We may also offer Services under the name of "Coachbit". Services offered through the Coachbit website (https://coachbit.com/ and all its sub-domains) and the Coachbit mobile app will also be regulated by this Policy
All Websites and mobile apps through which you can access the Services will be referred to as the "Platform" in this Policy.
Changes to this Policy. Unless notice is required in terms of any applicable laws, we may change the content of this Policy from time to time in line with any changes that the law or our internal business operations require, without prior notice. However, we will notify you of any material changes to this Policy. The current version of this Policy that applies each time you visit and/or use our Platform and/or Services will regulate our relationship. It is your responsibility to consider the Policy each time you visit the Platform. If you do not agree with any terms of this Policy, you must stop using the Platform and/or Services.
The right to privacy and this Policy is important to us. We are committed to taking steps to protect your privacy when you use the Platform and Services and we therefore implement business practices that comply with applicable laws, including the Protection of Personal Information Act 4 of 2013 ("POPI ") and the General Data Protection Regulation ((EU) 2016/679) ("GDPR") (collectively "Applicable Law"). In this Policy, we explain how we will use and protect your Personal Information in light of Applicable Law.
Where we refer to "Personal Information" in this Policy, we mean personal information as defined in Applicable Law, being information that may be used to directly or indirectly identify you. Personal Information includes, for example, your name, surname, email address, identity number, contact details, photograph and location.
We collect Personal Information about you from the following sources:
The following categories broadly describe the types of Personal Information that we process:
Coachbit will only process the Personal Information of children with the consent of a parent or guardian of that child where required in terms of Applicable Laws.
We only process adequate and relevant Personal Information for the following purposes and legal bases:
In addition to the above purposes, we may use your Personal Information for other purposes if the law allows for it, if you consent to it, or if it is in the public interest to do so. All purposes for the processing of your Personal Information will be legal in terms of Applicable Law.
We may process your Personal Information to contact you to provide you with information regarding our Platform and Services that may be of interest to you. Where we provide Services to you (where you are a customer of ours), we may send information to you regarding our Services and other information that may be of interest to you, using the contact details that you have provided to us. We will only send you direct marketing communications where you have consented to us sending you direct marketing or otherwise in compliance with Applicable Laws.
You may unsubscribe from any direct marketing communications at any time by clicking on the unsubscribe link that we include in every direct marketing communication, in your account settings on the Platform or by contacting us and requesting us to do so.
After you unsubscribe, we will not send you any direct marketing communications, but we will continue to contact when necessary in connection with providing you with the Services or in connection with our business.
We will keep your Personal Information confidential and only share it with others in terms of this Policy, or if you consent to it, or if the law requires from us to share it.
We may disclose your Personal Information to:
If we engage third party processors to process your Personal Information, the processors will only be appointed in terms of a written agreement which will require the third party processors to only process Personal Information on our written instructions, use appropriate measures to ensure the confidentiality and security of your Personal Information and comply with any other requirements set out in the agreement and required by Applicable Law.
Our Platform may connect to various social media websites or apps, including, but not limited to, Facebook, Twitter, LinkedIn, Google+ and Instagram. If you want to use our Platform for social media integration, we will share your Personal Information with the relevant social media websites or apps.
We may disclose your personal information for the specific purposes of informing our tutoring partner Teach Me 2 Proprietary Limited, Registration number: 2018/199351/07, Address: 16 Thicket Street, Newlands, Cape Town, South Africa, email address: email@example.com, or any of its subsidiary companies including Teach Me 2 Limited (USA) (hereinafter referred to as Teach Me 2).
Should you become a client of both Teach Me 2 or any of its subsidiaries and Coachbit, Inc. in order to provide you with the most optimal services, we will share salient information regarding grades, coaching experience, and other personal information to ensure that you have the most productive service experience across the two platforms as we see these services as inextricably linked and by the use of our services, you consent to the sharing of such information.
Due to the nature of the Services and Coachbit being established in different countries, we need to transfer Personal Information to and from the different countries for internal business purposes.
We may transfer your Personal Information to recipients in other countries. We will only transfer Personal Information to third parties in countries with adequate data protection laws or do so in terms of a written agreement with the recipient which imposes data protection requirements on that party as required by Applicable Law.
Please note that when you transfer any Personal Information directly to a third party in another country (i.e. we do not send your Personal Information to the third party), Coachbit is not responsible for that transfer of Personal Information (and such transfer is not based on or protected by this Policy). Any Personal Information that we receive from a third party country will nevertheless be processed in terms of this Policy.
