MILPARK EDUCATION PROPRIETARY LIMITED

PRIVACY POLICY

Full Version

Last Revised:     01 July, 2017

Effective:             08 March, 2015

Scope

This Policy applies to website visitors, current and potential students, alumni, and any other user of our Sites and services offered through our Sites, including any websites or mobile applications operated by or on our behalf. This Policy applies to both online and offline collection, storage, processing, and transfer of Personal Information.

By using, visiting or browsing our Sites, using our services or enquiring about our services, you accept and agree to the terms of this Policy

Certain Sites or services may be subject to additional privacy policies or privacy disclosures relating to the services provided on the Site(s) (collectively “Additional Policies”). In the event of any direct conflict between any Additional Policies and this Policy, the Additional Policies will control.

Milpark Education (Pty) Limited (“Milpark”) may amend or otherwise modify this Privacy Policy at any time by posting such changes on this Site at least 30 days’ prior to the effective date thereof, so please re-visit this page periodically to check for updates. The date of last revision is shown at the top of this document.

Contents

  1. Definitions
  2. Information We Collect
  3. Information Collected Automatically
  4. Information You Provide to Us
  5. How We Use This Information
  6. Location of Information Processing
  7. Do Not Track
  8. Opt Out
  9. Our Security Measures
  10. Call Monitoring
  11. Internet Technologies Used
  12. Site Hosting and Links From Our Sites to Other Websites
  13. Privacy Policy Changes
  14. How to Access Your Information and Contact Us
  15. The Information Regulator

1. Definitions

As used in this Policy, the following terms have the following meanings:

"Business Associates" means third party service providers which Milpark or any Educational Partner may contract with to provide services on its behalf including but not limited to, Social Networking, hosting, web analytics, lead generation, educational business, or career services.

“Do Not Track” or “DNT” means a browser based signal that, when set, signifies an Internet user’s desire not to be tracked online.

 “Educational Partners” means: a.) Apollo Education Group, Inc. and its subsidiaries and affiliates including educational companies or institutions that Apollo Education Group, Inc. or its subsidiaries and affiliates may be providing educational or other related services to under contract; and b.) third party companies who may participate in career initiatives of Milpark, Apollo Education Group, Inc. or its subsidiaries and affiliates.

 “Information” means any information collected and includes but is not limited to: “Personal Information”, “Web Analytical Information” or any other information collected from you through our Sites.

“Personal Information” means Information relating to a living natural or, to the extent applicable, existing juristic person that may be used, alone or in combination, to identify that person.

"Site" or "Sites", means websites operated by or exclusively on behalf of Milpark Education (Pty) Ltd., regardless of domain name or IP address.

“Social Network”, means various Internet communication technologies provided on Sites that facilitate conversation and interaction between people online and includes, but is not limited to, blogs, discussion forums, wikis, chat sessions, news groups, etc.

“Social Network Content” (or “SNC”) means user-generated content you consent to share via a Social Network and includes, but is not limited to, Personal Information, digital sounds, and pictures that you upload to a Social Network. It also includes your Personal Information that may be displayed on other users’ Social Network pages.

“We”, “us”, and “our” refer to Milpark Education  Proprietary Limited (registration number: 2004/026244/07).

“Unrelated Entities” means third parties that are not Educational Partners and who are not providing services as Business Associates.

“Web Analytical Information” means internet-generated Information we collect when you visit our Sites. This Information may be linked with Personal Information. When linked with other Information identifying you personally, either alone or in combination with other Information, then such Information also will be considered Personal Information.

“You”, “yourself” or “your” refer to you as the website visitor, current or potential student, employees, suppliers, alumni and any other user of our Sites and services offered through our Sites, including any websites or mobile applications operated by or on our behalf.

2. How We Collect Information

We collect various types of Information from you through our Sites and other websites where you can express interest in our services, through our mobile applications, over the phone, via printed forms, and in person. Some Information is collected automatically through various web and internet technologies including Social Networking tools used by our Sites. Other Information is collected when you provide it to us voluntarily. We may also obtain information from Business Associates, Educational Partners and Unrelated Entities and combine that with information we collect about you. 

3. Information Collected Automatically on the Sites

Each time you visit one of our Sites, Web Analytical Information is automatically gathered. In general, this Information does not identify you personally. Examples of Web Analytical Information include, but are not limited to:

  • IP address
  • Collection Date
  • Publisher Name
  • Connection Speed
  • Day of Week and Time of Day (hour)
  • Language Settings
  • Geographic Area (including relating to IP address, if available)
  • Domain

This Information may be linked with Personal Information to accomplish the purposes described in this Policy. 

