Privacy Policy

Introduction

Henley Business School – Africa (“Henley Africa”), a division of the University of Reading (Incorporated in the United Kingdom) is committed to protecting and respecting your privacy.

This Privacy Notice, which must be read together with our Website terms and conditions (“Terms“), sets out the basis on which any personal information we collect from you, or that you provide to us, will be collected, used, stored and processed by us (“Process“). Unless defined elsewhere, terms in this Privacy Notice shall bear the same meaning ascribed to them in the Terms.

In adopting this Privacy Notice, we wish to balance our legitimate business interests and your reasonable expectation of privacy. Accordingly, we will take reasonable steps to prevent unauthorised access to, or disclosure of your Personal Data (as defined below under the paragraph “What types of Personal Data do we Process?”).

Consent

By accessing, using and/or downloading any Content from the Website in any way, you signify that you have read and agree to comply and be bound by this Privacy Notice and by the Terms which can be accessed at www.henleysa.ac.za.

In particular you consent that we may Process Personal Data for the purposes of providing you with access to the Content and our Website and for any of the purposes listed in this Privacy Notice.

If you do not agree with this Privacy Notice, please do not continue to use the Website and/or the Content.

Whilst the supply of your Personal Data is voluntary, a consequence of failing to provide the Personal Data is that we will be unable to provide the Content to you and may not be able to provide you with any of our products or Services. The terms “Content” and “Services” have the same meaning in this Privacy Notice as the meaning given to them in the Terms.

What types of Personal Data do we Process?

The types of Personal Data that we may Process includes information necessary for our legitimate business interests and the categories of personal information identified in relevant data protection laws in the Republic of South Africa. This may include personal information which contains identifiable information such as (amongst other things) your first and last name, identity number, email address, postal address, telephone numbers, date of birth, and information related to your educational history (“Personal Data“).

We will attempt to limit the types of Personal Data we Process to only that to which you consent and which is necessary for our legitimate business interests. Should you not consent to providing Personal Data which is necessary for us in our legitimate interests, we reserve the right to not provide a Service.

How and when does Henley Africa collect Personal Data?

Henley Africa will collect your Personal Data in several ways, including:

• when you make use of the Services and Content on the Website;
• when you browse the Website;
• when we carry out demographic research;
• when you register an account on the website;
• should you be registered on a course, on the online learner support systems;
• when you give us information or supporting documents which we ask for on the Website;
• with your consent when you participate in peer or research activities;
• when you respond to us in written or electronic format such as through email or facsimile as required through interactions with us; and
• When you join or participate on social networks with Henley Africa-related groups, or with content considered public domain such as Twitter hashtags.

When you visit our Website, our web server also automatically records the name of your ISP (Internet Service Provider), the website from which you visit us, the pages on our sites you visit and in what sequence, and the date and length of your visit. This information is aggregate and anonymous data and does not identify you specifically.

How does Henley Africa use your Personal Data?

We may use your Personal Data to:

• provide services you request;
• to retain and make available to you information or via the Website;
• as a registered user, to notify and authenticate your identity when you view and access the designated area of the Website or other supporting databases such as student records;
• to verify your identity on the Website;
• allow you to participate in recreational activities on the Website or Learner Management Systems (e.g. participate in our message boards);
• inform you of changes made to our Website;
• inform you of additional services, courses, seminars, programmes offered by us which you may find interesting;
• respond to any queries you may have;
• develop a more direct relationship with you for the purposes described in this section;
• develop an online user profile;
• understand general user trends and patterns so we can develop and support existing and ongoing marketing strategies for our services;
• facilitate our legitimate business interests;
• with consent, as aggregate data for academic research; and
• for security, administrative and legal purposes.

Use of cookies and IP addresses

Cookies are pieces of information a Website transfers to a user’s hard drive for record-keeping purposes. Cookies make surfing the web easier for you by saving your preferences and, tracking your online habits, traffic patterns, and making sure you do not see the same advertisement too often. The use of cookies is an industry standard. We may place a “cookie” on your browser to store and sometimes track information about you.

While most browsers are initially set up to accept cookies you can reset your browser to refuse all cookies or indicate when a cookie is being sent. Further, please note that some aspects of the Website will not function properly if you refuse cookies.

An IP address is a number that is automatically assigned to a computer whenever it is connected to the Internet. We log IP addresses, or the location of computers on the Internet.

