Privacy Policy

Privacy Statement

Last updated: November 11, 2021
We will review this Privacy Notice and may amend or supplement this Notice from time to time, in accordance with regulatory changes, business strategies and new technology introduced into our operations.

We will publish an updated version of this Notice, as and when amendments or supplements have been made on our website.

In some instances, we may receive your personal information (including your name and contact details) from a third party, and we will notify you of our collection of your personal information as soon as reasonably practicable after its collection.

Should we have previously issued a Personal Information Protection Notice to you in relation to the collection of your personal information including similar categories of personal information or for a similar purpose of collection, we would not have to issue a new Privacy Notice and will be compliant with Section 5 (a) (i) and 18 of the POPI Act.

This Privacy Policy describes our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

WOE values your privacy and will be transparent about the personal information that we process when we interact with you. The aim of this Privacy Notice is to inform and provide you with an overview of how we process your personal information in our organisation, and by doing so we are fulfilling our notification obligation.

We commit ourselves to manage and process your personal information in accordance with the applicable privacy and information protection laws and regulations, to ensure the lawful, fair, and transparent processing of your personal information for any specified, explicit, and legitimate purpose, in a reasonable manner that does not infringe on your right to privacy.

We recognise and are committed to your right to privacy, which includes, but is not limited to the right to the protection against the unlawful collection, retention, dissemination and use of personal information.

Privacy Policy

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
  • Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to woegroup.org – World Of Ethics Group, Bryanston The Campus, Twickenham Building, Bryanston, South Africa, 2021
  • Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
  • Account means a unique account created for You to access our Service or parts of our Service.
  • Website refers to World Of Ethics Group Of Companies, accessible from https://woegroup.org/
  • Service refers to the Website.
  • Country refers to: South Africa
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
  • Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
  • Personal Data is any information that relates to an identified or identifiable individual.
  • Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

    Collecting and Using Your Personal Data

    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. Personally identifiable information may include, but is not limited to:
    Email address
    First name and last name
    Phone number
    Address, Country, Province, Postal code, City

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

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 analyze Our Service.

You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service.

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser. Learn more about cookies: All About Cookies.

We use both session and persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies

Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

Functionality Cookies

Type: Persistent Cookies

Why We Collect and Process Personal Information

Our reason for collecting your personal information depends on the activity at hand. Our intention for collecting personal information, includes but is not limited to:

Contests, Email Newsletters and Inquiry Information to allow us to be in contact with you in relation to your enquiry or your participation in WOE email newsletters or the contests; to personalise our services for you, notify you of special offers or promotions that we believe may be of interest to you, and to send our newsletters to you, or to provide you with customer service, as well as to monitor our provision of customer service. In some cases, we may use elements of your Personal Data for external communications purposes, for example, drafting a press release regarding a contest winner.

Website Information to monitor and administer your enquiries you may send; to analyse trends, usage and activities with users on our website, to ensure its technological compatibility; to help us create websites that best suit our users’ interests and preferences, and to assist in identifying products and services, site features, advertisements, as well as offers that may be of particular interest to you (for example, as part of extended market research). We also use website information to monitor and maintain the security of our website and prevent cyber security incidents, as well as to collect feedback on website usage, provide IT support to online visitors, and to gauge the success of our marketing initiatives.

Portal Subscriber Information to administer the specific relationship, fulfil contractual obligations, deal with quality issues, assist with business planning and development, assist suppliers or other portal subscribers to achieve goals, and to administer incentive programmes. In certain limited cases, we also use Personal Data to facilitate billing and invoicing, or for the purpose of product traceability or compliance with regulatory requirements or contractual requirements. We obtain personal information via the portal for the purpose of processing bookings. We do not save bank details; however, we redirect to a third-party service provider, where payment is facilitated.

Research & Development and Market Research Information to perform market research, improve our products and services (for R&D purposes), and for the study and understanding of the business and preferences of consumers or operators.

