Last updated: 7 August 2018
Welcome to the web site (the “Site”) of SkillsPassport South Africa (Pty) Ltd. (trading as SkillsPassport)
Terms Used In This Policy Document
To make things easier to read, SkillsPassport refers to the following terms in this policy document:
“Model” – The SkillsPassport business model, together with the Site.
“you” and/or “your” – You as the person currently reading this policy document and whom may have accessed the Model via the internet, mobile app or other platform.
“Personal Data” – Information which identifies you personally person, known as ‘personal information’ in South Africa.
“Agent” – A Member that has been promoted from a Member to an Agent by a Campaign Partner. The Agent has the responsibility of signing-up Members.
“Campaign Partner” – An Agent that has been promoted to a Campaign Partner by SkillsPassport. The Campaign Partner has the responsibility of developing a group of Agents that sign-up Members and businesses.
“Member” – A person signed-up on the Platform by an Agent.
“Emloyer” – A person that signs-up on the Platform for the purpose of finding Members to employ.
“Platform” – Web-enabled, mobile-application that creates a credible dynamic digital profile for Members
“De-identified information” – Information which does not identify you personally.
“Affiliates” – SkillsPassport related companies.
This Site is operated by SkillsPassport and provides information about the Model.
This Policy sets out SkillsPassports’ policy with respect to Personal Data and other information that is collected from visitors and users of the Model.
SkillsPassport asks you to please read this Policy carefully so that you understand how SkillsPassport will treat your information. By using the SkillsPassport Model, you confirm that you have read, understood and agree to this Policy. If you do not agree to this Policy, please do not use the Model. If you have any queries, please email us at firstname.lastname@example.org.
SkillsPassport is a South African company, situated at: Waterkloof Park, 469 Julius Jeppe Street, Waterklood, Pretoria, 0181
SkillsPassports’ legal status under applicable data privcy laws.
SkillsPassport is the data controller under South Africa’s Protection of Personal Information Act (POPI) of 2013. SkillsPassport conforms to this Act in terms of the collection, use, and retention of personal data.
Information SkillsPassport Collects
When you interact with SkillsPassport through the Model, SkillsPassport may collect Personal Data and other information from you, as further described below.
Personal Data That You Provide Through the Model
SkillsPassport collects Personal Data from you when you voluntarily provide such information, such as when you contact SkillsPassport with inquiries, participate in a SkillsPassport survey, are signed-up as a Member by an Agent to gain access to the Model or use the Model, you sign-up as a Employer such information typically includes your:
- telephone number;
- email address;
- home address;
- information about your home which you give us;
- your payment details;
- your IP address; and
- any other personal information which you give us in connection with the Model.
If you are a Member you may have indicated, via the Platform, that you may be interested in an employment opportunity sent to from an Employer via the Platform. In this case, your contact details will be provided to the Employer.
If you are a Member, some of your Personal Data will be made visible and searchable by Employers. By voluntarily providing us with Personal Data, you are consenting to our use of it in connection with the Model and in accordance with this Policy.
When you interact with SkillsPassport through the Model, SkillsPassport receives and stores certain De-identified information which is collected passively using various technologies. This includes: Technical or other details about any device which you use to access the Model, including: Internet and/or network connection; your Media Access Control (MAC); any device Unique Device Identifier (UDID) or equivalent; your operating system, browser type or other software; your hardware or mobile device details (including your mobile device type and number and mobile carrier details), if applicable; or other technical details. This is technical data about our users and their actions and patterns, which we do not believe identifies any individual;
Details of your use of the Model including, but not limited to: metrics information about when, where and how you use the Model; traffic data; and your geographical location data.
SkillsPassport may store such information itself or such information may be included in databases owned and maintained by SkillsPassports’ affiliates, agents or service providers. The Model may use such information and pool it with other information on an anonymised and generalised basis to track, for example, the total number of users of the Model, the number of visitors to each page of the Site and the domain names of SkillsPassports’ visitors’. It is important to note that no Personal Data is available or used in this process.
