Privacy Notice

WEBSITE PRIVACY NOTICE

Introduction

As an external company duly registered in South Africa, Henley Business School Limited (Incorporated in the United Kingdom) (“Henley Africa”), we are committed to protecting and respecting your privacy when you browse our website.

As “Responsible Party” under the Protection of Personal Information Act 4 of 2013 as amended from time to time (“POPIA”), Henley Africa undertakes to Process your Personal Information in accordance with the conditions of lawful processing as set forth in POPIA, “this Privacy Notice” and only to the extent required for Henley Africa to discharge its contractual or statutory obligations or to pursue its legitimate interests to perform its business on a day-to-day basis.

“Process” means anything that can be done with Personal Information, including its collection, receipt, recording, organisation, collation, storage, updating, modification, retrieval, alteration, consultation, dissemination, merging, linking, restriction, degradation, erasure, destruction, or usage in any other manner whatsoever.

“Personal Information” means the types of information as listed in POPIA relating to an identifiable, living, natural person and (where applicable) also an identifiable, existing juristic person. A “Data Subject” is the natural or juristic person whose/which Personal Information Henley Africa Processes.

The purpose of this Privacy Notice is to explain to you what Personal Information Henley Africa will Process when you visit our website and what your rights are under POPIA, so that you can make an informed decision before browsing and sharing your Personal Information on our website.

Cookies and IP Addresses

A cookie is a small text file which is placed onto your device (e.g. computer, smartphone, or another electronic device) when you use Henley Africa’s website. A cookie file is stored in your web browser and allows Henley Africa to learn more about how website users use and access our website. For example, these cookies allow Henley Africa to count visits and traffic sources, so that we can measure and improve the performance of our website.

Forementioned are “First Party Cookies”, which means they are set and controlled by Henley Africa. Occasionally, third parties may set cookies on Henley Africa’s website, which we do not control. These are called “Third Party Cookies”. This will for example happen when Henley Africa includes embedded content on some pages of its website. When Website Users visit a page with embedded content, the third-party service provider may set its own cookies on their web browser.

You are presented with a cookie notice on your first visit to Henley Africa’s website, requesting, capturing and storing your consent. Kindly note, if you do not consent to cookies some functionality on Henley Africa’s website may not work properly or at all.

An IP address is a number that is automatically assigned to a computer whenever it is connected to the Internet. Henley Africa logs IP addresses (or the location of computers on the internet) for the purposes of system administration and audit.

Henley Africa does not ordinarily link IP addresses to Personal Information, which means your session under normal circumstances will remain anonymous. However, we cannot guarantee that this will always be the case, as it may be necessary to identify a particular user for security, compliance and investigative reasons.

What types of Personal Information do we Process and when?

Apart from forementioned cookies & IP addresses, Henley Africa will Process no Personal Information when you simply browse our website.

When you however fill an online form for a service request and depending on the nature of your service request, Henley Africa will Process amongst others the following types of Personal Information:

• First Name
• Surname
• Email Address
• Mobile Phone Number
• Current Qualification
• Nature of Service Request (drop-down menu)
• Personal Preferences (free hand field)

Kindly note the tick box at the bottom of the online form you are completing, which states: “By ticking below, you agree to our Website Privacy Notice and consent to Henley Africa Processing your Personal Information.”

Why do we Process your Personal Information?

Henley Africa Processes forementioned Personal Information amongst others to:

• Fulfil your service request (e.g. brochure, consultation, quote), and to
• Add your contact details to our customer relations management system for ongoing communication purposes (incl. marketing).

Kindly note the tick box at the bottom of the online form you are completing, which states “I agree to receive other communications from Henley Business School (incl. marketing communications) and understand that I can opt out at any time”. If you do not tick the box, your contact details will not be added to our customer relations management system for ongoing communication purposes (incl. marketing).

Even if you tick the box, you may opt out at any time via the unsubscribe/opt-out options included in Henley Africa’s emails and SMS communications.

What about Personal Information that is publicly available?

If at any time Henley Africa’s website offers any chat rooms, message boards, blogs, newsgroups or forums, etc., anything you post in any of these forums shall be considered “Public Personal Information”.

Kindly note, Henley Africa may Process the Public Personal Information that you disclose in accordance with this Privacy Notice. Henley Africa, however, is not responsible for other parties’ use of the Public Personal Information that you make available on our website via any chat room, message board, blog, newsgroup, forum or another public discussion platform.

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

Henley Africa will take reasonable precautions to protect your Personal Information against loss, misuse or alteration. Among other security measures, 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.

No company or service, however, can guarantee complete security. Unauthorised entry or use, hardware or software failure, and other factors may compromise the security of Data Subjects’ Personal Information at any time. Henley Africa also cannot guarantee the security of Personal Information transmitted to us via unsecured means; any such transmission is at the Data Subject’s own risk.

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.

For how long will Henley Africa store my Personal Information?

Henley Africa will delete Personal Information about Data Subjects, or render it anonymous, within a reasonable time after fulfilling the purposes mentioned above, unless:

• Retention of the Personal Information is required by law;
• We reasonably require the Personal Information for lawful purposes related to our day-to-day business functions or activities;
• Retention of the Personal Information is required by a contract between the parties thereto; or
• Where the Data Subject has consented to the retention of the Personal Information

Further to section 14(2) of POPIA, Henley Africa may also retain Personal Information for periods in excess of those contemplated above for historical, statistical or research purposes because it has established appropriate safeguards against such Personal Information being used for any other purposes.

Will my Personal Data be shared with anyone else?

Henley may disclose Personal Information about Data Subjects with its service providers (incl. “Operators” whom/which Process Personal Information on our behalf), for example:

• The IT company hosting the Website on behalf of Henley Africa; and
• Public relations and marketing companies, who help Henley Africa to manage its electronic communications with Data Subjects.

In such event, Henley Africa will bind aforementioned service providers and Operators by agreement to keep your Personal Information confidential and not allow it to be used for any other purpose than to carry out the services they are performing for Henley Africa.

Henley Africa may furthermore disclose Personal Information about Data Subjects to a third party, if and where it is necessary to comply with a legal obligation or the decision of a judicial authority, a public authority or a government body or if disclosure is necessary for national security, law enforcement or other matters of public interest.

Henley Africa may moreover transfer and disclose Personal Information about Data Subjects to its parent entity in the United Kingdom. In such event, the Personal Information will be Processed in terms of the United Kingdom’s Data Protection Act 2018, which provides protection equivalent to POPIA.

What are Data Subjects’ rights in respect of their Personal Information?

Data Subjects have the right to:

• Request access to their Personal Information
• Request rectification of the Personal Information that Henley Africa holds about them
• Request destruction or deletion of their Personal Information
• Object to the processing of their Personal Information, where Henley Africa is relying on a legitimate interest (or that of a third party)
• Lodge a complaint with the Information Regulator should they not be satisfied with Henley Africa’s response to any of their above requests at https://www.justice.gov.za/inforeg

Who do Data Subjects contact to exercise their rights?

Should Data Subjects want to exercise any of their above-mentioned rights or have any question/s about how Henley Africa Processes their Personal Information or about this Privacy Notice in general, they can reach out to the Information Officer at JacquesLR@Henleysa.ac.za.