Privacy Policy
1. Introduction
CoLT (Center of Learning and Training) is a comprehensive e-learning platform designed to simplify learning and amplify success for students, educators, and institutions. The platform is owned and operated by wCyber Solutions (Pty) Ltd, a private company registered in Zimbabwe.
This Privacy Policy clarifies how we collect, use, and safeguard data from users and visitors to our website, including:
- (i) CoLT account holders, such as learners, instructors, and administrators who actively use the platform (“Users”);
- (ii) other individuals who may visit our website.
We reserve the right to update this Privacy Policy periodically by publishing a new version on the CoLT website. You are encouraged to review this page occasionally to ensure you are aware of any updates. We may also notify you of changes to this Policy through email or public notice on our website. This Privacy Policy outlines your privacy rights and explains how the law protects your Personal Information when processed by wCyber Solutions.
It is essential that you read this Policy in conjunction with our Website Terms and any additional terms, conditions, or policies incorporated by reference in this Policy. By registering for our services or providing your Personal Information in any way, you are acknowledging your acceptance of the terms outlined in this Policy. Should you disagree with any portion of this Policy, we ask that you refrain from registering for or using any of CoLT’s services.
This Policy was last updated on 1 November 2024.
By agreeing to this Policy, accessing our website, or utilizing our services, you acknowledge that you have read, understood, and consent to be bound by this Policy.
2. Important information and who we are
2.1 Purpose of this privacy policy
This Privacy Policy complies with, and facilitates the obligations required from, the European Commission’s General Data Protection Regulation, 2016/679 (“GDPR”) as well as the South African Protection of Personal Information Act No. 4 of 2013 (“POPI”), as amended.
Due to the nature of some of our services as a provider of various payment and facilitation tools, we process not only your General Personal Information, but also Special Categories of Personal Information, being your Financial Data.
It is important that you read this Privacy Policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing Personal Information about you, so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.
You may not submit any other person’s personal information to wCyber, and warrant that such information you submit is your own, and lawfully yours to provide.
2.2 Controller and processor
wCyber is the data controller and is responsible for your Personal Information in instances where we decide the processing operations concerning your Personal Information. Sometimes we also operate as a processor of Personal Information on behalf of a third-party data controller, where that data controller’s privacy terms will apply, but we will draw your attention to them when applicable.
We have appointed a data representative at wCyber who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the representative using the details set out below.
You have the right to make a complaint at any time to your territories’ specific South African, European Union or UK information regulator’s office (such as the 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.
2.3 Changes to the privacy policy and your duty to inform us of changes
We may amend this Policy at any time by posting a revised version on our Website. The revised version will apply to all Data Subjects with effect from the time we post it.
This Privacy Policy version was last updated on 13 November 2019 and historic versions are archived and can be obtained by contacting us.
It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us.
2.4 Third-Party links on website
The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements or terms. When you leave our Website, or engage with such third parties, we encourage you to read the distinct privacy policy of every third-party you engage with.
3. The Data We Collect About You
a. Personal Data
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
b. Types of Personal Information We Collect
- i. Identity Data - First name, last name, ID number, date of birth, passport number, city and country, Google/Facebook Authentication Token, legal entity name, company registration number, directors’ personal details, etc.
- ii. Contact Data - Billing address, delivery address, email address, social media contact details, and telephone numbers.
- iii. Financial Data - Payment provider information, payment card details, banking details, credit card tokens, and location of in-store payment.
- iv. Transaction Data - Details about payments, contracts, subscriptions, invoices, and services obtained.
- v. Social Media Data - Publicly accessible profile information, including images, likes, followers, comments, and posts.
- vi. Technical Data - Internet usage information, IP address, browsing habits, system type, screen resolutions, and cookie preferences.
- vii. Profile Data - Username, password, interests, preferences, feedback, and survey responses.
- viii. Biometric Data - Age, gender, and derived data from your profile.
- ix. Usage Data - Information about how you use our tools, website, surveys, and services.
- x. Marketing and Communications Data - Preferences in receiving marketing and communication preferences.
c. Aggregated Data
We collect, use, and share Aggregated Data (statistical or demographic data) for any purpose. Aggregated Data is derived from your Personal Information but is not considered Personal Information in law, as it does not reveal your identity. If combined with your Personal Information to directly or indirectly identify you, it will be treated as Personal Information.
d. Special Categories of Personal Information
We collect certain sensitive data (such as Financial Data) in line with legal requirements. We take special precautions regarding the safety and integrity of such information.
e. Required Personal Information
If required by law or a contract and you fail to provide necessary data, we may not be able to perform our services and may need to cancel access, with prior notification.
f. “Cookies” Information
We may use cookies (small text files) to collect Usage Details. Cookies can be session-based (disappear after closing the browser) or persistent (remain until removed). Adjust your browser settings to manage cookies.
