VALENTURE PRIVACY POLICY

1. INTRODUCTION

1.1. This privacy policy ("this Policy") of Valenture Ltd ("Valenture", "us" or "we")

contractually regulates our right to collect and use the information that we have

about you ("User" or "you", which includes both the parent or legal guardian and

the minor child of the parent or legal guardian) and your rights in this regard, and

applies to your use of our website (https://www.valentureinstitute.com/, including all

sub-domains), which includes the learner management system, also referred to as

the Online Campus ("Website"), the Valenture Institute App as downloaded from a

mobile app store ("App") and the services that we offer ("Services") through our

platform made available through the App and Website (collectively, the "Platform").

This Policy creates a legally binding agreement between us and you and will apply

as soon as we collect your data, or you start using the Platform or Services.

1.2. Your use of the Platform and Services will be regulated by this Policy as well

as any other terms that are available on the Platform and/or the agreements that

you enter into with us.

1.3. Changes to this Policy: unless notice is required in terms of any applicable

laws, we may change this Policy from time to time in line with any changes that the

law or our internal business operations require, without prior notice. However, we

will notify you of any material changes to this Policy. The current version of this

Policy that applies each time you visit and/or use our Platform and/or Services will

regulate our relationship. It is your responsibility to consider the Policy each time

you visit the Platform. If you do not agree with any terms of this Policy, you

must stop using the Platform and/or Services.

1.4. The right to privacy and this Policy is important to us. We are committed to

taking steps to protect your privacy when you use the Platform and Services and we

therefore implement business practices that comply with the South African

Protection of Personal Information Act, 4 of 2013 ("POPI") and the General Data

Protection Regulation ((EU) 2016/679) ("GDPR") (collectively referred to as

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"Applicable Law" in this Policy). In this Policy, we explain how we will use and

protect your Personal Information in terms of Applicable Law.

2. PERSONAL INFORMATION

Where we refer to "Personal Information" in this Policy, we mean personal information as

defined in Applicable Law, being information that may be used to directly or indirectly

identify you. Personal Information includes, for example, your name, surname, email

address, identity number, contact details, photograph and location.

3. COLLECTING YOUR PERSONAL INFORMATION

3.1. We collect Personal Information about you from the following sources:

3.1.1. directly from you when you provide it to us, such as when you sign

up to use our Platform and Services, contact us or through the

course of our relationship with you;

3.1.2. in the case of a child, from your parent or legal guardian;

3.1.3. from public sources where you have made your Personal

Information public, such as on social media;

3.1.4. from your use of our Platform or use of any features or resources

available on or through our Platform; and

3.1.5. from third parties when you interact with them through the

Platform, where they are authorised to share your Personal

Information or your interaction with us as a result of the Services

or as required of the third parties to share it with us or otherwise if

Applicable Laws allow us.

3.2. Where you provide information, including Personal Information, about

someone other than yourself, you warrant that you have that person's consent to

provide that information for the purpose for which you provide it to us.

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4. CATEGORIES OF PERSONAL INFORMATION THAT WE PROCESS

4.1. General personal details: your name and surname, gender, date of birth,

age, nationality, language preferences, identity or passport number.

4.2. Special personal information: such as biometric information, health

information, genetic data, race or ethnic origin, or criminal behaviour of the data

subject.

4.3. Contact details: your address, contact number, email address, and public

social media profile(s).

4.4. User information: Personal Information included in correspondence,

transaction documents, use of the Services or other materials that we process in the

course of providing the Services.

4.5. Education information: present school, level of education, type of education

curriculum and subjects being studied, and extra-curricular activities.

4.6. Consent records: records of any consents you have given us in respect of

using your Personal Information and any related information, such as the specific

details of the consent. We will also record any withdrawals or refusals of consent.

4.7. Payment details: details related to any payments made, such as payment

method, information provided by payment gateway service provider, payment

amount, date and reason for payment and related information.

4.8. Data relating to our Platform: such as the type of device you use to access

the Website and App, the operating system and browser, browser settings, IP

address, dates and times of connecting to and using the Platform and other

technical communications information.

4.9. Cookies and other technologies.

4.10. Account details: such as your username, password, usage data, and

aggregate statistical information.

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4.11. Content and advertising data: records of your interactions with our online

advertising on the various websites which we advertise and records relating to

content displayed on web-pages displayed to you.

4.12. Views and opinions: any views and opinions that you choose to share with

us, or publicly post about us on social media platforms or elsewhere.

