Online Privacy Notice – Bramble Hill International Academy

1. About the Privacy Notice

1.1. Bramble Hill International Academy strives to ensure that our use of Personal Information of data subjects is lawful, reasonable, and relevant to our business activities, with the ultimate goal of improving our offerings and your experience.

1.2. This notice applies to Bramble Hill International Academy, its subsidiaries and business units. Reference to “Bramble Hill International Academy”, “we”, “us” or “our” in this notice means Bramble Hill International Academy.

1.3. Bramble Hill International Academy respects privacy and is committed to protecting the privacy of visitors to this site. Bramble Hill International Academy seeks to employ best practice when it comes to the collection and processing of personal information in accordance with the following legislation:

1.3.1. Protection of Personal Information Act 4 of 2013; and

1.3.2. Promotion of Access to Information Act 2 of 2000.

1.4. Where we provide links to websites of other organisations, this Privacy Notice does not cover how that organisation processes personal information. If you follow a link to any website, please read the privacy notice of the website you visit before you submit any personal information to such website. Bramble Hill International Academy is not responsible for information captured and processed on any website linked to our website.

1.5. This Online Privacy Notice sets out what we will do with any Personal Information we collect from or about you, or that you provide to us, when you use our services, including our websites and student portals (which we also collectively refer to in this Privacy Notice as the “Website”) or when you enrol at any of our institutions. Please read this Privacy Notice carefully to understand our views and practices regarding your Personal Information and how we will treat it.

1.6. It is important that you read this Privacy Notice together with our website terms and conditions and any other document or agreements which describes the manner in which we may provide in specific circumstances when we are collecting or processing personal information about you. This will enable you to properly understand the manner in which Bramble Hill International Academy will process your Personal Information. This Privacy Notice supplements our website terms and condition and any such other documents and agreements, and this Privacy Notice is not intended to override them.

1.7. If you are a consumer, as defined in the Consumer Protection Act 68 of 2008 (“Consumer Protection Act”) we have a duty to point out certain important terms to you. The paragraphs which contain these important terms and reasons why they are important are set out below.

1.7.1. Limitations of risk, legal responsibilities and liability. Clauses 8 and 11 are important because they limit and exclude obligations, liabilities and legal responsibilities that we may otherwise have. As a result of these clauses, your rights and remedies against us and other persons and entities are limited and/or excluded. These clauses also limit and exclude your right to recover or make claims for losses, damages, liability or harm you or others may suffer. Clause 8 and 11 state that you
know and accept that the Internet is not absolutely secure and there is a risk that
your Personal Information will not be secure when transmitting over the Internet.

1.7.2. Assumption of risk, legal responsibilities and liability to you. Clause 11 is important
because you take on risk, legal responsibilities and liability. As a result of this clause, you may also be responsible for claims and other amounts. You will also be
responsible for, and you accept, various risks, damages, harms, and injury which
may be suffered by you and others as stated in this clause. In terms of this clause,
you waive your rights and as a result we may not have to perform our duties and
you may not become aware of information that you may need to protect yourself.

1.7.3. Acknowledgement of fact by you. Clause 5 is important because it contains
statements which are acknowledgments of fact by you. You will not be able to deny
that the statements are true. We may take action against you and may have claims
against you as a result of these statements. You will not be able to take any action
against us if you suffer harm as a result of these statements.

2. The Personal Information that we collect about you

2.1. Bramble Hill International Academy may collect, receive, record, organise, collate,
store, update, change, retrieve, read, process, analyse, use and share your Personal
Information in a way set out in this Privacy Notice. When we do one or more of these
actions with your Personal Information, we are “Processing” your personal

2.2. “Personal Information” refers to private information about an identifiable person
(which includes natural persons as well as juristic persons, such as companies or
trusts). Personal information does not include information that does not identify a
person (including in instances where that information has been de-identified). The
type of personal information that we collect about you may differ on the basis of the
services that you receive from Bramble Hill International Academy.

2.3. We may process different kinds of personal data about you which we have grouped
together as follows:

• Identity Data, which includes information concerning your name, username or
similar identifier, marital status, title, date of birth, gender, race and legal status, as
well as copies of your identity documents, photographs, identity number, registration number and qualifications.

