Privacy Policy

LearnSmartly ("we", "us", "our") respects your privacy and protects your personal information in line with POPIA. This policy explains what we collect through www.learnsmartly.institute, why, how we protect it, who we share it with, and the rights you have.

1 · Who is responsible for your information

Under POPIA the responsible party is the party that decides why and how your information is processed. That is:

Learnsmartly SA (Pty) Ltd
Company registration number: [to confirm]
Registered address: [to confirm]
Information Officer: David Maclean
Email: david@learnsmartly.institute

2 · The operators who process information for us

We use service providers ("operators" under POPIA) who process personal information on our behalf and on our instruction:

• Ennea International [legal entity to confirm] — hosts our customer relationship management system at crm.enneainternational.com, where enquiry and contact records are stored, under a written operator agreement.
• Our website platform and database — hosts this site and stores the records it creates: newsletter and field-guide sign-ups, programme applications, assessment reports and certificate records.
• Intuit Mailchimp — email delivery for the field guide and updates. Located in the United States (see cross-border transfers).
• Microsoft (Microsoft 365 and Bookings) and Calendly — scheduling of discovery calls.
• Google (Analytics, via Google Tag Manager) — measuring how the site is used.

Each operator must keep your information secure and process it only for the purposes we specify.

3 · What we collect

• What you give us: name, email address, organisation, job role, telephone number where you provide one, and anything else you enter when you download a resource, complete a form, apply to a programme, or book a call.
• Assessment information: where you take a LearnSmartly assessment, your responses and the resulting report.
• Technical information: collected automatically — IP address, device and browser type, pages visited, and where you came from.

4 · Why we process it, and our lawful basis

We process your information to:

• send you the resources you ask for;
• deliver assessments, reports and programmes you or your organisation have bought;
• send occasional updates you have consented to receive;
• arrange and hold discovery calls you book;
• answer your enquiries; and
• understand how the site and our campaigns perform.

Our lawful basis is your consent, the performance of a contract where you or your organisation have engaged us, and our legitimate interests in running and improving the business, balanced against your rights. Giving us your information is voluntary; without it we may not be able to send you the resource or arrange your call. You can withdraw consent at any time.

5 · Marketing and how to opt out

Where you have consented, we may email you occasional updates. Every marketing email carries an unsubscribe link, and you can opt out at any time through that link or by contacting us. Unsubscribing does not affect resources you have already asked for.

6 · Who we share it with

Only the operators listed in section 2, and only as needed. Where an organisation has commissioned an assessment for its people, group-level findings are shared with that organisation; individual reports are shared with the individual. We do not sell your personal information. We may disclose information where the law requires it, or to establish or defend legal rights.

7 · Cross-border transfers

Some operators — Mailchimp, Microsoft and Google — process information outside South Africa. Where that happens we take reasonable steps to ensure it enjoys a comparable level of protection, consistent with POPIA, through those providers' contractual commitments and standard data-transfer safeguards. [Safeguards to be confirmed by our attorney.]

8 · How long we keep it

• Enquiry and marketing contacts: up to 36 months after your last contact with us, then deleted or anonymised.
• Assessment responses and reports: for the duration of the client engagement and up to 5 years afterwards, so reports can be re-issued and change can be measured over time.
• Records we must keep by law (for example financial records): for the period the law requires.

9 · Your rights

Under POPIA you may:

• ask what personal information we hold about you, and see it;
• ask us to correct or update anything inaccurate or out of date;
• ask us to delete information we are no longer entitled to keep;
• object to processing in certain circumstances;
• withdraw consent to marketing at any time; and
• complain to the Information Regulator (section 12).

To exercise any of these, email david@learnsmartly.institute. We may need to verify who you are first.

10 · Cookies and analytics

This site uses cookies and Google Analytics, loaded through Google Tag Manager, to understand how visitors use the site and how our campaigns perform. We do not use these cookies to identify you personally. You can control or block cookies through your browser settings; the site works without them.

11 · Changes to this policy

We may update this policy from time to time. The current version is always at www.learnsmartly.institute/privacy.

12 · Contact us, and the Information Regulator

For any privacy question, or to exercise your rights, contact the Information Officer at Learnsmartly SA (Pty) Ltd: david@learnsmartly.institute.

You may also complain to The Information Regulator (South Africa) — inforegulator.org.za.