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
"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.
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
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.
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
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
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;
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.
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
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.
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
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
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
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
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
10.1.5.2. to your Personal Information being processed for direct
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
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.
11.1. 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.
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.
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
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
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
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.
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 firstname.lastname@example.org.
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 email@example.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 firstname.lastname@example.org. 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.
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
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
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 email@example.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
18.2. You also have the right to formally lodge a complaint in terms of Applicable
Law as follows:
Address: SALU Building, 316 Thabo Sehume Street,
Tel: 012 406 4818
Fax: 086 500 3351
GDPR The European
Online complaint procedure:
Address: European Commission, Secretary-General
B-1049 Brussels, BELGIUM
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: firstname.lastname@example.org.
19.6. Website address: https://www.valentureinstitute.com/.
19.7. Physical and postal address: 100 Brompton Rd, London, SW3 1ER, United
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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