• Contact Data, which includes billing addresses, delivery addresses, email
addresses and telephone numbers.

• Financial Data, which includes bank account and payment card details, insurance
information, and financial statements.

• Transaction Data, which includes details about payments to and from you.

• Service Data, which includes information concerning your interactions with
Bramble Hill International Academy as well as your performance in Bramble Hill
International Academy administered educational courses.

• Security Data, which may include records of your access to our facilities, as well
as CCTV camera footage of you on or nearby our premises.

• Technical Data, which includes your internet protocol (IP) address, your login
data, browser type and version, time zone setting and location, browser plug-in
types and versions, operating system and platform, and other technology on the
devices you use to access the Website.

• Usage Data, which includes information about how you use our website, products
and services.

• Marketing and Communications Data, which includes your preferences in
receiving marketing from us and our third parties and your communication

2.4. If any of the information you provide to us:

2.4.1. contains special personal information such as health, religion, ethnic or race
information, your consent is the lawful basis on which we rely to process such
information unless any other lawful basis exist allowing us to process such

2.4.2. contains the processing of personal information of children (minors), for instance
information given to us about a child during a complaint resolution process, this
processing of personal information of children may only be carried out with the prior
consent of the competent person such as a parent or legal guardian, unless lawful
basis exist allowing us to process such information without the aforementioned

2.5. We do not provide services directly to children, and our site is not available for use by
any person under the age of 18 years without consent and supervision from a
competent person such as parent or a legal guardian. This Privacy Notice also
applies in a case where a child makes use of our website with the consent from a
competent person. Use of our website by a child without the relevant consent from a
competent person is prohibited.

2.6. Bramble Hill International Academy may also process, collect, store and/or use
aggregated data, which may include historical or statistical data (“Aggregated Data”)
for any purpose. Aggregated Data could be derived from your personal information
but is not considered personal information as this data will not directly or indirectly
reveal your identity. However, if we combine or connect Aggregated Data with your
personal information so that it can directly or indirectly identify you, we will treat the
combined data as personal information which will be used in accordance with this
Privacy Notice.

3. How we collect your Personal Information
We collect your personal information in three ways, namely:

• through direct or active interactions with you;

• through automated or passive interactions with you; and

• from third parties.

3.1. Direct or active collection from you
We may require you to submit certain information in order for you to access certain
portions of the Website and to enable us to provide certain services to you (e.g.,
providing further requested information, enrolling in a school, prospectus ordering
etc.) or to conclude an agreement with us, or to fulfil our statutory obligations. We
also collect information directly from you when you communicate directly with us, for
example via e-mail, telephone calls, feedback forms, site comments and forums. If
you contact us, we may keep a record of that correspondence. The information we
may actively collect from you may include any of the information listed in section 2 of
this Privacy Notice.

3.2. Passive collection from your Access Device
We passively collect some of your personal information from devices that you use to
access and navigate through the Website or to access any network administered by
Bramble Hill International Academy (each an “Access Device”), using various
technological means. The information which we passively collect from your Access
Device may include your Identity Data, Contract Data, Security Data, Technical Data,
Usage Data, Marketing and Communications Data, and any other information which
you permit us, from time to time, to passively collect from your Access Device.

3.3. Information collected from third parties.
Bramble Hill International Academy may receive personal information about you from
various third parties and public sources and will treat that information with due care.

4. How the Information Collected is Used

4.1. Personal information provided to Bramble Hill International Academy by you will only
be used for the purposes stated when the personal information is requested.

4.2. We may use your personal information:

• to provide our services to you, as well as any goods that you may purchase from
us (including goods you purchase from our parent portal);

• to administer our various education programmes;

• to operate our facilities;

• to comply with our statutory obligations, including submissions to the Companies
and Intellectual Property Commission, as well as interacting with regulatory

• to conduct business case analysis;

• to conduct Bramble Hill International Academy ‘s recruitment exercises, including
referrals, and hiring processes, including the capturing of a job applicant’s details
and the providing of status updates to such a job applicant. In this context
Bramble Hill International Academy will conduct criminal record and credit

• to retain and make information available to you on the Website;

• to provide you with marketing that is relevant to you, or to direct information
concerning Bramble Hill International Academy;

