Privacy Policy

April 4, 2022

At WaFunda, we value and respect your privacy and strive to protect all Personal Information in our possession. WaFunda will only collect and use Personal Information in accordance with this Privacy Policy. In the provision of Personal Information to us, you agree to this Privacy Policy and authorise us to process such information in accordance with this policy.

Reference in this policy to “we”, “us”, “our”, or any similar terms is to WaFunda.

Jurisdiction

WaFunda is a business registered and domiciled in the Republic of South Africa, processing data in the Republic of South Africa and, as such, complies with the South African Protection of Personal Information Act No. 4 of 2013 (POPIA)

A Data Subject may reside within the Republic of South Africa, or in countries outside of this jurisdiction where the laws of those countries differ to the laws applicable in the Republic of South Africa. The Personal Information we collect may, thus, be transferred to, stored and processed outside of the jurisdiction in which you reside. By accepting this Privacy policy, and agreeing to WaFunda processing your Personal Information, you agree to the transfer, storing or processing of it outside of your jurisdiction.

Data subjects with citizenships from jurisdictions other than of South Africa and who are also resident outside of South Africa, please note that WaFunda complies with all South African data protection laws when processing Personal Information pursuant to the company’s main operations occurring in South Africa. Should foreign law be applicable in any regard to your use of our services and/or the platforms that support these services in any way, including how we may process your Personal Information, please contact the WaFunda Information Officer at the email address at the end of this Privacy Policy who will gladly engage you on its application and your rights.

In accordance with POPIA, we have appointed an Information Officer at WaFunda who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the Information Officer using the details set out later in this policy.

You have the right to make a complaint at any time to the South African regulator’s office (Information Regulator’s Office of South Africa). We would, however, appreciate the chance to deal with your concerns before you approach any such regulator, so please contact us in the first instance.

WaFunda’s Services

WaFunda’s Data Subjects are typically:

 

  • Persons or entities seeking information relating to the design, development, hosting, support and maintenance of software solutions and platforms (our customers)
  • Persons or entities, such as learning institutions or youth programmes, seeking information about the services we can provide and administer on their behalf to their learners, students or youth beneficiaries
  • Persons or entities for whom we provide our services and platforms to in performance of a contract agreed with them, including students and learners who we have engaged with directly and who we have signed a contract with individually
  • Users of our platforms, such as learning institutions or youth programme employees, and learners, students or youth beneficiaries
  • Fund Managers that administer international funds and investors, or local funders that have established funds or bursaries, to support the learning and development of youth in South Africa
  • Learners, students and youth beneficiaries who have been recommended to us through our customers, the learning institutions and youth programmes we work with, and who have consented to us collecting their Personal Information in order for us to provide certain services, assess their eligibility for funding or for loans, and to ensure approved learners, students and youth beneficiaries continue to meet the criteria of the fund and/or loan
  • Family members (“student champions”) of learners, students or youth beneficiaries who have consented to us collecting their Personal Information in support of that individual in order to further qualify their eligibility for funding or a loan
  • Learning Institutions who wish for their institution or students to be considered for eligibility of loans or funding

 

We act as the Responsible Party, as defined in POPIA, for the processing of our Data Subject’s Personal Information, in order to establish a business relationship, enter into contractual agreements, and provide our services and platforms to them. We are responsible for these Data Subject’s Personal Information in instances where we decide the processing operations concerning their Personal Information.

As an organisation that provides services to, and develops and administers platforms to support these services, on behalf of some of our Data Subjects (such as the learning institutions and fund managers we work with in accordance with an agreement signed with them) we may collect, process, store, share and create Personal Information of their employees, learners, students and youth beneficiaries. In these instances, we act as the Operator, as defined in POPIA, of the Personal Information shared with us and collected, processed, stored, shared and created by us in the provision of these services. The decisions regarding the processing operations, in conjunction with the services and platforms made available to their employees, learners, students and youth beneficiaries, are made by our Data Subjects who remain the Responsible Party of the Personal Information we process on their behalf. In this instance the Responsible Party’s privacy terms will apply, but we will draw your attention to them, when applicable.