4.13. Children's Personal Information: Personal Information of any User that

qualifies as a child in terms of the Applicable Law of the applicable jurisdiction

necessary for us to render the Services and with the consent of a parent or

guardian. We will only intentionally process the Personal Information of children

with the consent of a parent or guardian of that child where required in terms of

Applicable Law.

5. PURPOSES OF PROCESSING PERSONAL INFORMATION

5.1. We only process adequate and relevant Personal Information for the following

purposes and legal bases:

5.1.1. to perform in terms of our agreement with you (provide you with

the Services and access to the Platform, including registering for

and delivering the Services);

5.1.2. operate and manage your account or your relationship with us;

5.1.3. monitor and analyse our business to ensure that it is operating

properly, for financial management and for business-development

purposes;

5.1.4. contact you by email, telephone, text message, push notifications

or other means to inform you about our Services, unless you have

opted-out of such communications (direct marketing);

5.1.5. form a view of you as an individual and to identify, develop or

improve the Platform and Services that may interest you;

5.1.6. carry out market research and surveys, business and statistical

analysis and necessary audits;

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5.1.7. for fraud prevention;

5.1.8. perform other administrative and operational tasks like testing our

processes and systems and ensuring that our security measures

are appropriate and adequate; and

5.1.9. comply with our regulatory, legal or other obligations.

5.2. In addition to the above purposes, we may use your Personal Information for

other purposes if the law allows for it, if you consent to it, or if it is in the public

interest to do so. All purposes for the processing of your Personal Information will

be allowed in terms of Applicable Law.

6. DIRECT MARKETING

6.1. We may process your Personal Information to contact you to provide you with

information regarding our Services that may be of interest to you. Where we provide

Services to you (where you are a customer of ours), we may send information to

you regarding our Services and other information that may be of interest to you,

using the contact details that you have provided to us. We will only send you direct

marketing communications where you have consented to us sending you direct

marketing or otherwise in compliance with Applicable Laws.

6.2. You may unsubscribe from any direct marketing communications at any time

by clicking on the unsubscribe link that we include in every direct marketing

communication or by contacting us and requesting us to do so.

6.3. After you unsubscribe, we will not send you any direct marketing

communications, but we will continue to contact when necessary in connection with

providing you with the Services or in connection with our business.

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7. DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES

7.1. We will keep your Personal Information confidential and only share it with

others in terms of this Policy, or if you consent to it, or if the law requires from us to

share it. We may disclose your Personal Information to:

7.1.1. the qualification bodies that we partner with to provide you with the

Services as further described in the Terms and Conditions on the

Platform;

7.1.2. our business partners or third party service providers and

processors in order to provide you with access to the Platform

and/or the Services, such as data storage and other necessary

service providers, third party payment processors, etc. in

accordance with written agreements with these third parties;

7.1.3. legal and regulatory authorities, upon their request, or for the

purposes of reporting any breach of Applicable Law;

7.1.4. accountants, auditors, lawyers and other external professional

advisors in terms of written agreements with them;

7.1.5. any relevant party to the extent necessary for the establishment,

exercise or defence of legal rights, criminal offences, threats to

public security, etc.;

7.1.6. any relevant third party if we sell or transfer all or any portion of

our business or assets; and

7.1.7. any relevant third party provider where our Platform uses third

party advertising, plugins or content.

7.2. If we engage third party processors to process your Personal Information, the

processors will only be appointed in terms of a written agreement which will require

the third party processors to only process Personal Information in terms of our

mandate, use appropriate measures to ensure the confidentiality and security of

your Personal Information and comply with any other requirements set out in the

agreement and required by Applicable Law.

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7.3. Our Platform may connect to various social media websites or apps,

including, but not limited to, Facebook, Twitter, LinkedIn, Instagram. If you want to

use the Platform for social media integration, we will share your Personal

Information with the relevant social media websites or apps.

8. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

8.1. Due to the nature of the Services and our business being established in

different countries and us working with business partners and service providers in

different countries, we may need to transfer Personal Information to and from the

different countries for internal business purposes.

8.2. We may transfer your Personal Information to recipients in other countries.

We will only transfer Personal Information to third parties in countries with adequate

data protection laws or do so in terms of a written agreement with the recipient

which imposes data protection requirements on that party as required by Applicable

Law.

