Xcallibre (Pty) Ltd and its affiliates (collectively “Xcallibre” “us” and “we”) understand the importance of protecting your personal data.
This Privacy Statement describes how Xcallibre collects and uses your personal data, who we share it with, and your choices and rights in relation to your personal data.
It applies to personal data that we collect from you during your interactions with us, whether online, including through our websites (including mobile sites) and social media sites (“Sites”), mobile applications (“Apps”) (collectively “Online Services”) that link to this Privacy Statement, in writing or orally, or personal data that we may collect offline or receive from third parties.
2. Xcallibre Privacy Principles
- We’re deeply committed to creating a safe and secure online environment for you.
- We do not sell your personal information to third parties. We established ourselves as a not-for-profit organization so that our mission of education and your trust will not be in conflict with a for-profit motive.
- We strive to provide you with access to and control over the information you give us, and we take the protection of your information very seriously.
- We take extra precautions for our younger learners under the age of 13, including restricting child accounts to automatically block features that would allow a child to post or disclose personal information.
- Our mission is to provide you with a better learning experience, not to sell you products.
3. Personal data we collect
Personal data is any information that identifies you as an individual or relates to you as an identifiable individual. We take the information you provide to us very seriously, and we strive to put you in control of decisions around your information.
You can use many features of the Service without registering for an account or providing any other personal information. If you create an account on the Xcallibre Service, or communicate with Xcallibre, you may provide to Xcallibre what is generally called “Personal Information” or “Personal Data,” such as your full name, birthdate, email address or other information that can be used to identify you. Information which cannot be used to identify you as an individual is “de-identified” or non-personal information.
We collect information, including personal information, in a variety of ways which may vary according to your use of the Service and your account settings. The categories of personal information we collect may include:
- Contact and profile information (your name, email address, postal address, telephone number, your gender; and social media account information, etc.
- Account and authentication information from third-party integrated services
- Location information
- Information about your browser or device
- Non-personal information which may be linked to your Personal Information
- log-in and account information for authentication purposes and account access;
We may also collect other information that does not personally identify you. Such other information includes browser and device information, website and application usage data, IP addresses, demographic information such as marketing preferences, geographic location, primary language, and information collected through cookies and other technologies or information that has been anonymised or aggregated. If we link this information with your personal data, we will treat that linked information as personal data.
You can choose not to provide personal data to us when requested. However, if this is necessary to provide you with our solutions and services, access to our Online Services, or to perform administrative functions, we may be unable to do these things.
Below, we describe examples of the categories of information we collect from and about you when you use our Service:
Information you provide to us and information we receive about you from others
Contact and profile information.
When you create an account on the Xcallibre Service, or communicate with us, we may collect personal information including your name, email address, and birthdate. After you register, you may also choose to provide additional information in your profile, such as your nickname, location (city), and other personal or demographic information. In addition, we may ask you for personal information at other times, such as when you contact our technical support team, send us an email, complete a user survey, or otherwise communicate with Xcallibre.
Information from Integrated Sign-On Services.
Information obtained from other users.
We make available certain features on our Service that allow other users to provide us information about you. For example, a client may provide information relating to a customer, such as username and contact details, etc.
Information provided by partners and other sources.
Information we collect to enable your participation in special programs or features.
From time to time, Xcallibre may feature a special program or activity we offer in partnership with a third party. If you participate in these special programs, Xcallibre may collect personal information from you to facilitate those programs.
Information about how you access and use the Service
Information about your use of our Service.
We may collect usage information about your use of our Service, such as the number of logins you have attempted, the number of pages viewed, and the amount of time spent on the system. This enables us to better tailor Xcallibre experiences that are most appropriate for you.
We may collect and use information about your location (such as your country) or infer your approximate location based on your IP address in order to provide you with tailored services for your region, but we don’t collect the precise geolocation of you or your device. You may be able to change the settings on your computer or mobile device to prevent it from providing us with any location information.
Usage and device information.
To provide a personalized learning and high-quality experience for our users, we may use various technologies that automatically record certain technical information from your browser or device when you visit our website, read our emails, use our Service or otherwise engage with us. This information is typically collected through a variety of tracking technologies, including cookies, web beacons, Flash objects, log files, and similar technology (collectively, “tracking technologies”). These tracking technologies cookies collect information about how you use the Service (e.g., the pages you view, the links you click, and other actions you take on the Service), information about your browser and online usage patterns (e.g., Internet Protocol (“IP”) address, browser type, browser language, referring / exit pages and URLs, pages viewed, whether you opened an email, links clicked), and information about the device(s) you use to access the Service (e.g., mobile device identifier, mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, and whether you access the Service from multiple devices). We may collect analytics data, or use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the Sites and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout. We may also work with third party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices. Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.
