Lusa SEI LMS

Privacy Policy

This Privacy Policy is effective as of: 1 July 2021 ("Effective Date")

READ THIS POLICY CAREFULLY BEFORE BROWSING THIS WEBSITE OR USING ANY OF THE SERVICES. YOUR CONTINUED USE OF THIS WEBSITE INDICATES THAT YOU HAVE BOTH READ AND AGREE TO THE TERMS OF THIS PRIVACY POLICY. YOU CANNOT USE THIS WEBSITE IF YOU DO NOT ACCEPT THIS POLICY. ALL SECTIONS OF THIS POLICY ARE APPLICABLE TO BOTH MEMBERS AND GUESTS UNLESS THE SECTION EXPRESSLY STATES OTHERWISE.

1. Introduction

1.1 For the purposes of this policy, Personal Information will be understood in accordance with the definition provided in the Protection of Personal Information Act 4 of 2013 (“the Act”). LusaSEI also subscribes to the principles for electronically collecting personal information outlined in the Act, and the further legislation referred to therein. We endeavour to ensure the accuracy and confidentiality of Personal Information in our possession.

1.2 In adopting this Privacy Policy, we wish to balance our legitimate business interests and your reasonable expectation of privacy. Accordingly, we will take all reasonable steps to prevent unauthorised access to, or disclosure of your Personal Information. However, it is impossible to guarantee that your Personal Information shall be 100% secure.

2. Processing Personal Information

2.1 All users will be prompted to register a profile with LusaSEI. In so doing, users may be asked to provide the following Personal Information pertaining to themselves or the data subjects to which you have validly obtained consent to disclose:

2.1.1 First name;

2.1.2 Surname;

2.1.3 Email;

2.1.4 Physical address;

2.1.5 Phone number;

2.1.6 Identity Number

2.1.7 Consent to being recorded and photographed during live training

2.1.8 Consent to receive marketing and promotional material

2.2 We will attempt to limit the types of Personal Information we process to only that to which you consent to (for example, in the context of online registration, newsletters, message boards, surveys, polls, professional announcements, SMS, WhatsApp and other mobile services), but, to the extent necessary, your agreement to these this Privacy Policy constitutes your consent as contemplated in section 69 of the Act.

2.3 All payment information will be captured through the Pluto Education Website. Further, LusaSEI shall not retain payment information on behalf of its users.

2.4 We will not collect, use or disclose sensitive information (such as information about racial or ethnic origins or political or religious beliefs, where relevant) except with your specific consent or in the circumstances permitted by law.

2.5 By agreeing to the terms contained in this Privacy Policy, you consent to the use of your Personal Information in relation to:

2.5.1 Informing you of changes made to our website;

2.5.2 The provision and performance of LusaSEI LMS services;

2.5.3 The provision of marketing and promotional material

2.5.4 Responding to any queries or requests you may have;

2.5.5 Developing an online user profile;

2.5.6 For security, administrative and legal purposes; and

2.5.8 The creation and development of market data profiles which may provide insight into market norms, practices and trends to help us improve our offering to you. Any information shall not be used in any way which may compromise the identity of a user.

2.6 Any emails sent by LusaSEI will only be in connection with the provision of our services and/or the marketing thereof.

2.7 The Personal Information provided by you is necessary in order that LusaSEI may provide the requisite services to you, and failure to provide such Personal Information may render LusaSEI unable to provide such services.

2.8 When you visit LusaSEI LMS platform, even if you do not create an account, we may collect information, such as your IP address, the name of your ISP (Internet Service Provider), your browser, the website from which you visit us, the pages on our website that you visit and in what sequence, the date and length of your visit, and other information concerning your computer’s operating system, language settings, and broad demographic information. This information is aggregated and anonymous data and does not identify you specifically. However, you acknowledge that this data may be able to be used to identify you if it is aggregated with other Personal Information that you supply to us. This information is not shared with third parties and is used only within LusaSEI and Pluto Education on a need-to-know basis. Any individually identifiable information related to this data will never be used in any way different to that stated above, without your explicit permission.

 3. Site security

3.1 Although absolute security cannot be guaranteed on the internet, LusaSEI’s service provider, Pluto Education has in place up-to-date, reasonable technical and organisational security measures to protect your Personal Information against accidental or intentional manipulation, loss, misuse, destruction or against unauthorised disclosure or access to the information we process online.

3.2 While we cannot ensure or warrant the security of any Personal Information you provide us, Pluto Education will continue to maintain and improve these security measures over time in line with legal and technological developments.