In operating the Model, SkillsPassport may use a technology called “cookies.” SkillsPassport utilises first and third party cookies. This enables SkillsPassport to: a) Improve the User’s experience on the Site through various means such as storing preferences (like keeping a User logged in) or determining aggregate usage behaviour (time on site, number of pages viewed etc.) through web analytics tools like Google Analytics. b) Provide more relevant Display Advertising to Users who have visited the Site, using third party tools such as Google Analytics Remarketing, Google Display Network Impression Reporting and Google Analytics Demographics and Interest Reporting.
Cookie Opt out
Most web browsers provide the option to block some or all cookie types should you wish to. Users can also opt out of the Google Display Network using the Ads Preferences Manager. Because many of Site’s features utilise cookies, SkillsPassport recommends that Users do not block them.
SkillsPassports’ Use of Your Personal Data and Other Information
By providing SkillsPassport with the information about you discussed above, you consent for SkillsPassport, subsidiaries and Affiliates to use that information in the following ways:
- to implement and monitor any contact you have as Employer with Members via the Platform;
- to share your Personal Data with SkillsPassport professionals in order to assist using the Platform;
- to ensure that content from the Model is presented in the most effective manner for you and for your computer or other device from which you access the Model;
- to provide you with information, products or services that you request from us or which we feel may interest you;
- to carry out SkillsPassport obligations arising from any contracts between you and SkillsPassport;
- to allow you to participate in interactive features of the Model, when you choose to do so;
- to notify you about changes to the Model;
- to improve or modify the Model, for example based on how you use the Model;
- to calculate conversion rates and other elements of the Models’ performance; and
- for marketing purposes (discussed further below).
SkillsPassports’ Disclosure of Your Personal Data and Other Information
SkillsPassport is not in the business of selling your information. SkillsPassport consider this information to be a vital part of its relationship with you. There are, however, certain circumstances in which SkillsPassport may share your Personal Data with certain third parties, as set out below:
SkillsPassport will share Member Personal Data with Employers as necessary for them to employ Members.
SkillsPassport will share Employer Personal Data with members in order to assist them in making a decision about whether they want to be employed by the Employer.
SkillsPassport will share Member Personal Data with Banks as necessary for them to provide their services to Members.
Mobile Network Operators
SkillsPassport will share Member Personal Data with Mobile Network Operators as necessary for them to provide their services to Members.
As SkillsPassport develops its business, SkillsPassport might sell or buy businesses or assets. In the event of a corporate sale, merger, re-organisation, dissolution or similar event, Personal Data may be part of the transferred assets.
SkillsPassport may also share your Personal Data with the SkillsPassport Related Companies if SkillsPassport needs to do so to fulfil this Policy.
Agents, Campaign Partners and Related Third Parties
SkillsPassport, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When SkillsPassport employs another company to perform a function of this nature, SkillsPassport only provides them with the information that they need to perform their specific function and under the same standards and protections as in this Policy.
SkillsPassport may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to:
- comply with a legal obligation,
- protect and defend the rights or property of SkillsPassport,
- act in urgent circumstances to protect the personal safety of users of the Model or the public, or
- protect against legal liability.
Aggregated Personal Data
In an ongoing effort to better understand and serve the users of the Model, SkillsPassport conducts research on its user demographics, interests and behaviour based on the Personal Data and other information provided to SkillsPassport. This research will be compiled and analysed on an aggregate basis, and SkillsPassport may share this aggregate data with its affiliates, agents and business partners. This aggregate information does not identify you personally. SkillsPassport may also disclose aggregated user statistics in order to describe its Services to current and prospective business partners, and to other third parties for other lawful purposes in fulfilment of this Policy.
Marketing and Advertising
SkillsPassport and its affiliates may use Personal Data to contact you in the future to tell you about services it believe will be of interest to you. If SkillsPassport does so, each communication sent to you will contain instructions permitting you to “opt-out” of receiving future communications. In addition, if at any time you wish not to receive any future communications or you wish to have your name deleted from a SkillsPassport mailing lists, please contact SkillsPassport as indicated below.