4. How is Your Personal Information Collected?
a. Collection Methods
- i. Direct interactions: Providing information through forms, website interactions, subscriptions, feedback, event attendance, etc.
- ii. Automated technologies: Automatic collection of Technical Data during website interaction, using cookies, server logs, etc.
- iii. Third-party sources: Information from analytics, social media, marketing platforms, and technical providers.
5. How We Use Your Information
a. Lawful Use of Personal Information
We use your Personal Information only when legally allowed and for legitimate reasons, which you expressly understand and consent to by accepting this Policy. Most commonly, we will use your information in the following circumstances:
- Contractual necessity: Where we need to perform on a contract with you.
- Legitimate interests: Where necessary for our or a third party’s legitimate interests, provided these interests don’t override your rights.
- Express consent: Where you have explicitly given consent.
- Legal obligation: Where we need to comply with a legal or regulatory obligation.
b. Purposes for Using Personal Information
Below is a description of all the ways we plan to use your Personal Information, with the legal bases we rely on. If you need details on the specific legal grounds, please contact us at info@wcyber.net.
| Purpose/Activity | Type of Data | Lawful Basis for Processing |
|---|---|---|
| To allow you to make use of the Services | Identity, Contact, Financial, Transaction, Marketing and Communications, Biometric |
• Express consent • Performance of a contract • Legal obligation • Legitimate interests (business growth, understanding service use) |
| To contract with you as a service provider to wCyber | Identity, Contact, Financial, Transaction, Marketing and Communications, Social Media, Market Research | • Performance of a contract with you • Necessary to comply with a legal obligation • Necessary for our legitimate interests (to keep our records updated and to study how users use our products/services) • Necessary for our legitimate interests (to develop our products/services and grow our business) • Express consent |
| To process market research data provided by you as a result of you opting into a market research or cultural research study | Identity, Contact, Financial, Transaction, Marketing and Communications, Social Media, Market Research |
• Performance of a contract with you • Necessary to comply with a legal obligation • Necessary for our legitimate interests (to keep our records updated and to study how users use our products/services) • Necessary for our legitimate interests (to develop our products/services and grow our business) • Express consent |
| To allow you to use the Website, or register you as a new Website user or participant in any wCyber event or competition | Identity, Contact, Financial, Transaction |
• Performance of a contract with you • Necessary for our legitimate interests (to recover debts due to us) • Express consent |
| To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | Identity Contact Technical Usage |
• Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) • Necessary to comply with a legal obligation • Express consent |
| To market our own Services to other companies or External Third Parties | Identity Contact Profile |
• Necessary for our legitimate business interests (for running our business, provision of services, marketing and pitching) • Express consent |
| To deliver relevant Website or service content and advertisements to you and measure or understand the effectiveness of the notices we serve to you | Identity Contact, Profile, Usage, Marketing and Communications, Technical, |
• Necessary for our legitimate interests (to study how users use our products/services, to develop them, to grow our business and to inform our marketing strategy) • Express consent |
| To use data analytics to improve our Website, services, marketing, programme relationships and experiences | Technical, Usage | • Necessary for our legitimate interests (to define types of users for our products and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy) • Express consent |
| To make suggestions and recommendations to you about events or services that may be of interest to you | Identity Contact, Technical, Usage, Profile | • Necessary for our legitimate interests (to develop our products/services and grow our business) • Express consent |
c. Marketing
We strive to provide choices regarding the use of Personal Information for marketing. You may use in-built prompts on communications or contact us to manage your marketing preferences.
f. Opting-Out
You can stop receiving marketing messages at any time by updating your preferences or following opt-out links in messages. Note, this does not apply to information provided as part of Website use, Services, or events.
g. Change of Purpose
We will only use your Personal Information for collected purposes unless we need it for a compatible reason. Contact us if you have questions about new purposes. We will notify you if we use it for unrelated purposes, and explain the legal basis for doing so.
Contact Us
wCyber Solutions (Pty) LtdBlock B Infinity Business Park, 4 Pieter Wenning Rd,
Witkoppen, Sandton, 2191, Johannesburg
51 Winson Rd,Hatfield,
Harare
Email: info@wcyber.net
Website: www.wcyber.net