• maintain and update our customer or potential customer databases;

• to establish and verify your identity on the Website;

• diagnose and deal with technical issues, customer support queries and other
user queries;

• operate, administer, maintain, secure and develop the Website and the
performance and functionality of the Website;

• to protect our rights in any litigation;

• detect, prevent or deal with actual or alleged fraud, security or the abuse, misuse
or unauthorised use of the Website and/or contravention of this Privacy Notice or
any of the terms and conditions that apply to the use of the Website;

• communicate with you and keep a record of our communications with you and
your communications with us;

• inform you about any changes to the Website, the Privacy Notice or other
changes which are relevant;

• to create user profiles and analyse and compare how you and other users make
use of the Website, including (without limitation) habits, click-patterns,
preferences, frequency and times of use, trends and demographics;

• to analyse and compare the kinds of Access Devices that you and other users
make use of and where you are using them; and

• for any other purposes relevant to our business activities, provided they are

4.3. Demographical and statistical information about user behaviour may be collected and
used to analyse the popularity and effectiveness of Bramble Hill International
Academy websites. Any disclosure of this information will be in aggregated and
anonymised form and will not identify individual users.

4.4. Bramble Hill International Academy will restrict its processing of your Personal
Information to the original purposes for which it was collected, unless Bramble Hill
International Academy reasonably considers that it is required to be processed for
another purpose and that purpose is compatible with the original purpose. If you
would like us to explain how the further processing for the new purpose is compatible
with the original purpose, please contact us.

5. Sharing of your Personal Information

5.1. We will not intentionally disclose, for commercial gain or otherwise, your Personal
Information other than as set out in this Privacy Notice or without your permission.

5.2. Bramble Hill International Academy may share your Personal Information under the
following circumstances:

5.2.1. to our agents, advisers, service providers and suppliers which have agreed to be
bound by this Privacy Notice or on terms which offer the same level of protection as
this Privacy Notice;

5.2.2. to our agent responsible for processing of pre-admission tests which have agreed to
be bound by this Privacy Notice or on terms which offer the same level of protection
as this Privacy Notice;

5.2.3. to our employees, suppliers, service providers and agents if and to the extent that
they need to know the information in order to provide the services for or to us for
which they have been appointed, such as hosting, development and administration,
technical support and other support services relating to the Website or the operation
of the Bramble Hill International Academy business. We will authorise any
information processing done by a third party on our behalf, amongst other things by
entering into written agreements with those third parties governing our relationship
with them and containing confidentiality and non-disclosure provisions;

5.2.4. in order to enforce or apply any other contract between you and us;

5.2.5. in order to protect our rights, property or safety or that of our customers, employees
and prospective employees, contractors, candidates and prospective candidates,
suppliers, service providers, agents and any other third party;

5.2.6. in order to mitigate any actual or reasonably perceived risk to us, our customers,
employees and prospective employees, contractors, candidates and prospective
candidates, agents or any other third party; and

5.2.7. to governmental agencies, exchanges and other regulatory or self-regulatory bodies
if required to do so by law or if we reasonably believe that such action is necessary

• comply with the law or any legal process;

• protect and defend the rights, property or safety of Bramble Hill International
Academy, or our customers, employees and prospective employees,
contractors, candidates and prospective candidates, suppliers, service
providers, agents or any third party;

• detect, prevent or deal with actual or alleged fraud, security or technical issues
or the abuse, misuse or unauthorized use of the Website and/or contravention
of this Privacy Notice; and

• protect the rights, property or safety of members of the public. If you provide
false or deceptive information about yourself or misrepresent yourself as being
someone else, we may proactively disclose such information to the appropriate
regulatory bodies and/or commercial entities.

6. Cross-border Transfer

6.1. Information that we collect from you may be collected in, or transferred to, a
destination outside of South Africa. Such destination may not have comparable data
protection legislation, and such collected information may also be processed by staff
operating outside South Africa who work for us or by one of our contractors.
However, we will ensure that there is either binding corporate rules or a binding
agreement in place to ensure your information is processed in line with South African
privacy legislation and this Privacy Notice.

6.2. Please contact us if you want further information on the specific mechanism used by
us when transferring your personal information outside of South Africa or the
destination in which we collected the personal information.

