Privacy Policy

1. Introduction
   • At SYTS, we adhere to the highest standards of protecting your personal information when we process it by virtue of your use of our services or any of our website, syts.co.za, our application or any associated platforms (collectively, “the Website”), or by providing us with your personal information in any other way. As such, we have created this specific and detailed privacy policy for you to read and to understand exactly how we safeguard your personal information and respect your privacy (“Privacy Policy”).
   • This Privacy Policy is to be read as if specifically incorporated into the Terms of Service, available at: http://www.syts.co.za/terms-of-service.
   • Please read this Privacy 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. All sections of this privacy policy are applicable to both members and guests unless the section expressly states otherwise.
   • Please note that we are a private limited liability company duly registered and operating in accordance with the laws of the Republic of South Africa.
   • Not all terms are necessarily defined in order or may be defined in our Terms of Service (“Terms”).
2. Who We Are
   • This Privacy Policy aims to give you information on how we collect and process your personal information through any form of your engagement with us including when contracting or corresponding with us or providing us with your personal information in any other way.
   • This Privacy Policy complies with, and facilitates the obligations required from, the South African Protection of Personal Information Act, No. 4 of 2013 (“POPI”), as amended.
   • 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 personal information. This Privacy Policy supplements the other notices and is not intended to override them.
   • Responsible Party and Operator
     • We are the “Responsible Party” and are responsible for your personal information in instances where we decide the processing operations concerning your personal information. We also operate as an “Operator” of personal information on behalf of partners within our network, where that entity is the Responsible Party and their privacy policy will apply to you.
     • We have appointed an information officer at SYTS 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 our information officer using the details set out below.
   • Our contract details:
     • Information Officer: Tarryn De Matteis
     • Address: 4C, 4 Clarens Road, Sea Point, Cape Town, Western Cape, South Africa, 8005.
     • Contact Number:  (+27) 72 887 2536.
     • Website:  https://syts.co.za;
     • Email address: [email protected]

You have the right to make a complaint at any time to the South African regulator’s office (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.

• Changes to this Privacy Policy
  • This Privacy Policy was last updated on 16 November 2023 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.
  • This Privacy Policy is subject to change without notice and is updated or amended from time to time and will be effective once we upload the amended version to the Website. Your continued access or use of the Website constitutes your acceptance of this Privacy Policy, as amended. It is your responsibility to read this document periodically to ensure you are aware of any changes.

3. What We Collect About You
   • For the purposes of this section, Personal Information will be understood in accordance with the definition provided in the Protection of Personal Information Act 4 of 2013 (“POPI“). We endeavour to ensure the quality, accuracy and confidentiality of Personal Information in our possession.
   • Personal information, or personally identifiable information, means any information about an individual, both natural and juristic entities (i.e., people and companies), from which that entity can be identified. It does not include information where the identity has been removed (anonymous data).
   • We may collect, use, store, and transfer (“process”) different kinds of personal information about you which we have grouped together as follows:
     • Identity Data including full name, age, gender, identity or passport number, copy of ID or passport, proof of university enrolment, proof of employment, or the information about your company such as company name, address and/or company registration details;
     • Contact Data including email address, physical/registered addresses, and contact phone numbers;
     • Profile Data including all the data and information available in your profile such as payment history, services used, statements, rewards, and subscriptions;
     • Social Media Data including all the data available on your publicly available social media profile;
     • Financial Data including bank account details and third-party payment provider information and payment card details (which we do not process but is processed by a payment service provider on our instruction);
     • Transaction Data including details about payments to and from you, contracts, contractual terms, contract fees, signups, subscriptions, invoices and other details of products and services you have obtained from us, or provide to us;
     • Technical Data including internet protocol address/es, login data, browser type and version, time zone setting and location, cookies, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website;
     • Usage Data including information about how you use our company, Website, surveys, and Services; and
     • Marketing and Communications Data including your preferences in receiving notices and marketing from us and our third parties and your communication preferences as well as details of which communications were sent to you and how they were sent.
   • 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, MMS and other mobile services), but, to the extent necessary, your agreement to this this Privacy Policy constitutes your consent as contemplated in section 69 of POPI.
   • All payment information will be processed and stored by our licensed payment service provider.
   • We will not collect, use or process special categories of personal information without your specific consent or in the circumstances permitted by law.
   • We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal information but is not considered personal information in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature or service. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Privacy Policy.
4. Minor Data
   • Due to the nature of our business and service offering, we process very limited personal information of minors. By accepting this Privacy Policy, you, (including parents/guardians) expressly and informedly consent to our processing of such personal information where we will always store and process any such personal information at a higher standard than conventional personal information.
   • The data we collect about minors include the following information which we have grouped as follows:
     • Identity Data including full name, age, gender, identity or passport number, copy of ID or passport, school enrolment;
     • Contact Data including contract number, email address, physical address;
     • Profile Data including all the data and information available in your profile such as payment history, services used, statements, rewards, and subscriptions;
     • Transaction Data including details about payments to and from you, contracts, contractual terms, contract fees, signups, subscriptions, invoices and other details of products and services you have obtained from us, or provide to us;
     • Technical Data including internet protocol address/es, login data, browser type and version, time zone setting and location, cookies, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website; and
     • Usage Data including information about how you use our company, Website, surveys, and Services.
   • We will store and process all Minor Data in accordance with our security standard set forth in 7 below. Minor Data will always be stored at a more secure standard due to the sensitivity thereof.
5. How we will use your Personal Information
   • We will only use your personal information when the law allows us to and for legitimate reasons, which you hereby expressly understand and consent to. Most commonly, we will use your personal information in the following circumstances:
     • where we have your express consent to do so;
     • where we need to consult with you or perform on the Services contract we are about to enter into or have entered into with you;
     • where it is necessary for our legitimate business interests (or those of a third party) and your interests and fundamental rights do not override those interests; and/or
     • where we need to comply with a legal or regulatory obligation.