8.3. Please note that when you transfer any Personal Information directly to a third

party in another country (i.e. we do not send your Personal Information to the third

party), we are not responsible for that transfer of Personal Information (and such

transfer is not based on or protected by this Policy). Any Personal Information that

we receive from a third party country will nevertheless be processed in terms of this

Policy.

9. SECURITY

9.1. We have implemented appropriate technical and organisational security

measures designed to protect Personal Information against accidental or unlawful

destruction, loss, alteration, disclosure, access and other unlawful or unauthorised

forms of processing. These measures are in accordance with Applicable Law.

9.2. The internet is an open and often vulnerable system and the transfer of

information via the internet is not completely secure. Although we will implement all

reasonable measures to protect Personal Information, we cannot guarantee the

security of your Personal Information transferred to us using the internet.

Therefore, you acknowledge and agree that any transfer of Personal

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Information via the internet is at your own risk and you are responsible for

ensuring that any Personal Information that you send is sent securely.

10. YOUR LEGAL RIGHTS

10.1. You have certain rights in relation to your Personal Information. As available

and except as limited under Applicable Law, you have the following rights in respect

of your Personal Information:

10.1.1. right of access: the right to be informed of and request access to

the Personal Information that we process about you;

10.1.2. right to rectification: you may request that your Personal

Information be amended or updated where it is inaccurate or

incomplete;

10.1.3. right to erasure: the right to request that we delete your Personal

Information, subject to applicable limitations and exceptions;

10.1.4. right to restrict processing: you may request that we temporarily

or permanently stop processing your Personal Information;

10.1.5. right to object:

10.1.5.1. you may object to us processing your Personal

Information; and

10.1.5.2. to your Personal Information being processed for direct

marketing purposes;

10.1.6. right to information portability: you may request a copy of your

Personal Information and request your information to be

transmitted for use by another person; and

10.1.7. right not to be subject to automated decision-making: where a

decision that has a legal or other significant effect is based solely

on automated decision making, including profiling, you may

request that your Personal Information not be processed in that

manner.

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10.2. Where you have provided consent for us to process your Personal

Information, you may also withdraw your consent where our processing is based on

your consent. However, we may continue to process your Personal Information if

another legal justification exists for the processing.

11. USE OF COOKIES AND SIMILAR TECHNOLOGIES

11.1. Cookies are small files about browsing activity that are stored on a device's

web browser by the websites that are visited and are generally used to improve

user experience. When you use the Platform we automatically receive and record

information on our server logs from your browser, such as your location, IP address,

general internet usage and Google Analytics information. This is statistical data

about browsing actions and patterns. Cookies enable us to improve our Platform

and Services, estimate our audience size and usage patterns, store information

about your preferences and recognise when you return to the Platform.

11.2. In some instances, we collect and store information about your location

through cookies (other than when you share your location with us). We convert your

IP address or mobile GPS data into a rough geo-location, and we may use location

information to improve and personalise the Platform and Services for you.

11.3. You can set your web browser to refuse cookies or by downloading and

installing the Google Analytics Opt-out Browser Add-on, but your full use of the

Platform or Services might be limited and you may not be able to take advantage of

certain promotions we may run.

11.4. Please note that third parties may also use cookies, but we do not have

access to, or control over them, and therefore cannot take responsibility for them.

11.5. The various types of cookies (distinguished by their function, lifespan and

origin) that we may collect include the following:

11.5.1. first party cookies: cookies that are stored by the actual website

or app you are visiting which are only visible to that website or

app;

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11.5.2. third party cookies: cookies that are stored by third parties (other

than the actual website or app), such as Google Analytics, and are

generally used for cross-site tracking, retargeting and advertising;

11.5.3. necessary cookies: cookies that are necessary for the technical

operation of a website or app. For example, they enable you to

move around on a website or app and to use its features;

11.5.4. performance cookies: cookies that collect data on the

performance of a website or app. Examples include the number of

persons who visit a website or app, the time spent on the website

or app and errors that may arise during the use of the website or

app;

11.5.5. functionality or preference cookies: cookies that increase the

usability of a website or app by remembering a visitor's choices,

such as the language preference, login information, location of the

visitor, etc.;

11.5.6. targeting or advertising cookies: cookies that enable a website

or app to send its visitors personalised advertising, often based on

your browsing history; and

11.5.7. session cookies: these are temporary cookies that are deleted

once you close your browser. Permanent cookies are those that

are stored on your device until you delete them or until your

browser deletes them (after a period specified in the cookie).

