("Skillfully", "us" or "we") contractually regulates our right to collect and use
certain of your information as a customer ("User" or "you") and your rights in
this regard, and applies to your use of Skillfully's website (www.skillfully.co.za,
including skilfully.co.za, and all sub-domains)("Website"), and the services
that we offer ("Services") through our platform made available through the
Website ("Platform"). This Policy creates a legally binding agreement between
us and you and will apply as soon as you use the Website, Platform or Services.
1.2 Your use of the Website, Platform and Services will be regulated by this Policy
as well as any other terms that are available on the Website
. The Additional Terms include the terms and conditions applicable to
Users of the Website, Platform and Services ("the Commercial Terms") and
the general browser terms applicable to the general use of the Website
. If there is a conflict between this Policy and any of the
Additional Terms, the following order of preference will be applied in respect of
applying such terms: (1) the Commercial Terms; (2) this Policy (the privacy
policy); and (3) the Browser Terms, in so far as the Additional Terms are
applicable to you.
1.3 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
Website, Platform and/or Services will regulate our relationship. It is your
responsibility to consider the Policy each time you visit the Website or App.
you do not agree with any terms of this Policy, you must stop using the
Website, Platform and/or Services.
1.4 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 Website, Platform and
Services and we therefore implement business practices that comply with 2
applicable laws, including the Protection of Personal Information Act, 4 of 2013
("POPI") (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
We collect Personal Information about you from the following sources:
3.1 directly from you when you provide it to us, such as when you sign up to use
our Website, Platform and Services, when you contact us, or through the course
of our relationship with you;
3.2 from your use of our Website and/or Platform or use of any features or
resources available on or through our Website, and/or Platform; and
3.3 from third parties when you interact with them through the Website, and/or
Platform, or from your interaction with us as a result of the Services, or as
required of the third parties to share it with us.
4.1 General personal details: your name and surname, gender, date of birth, age,
nationality and language preferences.
4.2 Contact details: your address, contact number, email address, public social
4.3 User information: Personal Information included in questions and other
correspondence, transaction documents, use of the Services or other materials
that we process in the course of providing the Services.
4.4 Consent records: records of any consents you have given us in respect of
using your Personal Information and any related information, such as the
specific details of the consent. We will also record any withdrawals or refusals
4.5 Payment details: payment method, payment amount, date and reason for
payment and related information.
4.6 Data relating to our Website, Data and Platform: such as the type of device
you use to access the Website, the operating system and browser, browser
settings, IP address, dates and times of connecting to and using the Website
and other technical communications information.
4.7 Cookies and other technologies
4.8 Account details: such as your username, password, usage data, and
aggregate statistical information.
4.9 Content and advertising data: records of your interactions with our online
advertising on the various websites which we advertise and records relating to
content displayed on web-pages displayed to you.
4.10 Views and opinions: any views and opinions that you choose to share with
us, or publicly post about us on social media platforms or elsewhere.
4.11 Professional information: any information that you choose to share with us,
or publicly on social media platforms related to your profession, working roles
and professional interests.
4.12 Children's Personal Information: Personal Information of any user that
qualifies as a child in terms of the Applicable law of the applicable jurisdiction
necessary for us to render the Services and with the consent of a parent or
guardian. We will only process the Personal Information of children with the
consent of a parent or guardian of that child where required in terms of
5.1 We only process adequate and relevant Personal Information for the following
purposes and legal bases:
5.1.1 to perform in terms of our agreement with you as well as access to
the Website, and Platform;
5.1.2 to enable the Trainers to provide you with relevant training services,
including assessing whether your bookings satisfy credit risk considerations,
5.1.3 operate and manage your account or your relationship with us;
5.1.4 monitor and analyse our business to ensure that it is operating
properly, for financial management and for business-development
5.1.5 contact you by email, SMS, push notifications or other means to
inform you about our Services, unless you have opted-out of such
communications (direct marketing);
5.1.6 form a view of you as an individual and to identify, develop or
improve the Website, Platform and Services that may interest you;
5.1.7 carry out market research and surveys, business and statistical
analysis and necessary audits;
5.1.8 fraud prevention;
5.1.9 perform other administrative and operational tasks, like testing our
processes and systems and ensuring that our security measures
are appropriate and adequate; and
5.1.10 comply with our regulatory, legal or other obligations.
5.2 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.
6.1 We may process your Personal Information to contact you to provide you with
information regarding our 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
6.2 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 Website or by contacting us
and requesting us to do so.
6.3 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.
