Reference in this policy to “we”, “us”, “our”, or any similar terms is to WaFunda.
WaFunda is a business registered and domiciled in the Republic of South Africa, processing data in the Republic of South Africa and, as such, complies with the South African Protection of Personal Information Act No. 4 of 2013 (POPIA).
You have the right to make a complaint at any time to the South African regulator’s office (Information Regulator’s Office of South Africa). We would, however, appreciate the chance to deal with your concerns before you approach any such regulator, so please contact us in the first instance.
WaFunda’s Data Subjects are typically:
We act as the Responsible Party, as defined in POPIA, for the processing of our Data Subject’s Personal Information, in order to establish a business relationship, enter into contractual agreements, and provide our services and platforms to them. We are responsible for these Data Subject’s Personal Information in instances where we decide the processing operations concerning their Personal Information.
As an organisation that provides services to, and develops and administers platforms to support these services, on behalf of some of our Data Subjects (such as the learning institutions and fund managers we work with in accordance with an agreement signed with them) we may collect, process, store, share and create Personal Information of their employees, learners, students and youth beneficiaries. In these instances, we act as the Operator, as defined in POPIA, of the Personal Information shared with us and collected, processed, stored, shared and created by us in the provision of these services. The decisions regarding the processing operations, in conjunction with the services and platforms made available to their employees, learners, students and youth beneficiaries, are made by our Data Subjects who remain the Responsible Party of the Personal Information we process on their behalf. In this instance the Responsible Party’s privacy terms will apply, but we will draw your attention to them, when applicable.
When we establish a business relationship with you, provide our services or platforms to you, or communicate with you, we may collect your Personal Information. We do this in various ways, including:
As you interact with our website and platforms, we may automatically collect technical data about your equipment, browser, browsing actions and patterns. We collect this Personal Information by using cookies, server logs, Google Analytics and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies.
In order to engage with you, fulfill our contractual obligations, and provide our services and platforms to you, we may collect the following Personal Information from you.
As a Responsible Party, we may collect, process, store, share and create Personal Information in order:
As an Operator providing services, and developing and administering platforms utilised to support these services, in accordance with our contractual obligations to our Data Subjects (including our customers, and the learning institutions and fund managers we work with), we may collect, process, store, share and create Personal Information of their behalf in order to advise their employees, students, learners and youth beneficiaries:
We may also collect, process, store, share and create Personal Information in order to directly:
We may also collect, process, store, share and create Personal Information of our Data Subject’s employees, students, learners or youth beneficiaries in order to provide our Data Subjects with feedback on:
Where necessary to protect our legal rights and interests, or the interests of others, we may also use Personal Information in relation to legal claims, compliance with other local regulations or regulations in other countries or jurisdictions, audits, risk management, law enforcement processes, and other regulatory functions.
We may share Personal Information with:
We will otherwise treat all Personal Information as private and confidential and will not share it with other parties except:
When we engage with business partners, third party service providers or third party platform providers that process Personal Information on our behalf in order for us to provide our services to our Data Subjects, these entities will:
Third Party platform providers may also have their own Privacy Policies available on certain platforms for which we are solely administrators. Individuals who utilise these platforms may refer to these Privacy Policies for further details on the platform provder’s privacy practices, and privacy and security commitments.
WaFunda also operates and communicates through our Social Media channels and pages to inform, help and engage with interested parties, and to promote our organisation and services. These channels and pages are public and any of the users of the social media sites on which we operate may like, follow or subscribe to them.
When subscribing to, liking or following any of WaFunda’s channels or pages on a social media platform, please note the following:
When you engage with us through social media, your Personal Information may be processed by the site owner. This processing occurs outside of our control and may take place in a country outside South Africa that may have different privacy regulations.
We regularly update and monitor our social media channels and pages, and welcome feedback and queries sent to us through these sites. We try to join and encourage conversations whenever possible but cannot guarantee that we will read or reply to all messages sent to any of our official social media channels or pages. Relevant feedback on these social media sites, including the details of the individuals who posted comments, may be shared within the organisation for consideration, but we cannot guarantee that any feedback or suggestions will be acted upon by us.
In order for us to provide our Data Subjects (and their Data Subjects where applicable) and any platform end users with information about the services we offer and the about platforms we develop and administer to support these services, you accept and agree that:
WaFunda utilises Third Party Communication Providers to deliver all electronic communications when providing the services and administering the platforms agreed upon, and these providers operate outside of the Republic of South Africa. The Personal Information provided to WaFunda in order to engage our services, utilise the platforms and receive all electronic communications in relation to our services and our platforms is, thus, shared with these Third Party Communication Providers, and processed and stored within their Data Centres in their relevant countries. Should you not wish to have your Personal Information processed by these Third Parties in countries outside of the Republic of South Africa, WaFunda may not be able to provide our services to you, nor may the platforms we develop and administer be available to you.
Data Subjects may withdraw their consent to receiving electronic communications from us at any time by contacting us at email@example.com but, should consent be withdrawn, you may not receive further communications regarding any current or future services from us, nor related to any platforms that we develop or administer in support of our services.
Where electronic communications form part of the services we offer to our Data Subjects and we are required to send electronic communications in order to fulfil contractual obligations, we may not be able to action a request directly from a Data Subject’s employees, student, learner or youth beneficiary, or from a student champion, nor may they be able to withdraw consent to receive electronic communications. Any requests received in this regard will be dealt with on a case by case basis and will be communicated to the Data Subject or the relevant Responsible Party of the requester’s Personal Information.
Whilst we take reasonable measures to maintain the quality and accuracy of all our Personal Information in our possession, all Personal Information provided to WaFunda via our website, or any other methods of collection as outlined above, should be accurate, complete, and up to date. Should this Personal Information change, we encourage you to notify us of the change and provide us with up to date information.