We use or may use the data collected through tracking technologies to better display our website, to save you time, to provide better technical support, for promotional purposes, and to track website usage. For example, cookies help us to:
- Keep track of whether you are signed in or have previously signed in so that we can display all the features that are available to you.
- Remember your settings on the pages you visit, so that we can display your preferred content the next time you visit.
- Customize the function and appearance of the pages your visit based on information relating to your account; for example, in order to default you to a particular study level, or to remember customized settings for a report.
- Track website usage for various purposes including sales, marketing, and billing.
Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some features and services (particularly those that require you to sign-in) may not function properly if your cookies are disabled. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.
Deleting cookies does not delete Local Storage Objects (LSOs) such as Flash objects and HTML5. You can learn more about Flash objects – including how to manage privacy and storage settings for Flash cookies – on Adobe’s website or by clicking here. Various browsers may offer their own management tools for removing HTML5 LSOs. Please consult your browser’s “Help” function to learn more. If you choose to delete Flash objects from our sites, then you may not be able to access and use all or part of the sites or benefit from the information and services offered.
4. Sensitive personal data
We do not collect sensitive personal data about you, e.g. information relating to your health, religion, political beliefs, race or sexual orientation and ask that you do not send or provide this information to us.
5. How we collect your personal data
We may collect your personal data from you in a variety of ways when you interact with us, including:
- when you access our Online Services, or interact with us in any other way, or use our solutions and services.
- We collect personal data when you place orders for our solutions and services, you create an account with us, we process your orders and payment transactions, perform administrative and business functions, market our solutions and services to you and when you register for our events, workshops and seminars or subscribe to our mailing lists and newsletters.
- when you communicate with us.
- We collect personal data when we respond to your inquiries and requests, obtain feedback from you about our solutions and services or you apply for employment with us.
- from third party sources.
- We collect personal data from third parties, including public databases, social media sites, business partners with whom we offer co-branded services or engage in joint marketing activities and third parties that provide list enhancement or similar services.
6. Legal basis for processing your personal data
When we process your personal data in connection with the purposes set out in this Privacy Statement, we may rely on one or more of the following legal bases, depending on the purpose for which the processing activity is undertaken and the nature of our relationship with you:
- our legitimate interests (or those of a third party with whom we share your personal data) for the purpose of managing, operating or promoting our business, including direct marketing, and intra-Xcallibre group transfers of personal data for business and administrative purposes, except where such interests are overridden by your interests or fundamental rights or freedoms which require protection of personal data.
- where this is necessary to comply with a legal obligation on us.
- to protect the vital interests of any individual.
- where you have consented.
7. Use of your personal data
We may use your personal data to:
- enable you to effectively use and to improve our solution and services. For example, to:
- perform administrative and business functions and internal reporting.
- send administrative information to you.
- obtain feedback from you about our services and solutions including through client satisfaction surveys, in which event, we will only use your personal data for the sole purpose of sending you a survey (through our third party email delivery provider).
- respond to your inquiries and fulfill requests by you.
- assess the performance of our Online Services and to improve their operation.
- inform you about and provide you with our services and solutions.
- update our records and keep contact details up to date.
We engage in these activities to manage our contractual relationship with you, to comply with our legal obligations, or for our legitimate business interests.
- provide you with marketing materials and to personalise your experience. For example, to:
- send marketing communications to you.
- provide you with a more personalised experience when you interact with us.
- enable you to subscribe to our newsletters and mailing lists.
- enable you to register for Xcallibre events, workshops and seminars.
We engage in these activities with your consent or for our legitimate business interests.
- achieve our business purposes and analyse information. For example, to:
- establish, manage, and maintain our business relationship with you.
- compile usage statistics for our Online Services.
- recruit staff.
- process and respond to privacy requests, questions, concerns and complaints.
- fulfil legal and contractual obligations.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation and for our legitimate business interests.
Xcallibre uses this information in the following ways:
To provide and enhance our Service.
Xcallibre uses the information you provide or that we collect to operate, maintain, enhance, and provide all of the features of our Service.
To personalize your experience.