7.1 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:
7.1.1 registered Skillfully Trainers, our business partners or third party
processors in order to provide you with access to the Website,
Platform and/or Services, such as data storage service providers,
or third party payment processors, in accordance with written
7.1.2 registered Skillfully trainers, in order for them to assess the
credit risk of your bookings, where relevant;
7.1.3 legal and regulatory authorities, upon their request, or for the
purposes of reporting any breach of Applicable Law;
7.1.4 accountants, auditors, lawyers and other external professional
advisors in terms of written agreements with them;
7.1.5 any relevant party to the extent necessary for the establishment,
exercise or defence of legal rights, criminal offences, threats to
public security, etc.;
7.1.6 any relevant third party if we sell or transfer all or any portion of our
business or assets; and
7.1.7 any relevant third party provider where our Website or Platform
uses third party advertising, plugins or content.
7.2 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.
7.3 Our Website may connect to various social media websites or apps, including,
but not limited to, Facebook, Twitter, LinkedIn and Instagram. If you want to use
the Website for social media integration, we may share your Personal
Information with the relevant social media websites or apps.
8.1 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
8.2 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
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
9.1 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:
9.1.1 right of access: the right to be informed of and request access to the
Personal Information that we process about you;
9.1.2 right to rectification: you may request that your Personal
Information be amended or updated where it is inaccurate or
9.1.3 right to erasure: the right to request that we delete your Personal
Information, subject to applicable limitations and exceptions;
9.1.4 right to restrict processing: you may request that we temporarily
or permanently stop processing your Personal Information;
9.1.5 right to object:
220.127.116.11 you may object to us processing your Personal Information; and
18.104.22.168 to your Personal Information being processed for direct
9.1.6 right to information portability: you may request a copy of your
Personal Information and request that information to be transmitted
for use by another person; and
9.1.7 right not to be subject to automated decision-making: where a
decision that has a legal or other significant effect is based solely
on automated decision making, including profiling, you may request
that your Personal Information not be processed in that manner.
9.2 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.
10.1 When you use the Website and/or 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 Website, Platform and Services, estimate our
audience size and usage patterns, store information about your preferences
and recognise when you return to the Website and/or Platform.
10.2 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 the Website and Services for you.
be able to enjoy the full use of the Website, Platform or Services and you may
not be able to take advantage of certain promotions we may run.
to, or control over them, and therefore cannot take responsibility for them.
10.5 The various types of cookies (distinguished by their function, lifespan and
origin) that we may collect include the following:
10.5.1 first party cookies: cookies that are stored by the actual website
or app you are visiting which are only visible to that website or app;
10.5.2 necessary cookies: cookies that are necessary for the technical
operation of a website or app. For example, they enable you to
move around on a website or app and to use its features;
10.5.3 performance cookies: cookies that collect data on the
performance of a website or app. Examples include the number of
persons who visit a website or app, the time spent on the website
or app and errors that may arise during the use of the website or
10.5.4 functionality or preference cookies: cookies that increase the
usability of a website or app by remembering a visitor's choices,
such as the language preference, login information, location of the
10.5.5 targeting or advertising cookies: cookies that enable a website
or app to send its visitors personalised advertising, often based on
your browsing history; and
10.5.6 session cookies: these are temporary cookies that are deleted
once you close your browser. Permanent cookies are those that are
stored on your device until you delete them or until your browser
deletes them (after a period specified in the cookie).
Our Website and/or 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 on email@example.com.
13.1 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.
13.2 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.
14.1 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 on firstname.lastname@example.org.
14.2 Access: you have the right to request that we provide you with Personal
Information that we hold about you. You must contact us directly to do so or
send an email to email@example.com. 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
14.3 The right to access your Personal Information may further be limited in terms
of Applicable Law.
15.1 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
15.2 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 Website, App, Platform and Services.
15.3 This Policy also applies when we retain your Personal Information.
15.4 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 firstname.lastname@example.org.
17.1 If you want to raise any objection or have any queries about our privacy
practices, you can contact our data protection officer on email@example.com.
17.2 You also have the right to formally lodge a complaint in terms of applicable laws
Address: SALU Building, 316 Thabo Sehume Street,
Tel: 012 406 4818
Fax: 086 500 3351
18.1 Website and Platform owner: Skillfully Group Proprietary Limited (trading
as "Skillfully"), registration number 2017/272446/07.
18.2 Legal status: Skillfully Group (Pty) Limited is a private company, duly
incorporated in terms of the applicable laws of the Republic of South Africa.
18.3 Director details may be supplied by email request.
18.4 Description of main business of Skillfully Group (Pty) Limited: The
website is a marketplace for the employees of clients, or self-funding
individuals, to find and book corporate training. Also providing administrative
services to clients (e.g. generation of training reports for supervisors) and to
trainers (e.g. handling of bookings, billing, etc.).
18.5 Email address: firstname.lastname@example.org
18.6 Website address