We collect IP addresses for the purposes of system administration and to audit the use of the Website. We do not ordinarily link IP addresses to personal information, which means that your session may remain anonymous. However, we cannot guarantee that this will always be the case, as it may be necessary to identify a particular user when it is necessary to enforce compliance with the Terms or to protect our Website, its users or other interests.

What about Personal Data that is publicly available?

If at any time our Website offers any chat rooms, message boards, blogs, newsgroups or forums, etc., anything you post in any of these forums shall be considered public information (“Public Information“) and we Process the Public Information that you disclose. Such Public Information will be used in accordance with this Privacy Notice and shall be stored by us on our platform in accordance with the paragraph “How will Henley Africa store my Personal Data?” below. Please note that we are not responsible for other parties’ use of the Personal Data which you make available to such third parties through any chat room, message board, blog, newsgroup or forums, etc. on our Website.

Will my Personal Data be used for marketing purposes?

If we obtain your prior consent, we may use your Personal Data for the purposes of:

• direct marketing of our own services and on behalf of other companies within Henley Africa;
• research marketing; and
• direct marketing of products and services on behalf of selected third parties, if you have agreed to your details being passed onto third parties.

You are entitled to request that we desist from using your Personal Data for the purposes of direct marketing, and we will provide you with the necessary functionality for you to do so with ease, each time we market to you.

What security measures are in place to protect my Personal Data?

Although absolute security cannot be guaranteed on the Internet, we have in place up-to-date, reasonable technical and organisational security measures to protect your Personal Data against accidental or intentional manipulation, loss, misuse, destruction or against unauthorised disclosure or access to the information we Process online.

No company or service can guarantee complete security. Unauthorised entry or use, hardware or software failure, and other factors may compromise the security of user’s Personal Information at any time. Among other practices, your account is protected by a password for your privacy and security. You must prevent unauthorised access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.

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

How will Henley Africa store my Personal Data?

We store your Personal Data in a customer relationship management database located in Henley Africa’ server rooms in Johannesburg, South Africa.

The Website is hosted on secure hosting services in South Africa.

Should you be a student, Personal Data may also be stored in our Learner Management System (Blackboard) hosted in Europe.

Should you be a debtor, relevant Personal Data will be stored in our Financial Management system in Johannesburg.

Should you consent to being a direct marketing subject, only your Electronic contact data will be provided to our marketing platform (CRM) hosted in Johannesburg.

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 data, we will take the necessary steps to ensure that your Personal Data is adequately protected in that jurisdiction.

Your information will not be stored for longer than is necessary for the purposes described in this Privacy notice unless further retention is required by law or contractual obligation or otherwise reasonably required by us.

Will my Personal Data be shared with anyone else?

While we will attempt not to disclose any of your personal information to third parties, we may disclose your Personal Data to the following entities as part of a supplier or partnership relationship between Henley Africa and the third party:

• Mailchimp (Proprietary) Limited for marketing purposes;
• WeLoveIT (Proprietary) Limited, for hosting purposes;
• Blackboard for hosting purposes; and
• Metisware (Proprietary) Limited for CRM and hosting purposes.

Except when we have your permission or for purposes of our legitimate business interests, we do not guarantee that your personal information will not be shared with third parties without your permission.

You agree that your de-identified aggregate personal information may be shared under the following circumstances:

• to our holding companies, subsidiary companies, agents, advisers, service providers and suppliers;
• to monitor web traffic: web servers serving the Website automatically collect information about pages you visit. This information is used for internal review, to tailor information to individual visitors and for traffic audits. This information (as well as information from third-party market researchers), on an aggregated, anonymous basis, is provided to advertisers advertising on the Website. Should you provide personal information online as part of an online advertising promotion or in order to access a third party service, such information may be provided directly to the advertiser or the third party concerned;
• promotions: many promotions offer opportunities to request additional information from sponsors or third parties. When you request more information about a particular promotion, your e-mail address may be shared with the sponsor of that promotion;
• for statistics and advertisement purposes: we may perform statistical analyses in order to measure interest in the various areas of the Website (for product development purposes) and to inform advertisers as to how many consumers have seen or “clicked” on their advertising banners. We may also use aggregated demographic information to allow advertising banners on the Website to be targeted, in aggregate.
• government and law enforcement agencies: where the law requires that we disclose your personal information to a party, and where we have reason to believe that a disclosure of personal information is necessary to identify, contact or bring legal action against a party who may be in breach of the Terms or may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users, or anyone else that could be harmed by such activities.