SkillsPassport does not disclose personal information about identifiable individuals to advertisers, but SkillsPassport may provide them with aggregate and/or anonymised information about its users to help advertisers reach the kind of audience they want to target. SkillsPassport may make use of the information it has collected from you to enable it to comply with its advertisers’ wishes by displaying their advertisement to that target audience.
You can visit the Model without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain components of the Model.
Where and how does SkillsPassport store your personal information?
The information that SkillsPassport collects from you will be held in servers in South Africa. By submitting your personal information, you agree to this transfer, storing or processing. SkillsPassport will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Policy.
Unsolicited information and public forums
Please be aware that SkillsPassport does not accept unsolicited Personal Data unconnected with the Services and SkillsPassport will delete it as soon as it becomes aware you have sent it any such Personal Data (unless SkillsPassport are required to keep that Personal Data under this Policy).
You are responsible for any public publishing of information including Personal Data (for example on a discussion forum). Please remember that this may mean third parties gaining access to that information, for which you will be responsible.
SkillsPassport does not knowingly collect Personal Data from children (individuals under the age of 18). If you are under the age of 18, please do not submit any Personal Data through the Model. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Data on the Model without their permission. If you have reason to believe that a child under the age of 18 has provided Personal Data to SkillsPassport through the Model, please contact SkillsPassport, and it will endeavor to delete that information from our databases.
Links to Other Web Sites
This Policy applies only to the Model. The Services may contain links to other web sites not operated or controlled by SkillsPassport (the “Third Party Sites”). The policies and procedures SkillsPassport described here do not apply to the Third Party Sites. The links from the Model do not imply that SkillsPassport endorses or has reviewed the Third Party Sites. SkillsPassport suggests contacting those sites directly for information on their privacy policies.
SkillsPassport takes reasonable steps to protect the Personal Data provided via the Model from loss, misuse, and unauthorised access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free; any transmission is at your own risk. In particular, e-mail sent to or from the Model may not be secure. Therefore, you should take special care in deciding what information you send to SkillsPassport via e-mail. Please keep this in mind when disclosing any Personal Data to SkillsPassport via the Internet. Once SkillsPassport has received your information, it will use strict procedures and security features to try to prevent unauthorised access.
SkillsPassport undertakes that it has taken all reasonable precautions to secure all payment processing that is carried out to receive payment for the Model. SkillsPassport cannot be held responsible for security breaches occurring on your electronic device (Personal Computer or other electronic device used to browse the Site), which may result due to the lack of adequate virus protection software or spyware that you may inadvertently have installed on your device.
Registered SkillsPassport users will have a user name and password that enables you to access certain parts of the Model. You are advised to change your password upon registration and are responsible for keeping them confidential. Please don’t share them with anyone.
Other Terms and Conditions
As a South African citizen, you have the right to ask SkillsPassport not to process your Personal Data for marketing purposes by contacting SkillsPassport at email@example.com. The South African Protection of Personal Information Act gives you the right to access information held about you. Any access request may be subject to a small administrative fee to meet SkillsPassport costs in providing you with details of the information it hold about you. You may also email SkillsPassport at firstname.lastname@example.org to request that it deletes your personal information from its database.
SkillsPassport will use commercially reasonable efforts to honour your request. SkillsPassport may retain an archived copy of your records as required by law or for legitimate business purposes (and if so SkillsPassport will explain this to you at the time).
Changes to the Policy
Access to Information
To keep your Personal Data accurate, current, and complete, please contact SkillsPassport as specified below. SkillsPassport will take reasonable steps to update or correct Personal Data in its possession that you have previously submitted via the Model.
Please also feel free to contact SkillsPassport if you have any questions about the Policy or the information practices of the Models.
You may contact SkillsPassport as follows: info@Skillspassportsa.co.za