
Scope and Content
This Policy is in terms of the Protection of Personal Information Act and outlines what Personal Information is
collected, how it is collected, used, and disclosed, and how We uphold Your right to the Protection of Personal
Information when You make use of Our Service.
Who This Policy Applies To
This Policy applies to visitors of the Website, Users of the App, Sponsors, and Clients who have contacted Us.
Your Consent
By vising Our website, downloading Our App, subscribing to Our Service, registering an Account, or making a
purchase, You consent to this Privacy Policy.
Interpretation
The words of which the initial letter is capitalised have meanings defined under the following conditions. Clause and paragraph
headings are for purposes of reference only and shall not be used in interpretation. Unless the context clearly indicates a contrary
intention, any word connoting:
Any gender includes the other genders;
The singular includes the plural and vice versa; and
Natural persons include juristic persons and vice versa.
Definitions
For the purposes of this Privacy Policy:
“Account” means a unique Account created for You to access Our Service or parts of Our Service;
“Cookies” means a small amount of data generated by a website and saved by Your web browser. It is used to identify Your
browser, provide analytics, and remember information about You such as Your language preference or login information;
“Corporate Affiliates” means any person or entity which directly or indirectly controls, is controlled by or is under common
control with Us, whether by ownership or otherwise;
“Country” refers to the Republic of South Africa;
“De-Identify” means “to delete any information that—
o (a) identifies the data subject;
o (b) can be used or manipulated by a reasonably foreseeable method to identify the data subject; or
o (c) can be linked by a reasonably foreseeable method to other information that identifies the data subject,”;
Date of Last Review: 19 July 2022
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44 8th Avenue
Parktown North
2193
KolabEduTech (Pty) Ltd
Reg: 2020/258885/07
Directors: Nikole Montano
“Device” means any internet connected Device such as a phone, tablet, computer, or any other Device that can be used to
visit Our Service and use the Services;
“Flash Cookies” means Cookies that use locally stored objects;
“IP Address” means the number assigned to every Device connected to the Internet;
“Personal Data” means any information that can be used to identify a natural and/or juristic person;
“Personal Information” means information according to the applicable Personal Information laws which can be used to
identify a person;
“POPIA” means the Protection of Personal Information Act 4 of 2013;
“Public Information” means any information, including Personal Information, You share with a public audience, including
Personal Information You publish on Our site. Public information is available to anyone on or off Our Services and can be
seen or accessed through online search engines, APIs, and offline media;
“Service” means the kolab Website and Mobile Application;
“Sponsee” means the person being Sponsored by the Sponsor;
“Sponsor” means the person sponsoring the fees of the Sponsee for the use and access to Our Service;
“Sponsorship Agreement” means the Agreement entered into between the Sponsor and Sponsee;
“We”, “Us”, “Our” or “kolab” means KolabEduTech (Pty) Ltd;
“Web Beacon” means a small electronic file to check the User count of certain pages to generate statistics; and
“You” or “Your” means the individual accessing or using the Service and who is identifiable from the Personal Information.
Collection of Content
Types of Data Collected
Personal Data
While using Our Service, We may ask You to provide Us with certain Personally Identifiable Information that can be used to contact
or identify You. We rely on Your explicit consent to the collection and distribution of Your Personal Information. Personally
Identifiable Information may include, but is not limited to:
Email address;
First name and last name;
Contact Number;
Photograph;
Subscription Preferences;
Address;
Position;
Employment details;
Usage Data; and
School.
Date of Last Review: 19 July 2022
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44 8th Avenue
Parktown North
2193
KolabEduTech (Pty) Ltd
Reg: 2020/258885/07
Directors: Nikole Montano
Personal Data excludes the following:
Anonymous information;
Permanently de-identified information;
Non-personal statistical information; and
Non-confidential information that is public record.
Sensitive Personal Data
Sensitive Personal Data may be Collected dependant on the goods and/or Services, such as bank account details. Sensitive Personal
Data may also be collected when You upload Your position and Your School’s details.
We may, on occasion, also Collect the following Sensitive Personal Information:
trade union membership;
racial or ethnic origin; and
religious or philosophical beliefs.
Usage Data
Usage Data is collected automatically when using the Service and, in certain instances, even if You have not created an Account.
Third parties may be used to help Us Collect this Information. Usage Data may include information such as:
Information from Devices You use when interacting with Us or Our Service such as Device information and ID or unique
User ID, hardware and software information, Device type, Device event information, ID for advertising, and unique Device
token.