We have implemented appropriate technical and organisational security measures designed to protect Personal Information against accidental or unlawful destruction, loss, alteration, disclosure, access and other unlawful or unauthorised forms of processing. These measures are in accordance with Applicable Law.
The internet is an open and often vulnerable system and the transfer of information via the internet is not completely secure. Although we will implement all reasonable measures to protect Personal Information, we cannot guarantee the security of your Personal Information transferred to us using the internet. Therefore, you acknowledge and agree that any transfer of Personal Information via the internet is at your own risk and you are responsible for ensuring that any Personal Information that you send is sent securely.
You have certain rights in relation to your Personal Information. As available and except as limited under Applicable Law, you have the following rights in respect of your Personal Information:
Where you have provided consent for us to process your Personal Information, you may also withdraw your consent where our processing is based on your consent. However, we may continue to process your Personal Information if another legal justification exists for the processing.
When you use the Platform, we automatically receive and record information on our server logs from your browser. This information may include, amongst others, your location, IP address, cookie information and Google Analytics information. This is statistical data about browsing actions and patterns. We may also obtain information about your general internet usage through a cookie file which is stored on the hard drive of your computer. Cookies enable us to improve our Platform and Services, estimate our audience size and usage patterns, store information about your preferences and recognise when you return to the Platform.
In some instances, we collect and store information about your location through cookies (other than when you share your location with us). We convert your IP address or mobile GPS data into a rough geo-location and we may use location information to improve and personalise our Platform and Services for you.
The various types of cookies (distinguished by their function, lifespan and origin) that we may collect include the following:
Our Platform may include links to other apps or third party websites which do not fall under our supervision. We cannot accept any responsibility for your privacy or the content of these third party sites, but we display these links in order to make it easier for you to find information about specific subjects. Your use of and reliance on these links is at your own risk.
You may, on reasonable grounds, object to us using your Personal Information for certain purposes. If you object, we will stop using your Personal Information, except if Applicable Law allows its use. To exercise this right or to discuss it with us, please contact us at firstname.lastname@example.org.
We do not intentionally collect or use children's Personal Information for purposes other than providing the Services to Users that are children without the consent of a parent or guardian of the child unless the User is capable of consenting to the processing of his/her Personal Information in terms of the Applicable Laws in his/her jurisdiction. Similarly, we do not intentionally collect or process special/sensitive Personal Information and will only do so with consent or if allowed by Applicable Law.
We will only use the Personal Information of child Users for purposes of providing the Platform and Services to them in terms of the consent received or if there is a legal justification to use the Personal Information in terms of Applicable Laws.
Quality. We want to ensure that your Personal Information is accurate and up to date. You may ask us to correct or remove any Personal Information that you think is inaccurate, by sending us an email to email@example.com.
Access. You have the right to request us to provide you with Personal Information that we hold about you. You must contact us directly to do so or send an email to firstname.lastname@example.org. This request may be subject to an access to information request in terms of Applicable Laws and may require you to verify your identity, identify the rights you are wishing to exercise and pay a fee.
The right to access your Personal Information may further be limited in terms of Applicable Law.
We take every reasonable step to ensure that your Personal Information is only processed for the minimum period necessary for the purposes set out in this Policy.
We retain Personal Information in accordance with the required retention periods in Applicable Law or for legitimate business purposes. We will only retain your Personal Information for the purposes explicitly set out in this Policy. We may keep Personal Information indefinitely in a de-identified format for statistical purposes, which may include for example statistics of how you use the Platform and Services.
This Policy also applies when we retain your Personal Information.
We may retain your Personal Information for the duration of any period necessary to establish, exercise or defend any legal rights.
We will report any security breach to the applicable regulatory authority in terms of Applicable Law and to the individuals or companies whose Personal Information is involved in the breach. If you want to report any concerns about our privacy practices or if you suspect any breach regarding your Personal Information, kindly notify us by sending an email to email@example.com.
If you want to raise any objection or have any queries about our privacy practices, you can contact our data protection officer at firstname.lastname@example.org.
You also have the right to formally lodge a complaint in terms of applicable laws as follows:
Regulatory authority name
The Information Regulator
Address: SALU Building, 316 Thabo Sehume Street, Pretoria
Tel: 012 406 4818
Fax: 086 500 3351
The European Commission
Online complaint procedure: https://ec.europa.eu/info/about-european-commission/contact/problems-and-complaints/complaints-about-breaches-eu-law/how-make-complaint-eu-level_en#submitting-a-complaint-online
Address: European Commission, Secretary-General