This Privacy policy explains:

  • How we collect Personal Information
  • What Personal Information we collect
  • Use of Personal Information
  • Sharing of Personal Information
  • Social Media
  • Electronic Communications
  • Personal Information Accuracy and Incomplete Personal Information
  • Security of Personal Information
  • Transborder Flow of Personal Information
  • Retention of Personal Information
  • Children
  • Cookies
  • Website Links
  • Data Subject Rights
  • Data Breaches
  • Revisions to this Privacy Policy
  • Privacy Queries
  • Information Officer

How We Collect Personal Information

When we establish a business relationship with you, provide our services or platforms to you, or communicate with you, we may collect your Personal Information. We do this in various ways, including:

 

  • When you provide it to us such as when submitting an enquiry through the contact forms on our website.
  • When you communicate with us by email, chat, telephone, whatsapp, social media communication tool (such as LinkedIn), or any other means of communication.
  • When we engage in a contract with you in order to provide specific services to you and to administer those services for you.
  • When we request it from you in order to fulfil our legitimate business obligations, perform business administration, or to invoice and collect payment for agreed upon services.
  • When we provide support and customer services to you in performance of a contract.
  • When we request it from you, as a student/learner/youth beneficiary or your champion, in order to establish your eligibility for a loan or funding.
  • When we administer and manage approved loans or funding to students/learners/youth beneficiaries in or to ensure these individuals continue to meet the agreements and criteria for the loans or funding.
  • When we fulfil our agreed upon services to our Data Subjects and engage with you on their behalf in performance of a contract, or where they have obtained your consent for us to engage with you.
  • When we engage with you in order to onboard you onto one of the platforms that we administer in order to support the services we have a contractual agreement to provide to you.
  • When we enter into agreements with fund managers, funders and investors and act on their behalf in order to identify learning institutions, students, learners and youth beneficiaries eligible for loans for funding, and continue to administer and manage approved for loans and funding on their behalf to individuals and entities in order to ensure they meet the agreements and criteria of the loans or funding.
  • When we assess and qualify the Personal Information of learning institutions, students, learners and youth beneficiaries provided to us in order to establish their eligibility for funding.

Through our website and platforms

As you interact with our website and platforms, we may automatically collect technical data about your equipment, browser, browsing actions and patterns. We collect this Personal Information by using cookies, server logs, Google Analytics and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your technical equipment data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Privacy Policy.

What Personal Information We Collect

In order to engage with you, fulfill our contractual obligations, and provide our services and platforms to you, we may collect the following Personal Information from you.

Customers

  • Company Name, Registration Number and VAT Number
  • First and last names of contact persons
  • Email addresses of contact persons
  • Telephone numbers (mobile or landline number) of contact persons
  • Physical and postal addresses of the business
  • Technical and website usage information should you utilise our website

Learning Institutions

  • Learning Institution / Company Name, Registration Number and VAT Number
  • First and last names of contact persons
  • Email addresses of contact persons
  • Telephone numbers (mobile or landline number) of contact persons
  • Physical and postal addresses of the institution
  • Technical and website usage information should you utilise our website
  • End user names, contact information, and technical and platform usage information of employees of the learning institution who utilise our platforms

Students, learners and youth beneficiaries

  • First name and last name
  • Student Number
  • Contact Information (including phone number and email address)
  • Physical Address
  • Home address growing up
  • ID Number (including certified copies of ID books for Identity Verification purposes)
  • Date of Birth
  • Gender
  • Nationality
  • Race
  • Home Language
  • Education level and last place of education (such as High School or College and its location)
  • Current education and fees payable
  • Disability and type (if applicable)
  • Source of income
  • Employment Status
  • Details of Social Grants (if applicable)
  • Technical and website usage information should you utilise our website or platforms
  • End user names, contact information, and technical and platform usage information of the students, learners and youth beneficiaries who utilise our platforms