4. Information You Provide to Us

In addition to the Web Analytical Information automatically collected when you visit our Sites, Milpark also collects, uses, and discloses Personal Information that you provide to us voluntarily online or offline when you respond to a survey or a request for information; in connection with employment opportunities or other products and services; set up a Social Network or other Site profile; or use one of our career resources or other interactive tools. You may elect not to provide such Personal Information by foregoing participation in surveys, forfeiting employment opportunities or not using Social Networks or Sites, or foregoing other activities, but such election might prevent us from providing you with certain products or services.  While the exact nature of the Personal Information may vary depending on the type of response or service requested, the following is a non-exclusive list of the types of Information that may be collected to the extent it is necessary and applicable for the intended purposes:

  • First, Middle and Last Name, Previous Names
  • Street Address, City, State, Country, Postal Code
  • Date of Birth
  • Place of Birth
  • Gender
  • Race
  • Ethnicity
  • Country of origin
  • Employment History
  • Native Language
  • Address Type
  • E-mail address
  • Valid Day or Evening Telephone Number
  • Cell Phone Number
  • Confirmation of the age of majority
  • Citizenship
  • Prior Education History
  • Social Networking Content
  • Learning, Skill, or Career Assessment data
  • Job Title
  • Information related to Supplier opportunities
  • Identity Number in connection with employment opportunities 

5. How We Use and Disclose This Information

Personal Information

We will not sell, rent or lease your Personal Information to others except in accordance with this Policy.

We may collect, use, and disclose Personal Information for the following purposes and you hereby consent to us processing your Personal Information for the following purposes:

  • to provide you with requested information, products and services
  • to respond to your inquiries and provide support
  • for employment related purposes
  • for investor relations related purposes
  • for media related purposes
  • for supplier related purposes
  • for our internal marketing purposes, which includes, but is not limited to, sending you material about products, services, updates, etc. that we think may be of interest to you
  • for fostering communication and collaboration through Social Networks
  • for sharing with our Educational Partners who may contact you with respect to their educational or other services
  • for sharing with our Educational Partners or Business Associates who are performing services on our behalf, who will process such Personal Information only to the extent that we have been made aware thereof and have authorised such processing and who will treat the Personal Information as confidential and will not disclose it to any third party
  • to analyze how Sites and services are being accessed and used
  • for investigation of information security and information asset protection related incidents
  • to test, correct and improve our content, applications and services
  • to develop new applications, products and services
  • to improve Site and service performance and delivery
  • to prevent potentially illegal activities (including illegal downloading of copyrighted materials)
  • to investigate suspicious information that denotes illegal activity
  • to analyze risk and business results
  • to maintain business records for reasonable periods
  • to enforce our Terms of Use
  • to provide to Educational Partners, Business Associates or Unrelated Entities in connection with the contemplated or actual reorganization, merger, acquisition, financing, securitization, insuring, sale or other disposal of all or part of our business or assets, including for the purposes of determining whether to proceed with such transaction or fulfilling any records or other reporting requirements to such parties. In the event of any actual reorganization, merger, or acquisition such Information may be transferred as part of the transaction to the acquirer
  • and/or as may be required or permitted by legal, regulatory, industry self-regulatory, insurance, audit, or security requirements applicable to Milpark, our Educational Partners, or our Business Associates. 

You have the right to object to and opt-out of our collection, use, disclosure and other processing of your Personal Information subject to applicable contractual, educational, legal or technical restrictions and reasonable notice pursuant to paragraph 8 below.

6. Location of Information Processing

We operate or may process information in multiple jurisdictions and some Educational Partners and Business Associates may be located outside of the jurisdiction in which you reside. In such cases, your Personal Information may be collected, used, disclosed, stored and processed in these other jurisdictions for the purposes described in this Policy. The data protection and other laws of the other countries might differ from your jurisdiction but we undertake to ensure that your Personal Information will not be transferred to any jurisdiction where the data protection and other laws do not provide an adequate level of protection in respect of the processing thereof, which is comparable to that provided where you reside. We require our Educational Partners and Business Associates to use your Personal Information in accordance with this Policy and to take appropriate, reasonable technical and organisational measures to prevent: (i) loss of, damage to or unauthorised destruction of the Personal Information; and (ii) unlawful access to or processing of the Personal Information. You hereby consent to us transferring your Personal Information in this way and the processing of your Information across international borders. Your Information may be subject to the laws of those other jurisdictions, including lawful requirements to disclose Personal Information to government authorities. 

7. Do Not Track

Do Not Track (DNT) is a browser based signal that, when set, signifies your desire not to be tracked online. Because there is not yet a consensus on how companies should respond to web browser-based or other DNT mechanisms, Milpark does not itself respond to web browser-based DNT signals. 

8. Opt-Out

Marketing Communications

If you do not wish to receive marketing email communications from us, you may express your choice where indicated on the applicable email or other communication, or email studentservices@milpark.ac.za.

If you do not wish to receive marketing telephone calls or mailings, you may express your choice to opt-out by emailing studentservices@milpark.ac.za.

Marketing opt-out requests will only remove you from our list and the list of any Business Associate performing services on our behalf. We are not responsible for the use any other party may make of the Information once it has been transferred in accordance with this Policy and you will need to contact such entity to have your Information removed from their database.

Social Networking Content

You may change various user settings related to sharing your Personal Information contained in any user profile you set up as part of Social Network activities furnished by us, subject to contractual, educational, legal or technical restrictions and reasonable notice. Note that your withdrawal from Social Network activities might prevent us from providing you with certain products or services.