Computer and connection information such as statistics on Your page views, traffic to and from the sites, referral URL, Ad
Data, Your IP Address, Your browsing history, the type of Internet browser You use, the pages, applications or Services
You’ve viewed or engaged with before or after using Our Service, and Your web log information.
Analytics which include, among other things, details about how You’ve used Our Service (including links to third party
applications), the pages of Our Service that You visit, the time and date of Your visit, and the time spent on those pages.
Usage information which includes, but is not limited to, information about Your interactions with Our Services, such as the
pages or other content You view, Your searches, emails and messages generated through Your use of the Service.
Location information such as different types of information about Your general location or more specific location information
may be collected when You use certain features of Our Service. Most mobile Devices allow You to control or disable the
use of location Services for applications in the device’s settings menu. This information may include geo-locations.
Transactional and financial information in order to provide Our Service, We may collect information relating to Your
transactions and financial information relating to Your use of Our Service. This may include dates and times, amounts, related
transaction details, and financial history.
Photos and images when You grant permission to Your camera and photo gallery. This allows You to upload pictures to Our
Service. These permissions can be denied via Your Device.
We may infer certain information from Your activity.
Details that You save to Your profile.
Date of Last Review: 19 July 2022
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44 8th Avenue
Parktown North
2193
KolabEduTech (Pty) Ltd
Reg: 2020/258885/07
Directors: Nikole Montano
Information You give Us
The Information You give Us include the following:
Your Account Information when You register for Our Service and when You update and add Information to Your Account;
Profiles that You may be required to complete, such as adding Your phone number and gender;
Your Job Information for the Service;
Your Identification for authentication and verification of You and Your Account;
Information that You add to forms;
The content You add, including metadata and embedded information;
Payment Information when You make payments, either to Us or third parties, when using Our Service;
The communications between Us or other Users when using Our Service, including, but not limited to calls made to Us and
interacting with Sponsors;
Any communication and engagement with the community on Our Service.
Any other Information You provide directly to Us, such as feedback, searches, updates and additions to information, reviews,
progress updates or other features of Our Service.
If You provide us with any Personal Information relating to a third party (e.g., information of your spouse, children, parents,
employees, and/or persons associated with your institution, organisation or trust etc.), by submitting such Information to Us, You
represent to Us that You have obtained the requisite consent to do so.
Collection from Third Parties
Analytics information from Third Parties, which is generally anonymous but may still include information such as Device
information, IP Address, and Your geodemographic location.
Information to supplement Your Account, to the extent permitted by law, such as publicly available information.
Information provided by other Users about You. However, these Users must receive Your explicit consent and inform You
about the contents of this Policy and other applicable Policies.
Background Information about You, to the extent permitted by applicable laws. This may require You to be subjected to or
must provide credit and background checks, or We may obtain these from public records. If this does occur, We will contact
You. However, if You refuse this requirement, We may refuse You access to Our Service.
Advertising information, unless You have opted out, We may receive information through Our Partnerships with Ad
Networks. This may include You and Your activities on and off Our Service, or about Your experiences and interactions.
Additional information from public sources about You that is publicly available, to the extent permitted by applicable law.
Social Accounts
If You sign in or register Your Account using social media sites, those sites may automatically give Us access to some Personal
Information they hold about You. This may include:
Content You viewed, content You liked, and information about the advertisements You were shown or clicked on; and
Any Accounts with video content may share Your video viewing with, or collect information about Your video viewing
from, third-party social media sites for at least two years or until You withdraw consent.
Date of Last Review: 19 July 2022
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44 8th Avenue
Parktown North
2193
KolabEduTech (Pty) Ltd
Reg: 2020/258885/07
Directors: Nikole Montano
The Personal Information We have access to is controlled by You based on Your privacy settings on the social media site and
through the permissions You give Us when You grant Us access. When You grant Us access to information held by social media
sites You agree that We may collect, use, and retain it in accordance with this Privacy Policy.
How Information Is Used
We may use Personal Data for the following purposes:
To Provide and Manage Our Service
In order to monitor the usage of Our Service and provide Our Services to You such as providing the Services You request, location-
based Services, and making payments. We will also need to manage Our Service such as the provision, operation, protection,
improvement, and optimisation of Our Service. We may use Third Party Service Providers to provide better improvement of Our
Service.
To Personalize and Improve Our Service
To personalise Our Service to You, We may use the Information to improve the ranking of search results, saving information for
You to allow easier login and payments, help You create a profile, and add lesson details (unless You opt out of this). We may also
use Your Information to better train Our staff.
To Manage Your Account
This is to manage Your registration and, depending on the Personal Information You give Us, We can then provide You with access
to different functionalities.