Student Champions

  • First name and last name
  • Name of the student/learner/youth beneficiary they are championing, the relationship to this individual and length of time they have known them
  • Contact Information (including phone number and email address)
  • Physical Address
  • ID Number (including certified copies of ID books for Identity Verification purposes)
  • Date of Birth
  • Gender
  • Highest level of education
  • Employment Status and Source of Wealth
  • Number of people in the household

Fund Managers and Funders or Investors

  • Company Name, Registration Number and VAT Number
  • First name and last names of contact persons at the company
  • Funder or Investor Name (if an individual entity)
  • Fund Name
  • Email addresses of contact persons
  • Telephone numbers (mobile or landline number) of contact persons
  • Physical and postal addresses of the company
  • Technical and website usage information should you utilise our website

Use of Personal Information

As a Responsible Party

As a Responsible Party, we may collect, process, store, share and create Personal Information in order:

 

  • To communicate with you regarding the products or services you have requested information on
  • To engage with you and provide and administer services to you as per a contractual arrangement
  • To onboard you to the platforms we provide and administer in support of the services we are in agreement to provide to you
  • To advise you about new and updated content available on the platforms we administer and provide to you
  • To advise you about any issues or incidents relating to the security or availability of a platform we develop or administer
  • To advise you of any incentives or competitions offered with regards to our services and platform 
  • To better manage our business and our relationship with you 
  • To provide customer support to you for the services you have engaged us to provide to you and administer on your behalf
  • To provide technical support to you for the platforms we develop and administer
  • To conduct administrative and business functions
  • To invoice you and verify that payments for our services have been processed
  • To update our records and keep your Personal Information up to date
  • To improve the services and platform we provide and administer, and to develop and offer new products, platforms and services
  • To notify you about benefits and changes to the services we offer or the platforms we develop or administer
  • To respond to your enquiries or customer service requests
  • To resolve any disputes or respond to any complaints
  • To advise you of any security or privacy issues or incidents involving your Personal Information
  • To prevent fraudulent or unauthorised use of our products, platforms and services
  • To enable you to effectively use our website and platforms
  • To compile website and platform usage statistics
  • To assess the performance of our website and platforms and to improve their operation

As an Operator

As a Responsible Party

As an Operator providing services, and developing and administering platforms utilised to support these services, in accordance with our contractual obligations to our Data Subjects (including our customers, and the learning institutions and fund managers we work with), we may collect, process, store, share and create Personal Information of their behalf in order to advise their employees, students, learners and youth beneficiaries:

  • Of the services and the platforms we are providing, and administering, on behalf of our Data Subjects
  • How to register on and utilise the relevant platforms
  • About new and updated content available on the platforms
  • About how to use and operate the platforms we develop or administer efficiently and effectively
  • Of any incentives or competitions offered with regards to our services and platforms as agreed to in accordance with our contractual obligations to our Data Subjects
  • About any issues or incidents relating to the security or availability of a platform
  • About any any security or privacy issues or incidents involving their Personal Information

We may also collect, process, store, share and create Personal Information in order to directly:

  • Respond to any platform technical queries
  • Respond to any other support queries escalated to us with regards to the services we provide and administer
  • Update and correct our records and ensure Personal Information is accurate and up to date

We may also collect, process, store, share and create Personal Information of our Data Subject’s employees, students, learners or youth beneficiaries in order to provide our Data Subjects with feedback on:

  • The engagement of their Data Subjects with the service we offer and platforms we administer in accordance with our agreement with them
  • Reports and Analytics on the services and platforms we provide (including engagement trends)
  • The progression through, or use of, the content on the platform by their Data Subjects in order to ensure their Data Subjects are meeting the learning targets and objectives

General

Where necessary to protect our legal rights and interests, or the interests of others, we may also use Personal Information in relation to legal claims, compliance with other local regulations or regulations in other countries or jurisdictions, audits, risk management, law enforcement processes, and other regulatory functions.