3.3 Your information will not be stored for longer than is necessary for the purposes described in these Terms or as required by applicable legislation.

3.4 The Personal Information LusaSEI collects from users shall only be accessed by LusaSEI employees, representatives and consultants on a need-to-know basis, and subject to reasonable confidentiality obligations binding such persons.

3.5 We do not accept any users, or representatives of users, under 18 years of age or who otherwise does not have the relevant capacity to be bound by this Privacy Policy unless such users have, through their parent or guardian, consented to the terms hereof.

3.6 You hereby consent to the sharing of your Personal Information to the following third parties categories of third parties:

3.6.1 Payment Gateways;
3.6.2 Entities which provide for the signing into and out of the platform offered by Pluto Education
3.6.3 Video conferencing service providers;
3.6.4 File storage repository providers;
3.6.5 Third party products and service providers which are integrated into our platform;
3.6.6 Service providers which provide plagiarism checking services;
3.6.7 CRM and other customer management service providers;
3.6.8 Website tracking and other cookie related service providers;
3.6.9 Third party booking related tools and service providers; and/or
3.6.10 Website hosting providers.

3.7 LusaSEI’s platform through the Website, may contain links to other third party websites, including (without limitation) social media platforms, payment gateways, appointment scheduling and/or live chat platforms (“Third Party Websites”). If you select a link to any Third Party Website, you may be subject to such Third Party Website’s terms and conditions and/or other policies, which are not under the control, nor responsibility, of LusaSEI.

3.8 LusaSEI does not accept any responsibility for any loss or damage in whatever manner, howsoever caused, resulting from your disclosure to third parties of personal information. Users should evaluate the security and trustworthiness of any Third Party Website before disclosing any personal information to them.

4. Your Rights

4.1 Users have the right of access to their Personal Information stored and processed by LusaSEI. This may be done by emailing us at the address referred to in clause 7.4.6 below.

4.2 Users have the right to rectification of Personal Information that we hold on a user’s behalf, in instances where such Personal Information is incorrect or incomplete.

4.3 Users have the right of erasure of Personal Information (“right to be forgotten”) if such information is no longer needed for the original processing purpose, alternatively if a user withdraws their consent and there is no other reason or justification to retain such Personal Information, further alternatively, if a user has objected to such Personal Information being processed and there is no justified reason for the processing of such Personal Information.

4.4 Users have the right to restrict/suspend processing of Personal Information to only that which is strictly necessary for LusaSEI to perform its services to a User.

4.5 If we breach any of the terms of this Privacy Policy, users have the right to complain to the requisite data protection authority in their territory, and in addition, same may be raised with LusaSEI at the mail address stipulated in clause 7.4.6 below.

4.6 Users have a right to withdraw their consent at any time, if processing of Personal Information is based on consent.

4.7 Users have a right to object to processing of Personal Information, if such processing is based on legitimate interests.

4.8 Users have a right to object to the processing of Personal Information for direct marketing purposes.

4.9 Users have the right, should you feel that your Personal Information is not being processed in accordance with this Privacy Policy or any other applicable law, to lay a complaint with the appropriate data / Personal Information processing authority:          South Africa: Information Regulator: 010 023 5207 or inforeg@gov.za;

5 Application Of The Electronic Communications And Transactions Act 25 Of 2002 (“Ect Act”)

5.1 Data Messages (as defined in the ECT Act) will be deemed to have been received by LusaSEI if and when LusaSEI responds to the Data Messages.

5.2 Data Messages sent by LusaSEI to a user will be deemed to have been received by such user in terms of the provisions specified in section 23(b) of the ECT Act.

5.3 Users acknowledge that electronic signatures, encryption and/or authentication are not required for valid electronic communications between users and LusaSEI.

5.4 Information to be provided in terms of section 43(1) of the ECT Act:

5.4.1 Users warrant that Data Messages sent to LusaSEI from any electronic device, used by such user, from time to time or owned by such user, were sent and or authorised by such user, personally.

6. Contact details

6.1 This Website is owned and operated by Pluto Education (Pty) Ltd, a private limited South African company operating in accordance with the company laws of the Republic of South Africa, hosting services to LusaSEI.

6.2 Address for service of legal documents: 31 Faickney Street, Sasolburg, Free State, 1947

6.3 Contact Number: +27 (16) 976 0933

6.4 LusaSEI – located at www.lusasei.com

6.5 Email address: info@lusasei.co.za