To Verify the Identity of Users or Third Parties
This is to verify and authenticate You and Information You provide. This also includes Information that You provide Us relating to
other Users.
To Ensure We Comply with Our Obligations
In order to comply with the law, including the applicable Protection of Personal Information laws, We will use Your Information
for this, subject to legal requirements. This also includes required disclosures.
For the Performance of a Contract
Your Information may be used to enforce compliance and undertakings of Subscription contracts, Sponsorship contracts and other
agreements between Us or Third Parties.
To Contact You
We may need to contact You regarding, with the inclusion of but not limited to, updates, products, and security updates. We may
contact You via emails, SMSs, telephone calls, messaging Your Account or other forms of electronic communication. These are
subject to Your Device and Account settings.
To Conduct Research
Date of Last Review: 19 July 2022
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44 8th Avenue
Parktown North
2193
KolabEduTech (Pty) Ltd
Reg: 2020/258885/07
Directors: Nikole Montano
We may conduct internal research to improve Our Service which may include Users’ demographics, interests, and behaviour.
To Provide You with News, Special Offers and General Information
Unless You have opted out, We may contact You regarding similar offers to those You have purchased, saved, and enquired about.
To Manage Your Requests
To attend and manage Your requests to Us, such as for Customer support, fees, and payments, and troubleshooting problems.
To Resolve Disputes
We may use Your Information to resolve disputes with or between any of Our Users or Third Parties (such as Sponsors). We will
ask for Your permission before disclosing Your contact details to a Third Party involved in a dispute unless this is permitted under
the applicable Protection of Personal Information laws. This may also be used to establish and defend legal rights protecting the
operations, Our rights, privacy, safety, or property of kolab or other group companies or business partners, You, or others; and
pursue available remedies or limit Our damages.
For Trust, Safety and Assurance
This is to Protect the rights, property, or safety of Users, Third Parties or Us. It also includes preventing harm to Us or others and
detecting and preventing fraud, spam, abuse, security incidents, and other harmful activities.
To Allow Our Business to be Audited
If Our business needs to be audited, We may use Your Information for such.
To Conduct Investigations
If We need to conduct investigations and make risk assessments, We may use Your Information for this purpose.
For Business Transfers
We may use Your Information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale
or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in
which Personal Data held by Us about Our Service Users is among the assets transferred.
For Other Purposes
We may use Your Information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of
Service and to evaluate and improve Our Service’s products, services, marketing, and Your experience.
To Help You Publish Things
This is to help You (including but not limited to) show all or parts of Your public profile, publish on Our Service (You are solely
responsible for this), and to provide feedback and reviews.
To Do Things with Your Express Consent
We may disclose Your Information at Your direction, or otherwise as You agree with Us, for example when You authorise Third
Party access, or when You ask Us or authorise Us access to third parties.
Date of Last Review: 19 July 2022
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44 8th Avenue
Parktown North
2193
KolabEduTech (Pty) Ltd
Reg: 2020/258885/07
Directors: Nikole Montano
Our Lawful Basis
We may use Your Personal Information for the following legitimate purposes:
Performance of Contract: We may use Your Personal Data to ensure that We are able to enter into, and perform according
to, a contract with You.
Legitimate Interest: We may use your Personal Information for legitimate interests when these interests do not override Your
right to privacy and the protection of Your Personal Information.
Compliance with Legal Obligations.
Disclosure
We may disclose Your Personal Information for the following reasons, subject to the applicable legal requirements:
To Service Providers, Suppliers and Sub-Contractors;
To Our Group Companies;
Within Our Company for the provision of Services, customer modelling, and statistical and trend analysis;
To protect and defend Our rights or property;
To prevent or investigate possible wrongdoing in connection with the Service;
To Credit Reference Agency or Verification Company;
To protect the personal safety of Users of the Service or the public; and
To protect against legal liability.
We may also disclose Your Information to law enforcement agencies, Our corporate affiliates, Our business partners, and with Your
consent.
Sponsorships
Should you receive Sponsorship of the KolabEduTech (Pty) Ltd App, We will request permission in the Sponsorship Agreement to
share Information about You with the Third Party responsible for the Sponsorship. This information includes (but is not limited to)
the name of the institution at which You are employed or where You may be studying, the Province in which You reside, the number
of years spent in the education profession, the classes You teach, and the number of learners in Your class.
Access, Correction, Deletion and Opting Out
You can access, correct, and delete Your Personal Information, change Your preferences, and opt out of Cookies via Your Account
or Device settings, or You can contact Us directly. You can also access Our PAIA Manual on the Website. It is Your right to
withdraw at any time.
