Last updated: ⚠️ [date]
1. Who This Policy Covers
This Privacy Policy explains how Entreprenerdy collects, uses, and protects personal information in connection with the Entreprenerdy website and EMS platform, in accordance with South Africa’s Protection of Personal Information Act (POPIA).
2. Information Officer
In terms of POPIA, our Information Officer is: ⚠️ [name] (info@entreprenerdy.co.za) — POPIA requires this to be registered with the Information Regulator and published.
3. What We Collect
From website visitors:
- Contact details submitted via forms (name, email, organisation, message)
- Usage data (see Cookie Policy)
From EMS platform users and their programme beneficiaries:
- Account and profile information
- Programme, cohort and diagnostic data
- Compliance and verification documentation
- Mentoring session records
- Financial/spend attribution data related to programme activity
⚠️ [Beneficiary data may include sensitive information depending on programme type — e.g. income, ID numbers, disability status for certain government/ESD frameworks. This needs specific legal review, as POPIA treats “special personal information” differently and may require additional consent mechanisms.]
4. Why We Process This Information
- To provide and operate the Services
- To generate compliance, monitoring and reporting outputs on behalf of client organisations
- To respond to enquiries and demo requests
- To send the monthly newsletter, where subscribed (opt-in, cancellable at any time)
- To meet legal and regulatory obligations
5. Legal Basis for Processing
We process personal information on the basis of: performance of a contract with our clients, consent (e.g. newsletter), legitimate interest (e.g. improving the Services), and compliance with legal obligations. ⚠️ [Confirm each processing activity’s specific legal basis with counsel.]
6. Data Controller vs. Data Processor
For beneficiary data uploaded by client programmes, the client organisation is typically the data controller (they determine why and how the data is processed); Entreprenerdy acts as the data processor. For website enquiries and newsletter subscribers, Entreprenerdy is the data controller. ⚠️ [Confirm this split matches your actual contractual arrangements.]
7. Who We Share Information With
- ⚠️ [Hosting/infrastructure providers — name them once confirmed]
- ⚠️ [Any third-party tools used for email, analytics, forms — name them]
- Client organisations, in respect of their own programme’s beneficiary data
- Regulators or auditors, where legally required (e.g. verification agencies, government oversight bodies)
We do not sell personal information.
8. Data Retention
We retain personal information for as long as necessary to provide the Services and meet legal, regulatory or audit requirements. ⚠️ [Define specific retention periods — particularly important given the platform’s own “audit-ready” and longitudinal-tracking positioning; retention periods likely differ for government/donor-funded programmes with their own record-keeping rules.]
9. Security
We apply technical and organisational measures — encryption, role-based access control — to protect personal information, consistent with POPIA’s security safeguard requirements.
10. Your Rights
Under POPIA, you have the right to:
- Access the personal information we hold about you
- Request correction or deletion of inaccurate information
- Object to processing in certain circumstances
- Lodge a complaint with the Information Regulator
To exercise these rights, contact info@entreprenerdy.co.za.
11. Cross-Border Transfers
⚠️ [If any data is stored or processed outside South Africa — e.g. cloud hosting region — this must be disclosed and justified under POPIA’s cross-border transfer rules. Confirm hosting location with your dev/infrastructure team before publishing this section.]
12. Children’s Information
Where programme beneficiaries are minors (e.g. youth development programmes), client organisations are responsible for obtaining appropriate consent from a parent or guardian, or another competent person, in line with POPIA’s requirements for processing children’s personal information. ⚠️ [This needs specific legal review given the Youth Development and University solution pages target under-18 and young-adult participants.]
13. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be communicated to registered users.
14. Contact
Questions or complaints about this policy: info@entreprenerdy.co.za Information Regulator (South Africa): inforeg@justice.gov.za