Digital Frontiers Institute

Privacy Policy

LAST UPDATED: 17 September 2018

Guide To This Privacy Policy

  1. Introduction
  2. What Information Do We Collect?
  3. How Long Do We Keep Your Information?
  4. Cookies and Third Party Technologies
  5. How We Use Your Information
  6. Who Do We Disclose Your Information To?
  7. Our Processing Principles
  8. User Rights
  9. Processing Your Data Outside South Africa
  10. Use of the Website by children

11   Questions or Concerns About This Policy

 

  1. Introduction

This is the privacy policy of Digital Frontiers Institute NPC (registration number 2017/127296/08), a non-profit company registered in the Republic of South Africa, with our registered office being at 3rd floor, 113 Loop Street, Cape Town (“Privacy Policy”).

This Privacy Policy sets out the basis on which we collect, use, store, disclose and destroy information (“Process”) from users of our website, and our online campus platform (collectively, the “Website”), as well as your rights to control the certain use of that information. By accessing, or otherwise using the Website, you agree to our Processing of your information, in accordance with this Privacy Policy. If you think our policy falls short of your expectations or that we are failing to abide by our policy, please do tell us.

Questions, comments and complaints about our data practices can be submitted to our data protection officer at data@digitalfrontiersinstitute.org.

By making use of the Website, you agree to be bound by this Privacy Policy.

  1. What Information Do We Collect?

Where there is a legal basis to do so

We Process your personal data 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  • You provide consent for us to do so (which consent can be freely withdrawn at any time by you)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 for our Website to function, and 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

Information You Provide
We may collect information submitted by you to the Website, for example, when you complete a survey, submit information to us through the Website, or when you contact us. The information we collect may include personal data 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 via the Website, you consent to us using same. This consent may be withdrawn at any time, save 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.

Information Collected Automatically
When you visit the Website or receive correspondence from us, we may passively collect and store 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.

Financial/Credit Card Information

This information is never taken by us through our Website or otherwise. At the point of making payment, you are transferred to a secure page on the website of 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.

  1. How Long Do We Keep Your Information?

We keep all information for a minimum of 5 years.

  1. 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
  • Operating the online notification form – the form that you use to contact us for any reason. This cookie is set on your arrival at our Website and deleted when you close your browser.
  • Enhancing security on our contact form. It is set for use only through the contact form. This cookie is deleted when you close your browser.
  • 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.

  1. 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 services
  • To review usage and operation of the Website
  • To contact you for:
    • 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
    • Any other reason, with your express permission

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

  1. 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. The information we provide in this regard will not be personally identifiable information.

  • To Partners and/or affiliates

We may share your information with selected partners and/or affiliates we believe may have offers of interest to you. If you do not want us to disclose your information to service providers for their direct marketing or any other purpose, you may opt out of such disclosure by contacting us at data@digitalfrontiersinstitute.org.

  • Service providers

We may share your information with our service providers that provide us with business, professional, or technical support. These providers are only provided access to your information to the extent necessary in order to provide services to us, and they may not use or share your information for any other purposes.

  • Employers and/or parties linked to employment

We keep the information you provide to us in connection with a job application in order to contact you for job opportunities in the future. In the event that you are employed by us, we keep your information for the currency of your employment, and for 6 years after the termination of your employment.

  • Legal obligations

We may access or share your 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 information if it is necessary for an investigation relating to public safety, or as otherwise required by law.

  • Security

We may disclose your information to protect the security of the Website, our servers, network systems, and databases. We may also disclose your 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 share non-personally identifiable, aggregate or anonymous information with third parties for their marketing or analytics uses.

  1. Our Processing Principles

We are committed to protecting your information. We maintain appropriate procedures to safeguard and secure your information and to prevent unauthorised access of your 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 retain your personal data for as long as necessary to provide you with the services through the Website or to otherwise administer and maintain the services and our Website.

To ensure that your personal data is Processed correctly and with a suitable level of privacy, we have adopted the following Processing principles:

  • Personal data is Processed in a manner that is lawful, fair and transparent
  • Personal data is collected only for specified, explicit and legitimate purposes (and not further Processed in a manner that is incompatible with those purposes)
  • Personal data is adequate, relevant and is limited to what is necessary in relation to the purposes for which it is Processed
  • Personal data is accurate and kept up to date, and inaccurate or incomplete personal data will be rectified, erased or further Processing suspended
  • Personal data is not kept for longer than necessary for the purposes for which the data is collected or for which it is to be further Processed
  • Personal data is Processed in a manner that ensures appropriate security of the personal data
  1. User Rights

You have the following rights:

  • Right of access – to request a copy of the information that we hold about you. Access to this information may be subject to an administrative fee if the request is unfounded, excessive or repetitive.
  • 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 Website 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. Erasure will be subject to an administrative fee if your request is manifestly unfounded, excessive or repetitive.
  • 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 data by us.

Right to withdraw consent ­– you have the right to withdraw your consent to us Processing your personal data, by emailing us at data@digitalfrontiersinstitute.org.

If you wish to remove or change personally identifiable information from our Website or other databases, you may contact us at data@digitalfrontiersinstitute.org. To better safeguard your information, we will take reasonable steps to verify your identity before granting access or making corrections to your information.

  1. Processing Your Data Outside South Africa

Our Website is hosted in the Republic of South Africa. Data obtained within South Africa may be Processed outside South Africa and data 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 the data protection laws in South Africa and the European Union to ensure adequate protection of any such data.

  1. Use of the Website by children

No person under the age of 18 should submit any data on our Website or use the Website 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 Process any personal data belonging to minors.

  1. Questions or Concerns About This Policy

If you have any questions or comments about this Privacy Policy, please email us at data@digitalfrontiersinstitute.org. You also have the right to address any complaints to a European Union data protection authority.

Our designated data controller will be charged with making decisions regarding the purposes and methods of Processing of data in terms of this Privacy Policy.

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