12. LINKS ON OUR PLATFORM

Our Platform may include links to other apps or third party websites which do not fall under

our supervision. We cannot accept any responsibility for your privacy or the content

of these third party sites, but we display these links in order to make it easier for you

to find information about specific subjects. If you use or rely on these links, you do

so at your own risk.

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13. RIGHT TO OBJECT

You may, on reasonable grounds, object to us using your Personal Information for certain

purposes. If you object, we will stop using your Personal Information, except if

Applicable Law allows its use. To exercise this right or to discuss it with us, please

contact us on info@valentureinstitute.com.

14. CHILDREN'S INFORMATION AND SPECIAL PERSONAL INFORMATION

14.1. Due to the nature of the Services we provide, we collect and use children's

Personal Information with the consent of their parents or legal guardians.

14.2. We do not intentionally collect or use children's Personal Information (for

purposes other than providing the Services to Users that are children) without the

consent of a parent or guardian of the child unless the User is capable of

consenting to the processing of his/her Personal Information in terms of the

Applicable Laws in his/her jurisdiction.

14.3. Similarly, we will only collect or process special Personal Information without

your consent or if otherwise allowed by Applicable Law.

15. QUALITY AND ACCESS TO YOUR INFORMATION

15.1. Quality: we want to ensure that your Personal Information is accurate and up

to date. You may ask us to correct or remove any Personal Information that you

think is inaccurate, by sending us an email on info@valentureinstitute.com.

15.2. Access: you have the right to request that we provide you with Personal

Information that we hold about you. You must contact us directly to do so or send

an email to info@valentureinstitute.com. This request may be subject to an access

to information request in terms of Applicable Laws and may require you to verify

your identity, identify the rights you are wishing to exercise and pay a fee.

15.3. The right to access your Personal Information may further be limited in terms

of Applicable Law.

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16. RETENTION OF INFORMATION

16.1. We take every reasonable step to ensure that your Personal Information is

only processed for the minimum period necessary for the purposes set out in this

Policy.

16.2. We retain Personal Information in accordance with the required retention

periods in Applicable Law or for legitimate business purposes. We will only retain

your Personal Information for the purposes explicitly set out in this Policy. We may

keep Personal Information indefinitely in a de-identified format for statistical

purposes, which may include for example statistics of how you use the Platform and

Services.

16.3. This Policy also applies when we retain your Personal Information.

16.4. We may retain your Personal Information for the duration of any period

necessary to establish, exercise or defend any legal rights.

17. SECURITY BREACH

We will report any security breach to the applicable regulatory authority in terms of

Applicable Law and to the individuals or companies whose Personal Information is

involved in the breach. If you want to report any concerns about our privacy practices

or if you suspect any breach regarding your Personal Information, kindly notify us by

sending an email to info@valentureinstitute.com.

18. LODGING A COMPLAINT

18.1. If you want to raise any objection or have any queries about our privacy

practices, you can contact our data protection officer on

info@valentureinstitute.com.

18.2. You also have the right to formally lodge a complaint in terms of Applicable

Law as follows:

Applicable

Law

Regulatory

authority

name

Contact details

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POPI The

Information

Regulator

Website: http://www.justice.gov.za/inforeg/index.html

Address: SALU Building, 316 Thabo Sehume Street,

Pretoria

Tel: 012 406 4818

Fax: 086 500 3351

Email: inforeg@justice.gov.za

GDPR The European

Commission

Online complaint procedure:

https://ec.europa.eu/info/about-european-commission/cont

act/problems-and-complaints/how-make-complaint-eu-level

/submit-complaint_en

Address: European Commission, Secretary-General

B-1049 Brussels, BELGIUM

Fax: 3222964335

19. LEGAL DISCLOSURE

19.1. Platform owner: Valenture Ltd, company number 12192134.

19.2. Legal status: Valenture is a private limited company, duly incorporated in

terms of the applicable laws of England and Wales.

19.3. Director: SS SALTY.

19.4. Description of main business of Valenture: Valenture is a global private

online high school offering a curriculum recognised by the world's leading

universities. Our students experience a highly engaging, inclusive and socially rich

learning environment which is supported by expert tutors and mentors.

19.5. Email address: info@valentureinstitute.com.

19.6. Website address: https://www.valentureinstitute.com/.

19.7. Physical and postal address: 100 Brompton Rd, London, SW3 1ER, United

Kingdom.

19.8. Registered office address: Quadrant House, Floor 6, 4 Thomas More

Square, London, United Kingdom, E1W 1YW.

Last updated: 11 September 2019

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