Where indicated, it is necessary for us to be provided with accurate Personal Information to enable us to provide our services and administer the platforms that support these services. Should anyone decline to provide such information, or should such Personal Information be incomplete, we may not be able to provide our services or platforms to these individuals or entities.
We promote the protection of Personal Information by maintaining and continuously improving our privacy and security culture. We ensure all employees, contractors, business partners and service providers processing Personal Information are advised on how to handle Personal Information securely, with the utmost respect, and in compliance with POPIA. We provide regular privacy and security training and awareness sessions to all our employees and contractors and, where relevant, to business partners and third party service providers as well. All employees, contractors, business partners and third party service providers are made aware of their responsibilities in terms of laws and rules that apply to the processing and to the protection of the Personal Information of our Data Subjects and our customer’s Data Subjects, and with regards to our expectations of them when processing Personal Information on our behalf.
We make use of appropriate physical, administrative and technical security measures to protect all Personal Information that we collect and in our possession, and when we share Personal Information with other entities as outlined above. We regularly review our organisational security measures and ensure they are effective, up to date and follow best practices.
We will take reasonable actions to make sure that appropriate measures are in place before we transfer Personal Information to other countries if the transfer is necessary to provide our services and administer any platforms.
Individuals and entities may withdraw their consent to us processing or transferring their Personal Information across borders, however, this may mean that we are no longer able to offer our services or platforms to them.
We will retain Personal Information:
Where the services we provide to our Data Subjects, such as a learning institutions or youth programmes, has been contractually agreed upon and the students, learners and youth beneficiaries of these entities includes Children under the age of 18 (eighteen) years, the Responsible Party warrants to and in favour of WaFunda that they have procured the requisite permission and/or authorization to process (and allow WaFunda to process) any Personal Information in circumstances where such Personal Information relates to a minor child under the age of 18 (eighteen) years from the parents and/or guardians of such minor child. The Responsible Party shall further procure that the parents and/or guardians of minor children shall supervise any child’s use of the third party platform.
For all other learners, students, youth beneficiaries who have independently elected to make use of any of the services WaFunda provides, and who have contractually agreed to avail of these services and utilise the platforms that we provide in support of these services, we generally do not engage with or knowingly collect Personal Information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from children without verification of parental consent, we take steps to remove that information from our systems and servers.
The WaFunda website utilises cookies. Cookies are small data files that are placed on your computer (or other devices) when you visit a website. Cookies (and other similar technologies) help us give you the best experience of using our website. Cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A Cookie in no way gives us access to your computer, device or any information about you, other than the data you choose to share with us.
When you visit our website or view the information on our website, you may be able to access or click on links that direct you to other websites that are beyond our control. These websites may send their own cookies to you, collect Personal Information, technical or website usage information from you, or request Personal Information from you in performance of another service. We do not control the Privacy Policies of these Third Parties and we cannot be held liable for the use of any Personal Information provided by you to them for any reason whatsoever.
The Personal Information WaFunda collects, and the ways in which we use it, are necessary for us to provide our services, and the platforms we develop and administer, to our Data Subjects.
Where we are the Responsible Party of Personal Information, you may request access to any and all the Personal Information that WaFunda has in their possession about you upon provision of sufficient proof and verification of your identity.
Our Data Subjects have the right to:
The above rights are limited in some situations, such as where we are legally required to process or store your Personal Information, and may limit your ability to use our platforms and services. We will advise you about this at the time of the submission of a Data Subject Access Request and taking into consideration the type of request.
In order to enact your Data Subject Rights, you will normally not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, WaFunda may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with a request in these circumstances.
We may need to request specific information from you to assist us in confirming your identity and ensure your right to access your Personal Information (or to exercise any of the other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to request further information in order to speed up our response.
We will endeavour to respond to all legitimate requests within 30 days. Occasionally it may take us longer than if the request is particularly complex or if a number of requests, in which case, we will ensure that we notify you and keep you updated.
If you would like to exercise any of your Data Subject Rights, please contact firstname.lastname@example.org with your request.
Where we act as an Operator and process the Personal Information of our Data Subject’s employees, students, learners and youth beneficiaries, as agreed to contractually regarding the service we are providing to our Data Subjects and within the platforms required to support these services, Data Subject Rights requests must be made directly to the Responsible Party of this Personal Information for further evaluation and consideration in accordance with the Responsible Party’s privacy terms. The Responsible Party will advise WaFunda, as the Operator and service provider, of any Data Subjects Requests where we process Personal Information on their behalf and we will respond accordingly to provide them with the Personal Information in our possession, and take any actions necessary with regards to this Personal Information upon their instruction only.
As a Responsible Party, we will notify our Data Subjects and the relevant supervisory authority as soon as we become aware of any data breach that is likely to result in a risk to the privacy rights and freedoms of any of our Data Subject’s privacy rights and freedoms.
As an Operator acting on behalf of our Data Subjects when collecting, processing, storing, sharing and creating Personal Information, we will notify the Responsible Party and the relevant supervisory authority as soon as we become aware of any data breach that is likely to result in a risk to any of their Data Subject’s privacy rights and freedoms.
WaFunda has contractual agreements in place with our technical, hosting and third party platform providers in order to ensure that we are advised as soon as possible of any incidents or data breaches that may impact any end users who have registered on the platforms we develop and administer. In the event of any platform related incidents that may result in a risk to any end users’ privacy rights and freedoms, WaFunda will advise the relevant supervisory authority along with the end users and the Responsible Party where applicable.
If you believe your Personal Information has been accessed or acquired by any unauthorised person, please notify us immediately at the below email address.
WaFunda’s Information Officer is:
Name: Sophia Campello Beckwith
Phone Number: +2721 007 5786