We may take reasonable steps to verify Your identity before allowing You profile access or to correct details, such as giving You a
One Time Pin.
Date of Last Review: 19 July 2022
Page 8
44 8th Avenue
Parktown North
2193
KolabEduTech (Pty) Ltd
Reg: 2020/258885/07
Directors: Nikole Montano
Tracking Technologies and Cookies
We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking
technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse Our Service. The
technologies We use may include:
Google Maps APIs which can be used for aspects such as to creating custom and searchable maps, checking-in, and displaying
live data. This may collect information about You and Your Device for security purposes and collects this information in
accordance with its Privacy Policy.
Cookies to enhance performance and functionality, which include Flash Cookies and Web Beacons.
Persistent Cookies, including Cookies acceptance notice, and functionality Cookies.
Session Cookies, including essential Cookies.
Cookies for advertising and remarketing.
Retention of Your Personal Data
We will only retain Your Personal Information for the duration of the purposes contained in this Policy, with specific reference to
the clause “How Your Information is Used”.
Security of Your Personal Data
The security of your Personal Data is important to Us but remember that no method of transmission over the
Internet, or method of electronic storage, is 100% secure. While We strive to use commercially acceptable
means to protect your Personal Data, We cannot guarantee its absolute security.
Transfer of Your Personal Data
Your information is processed where We, in this case Our incorporation in the Republic of South Africa, and Our parties involved
are located. This means that Your Personal Information may be transferred to and maintained in other governmental jurisdictions.
These jurisdictions may have different Data Protection laws, but We take all reasonable steps to ensure that Your data is treated
according to this Privacy Policy. We do not transfer Your data unless they have adequate controls in place, such as the protection
of Your Data.
By consenting to this Privacy Policy, You also consent to the transfer of Your Data.
Third Parties and Links to Other Websites
Our Service may contain links to other websites that are not operated by Us and, by clicking on these links, You will be redirected
to the websites.
Date of Last Review: 19 July 2022
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44 8th Avenue
Parktown North
2193
KolabEduTech (Pty) Ltd
Reg: 2020/258885/07
Directors: Nikole Montano
Once You use a link to access another website, this Privacy Policy as well as Our other Policies, such as the Terms of Use, no longer
apply. It is recommended that You familiarise Yourself with the applicable policies of those websites.
This Privacy Policy only applies to Our Service and not to Third Party sites and Services. We have no control over the privacy
policies and practices, content, opinions, and accuracy of these Third Parties and their services and therefore assume no liability.
If We use a Third-Party payment service to process payments made through the App, this Clause will also apply.
We may use Third Party Service Providers to provide better improvement of our Service.
Children's Privacy
Age restrictions
The Services are addressed to businesses and individuals being eighteen years of age or older. By registering an Account, you
warrant and represent that you have that legal age as further described in the Terms.
Authorisation by law
We may not Process any Personal Information of Minors unless it falls under one of the certain grounds under Section 35 of POPIA.
We will only Process Information for historical, statistical, or research and all Data will be De-Identified.
Access
Although Personal Information of Children is De-Identified, We have provided additional security by restricting access only to the
persons who need it for work or legitimate purposes.
Storage
The names of the children in Your class are only stored on Your mobile device. For each child a SHA256 hashed value is sent to
the server. Hashing prevents anyone from reversing the newly hashed value, so there is no way to determine a child's name from
the hashed values that are stored on the server.
Your Duty
You have the following duties in order to facilitate Our protection of Your Personal Information. This includes, but is not limited
to:
Informing Us of a change to your Personal Data/Information.
Safeguard Your Personal Data/Information, such as the use of strong passwords on unsecure websites.
Confirm Your identity to ensure Your ability to assert Your rights.
Date of Last Review: 19 July 2022
Page 10
44 8th Avenue
Parktown North
2193
KolabEduTech (Pty) Ltd
Reg: 2020/258885/07
Directors: Nikole Montano
Changes To This Privacy Policy
We may update Our Privacy Policy from time to time. We will use Our best endeavours to notify You at least two weeks before the
implementation of the amended Privacy Policy. We will notify You via email and/or other notice such as a banner when accessing
Our Service.
We will also amend the “last updated’ date on this Privacy Policy.
You are advised to review this Privacy Policy from time to time to ensure that You are up to date on the changes.
Contact Us
If You have any questions about this Policy or You need to speak to Our Information Officer, please contact:
DETAILS
Information Officer
NAME
NIKOLE MONTANO
EMAIL
CONTACT NUMBER
0765712986
