Privacy Policy for EduFlow360

Responsible Party: Paypertuity (Pty) Ltd t/a EduFlow360

Last Updated: 14 June 2024
Effective Date: 14 June 2024

1. Introduction and Scope

Welcome to EduFlow360. Your privacy is critically important to us. This Privacy Policy outlines how Paypertuity (Pty) Ltd ("we," "us," or "our") collects, uses, processes, and protects your Personal Information in compliance with the Protection of Personal Information Act (POPIA) of South Africa.

This policy applies to:

• Visitors and users of our website (e.g., www.enterflow360.com).
• Our clients (e.g., Public Funding Agencies, Higher-Education Institutions, Scholarship Funds) who use the EduFlow360 platform and related services (the "Service").
• The individuals (e.g., students, administrators) whose Personal Information we process on behalf of our clients as part of providing the Service.

By using our website or our Service, you acknowledge that you have read and understood this Privacy Policy.

2. The Responsible Party & Information Officer

For the purposes of POPIA, the "Responsible Party" is the entity that determines the purpose of and means for processing Personal Information.

• Legal Entity: Paypertuity (Pty) Ltd
• Registration Number: [Your Company Registration Number]
• Physical Address: [Your Full Physical Address]

We have appointed an Information Officer who is responsible for overseeing our compliance with POPIA. You can contact our Information Officer with any questions or concerns regarding this policy or your Personal Information:

• Information Officer: [Name of Information Officer]
• Email: informationofficer@paypertuity.co.za
• Postal Address: [Your Postal Address]

3. Personal Information We Collect and Why

We collect Personal Information in different ways depending on your interaction with us. We are committed to the principle of "processing limitation," meaning we only collect information that is necessary for a specific purpose.

A. Information You Provide Directly to Us

When you contact us (e.g., "Get in Touch" form, "Get Started," "Demo Request"): We collect your name, email address, company name, and the content of your message.
Purpose: To respond to your inquiries, provide you with information about our Service, schedule a demo, and manage our business relationship.
Legal Basis: Legitimate Interest.

When you subscribe to our newsletter: We collect your email address.
Purpose: To send you marketing communications.
Legal Basis: Consent.

When you become a Client: We collect contact details of your designated representatives, billing information, and credentials for user accounts on the EduFlow360 platform.
Purpose: To fulfill our contractual obligations.
Legal Basis: Performance of a Contract.

B. Information We Process on Behalf of Our Clients (As an "Operator")

When our clients use the EduFlow360 platform to manage student funding, they are the Responsible Party and we act as an Operator. Data processed may include student personal, academic, and financial information.

Purpose: To provide the core functionality of the EduFlow360 Service.
Legal Basis: Performance of a Contract with our client.

C. Information Collected Automatically (Website Usage & Cookies)

When you visit our website, we may collect technical information such as IP address, browser type, and pages visited.
Purpose: Security, analytics, and improving user experience.
Legal Basis: Legitimate Interest / Consent for non-essential cookies.

4. How We Use Your Personal Information

• Operate and improve our Service.
• Ensure security and legal compliance.
• Communicate with you about updates and support.

5. Cookies and Tracking Technologies

We use cookies to enhance functionality and analyze traffic. You can manage cookies via your browser settings; disabling some may impact site functionality.

6. Data Sharing and Disclosure

We do not sell your Personal Information. We may share it with technology partners (e.g., Microsoft Azure), as instructed by clients, to comply with legal obligations, or in business transfers.

7. International Data Transfers

Where data is transferred outside South Africa, we ensure adequate protection via POPIA-compliant mechanisms.

8. Data Security and Integrity

We implement technical and organisational measures such as encryption, access control, and secure Azure infrastructure.

9. Data Retention

We retain Personal Information only as long as necessary or as required by law.

10. Your Rights as a Data Subject

You have rights of access, rectification, erasure, objection, restriction, and the right to lodge complaints with the Information Regulator of South Africa (inforegulator.org.za).

11. Children's Privacy

Our website is not intended for children under 18. Student data processed within the Service is handled under our clients' responsibility.

12. Changes to This Privacy Policy

We may update this policy periodically. Material changes will be communicated via the "Last Updated" date and, where appropriate, additional notice.

13. Account Deletion

You may delete your account at any time by either of the following methods:

• In-App: Open the NSFAS Pulse mobile app, navigate to Settings ▸ Delete Account, and follow the on-screen prompts.
• Email Request: Send a deletion request to info@lebonconsulting.co.za from the email address associated with your account.

Once we have verified your identity, we will permanently delete your account and the associated personal information within a reasonable period. Please note that, in accordance with the Financial Intelligence Centre Act (FICA), we are legally required to retain certain transactional and identification records for a minimum of five (5) years after the end of our business relationship or the date of the relevant transaction. These records will be securely stored, isolated from active processing, and automatically erased once the statutory retention period expires.

14. How to Contact Us

Questions or concerns? Contact our Information Officer at informationofficer@paypertuity.co.za.