Privacy Policy — Grace & Guardian eLearning Portal
Effective Date: 9 August 2025
This Privacy Policy explains how
Grace and Guardian (Pty) Ltd ("Grace & Guardian", "we",
"us", "our") collects, uses, discloses, and protects
personal information when you use our eLearning Portal ("Portal"),
websites, and related services.
Grace and Guardian (Pty) Ltd
- Reg. No:
2014/105020/07
- BEE Status:
100% Black-owned (BEE Level 1)
- Address:
7 Bamboes Street Chantelle, Akasia 0182, Pretoria
- Phone:
079 374 8645
- Email:
training@gracenguardian.co.za
1)
Who This Policy Covers
- Learners, prospective learners, employer/sponsor
representatives, trainers/assessors/moderators, website visitors, and any
user of our Portal and services.
2)
What We Collect
- Identity data:
Name, ID/passport number, date of birth, gender, learner/employer
identifiers.
- Contact data:
Email, phone numbers, physical/postal addresses.
- Account data:
Usernames, passwords (hashed), role/permissions, enrollment history.
- Training data:
Course registrations, attendance, assessments, results, certificates,
portfolios of evidence, uploaded assignments, feedback.
- Employment/sponsor data: Employer name, role, supervisor contact,
sponsorship/PO details if applicable.
- Financial/billing data: Payment records, invoices, transaction references; we
do not store full card details if using a payment gateway.
- Technical data:
Device, browser type/version, IP address, approximate location, Portal
usage analytics, cookies and similar technologies.
- Compliance data:
Copies of IDs, proof of address, professional/SETAs records where
required, declarations, disciplinary records related to academic
integrity.
- Communications:
Emails, calls, support tickets, survey responses, consent records.
3)
How We Collect Data
- Directly from you during registration, enrollment,
communications, assessments, and submissions.
- From your employer/sponsor when they enroll or manage
learners.
- Automatically via cookies, logs, and analytics when you
use the Portal.
- From third-party verifications, SETAs, or regulators
where required for accreditation or certification.
4)
Why We Process Your Data (Lawful Purposes)
- Contractual:
To register accounts, deliver courses, manage assessments, issue
certificates, and provide learner support.
- Legal/Regulatory:
To comply with PSIRA/SASSETA, LGSETA, ETDP SETA, Services SETA, SAATCA/ISO
and other statutory/recordkeeping requirements (e.g., R638 for Food Safety
training).
- Legitimate interests:
To maintain platform security, improve courses and services, conduct
analytics, prevent fraud/abuse, and manage business operations.
- Consent:
For optional communications, certain analytics/marketing cookies,
testimonials, or where consent is required by law.
5)
How We Use Your Data
- Provide and personalize access to the Portal and
courses.
- Verify identity; manage attendance, assessments,
moderation, and certification.
- Maintain accreditation and quality assurance evidence
(e.g., PoEs, assessor/moderator records).
- Communicate about enrollments, schedules, results,
certificates, updates, and service notices.
- Billing, invoicing, and payment reconciliation.
- Monitor performance, usage, and security; troubleshoot
and improve services.
- Meet legal, regulatory, and audit requirements; respond
to lawful requests.
6)
Cookies and Tracking
- We use:
- Strictly necessary cookies for login/session security
- Functional cookies
for preferences
- Analytics cookies
to understand usage and improve content
- Third-party cookies
where we embed tools (e.g., videos, payment, analytics)
- See our Cookie Policy for details and consent choices.
You can manage preferences via the cookie banner and your browser
settings.
7)
Sharing and Disclosures
- Accreditation/regulatory bodies (e.g., PSIRA, SASSETA, LGSETA, ETDP SETA, Services
SETA, SAATCA) for verification, reporting, moderation, or certification.
- Employers/sponsors
for enrollment management, attendance, progress, and billing, where they
fund or manage the training.
- Service providers
for Portal hosting, communications, analytics, proctoring, payment
processing, and IT/security under confidentiality and data protection
obligations.
- Assessors, moderators, verifiers, and trainers for course delivery and quality assurance.
- Professional advisors and auditors under duty of confidentiality.
- Authorities
if required by law, court order, or to protect rights, safety, and
security.
- In a business transfer or reorganization, subject to appropriate safeguards.
- We do not sell personal information.
8)
International Transfers
- Our Portal and service providers may process data in or
outside South Africa. Where data is transferred internationally, we
implement appropriate safeguards consistent with applicable data
protection laws.
9)
Data Retention
- We retain personal information for as long as necessary
to deliver services, meet legal/regulatory/accreditation requirements,
resolve disputes, and enforce agreements.
- Typical retention periods:
- Training/assessment/certification records per
SETA/regulatory requirements
- Billing/financial per tax and accounting laws
- Support/communications for operational and audit
purposes
- When no longer required, data is securely deleted or
anonymized.
10)
Data Security
- We implement administrative, technical, and physical
safeguards appropriate to the sensitivity of the data, including access
controls, encryption in transit, secure hosting, backups, and staff
training.
- No system can be 100% secure; we continuously improve
controls and monitor for incidents. We will notify you and regulators of
significant breaches as required by law.
11)
Your Rights
- Access your personal information and request copies;
request correction of inaccurate or incomplete information.
- Request deletion, restriction, or objection to certain
processing; withdraw consent where applicable without affecting prior lawful
processing.
- Request portability of data you provided.
- Lodge a complaint with the Information Regulator (South
Africa): justice.gov.za/inforeg.
- To exercise rights, contact training@gracenguardian.co.za; we may need
to verify your identity.
12)
Children and Vulnerable Persons
- Our courses generally target adults. For minors (under
18) or vulnerable persons, we process data with appropriate consents and
safeguards from parents/guardians or employers, in line with legal
requirements.
13)
Communications Preferences
- Service/transactional messages are necessary for course
participation.
- You can opt in/out of optional marketing and surveys at
any time via links provided or by contacting us.
14)
Third-Party Websites and Services
- The Portal may link to third-party sites or include
embedded tools. Their privacy practices are governed by their policies; we
are not responsible for their content or handling of personal information.
15)
Changes to This Policy
- We may update this Privacy Policy periodically. The
latest version will be posted with a new Effective Date. Material changes
may be communicated through the Portal or email.
16)
Contact Us
Grace and Guardian (Pty) Ltd
Email: training@gracenguardian.co.za
Phone: 079 374 8645
Address: 7 Bamboes Street Chantelle, Akasia 0182, Pretoria