6. Purposes for Which We Will Use Your Personal Information
   • We have set out below, a description of the purposes for which we will process your personal information:
     • The provision and performance of the services;
     • To contract with service providers;
     • To provide it to authorised service providers who need your personal information to provide their services to you (such as payment gateway providers and partners);
     • Informing you of changes made to our Website;
     • To process and service your payment for any services rendered by us or our service providers;
     • To manage payments, fees, and charges;
     • The provision of marketing related services to you by SYTS;
     • Responding to any queries or requests you may have;
     • Developing a more direct and substantial relationship with users for the purposes described in this clause;
     • Developing an online user profile;
     • Understanding general user trends and patterns so that we can develop and support existing and ongoing marketing strategies;
     • To meet our regulatory and compliance requirements;
     • For security, administrative and legal purposes; and
     • 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. Such information will be compiled and retained in aggregated form, but shall not be used in any way which may comprise the identity of a user.
   • Marketing
     • We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising. To manifest your rights attached to any marketing sent to you as an existing user, please use the in-built prompts provided on those communications, or contact us.
     • You will receive marketing communications from us if you have requested our services, requested information from us, or provided us with your details in any other circumstance and, in each case, have not opted-out of receiving that marketing.
     • You can ask us to stop sending you marketing messages at any time by using the built-in prompts or contacting us and requesting us to cease or change your marketing preferences. Where you opt-out of receiving these marketing messages, this opt-out will not apply to other personal information of yours which we process for another lawful basis or necessary communications we send when you use our Services.
   • Third-Party Marketing
     • Whilst we may use your personal information within our company, we will get your express opt-in consent before we share your personal information publicly with any entity outside of SYTS for marketing.
   • Change of Purpose
     • We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
     • If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
     • Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

7. Data Security
   • Although absolute security cannot be guaranteed on the internet, SYTS 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.
   • While we cannot ensure or warrant the security of any Personal Information you provide us, we will continue to maintain and improve these security measures over time in line with legal and technological developments.
   • We store your Personal Information directly, or alternatively, store your Personal Information on, and transfer your Personal Information to, a central database. If the location of the central database is located in a country that does not have substantially similar laws which provide for the protection of Personal Information, we will take the necessary steps to ensure that your Personal Information is adequately protected in that jurisdiction.
   • Your information will not be stored for longer than is necessary for the purposes described in these Terms or as required by applicable legislation.
   • The Personal Information SYTS collects from users shall only be accessed by SYTS employees, representatives and consultants on a need-to-know basis, and subject to reasonable confidentiality obligations binding such persons.
   • SYTS shall have the right, but shall not be obliged, to monitor or examine any information and materials including any website link that you publish or submit to SYTS for publishing on the Site.  You shall be solely responsible for the contents of all material published by yourself.
   • We constantly review our systems and data to ensure the best possible service to our users. We do not accept any users who otherwise does not have the relevant capacity to be bound by this Privacy Policy.
   • We share this information with our data processors and disclose all information regarding the data processor in our data processor agreement.