We use the information to personalize your experience while using the Service, including on various devices you may use to access the Service. For instance, Xcallibre remembers your recent activity so we can recommend the most appropriate content for you on your next visit and provide personalized learning experiences.
To communicate with you.
We use your information to communicate with you about your account and respond to inquiries. We may also use your Personal Information to provide you with information about Xcallibre features, services and other offerings that may be of interest to you.
To understand, improve, and develop our Service.
Xcallibre uses all the information that you provide or that we collect from users to understand and analyze the usage trends, learning behaviors, and preferences of our users, to improve the way the Service works and looks, and to create new features and functionality. We may also use information to maintain, develop, support and improve our Service and other educational products and services.
To enable your participation in Xcallibre partnership arrangements.
We use your information to enable your participation in programs or features we may offer in partnership with third parties, to the extent you wish to participate in such programs. For personal data subject to the European Union General Data Processing Regulations (“GDPR”), we rely on several legal bases to process the data. These legal bases include where:
- The processing is necessary to perform our contractual obligations in our Terms of Service or other contracts with you (such as to provide you the Service as described in our Terms of Service);
- You have given your prior consent, which you may withdraw at any time (such as for marketing purposes or other purposes we obtain your consent for from time to time);
- The processing is necessary to comply with a legal obligation, a court order or to exercise or defend legal claims;
- The processing is necessary for the purposes of our legitimate interests, such as in improving, personalizing, and developing the Service, marketing the Service, such as new features or products that may be of interest, and promoting safety and security as described above.
- If you have any questions about or would like further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided below.
8. Sharing your personal data
Xcallibre takes great care to protect the information you provide us. We do not rent or sell Personal Information that we collect from users with third parties.
Xcallibre will disclose personal information when you post content which is visible to others on the Service, when you consent or instruct us to share your personal information with third parties, or when we have a legitimate business or legal need to share your information. We may also disclose anonymous or aggregate information that does not reasonably identify you as an individual. To learn more, see additional description below.
We may share your personal data for the purposes set out in this Privacy Statement (as applicable):
- with our affiliates and subsidiaries for the purposes set out in this Privacy Statement. Xcallibre (Pty) Ltd is the party responsible for the management of jointly used personal data.
- with business partners with whom we offer co-branded services or engage in joint marketing activities.
- with service providers to provide operational services or facilitate transactions on our behalf, including but not limited to processing of orders, assisting with sales-related activities or post-sales support, client support, email delivery, data analytics and auditing.
- where you consent to the sharing of your personal data.
- in connection with, any joint venture, merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company.
- for other legal reasons.
- We may share your personal data in response to a request for information by a competent authority in accordance with, or required by any applicable law, regulation or legal process;
- where necessary to comply with judicial proceedings, court orders or government orders; or
- to protect the rights, property or safety of Xcallibre, its business partners, you, or others, or as otherwise required by applicable law.
Any third parties with whom we share personal data are contractually required to implement appropriate data protection and security measures to protect personal data and are not permitted to use personal data for any purpose other than the purpose for which they are provided with or given access to personal data.
9. Security of your personal data
Xcallibre is committed to protecting your personal data from accidental or unlawful destruction, loss, alteration, unauthorised access or disclosure by using a combination of physical, administrative and technical safeguards and contractually requiring that third parties to whom we disclose your personal data do the same.
Data security is important to you, and to us.
To protect your privacy and security, we take reasonable steps to verify your identity before granting you account access or making corrections to your information. For example, we may ask you to provide certain Personal Information to confirm your identity, and we may require that you create and use a password to access certain parts of our Service. You should create and maintain a strong password to help ensure the security of your account.
We try to ensure that our Service and information sent to us are safe, but no security measures are perfect.
Xcallibre uses certain physical, managerial, and technical safeguards designed to preserve the integrity and security of your Personal Information and other information we maintain in connection with our Service. We cannot, however, ensure or warrant the security of any or all of the information you transmit to Xcallibre, and you do so at your own risk. Once we receive your transmission of information, Xcallibre makes commercially reasonable efforts to ensure the security of our systems. When you enter sensitive information, we encrypt the transmission of that information using secure socket layer technology (SSL) or similar technologies. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and will notify you of the security incident in accordance with applicable laws and regulations.