6.3. Personal information shared for performance of the pre-admission test, done by an
external party outside the borders of South Africa, will be limited to the information
required to do the test. The safeguards listed in 6.1 will be adhered to at all times.

7. How we Store Information Collected

7.1. Personal information is held only as long as is necessary to provide the services to
you or as may be required in terms of legislation (including prescription periods) and
business requirements, whichever period is the longest. The details of this are
available on request to the Bramble Hill International Academy Information Officer in
the form of the Bramble Hill International Academy Data Retention Notice.

7.2. Personal information that you provide to us will be stored electronically on our
servers or those of our service providers, as well as in hard copy format (at times),
with reasonable organisation and technical safeguards in place to protect this
personal information. However, we do work with third party contractors, some of
whom host and operate certain features of the website.

7.3. If you subscribe for data, news, announcements, alerts or any such information to be
emailed to you from Bramble Hill International Academy, we will hold your details on
our database until such time as you chose to unsubscribe from this service. You may
do this at any stage by selecting the appropriate option in the alerts section of this

7.4. We may keep and process some or all of your personal information if and for as long

• we are required or permitted by law or a contract with you to keep it;

• we reasonably need it for lawful purposes related to our functions and activities;

• we reasonably need it for evidentiary purposes; or

• you agree to us keeping it for a specified further period.

7.5. To determine the appropriate retention period for personal information, Bramble Hill
International Academy will consider, among other things, the quantity, nature and
sensitivity of the personal information, the potential risk of harm from unauthorised
use or disclosure of your personal information, the purposes for which we process
your personal information and whether we can achieve those purposes through other
means. Bramble Hill International Academy will always comply with applicable legal,
regulatory, tax, accounting or other requirements as they pertain to the retention of
personal information.

8. Quality and Protection of your Information

8.1. We make every effort to keep the personal information we hold updated, complete
and accurate. It is your duty to provide Bramble Hill International Academy with your
most up to date personal information and you can do so in the following ways:

• Please use the Parent Portal (SCADSYS) to update on our system, you may
access through our website by clicking on the Parent Account Login button.

• You may e-mail our admissions office to update your information:

8.2. Bramble Hill International Academy strives to ensure the security of personal
information we hold by taking reasonable measures to prevent destruction, unlawful
access and loss of personal information. Any compromise of data integrity or
confidentiality will be reported to you by written notice.

8.3. Even by taking the above measures when processing personal information, we do
not guarantee that your personal information is 100% secure.

8.4. Please contact us by email at the aforesaid email address if you:

• Require access to any of your personal information we have on our database; or

• Wish to notify us of any change, modification or correction; or

• Would like to have your personal information removed from our records.
We will require suitable proof of identity from you before we can action any of the
above requests.

9. How We Use “Cookies”

In so far as our web pages use ‘cookies”, a cookie is a small file of letters and numbers
that we place on your computer or mobile device. These cookies allow us to distinguish
you from other users and assist us to provide you with a good experience when
browsing our website. It also allows us to improve our website.

10. Access to Information
The Promotion of Access to Information Act, 2000 gives you the right to access
information held about you. For further information about this right and how to exercise
it, please see Bramble Hill International Academy ’s PAIA Manual available at

11. You give up some of your rights
You agree that where the law requires us to make you aware of something (to inform or
notify you) or to do something else, we do not have to do this. This only applies as far as
the law allows this.
For example, sometimes the law says that we have a duty to make you aware of some
information or other matters, unless you agree that we do not need to do these things
(this is called a waiver of rights). Because you agree to this, we will not have this duty
anymore and will not need to make you aware of the information or other matters.

12. Your rights
Please note that, under certain circumstances, you may have rights under data
protection laws in relation to your personal information:

12.1. Request access to your personal information (commonly known as a “data
subject’ access request”). This enables you to receive a copy of the personal
information that Bramble Hill International Academy has about you. We may refuse
your request for access or disclosure of your personal information if any of the
grounds permitted in law applies.

