PRIVACY POLICY
IMPORTANT: BY SUBMITTING DATA AND/OR USING THIS WEB SITE YOU GIVE YOUR CONSENT THAT ALL PERSONAL DATA THAT YOU SUBMIT MAY BE PROCESSED IN THE MANNER AND FOR THE PURPOSES DESCRIBED IN THE FOLLOWING PRIVACY POLICY.
Online Privacy Notice – Warwick House
1. About This Privacy Notice
1.1 Purpose
Warwick House is committed to ensuring that the collection, processing, and use of personal information comply with lawful, reasonable, and relevant business practices. Our goal is to enhance our services while safeguarding your privacy.
1.2 Scope
This notice applies to Warwick House, its subsidiaries, and business units. References to “we,” “us,” or “our” refer to Warwick House.
1.3 Compliance with Privacy Laws
We respect your privacy and adhere to best practices in personal information protection, in accordance with:
● Protection of Personal Information Act (POPIA), Act 4 of 2013
● Promotion of Access to Information Act (PAIA), Act 2 of 2000
1.4 Third-Party Websites
Our website may contain links to external websites. This Privacy Notice does not apply to those sites. We encourage you to review their privacy policies before submitting personal information. Warwick House is not responsible for how third-party websites process your data.
1.5 Collection and Use of Personal Information
This Privacy Notice outlines how we collect, process, and protect personal information when you:
● Use our website and student portals (collectively referred to as the "Website").
● Enrol at any of our institutions.
Please read this notice carefully to understand our practices regarding your personal information.
1.6 Relationship with Other Policies
This Privacy Notice should be read alongside:
● Our Website Terms and Conditions.
● Any other agreements or documents that describe how we collect and process personal information.
This Privacy Notice supplements these documents and does not override them.
1.7 Consumer Protection Act Compliance
If you are a consumer as defined in the Consumer Protection Act (CPA), Act 68 of 2008, we highlight key clauses that affect your rights:
1.7.1 Limitations of Risk and Liability
Clauses 8 and 11 limit our obligations and liabilities. These clauses state that:
● The Internet is not completely secure, and personal information may be at risk during transmission.
● Your rights to claim losses, damages, or liability may be limited.
1.7.2 Assumption of Risk
Clause 11 outlines that:
● You accept certain risks related to data security.
● You may be responsible for claims or damages.
● You waive certain rights, which may affect your ability to access information.
1.7.3 Acknowledgment of Facts
Clause 5 contains statements that you acknowledge as true. These acknowledgments may impact your ability to dispute certain matters.
Certainly! Here’s the revised Privacy Notice section with the correct school name:
2. The Personal Information That We Collect About You
2.1 Processing of Personal Information
Warwick House may collect, receive, record, organize, collate, store, update, modify, retrieve, process, analyse, use, and share your personal information in accordance with this Privacy Notice. These actions constitute "Processing" of personal information.
2.2 Definition of Personal Information
"Personal Information" refers to identifiable details about an individual, including natural persons and juristic persons (such as companies or trusts). It does not include data that has been de-identified and can no longer be linked to an individual. The type of personal information we collect depends on the services you receive from Warwick House.
2.3 Categories of Personal Information We Process
We may process different types of personal data, grouped as follows:
● Identity Data – Includes your name, username, marital status, title, date of birth, gender, race, legal status, identity documents, photographs, identity number, registration number, and qualifications.
● Contact Data – Includes billing addresses, delivery addresses, email addresses, and telephone numbers.
● Financial Data – Includes bank account details, payment card details, insurance information, and financial statements.
● Transaction Data – Details payments made to and from you.
● Service Data – Information related to your interactions with Warwick House and your performance in Warwick House-administered educational courses.
● Security Data – May include records of access to our facilities, as well as CCTV footage on or near our premises.
● Technical Data – Includes your IP address, login data, browser type and version, time zone setting, location, browser plug-in types, operating system, and platform.
● Usage Data – Information on how you use our website, products, and services.
● Marketing & Communications Data – Preferences regarding marketing communications from us and third parties.
2.4 Special Personal Information & Data Processing
If any of the personal information provided to us falls into the following categories, additional protections apply:
● Special Personal Information – Includes sensitive data such as health status, religion, ethnic origin, or race. We will only process such information with your explicit consent, unless a lawful basis exists allowing us to process it without consent.
● Children’s Personal Information – If we process minor children’s personal information (for example, during a complaint resolution process), we will do so only with the prior consent of a competent person (such as a parent or legal guardian), unless lawful grounds allow us to process it without consent.
2.5 Children’s Use of Our Website
Warwick House does not provide services directly to children, and our website is not available for use by anyone under the age of 18 without the consent and supervision of a competent person (such as a parent or legal guardian). Any unauthorized use by minors without such consent is prohibited.