Information relating to Individual Consumers of our products and services to, if and to the extent permitted by applicable law, provide individual consumers of our products and services with marketing communications promoting our products and services (or those of third parties), to better understand our consumers’ needs, to address complaints on our products and services, and more generally to improve our relationships with individual consumers.

User-generated Content received through our online presence to better engage with our customers or individual consumers of our products, to interact with our customers, and to address complaints.

ID and Passport Information to help us prevent unauthorised individuals from accessing, changing, or deleting your Personal Data.

Internal Administrative Purposes to allow us to administer the business, including for purposes of audit, data analysis, sustainable cost advantage, compliance, governance, and legal, corporate social responsibility (CSR), security, accounts payable and receivable validation, and database records.

Combined Information, if and to the extent permitted by applicable law, to better understand your needs and interests. In particular, we may combine the Personal Data that you have provided to us with other information we have collected about you, whether online or offline, or with data obtained from other sources (such as our third-party advertising partners). In this way we can provide you with the most optimal customer experience and serve you advertisements or otherwise interact with you in ways that are specifically tailored to your interests and preferences. For example, if and to the extent permitted by applicable law: we may share a cryptographic hash of your email address with a third-party advertising partner, such as social networking sites where you are a registered user (by using the hashing process, your email address is not disclosed to the third party). If the hashed email address from us matches a hashed email address that the third-party advertising partner possesses, the third party identifies you as part of a group of individuals to whom our ads might be served on its website or on other media; and a third-party advertising partner may provide us with certain aggregate demographic information about the demographic group to which you belong, which is obtained from your profile and materials with the third-party advertising partner.

Personal Information including gender and medical information for endorsements and certification, from a training perspective.

We may also use your Personal Data, contingent on certain circumstances and for the following purposes:

  • For corporate communication purposes and for public affairs purposes (including, if necessary, to issue a public response to specific complaints)
  • To respond to your comments and questions (problem resolution)
  • To conduct sales and market research (for example, through surveys)
  • If and to the extent permitted by applicable law, for direct marketing purposes
  • To improve business relations
  • For public affairs purposes
  • To protect against and prevent fraud, or other criminal activities, unauthorised transactions, claims and other liabilities, and to manage exposure to risk
  • To handle legal disputes
  • To conduct corporate transactions (including mergers, acquisitions, and divestments), and
  • To improve and enhance our products and services, in general.

We will not use Personal Data for any purposes that are incompatible with those outlined in this Policy, unless you give us your free and informed consent for additional specific purposes.

Types of Personal Information We Collect and Process

PERSONAL INFORMATION – Individual

  • Full Name/s and Surname
  • Identification / Passport Details / Date of birth / Age
  • Contact Details – email / telephonic
  • Gender, Race or Ethnic Origin
  • Qualifications / Registrations / Memberships / Accreditations
  • Employment History / Salary Information
  • Complaints and Disciplinary Records
  • Personal Tax Income Reference
  • Financial Information / Banking Details
  • Contactable References
  • Driver’s Licence
  • Next of Kin Contact Information
  • Any form of correspondence
  • Relationship Status – marital / family relations
  • Physical / Postal Address

GENERAL INFORMATION – Company

  • CIPC Documents
  • Banking Details
  • Income Tax Reference
  • VAT Registration
  • Qualifications / Registrations / Memberships / Accreditations
  • BBBEE Certificate
  • Contact Details

Lawful Processing of Personal Information

Processing is necessary to carry out our business function to ensure that our daily business performance aligns with our vision and mission.

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.
  • To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
  • To manage Your requests: To attend and manage Your requests to Us.

We only process your personal information, if such:

  • Processing of a contract to which you are a party, e.g., service level agreement, student/training agreement, non-disclosure agreement, applications for examinations, applications for training agreement, membership, recruitment, subscriptions, services, etc.;
  • Processing complies with an obligation imposed by law on us, e.g., providing information to regulators, professional bodies, accreditation bodies, membership bodies, statutory bodies, law enforcement;
  • Processing protects your legitimate interest;
  • Processing is necessary for pursuing our interests or those of a third party, to which the information is supplied legitimately.