10 International Visitors
Our Service is operated and managed on servers located within South Africa. If you choose to use our Service from the European Union or other regions of the world with laws governing data collection and use that differ from South Africa law, then you acknowledge that Xcallibre will transfer your personal information to the South Africa for the purpose of performing the Service according to our contract (e.g., our Terms of Service) and for any other purpose for which you provide explicit, informed consent.
11 European Union Data Protection
Residents in the European Union are entitled to certain rights with respect to personal information that we hold about them:
Right of access and portability. The right to obtain access to your personal information, along with certain related information, and to receive that information in a commonly used format and to have it transferred to another data controller;
Right to rectification. The right to obtain rectification of your personal information without undue delay where that personal information is inaccurate or incomplete;
Right to erasure. The right to obtain the erasure of your personal information without undue delay in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed;
Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal information in certain circumstances, such as where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information; and
Right to object. The right to object, on grounds relating to your particular situation, to the processing of your personal information, and to object to processing of your personal information for direct marketing purposes, to the extent it is related to such direct marketing.
You may also have the right to make a complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here:
http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. In some cases our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
12 Cookies and Similar Technologies
- enabling you to sign in to our Online Services;
- authenticating you;
- keeping track of information you have provided to us;
- improving your browsing experience;
- customising our interactions with you;
- storing and managing your preferences and settings;
- compiling statistical data;
- analysing the performance and usability of our Online Services;
- measuring traffic patterns for our Online Services; and
- determining which areas of our Online Services have been visited.
These technologies collect information that your browser sends to our Online Services including your browser type, information about your IP address (a unique identifier assigned to your computer or device which allows your PC or device to communicate over the Internet), together with the date, time and duration of your visit, the pages you view and the links you click.
Our Online Services may also contain web beacons or similar technologies from third party analytics providers, through which they collect information about your activities across our Online Services to help us compile aggregated statistics.
13. Links to third party websites and applications
Our Online Services may contain links to third party websites and applications. We are not responsible for and make no representations or warranties in relation to the privacy practices or content of any third party websites and applications. Your use of such sites and applications is subject to the applicable third party privacy statement and is at your own risk.
14. Direct marketing
We may send you direct marketing communications about our solutions and services. You can choose whether you wish to receive marketing communications from Xcallibre by email, SMS, post and phone. You may opt out of receiving marketing materials from us at any time and manage your communication preferences by:
- following the unsubscribe instructions included in each marketing email or SMS text message from us;
- sending an email to email@example.com; or
- writing to:
Xcallibre (Pty) Ltd
Attn: Data Protection Officer
Third Floor, JT Ross House,
Lion Match Park,
892 Umgeni Road,
South Africa, 4001
Phone: +27 (0)87 365 3300
Fax : +27 (0)87 365 3301
Include your details and a description of the marketing material you no longer wish to receive from us. We will comply with your request as soon as is reasonably practicable.
If you opt out of receiving marketing related communications from us, we may still send you administrative messages as part of your ongoing use of our solutions and services, which you will be unable to opt out of.
We do not provide your personal data to unaffiliated third parties for direct marketing purposes or sell, rent, distribute or otherwise make personal data commercially available to any third party.
15. Retaining your personal data
We will retain your personal data for as long as is necessary to fulfil the purpose for which it was collected unless a longer retention period is required to comply with legal obligations, resolve disputes, protect our assets, or enforce agreements. The criteria we use to determine retention periods include whether:
- we are under a legal, contractual or other obligation to retain personal data, or as part of an investigation or for litigation purposes;
- personal data is needed to maintain accurate business and financial records;
- there are automated means to enable you to access and delete your personal data at any time;
- the personal data is sensitive personal data in which event we will generally retain this for a shorter period of time;
- you have consented to us retaining your personal data for a longer retention period, in which case, we will retain personal data in line with your consent.
16. Updates to this Privacy Statement
We may update this Privacy Statement at any time. If we do, we will update the “last modified” section at the bottom of this Privacy Statement.
We encourage you to regularly review this Privacy Statement to stay informed about our privacy practices.
17. How to contact us
If you have any questions about how your personal data is handled by Xcallibre, you have a privacy concern or you wish to make a request or a complaint relating to your personal data, please contact us.
You can reach us at firstname.lastname@example.org or at:
Xcallibre (Pty) Ltd
Attn: Data Protection Officer
Third Floor, JT Ross House,
Lion Match Park,
892 Umgeni Road,
South Africa, 4001
Phone: +27 (0)87 365 3300
Fax : +27 (0)87 365 3301 Last modified: 14 November 2019