12.2. Request correction of the personal information that we hold about you. This
enables you to ensure that any incomplete or inaccurate data that Bramble Hill
International Academy holds about you is corrected. To exercise this right, you
should contact us via email and inform us that your data is incomplete and/or
inaccurate. You will need to point out what you believe is inaccurate or incomplete
and explain to us how we should correct or complete it as well as provide us with the
evidence of inaccuracies where available. On receipt of your request, we will, as
soon as reasonably practicable, correct or complete your personal information.

12.3. Request erasure of your personal data. This enables you to request that Bramble
Hill International Academy delete or remove personal information where there is no
lawful basis for us continuing to process or retain it. You also have the right to ask us
to delete or remove your personal information where you have successfully exercised
your right to object to the processing thereof where we may have processed your
information unlawfully or where we are required to erase or de-identify your personal
information to comply with applicable law. Bramble Hill International Academy may
not always be able to comply with your request of erasure for specific legal reasons
which will be notified to you, if applicable, at the time of your request.

12.4. Withdraw consent at any time where we are relying on consent to process your
personal information. This will not affect the lawfulness of any processing carried
out before you withdraw your consent. If you withdraw your consent, we may not be
able to provide certain products or services to you. We will advise you if this is the
case at any time you withdraw your consent. Please note that we may continue to
process your personal information in certain instances where we are not relying on
your consent.

12.5. Right to object. You have a right to object in accordance with applicable data
protection or privacy legislation, at any time, from us processing or using your
personal information and we may no longer process your personal information.
Should you require to exercise your right to object, you should inform us that you do
not want us to process your personal information and state the reasons why we
should stop using such personal information to which you object. Should we not have
any lawful basis for processing the information you object to, we would stop using
such personal information objected to successfully, unless data protection or privacy
legislation or other agreements with you provide us with a lawful basis for or justifies
us in continuing to process such information, and we will inform you of the result of
your objection.

13. Direct marketing

13.1. Through your engagement with us you may be requested whether you agree to
receive marketing communications from us. You may refuse, accept, require us to
discontinue, or pre-emptively block any approach or communications from us if that
approach or communication is primarily for the purpose of direct marketing (“direct
marketing communications”).

13.2. You may opt out of receiving direct marketing communications from us at any time by
requesting us (in the manner set out in the communication or by contacting us at the
contact details set out in clause 17) to desist from initiating any direct marketing to
you. If you have opted out, we may send you written (which may include electronic
writing) confirmation of receipt of your opt out request, and not send you any further
direct marketing communications. Please note that you may continue to receive
communications from us that are not marketing related.

14. Consumer Protection Act and Protection of Personal Information Act

14.1. If any party of this Privacy Notice is regulated by or subject to the Consumer
Protection Act 68 of 2008 (“CPA”) or the Protection of Personal Information Act 4 of
2013 (“POPIA”), it is not intended that any part of this Privacy Notice contravenes
any provision of the said legislation. Therefore, all provisions of this Privacy Notice
must be treated as being qualified, to the extent necessary, to ensure that the
provisions of CPA and POPIA are complied with.

14.2. No provisions of this Privacy Notice (or any contract governed by this Privacy Notice):

14.2.1. does or purports to limit or exempt us or any person or entity from any liability
(including, without limitation, for any loss directly or indirectly attributable to our
gross negligence or wilful default or that of any other person acting for or controlled
by us) to the extent that the law does not allow such a limitation or exemption;

14.2.2. requires you to assume risk or liability for the kind of liability or loss, to the extent
that the law does not allow such an assumption of risk or liability; or

14.2.3. limits or excludes any warranties or obligations which are implied into this Privacy
Notice (or any contract governed by this Privacy Notice) by CPA or POPIA (to the
extent they are applicable) or which we give under CPA or POPIA (to the extent they are applicable), to the extent that the law does not allow them to be limited or excluded.

15. Governing Law
To the maximum extent possible, South African law applies to this Privacy Notice.
If any provision of this Privacy Notice is found to be illegal, void or unenforceable due to applicable law or by order of a court of a competent jurisdiction it shall be deemed deleted and the continuation in full force and effect of the remainder of the provisions will not be prejudiced.

16. Changes to our Online Privacy Notice
Any changes we may make to our Privacy Notice in the future will be posted on this page.

17. Contact
Any queries or concerns about privacy on this website should be sent by email to