We may share your personal information in the following situations:

With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.

Our employees will have access to your personal information to administer and manage our services and our stakeholder relationships.  Your personal information will further be shared with third parties, subject to the purpose of us collecting and processing your information, including but not limited to the following circumstances:

Business Transfers – In the event of a reorganisation, merger or sale, we may transfer any and all Personal Data we collect to the relevant third party involved in the reorganisation, merger or sale, with the consent of data subjects if and as required under applicable privacy laws.

With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.

Affiliates – We may share Personal Data with any of our affiliates or subsidiaries, for example, for the purpose of providing customer service, administering our contests, sweepstakes, and loyalty programmes, or improving our products and services. We may also share your Personal Data with affiliates or subsidiaries that provide shared services within WOE, for example, in connection with the purchase and sale of products, financial and accounting support, recordkeeping, customer billing and collections, order processing, credit control, accounts payable processing, and preparing and reporting estimates and results.

  • Oversight and other regulators, professional bodies, and statutory bodies
  • Accreditation, Registration, Regulatory Bodies
  • Government agencies and law enforcement
  • Our Board Members and Management

With Business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.

With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.

Service Providers – We share Personal Data with third-party providers of services relating to, for example, our website, the administration of our contests, our market research and sales, our recruiting efforts, our R&D activities or our public relations, IT systems or software, IT support, document and information storage, travel and mobility, translation services, and waste disposal services. These service providers only have access to the Personal Data necessary to perform their functions, only act on our behalf and under our instructions, and may not use it for purposes other than to perform such functions.

Customers – We may share Personal Data with our customers (for example, when collected through special purpose portals) to address traceability and other regulatory or contractual requirements or to facilitate problem resolution.

Legal – We may disclose Personal Data to courts, law enforcement agencies, and other government bodies where we believe that doing so is in accordance with or required by any applicable law, regulation, or legal process. We may also disclose Personal Data to external legal counsel to assist us with the establishment and defence of legal claims or to assist us on transactions (for example, to provide assistance in connection with mergers, acquisitions or divestments) or to other third parties also engaged in such legal matters (for example, to the adverse party in court proceedings, to judicial experts, to other stakeholders involved in the claim, etc.).

Third-Party Advertising Partners – we may share Personal Data with third-party advertising partners that place advertisements on our websites, or other websites or media to measure advertising effectiveness and to serve you with advertisements and other products and materials that best meet your interests and preferences. These third-party advertising partners may also provide us with certain information about you or the demographic group to which you belong, in which case we may combine this information with the Personal Data we have already collected about you in order to better understand your interests and preferences.

Third-Party Data Service Providers – we may share Personal Data with third-party data service providers who help us to segment and understand our customers by providing additional information so that we can send you what we believe will be the most relevant, targeted, and beneficial product offers and advertisements.

With Your Consent – We may also share Personal Data with other third parties subject to your prior consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Disclosure of Your Personal Data

Business Transactions – If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement – Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other Legal Requirements – The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability
  • 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.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Protection and Retention of your Personal Information

WOE will take the necessary steps to secure the integrity and confidentiality of personal information in our possession and under our control by taking appropriate, reasonable measures to prevent loss of, damage to, or unauthorised destruction of your personal information and unlawful access to or processing of personal information, regardless of the format.

Your personal information will be archived, as set out in the data retention schedule (available on request). The purpose of which the personal information was collected initially or subsequently processed, unless retention is required or authorised by applicable law, or we reasonably require the records for lawful purposes related to our functions or activities or is required by a contract or you have consented to the retention of the record.

Unfortunately, the transmission of information via the Internet is not completely secure. Despite our safeguards, we cannot guarantee the security of information transmitted to us via the Internet. Once we have received your information, we will maintain reasonable safeguards to protect it.