Other Collection, Use, and Disclosure

You have the right to object to and opt-out of our collection, use, disclosure and other processing of your Personal Information subject to applicable contractual, educational, legal or technical restrictions and reasonable notice. Note that if you opt-out of certain uses of your Personal Information, we may no longer be able to provide certain products or services. For more information on your ability to opt-out, email studentservices@milpark.ac.za

9. Our Security Measures

We will take appropriate, reasonable technical and organisational measures to secure and store your Information to protect against the loss of, damage to, unauthorized destruction of, unlawful access to or processing of, misuse of, and alteration of the Information under our control. We utilize generally accepted information security practices and procedures when collecting and processing your Personal Information, including but not limited to when accepting your credit card Information during the ordering process (whether online or otherwise), as well as whenever we ask you to login to any of our Sites.

Unfortunately, no data transmission over the internet can be guaranteed to be completely secure. As a result, although we will utilize such measures, we do not guarantee you against the loss, misuse, or alteration of Information under our control, and you provide Information to us at your own risk. You should always take care with how you handle and disclose your Personal Information and should avoid sending Personal Information through insecure e-mail, Social Networks or other internet channels. 

10. Monitoring of Communications

We may monitor and retain all incoming and outgoing communications for training of our representatives and for quality assurance purposes. To the extent such communications are selected, they are only retained as long as necessary to adequately discharge these purposes, unless a specific communication needs to be retained for legal reasons. If you prefer that your communications not be retained for any reason, please advise your representative. 

11. Internet Technologies Used

Cookies, web beacons, and other relevant internet technologies are used on our Sites to allow us to accomplish the uses set out above as well as to deliver Sites messaging and to keep track of your Information. These small pieces of program code reside in your computer and browser and can be removed. If you desire to remove such technologies you may do so, but this may render our Sites unusable to you. You can opt out of cookies or the other internet technologies used by disabling these features in your browser program. Consult your browser’s “Help” menu for assistance in changing cookie settings or removing cookie files. 

12. Site Hosting and Links from Our Sites to Other Websites

Some of our Sites may contain links to websites hosted by Educational Partners, Unrelated Entities, and Business Associates operating websites on their own behalf or on behalf of multiple entities. Some of these websites may collect your Personal Information and may apply their own policies on how your Personal Information is used. In addition, some of our Sites may have Additional Policies that apply to the use of Personal Information collected on that Site. PLEASE MAKE SURE TO READ THE POLICIES OF ANY WEBSITES YOU VISIT ON THE INTERNET CAREFULLY. PLEASE BE AWARE THAT WE ARE NOT RESPONSIBLE FOR THE PRIVACY PRACTICES OR THE CONTENT OF ANY WEBSITES THAT ARE NOT OPERATED BY OR EXCLUSIVELY FOR US, AND THE COLLECTION, USE, AND DISCLOSURE OF INFORMATION ABOUT YOU WILL BE SUBJECT TO THE POLICIES APPLICABLE ON THOSE WEBSITES. 

13. Privacy Policy Changes

Milpark may update this Policy or revise it from time to time, provided that any changes will be posted on this Site at least 30 days prior to the effective date of these changes. You should contact us as described below or check back at this Site periodically to obtain a current copy of this Policy. We urge you to review this Policy frequently to obtain the current version. Your continued provision of your Personal Information or use of our services or this Site following any changes to this Policy and your failure to opt-out prior to the changes becoming effective, constitute your acceptance of such changes. If we intend to use your Personal Information in a manner materially different from what we stated at the time it was collected, we may in certain circumstances require you to provide your consent to such changes. If you do not provide your consent to such changes, we may no longer be able to provide certain products or services and you may not be able to use any of our Sites.  In all cases of changes to this Policy, you will have a right to opt out of our collection, use, disclosure and other processing of your Personal Information subject to applicable contractual, educational, legal or technical restrictions and reasonable notice. Note that if you opt-out of certain uses of your Personal Information, we may no longer be able to provide certain products or services. For more information on your ability to opt-out, email studentservices@milpark.ac.za.

14. How to Access Your Information and Contact Us

You are entitled to:

  1. having provided adequate proof of identity, request that we confirm, free of charge, whether or not we hold Personal Information about you; and request the record or a description of the Personal Information about you that is held by us, including information about the identity of all third parties, or categories of third parties, who have, or have had, access to your Personal Information, within a reasonable time, in a reasonable manner and format, and in a form that is generally understandable; and
  2. request correction of your Personal Information to the extent that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully;
  3. object to the processing of your Personal Information.

If you want access to or wish to update or rectify any of your Personal Information or have any questions about our privacy practices, please contact our Chief Operations Officer at studentservices@milpark.ac.za or

Milpark Education (Pty) Limited
Attn: Chief Operations Officer
2nd Floor, Cnr Protea and Dreyer Street
Claremont, 7735

South Africa

15. The Information Regulator

Please take note that you are entitled by law to lodge a complaint with the Information Regulator established in terms of the Protection of Personal Information Act 4 of 2013, in the prescribed manner and form, alleging interference with the protection of the personal information. The Information Regulator has not, at the date of this Policy, been appointed and contact details for the Information Regulator are not yet available. We will notify you of these details following such details being made available.

 

Read our Terms of Use policy here.