8. Log Files

• • When you visit SYTS, 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 SYTS 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.

9. Cookies

• • SYTS uses cookies. A cookie is a small piece of information stored on your computer or smart phone by the web browser. The two types of cookies used on the Website are described below:
    • “Session cookies”: These are used to maintain a so-called ‘session state’ and only lasts for the duration of your use of the Website. A session cookie expires when you close your browser, or if you have not visited the server for a certain period of time. Session cookies are required for the Website to function optimally, but are not used in any way to identify you personally.
    • “Permanent cookies”: These cookies permanently store a unique code on your computer or smart device hard drive in order to identify you as an individual user. No Personal Information is stored in permanent cookies. You can view permanent cookies by looking in the cookies directory of your browser installation. These permanent cookies are not required for the SYTS website to work, but may enhance your browsing experience.

10. Links from SYTS
    • SYTS, and the services available 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 SYTS.
    • Hyperlinks to Third Party Websites are provided “as is”, and SYTS does not necessarily agree with, edit or sponsor the content on Third Party Websites.
    • SYTS does not monitor or review the content of any Third Party Website. Opinions expressed or material appearing on such websites are not necessarily shared or endorsed by us and we should not be regarded as the publisher of such opinions or material. Please be aware that we are not responsible for the privacy practices, or content, of other websites, either.
    • Users should evaluate the security and trustworthiness of any Third Party Website before disclosing any personal information to them. SYTS 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.
11. Disclosures of Your Personal Information
    • We may have to share your personal information with the following parties:
      • Internal third parties including any entity within our company group who act as joint responsible parties;
      • External parties including the International Student Identity Card Association (ISIC), ISIC discount partners, software service providers, South African or other national governments and/or their respective authorities pursuant to our adherence with anti-corruption and crime-fighting legislation; professional advisers acting as operators or joint responsible parties including lawyers, bankers, auditors and insurers; and
      • Third parties to whom we may choose to sell, transfer, or merge parts of our company or our assets. Alternatively, we may seek to acquire other organisations or merge with them. If a change happens to our company, we may continue to use your personal information in the same way as set out in this Privacy Policy.
    • We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information in accordance with our instructions and standards.
12. International Transfers
    • We may share and process your personal information outside of South Africa for the purpose of cloud storage or to engage with third parties.
    • Whenever we may transfer your personal information out of South Africa, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
      • We will only transfer your personal information to countries that have appropriate data protection legislation in place similar to that of South Africa; and/or
      • Where we use service providers, we may use specific contracts/clauses which ensure personal information is processed and secured lawfully.
    • You are welcome to contact us if you want further information regarding transfer of personal information out of South Africa.
13. Data Retention
    • We will only retain your personal information for as long as necessary to fulfil the purpose we collected it for including any legal, accounting, or reporting requirements.
    • To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purpose for which we process your personal information, any other South African applicable law requiring us to retain the personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
    • We may also anonymise your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
14. Your Legal Rights
    • You have rights in relation to your personal information where we are the “Responsible Party” or “Controller” over your personal information. Please contact us to find out more about, or manifest, these rights:
      • request access to your personal information;
      • request correction of your personal information;
      • request erasure of your personal information;
      • object to the processing of your personal information;
      • request a restriction of processing your personal information;
      • request transfer of your personal information; and/or
      • right to withdraw consent.
    • You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
    • We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
    • We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
    • Users with citizenships from jurisdictions other than South Africa, please note that we comply with South African data protection laws when processing your personal information as we are a South African entity. Should foreign law be applicable to your use of the Services and/or the Platform in any way, including how we may process your personal information, please contact us and we will gladly engage with you on your rights.