2.6 Aggregated Data Processing
Warwick House may process, collect, store, and use Aggregated Data, including historical or statistical data, for various purposes. Aggregated Data is not considered personal information because it does not directly or indirectly reveal an individual’s identity. However, if Aggregated Data is combined with identifiable personal information, it will be treated as personal information in accordance with this Privacy Notice.
3. How We Collect Your Personal Information
We collect your personal information in three ways:
● Direct or active interactions with you
● Automated or passive interactions with you
● Third parties
3.1 Direct or Active Collection from You
We may require you to submit personal information to:
● Access certain portions of our website
● Receive specific services (e.g., enrolment, prospectus requests)
● Conclude agreements or comply with statutory obligations
● Communicate directly with us via email, phone, feedback forms, comments, or forums
If you contact us, we may keep a record of that correspondence. The information we collect actively may include any data listed in Section 2 of this Privacy Notice.
3.2 Passive Collection from Your Access Device
We also passively collect personal information from the device you use to access our website or any network administered by Warwick House ("Access Device").
This includes:
● Identity Data
● Contact Data
● Security Data
● Technical Data
● Usage Data
● Marketing & Communication Data
● Any other information you permit us to collect from your Access Device
3.3 Information Collected from Third Parties
Warwick House may receive personal information about you from third parties and public sources. We handle all such information with due care, in line with POPIA compliance.
4. How We Use the Information Collected
4.1 Purpose of Data Collection
Personal information provided to Warwick House will only be used for the stated purposes when the data is collected.
4.2 Ways We Use Your Personal Information
We may use your data for:
● Providing our services and processing purchases (including through our parent portal)
● Administering educational programs
● Operating our facilities
● Complying with statutory obligations, including regulatory interactions and submissions
● Business case analysis
● Recruitment exercises, including referrals, hiring, and background checks
● Maintaining our customer database
● Identity verification on the Website
● Technical support, issue diagnosis, and customer queries
● Website maintenance, administration, and security
● Protecting our rights in litigation
● Detecting, preventing, or handling fraud, security breaches, and unauthorized website use
● Communicating with you and maintaining correspondence records
● Informing you of policy or Website updates
● User profiling – analysing trends, habits, and device usage
● Comparing user Access Devices and locations
Any other lawful business purposes relevant to our operations
4.3 Anonymized User Analytics
We may collect demographical and statistical information about user behaviour. Any disclosure of this information will be in aggregated and anonymized form and will not identify individual users.
4.4 Restriction on Further Processing
Warwick House will restrict its processing of personal information to the original purpose unless a new processing requirement arises that aligns with POPIA compliance. If you need an explanation of how new processing aligns with the original purpose, please contact us.
5. Sharing of Your Personal Information
5.1 General Disclosure Principles
We will not intentionally disclose your personal information, whether for commercial gain or otherwise, beyond the provisions of this Privacy Notice or without your permission.
5.2 Circumstances Under Which We Share Personal Information
Warwick House may share your personal information under the following circumstances:
● 5.2.1 With our agents, advisers, service providers, and suppliers, provided they adhere to this Privacy Notice or offer equivalent data protection standards.
● 5.2.2 With our agent responsible for pre-admission tests, under terms providing equal protection to this Privacy Notice.
● 5.2.3 With our employees, suppliers, and agents, where access to information is necessary to provide services such as hosting, development, administration, technical support, and operational functions. Written agreements with third parties include confidentiality and non-disclosure provisions to safeguard data.
● 5.2.4 To enforce or apply contracts between you and Warwick House.
● 5.2.5 To protect our rights, property, and safety or those of customers, employees, suppliers, and affiliated parties.
● 5.2.6 To mitigate risks affecting Warwick House or stakeholders.
● 5.2.7 To governmental agencies, regulators, and self-regulatory bodies if legally required or deemed necessary to:
● Comply with legal obligations
● Protect rights, property, or safety
● Investigate fraud, security threats, misuse of services
● Safeguard public interests
If false or deceptive information is provided, we may proactively disclose such data to regulatory bodies or commercial entities.
6. Cross-Border Transfer
6.1 Data Transfers Outside South Africa
Personal information collected from you may be stored or processed outside South Africa in locations where data protection laws may differ. In such cases, Warwick House ensures:
● Binding corporate rules or agreements are established.
● Data processing remains compliant with South African privacy laws and this Privacy Notice.
6.2 Information on Transfers
If you require details on the specific mechanisms used for transferring data outside South Africa, please contact us for further information.
6.3 Pre-Admission Test Data Transfers
Personal information required for pre-admission tests, processed externally, will be limited to essential data and will comply with the safeguards stated in Section 6.1.