How can I find out what Personal Data Henley Africa holds about me?

To see the Personal Data we have Processed through this Website that relates to you, to cancel it and/or to correct or update this Personal Data, please email us at info@henleysa.ac.za. In addition, we will always give you the opportunity to update your preferences regarding our use of your Personal Data.

You will also have the right to object, at any time, to the Processing of your Personal Data and lodge a complaint with the regulatory authorities pursuant to any applicable data protection legislation.

To protect your privacy and security we will take reasonable steps to verify your identity before granting access. If you have any additional questions about Personal Data we hold about you, please contact us on the compliance details published at info@henleysa.ac.za

How can I exercise my privacy rights?

You may have certain rights relating to your Personal Information, depending on your location and subject to local applicable laws. These rights may include, subject to any exceptions or limitations:

• The right to know what Personal Information is being collected and for what purpose.
• The right to know what Personal Information is being “shared”, for what purpose and the categories of recipients of your Personal Information.
• The right to access your Personal Information.
• The right to have your Personal Information rectified, corrected or updated.
• The right to have your Personal Information deleted, including from any third parties where your Personal Information has been shared or disclosed.
• The right to opt out of the “sharing” of your Personal Information.
• The right to object to the processing of your Personal Information.
• The right not to be subject to any automated decision making and profiling.

If you would like to access, review, update, correct, and delete any Personal Information we hold about you, or exercise any other privacy rights available to you, including the right to request a copy of standard contractual clauses if located within the European Economic Area ("EEA"), you can either contact our Information Officer or fill out the request form that is part of our Section 51 PAIA Manual. Our privacy team will review your verifiable privacy rights request (“Privacy Rights Request”) and respond to you as quickly as possible. If we are unable to comply with your request due to an exception or limitation, we will explain this in writing. If we need more time, we will inform you of the reason and extension period in writing.

International data transfers

HBS is a company operating globally. Therefore, Personal Information of individuals who visit our website and/or who use our services or otherwise interact with us may be transferred and accessed from around the world, such as from countries where HBS, our Affiliates or Operators operate. 

 We will protect your Personal Information in accordance with this Notice wherever it is processed. HBS does not voluntarily or actively transfer or disclose our customers’ Personal Information.

Information for individuals in the European Economic Area (“EEA”) and the United Kingdom (“UK”)

Operating globally, HBS may transfer Personal Information from South Africa (SA) to the EEA or the UK and other countries, including Personal Information we receive from individuals residing in the EEA or the UK who visit our website and/or who may use our services or otherwise interact with us. Please note that the term Personal Information used in this Notice is equivalent to the term “personal data” under applicable EEA and UK data protection laws for individuals located in the EEA or the UK. 

When HBS engages in such transfers of Personal Information, it relies on: 

- Adequacy Decisions, as adopted by: 

• European Commission (“EC”), based on Article 45 of Regulation (EU) 2016/679 (GDPR) – for more information, and to access the full list of countries deemed adequate to date, please visit https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions 
• UK Secretary of State, based on Article 45 of the UK GDPR and Section 17A of the Data Protection Act 2018 - for more information, and to access the full list of countries deemed adequate to date, please visit https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/international-transfers/.

Use of the Website by children

The Website is not targeted at children under the age of 18. We will not knowingly collect information from persons in this age group.

Changes to this Privacy Notice

From time to time, we may revise this Privacy Notice to reflect company initiatives, changes in the law or technology or changes in our practices regarding the Procession and use of Personal Data. If we decide to change this Privacy Notice, we will deem you to be aware of these changes should you use the website at a date later than the publication of a change.

We will not use or disclose Personal Data provided to us pursuant to this Privacy Policy Notice in ways other than the ones described above, without informing you and providing you with the opportunity to consent to such modified conditions concerning the use and disclosure of your Personal Data.

Governing law

The contents of this Privacy Notice shall be governed by South African law.

If any provision of this Privacy Policy notice is judged to be illegal, void or unenforceable due to applicable law or by order of a court of competent jurisdiction it shall be deemed deleted and the continuation in full force and effect of the remainder of the provisions will not be prejudiced unless a court of competent jurisdiction determines that the substantive purpose of this Privacy Notice is then frustrated, in which case you may contact Henley Africa at the address in paragraph 16 below in order to opt-out of the Privacy Policy Notice.

How can I contact Henley Africa?

If you have any questions or comments about this Privacy Notice please feel free to contact us at info@henleysa.ac.za