Marketing Activities

WOE may contact you periodically to provide information regarding our events, seminars, products, services, and content that may be of interest to you and to invite you to participate in research and projects. If applicable law requires that we receive your consent before we send you certain types of marketing communications, we will only send such communications after receiving your consent.

Laws Authorising or Requiring the Collection of Personal Information

Under certain circumstances, we are authorised or required by law to collect your personal information. These laws include but are not limited to the below and includes their applicable Regulations and Directives, etc.:

  • Auditing Professions Act, 26 of 2005
  • Income Tax Act, 58 of 1962
  • Basic Conditions of Employment Act, 75 of 1997
  • Occupational Health and Safety Act, 85 of 1993
  • Chartered Accountant Designation (Private) Act, 67 of 1993
  • National Qualifications Framework Act, 67 of 2008
  • Companies Act, 71 of 2008
  • Value Added Tax Act, 89 of 1991
  • Compensation of Occupational Injuries and Diseases Act, 130 of 1993
  • Skills Development Act, 97 of 1998
  • Disaster Management Act, 57 of 2002
  • Tax Administration Act, 28 of 2011
  • Employment Equity Act, 55 of 1999

Your Rights

The POPI Act guarantees you, as a data subject, certain rights that you may exercise against us where applicable.

You have the right to be informed if your personal information is collected, or accessed, by an unauthorised person. In addition, you have the right of access to their personal information and to require that personal information is updated, corrected, destroyed or processed.

The Act does not apply to personal information processed:

in the course of a personal or household activity, or where the processing authority is a public body involved in national security, defence, public safety, anti-money laundering, or the Cabinet or Executive Council of the Province, or as part of a judicial function.

Personal information can only be processed (Section 11):

  • with the consent of the “data subject”; or
  • if it is necessary for the conclusion or performance of a contract to which the “data subject” is a party; or
  • if it is required by law; or
  • if it protects a legitimate interest of the “data subject”; or
  • if it is necessary to pursue your legitimate interests, or the interest of a third party to whom the information is supplied.

You have the right to object to having your personal information processed. You have the right to withdraw your consent, or object if you can show legitimate grounds for your objection.

A Responsible Party has to collect personal information directly from the “data subject”, unless:

  • this information is contained in some public record or has been deliberately published by the data subject;
  • collecting the information from another source does not prejudice the subject;
  • it is necessary for some public purpose; or to protect their own interests;
  • obtaining the information directly from the subject would prejudice a lawful purpose or is not reasonably possible.

Your Personal Information will only be kept if it is allowed by law, or the information is needed to keep the record for lawful purpose or in accordance with the contract between the company and the data subject, or the data subject has consented to the data processor keeping the records (Section 14).

WOE is entitled to keep records of personal information for historical, statistical or research purposes if it has been “de-identified” and safeguards have been established to prevent the records being used for any other purposes.

Personal information will only be used for the purpose for which the data was collected (Section 15).

Documentation relating to personal information and how it has been processed will be maintained as referred to in Section 14 or 51 of the Promotion of Access to Information Act.

When information is being collected, data subjects will be made aware of (Section 18):

  • the information that is being collected and if the information is not being collected from the subject, the subject must be made aware of the source from which the information is being collected;
  • the name and address of the organisation collecting the information;
  • the purpose of the collection of information;
  • the period for which the information will be retained, and assurance given that it will be destroyed in accordance with our data retention schedule (available upon request);
  • whether the supply of the information by the subject is voluntary or mandatory;
  • the consequences of failure to provide the information;
  • whether the information is being collected in accordance with any law;
  • who will be receiving the information;
  • that the data subject has access to the information and the right to rectify any details;
  • that the data subject has the right to object to the information being processed (if such right exists);
  • that the data subject has the right to lodge a complaint to the Information The contact details of the Information Regulator must also be supplied (Section 18).

This Privacy Notice must be read in conjunction with the POPI Act, which can be downloaded from Act No. 4 of 2013: Protection of Personal Information Act, 2013.

Contact Information

Information Officer:    Elfriede Giard     

Email address: elfriede@woegroup.org

 

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