7. How We Store Information Collected
7.1 Retention Period
Personal information is retained for as long as necessary to:
● Provide services to you
● Meet legal, regulatory, and business requirements
● Comply with data retention policies outlined in the Warwick House Data Retention Notice (available upon request).
7.2 Secure Storage Methods
Your personal data is electronically stored on our secure servers or those of our service providers. Some records may be kept in hard copy format, with appropriate organizational and technical safeguards in place.
7.3 Subscription-Based Data
If you subscribe for alerts, news, or notifications, your details will remain in our database until you unsubscribe via the designated options.
7.4 Extended Retention Considerations
We may retain and process your personal information for as long as:
● Legally required or permitted under contract.
● Necessary for operational functions and lawful business purposes.
● Needed for evidentiary purposes.
● You agree to extended retention for a specified period.
7.5 Data Retention Assessment
To determine the appropriate retention period, Warwick House considers:
● Type, nature, and sensitivity of personal information
● Potential risks from unauthorized disclosure
● Processing objectives and feasibility of alternative methods
● Compliance with legal, regulatory, tax, and accounting requirements
8. Quality and Protection of Your Information
8.1 Maintaining Accuracy
We strive to ensure that the personal information we hold is updated, complete, and accurate. It is your responsibility to provide Warwick House with your most up-to-date personal information, which can be updated through:
● The Parent Portal (SCADSYS) via our website by clicking the Parent Account Login button.
● Emailing our admissions office at [insert correct Warwick House email address].
8.2 Security Measures
Warwick House takes reasonable measures to prevent destruction, unauthorized access, or loss of personal information. Any compromise in data integrity or confidentiality will be reported to you via written notice.
8.3 No Absolute Guarantee
Despite our best efforts, we cannot guarantee absolute security for your personal information.
8.4 Your Rights to Update Personal Information
You may contact us via email at the specified address to:
● Request access to personal information stored in our database.
● Notify us of changes or corrections needed.
● Request removal of your personal information.
We require proof of identity before processing such requests.
9. How We Use "Cookies"
Cookies are small files of letters and numbers stored on your computer or mobile device. These enable us to:
● Distinguish users for a better browsing experience.
● Enhance website functionality and performance.
10. Access to Information
Under the Promotion of Access to Information Act (PAIA), 2000, you have the right to request access to personal information held about you. For details, refer to Warwick House’s PAIA Manual at [insert correct Warwick House website link].
11. Waiver of Certain Rights
You agree that where the law requires us to inform or notify you of something, we do not need to do so unless explicitly stated by legal provisions. For example, where the law allows waiving rights, we will not be obligated to make you aware of certain information.
12. Your Rights Under Data Protection Laws
12.1 Access to Personal Information
You may request a copy of personal information held about you. However, Warwick House may lawfully refuse access if valid grounds apply.
12.2 Request Correction of Data
To correct inaccurate or incomplete data, contact us via email with:
● Details on inaccuracies.
● Instructions on corrections.
● Evidence supporting the request (where applicable).
We will make corrections as soon as reasonably practicable.
12.3 Request Erasure of Personal Data
You may request deletion of your personal information, provided:
● No lawful basis requires Warwick House to retain it.
● You successfully object to data processing.
● Data has been processed unlawfully or requires deletion under legal regulations.
Warwick House may decline deletion if legal reasons apply.
12.4 Withdraw Consent
You may withdraw consent at any time, but this will not affect prior lawful processing. Withdrawal may impact services provided, and Warwick House will advise if withdrawal affects usability.
12.5 Right to Object
You may object to Warwick House processing your personal information. If no lawful basis exists to continue processing, Warwick House will cease processing upon successful objection.
13. Direct Marketing
13.1 Your Right to Accept or Refuse Marketing
Upon engagement, you may choose:
● To receive marketing communications.
● To refuse or preemptively block marketing outreach.
13.2 Opting Out
You may opt out of direct marketing at any time via the contact details in Clause 17. Warwick House will confirm receipt and ensure no further direct marketing is sent.
Note: You may still receive non-marketing communications.
14. Compliance with the Consumer Protection Act & POPIA
14.1 Legal Compliance
This Privacy Notice complies with:
● Consumer Protection Act (CPA), 2008
● Protection of Personal Information Act (POPIA), 2013
All provisions are qualified where necessary for legal compliance.
14.2 Legal Limitations
This Privacy Notice does not:
● Exempt liability for gross negligence or wilful misconduct.
● Require assumption of risk beyond legal allowances.
● Limit obligations under CPA or POPIA beyond lawful constraints.
15. Governing Law
This Privacy Notice is governed by South African law. If any provision is deemed illegal, void, or unenforceable, it will be removed while the remaining provisions remain valid.
16. Privacy Notice Updates
Changes to this Privacy Notice will be posted on this page.
17. Contact Information
For privacy-related queries, please contact Warwick House at:
● admin@warwickhouse.org.za