Sharing Of Personal Information

We may share Personal Information with:

  • any person that works for WaFunda, either full time or part time
  • any business partner, third party service provider, or third party platform provider that is under contract to WaFunda to assist with the provision of our services
  • third party service providers that assist us with fulfilling our legal, financial and compliance obligations such as credit bureaus and identity verification providers
  • companies, organisations and entities that provide services to us, including in relation to technical infrastructure, marketing and analytics, platform hosting, and platform and website development
  • third party communication service providers in order to deliver emails and other communications to you regarding your profile, our platforms, our services, and other business and administrative functions
  • suppliers, affiliates, partners or agents in order to provide you with our platforms and services
  • our professional advisers, consultants and other similar services
  • legal and regulatory authorities that we are required to submit information to for financial, tax, B-BBEE or other statutory purposes as required by an applicable law or regulation
  • legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation
  • any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights
  • any relevant party for the purposes of the prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including, but not limited to, safeguarding against and the prevention of threats to public security

We will otherwise treat all Personal Information as private and confidential and will not share it with other parties except: 

  • Where permission has been granted
  • Where we believe that it is reasonably necessary to comply with any law or regulation, legal process or governmental request, or to protect the rights, property or safety of us, our Data Subjects, our end users and any other individuals or entities who we have engaged with any contracts with

When we engage with business partners, third party service providers or third party platform providers that process Personal Information on our behalf in order for us to provide our services to our Data Subjects, these entities will:

  • be subject to binding contractual obligations to only process such Personal Information in accordance with our prior written instructions or contractual agreement with them
  • use appropriate measures to protect the confidentiality, integrity and availability of such Personal Information entrusted to them
  • comply with our privacy principles and practices when we outsource any services to them
  • advise us as soon as possible after the detection of any incidents relating to the Personal Information of our Data Subjects, including unauthorised access to, exfiltration, alteration, destruction or loss of any of the Personal Information, so that we may act swiftly, appropriately and in accordance with our Data Breaches statement below

Third Party platform providers may also have their own Privacy Policies available on certain platforms for which we are solely administrators. Individuals who utilise these platforms may refer to these Privacy Policies for further details on the platform provder’s privacy practices, and privacy and security commitments.

Social Media

WaFunda also operates and communicates through our Social Media channels and pages to inform, help and engage with interested parties, and to promote our organisation and services. These channels and pages are public and any of the users of the social media sites on which we operate may like, follow or subscribe to them. 

When subscribing to, liking or following any of WaFunda’s channels or pages on a social media platform, please note the following:

  • the general public can access and read any Personal Information posted or shared by your or anyone else on these sites
  • we are not responsible for any Personal Information posted or shared by you or other users on these sites 
  • we are not responsible for any other information posted on these sites other than the information posted by our designated administrators or moderators on our official WaFunda channels and pages
  • we do not endorse the social media sites themselves, nor any information posted on them by third parties or other users

When you engage with us through social media, your Personal Information may be processed by the site owner. This processing occurs outside of our control and may take place in a country outside South Africa that may have different privacy regulations.

We regularly update and monitor our social media channels and pages, and welcome feedback and queries sent to us through these sites. We try to join and encourage conversations whenever possible but cannot guarantee that we will read or reply to all messages sent to any of our official social media channels or pages. Relevant feedback on these social media sites, including the details of the individuals who posted comments, may be shared within the organisation for consideration, but we cannot guarantee that any feedback or suggestions will be acted upon by us.

Electronic Communications

In order for us to provide our Data Subjects (and their Data Subjects where applicable) and any platform end users with information about the services we offer and the about platforms we develop and administer to support these services, you accept and agree that:

  • Any communication, agreement, or notice relating to the services we offer as well as the administration, the content, security, and use of the platforms that support our services shall be provided electronically via the email address or phone number provided to WaFunda
  • You will have access to the necessary hardware and software to receive, access, and retain electronic communications sent to you with regards to our services
  • Communication sent to the email address or phone number provided will be deemed to have been received by you

WaFunda utilises Third Party Communication Providers to deliver all electronic communications when providing the services and administering the platforms agreed upon, and these providers operate outside of the Republic of South Africa. The Personal Information provided to WaFunda in order to engage our services, utilise the platforms and receive all electronic communications in relation to our services and our platforms is, thus, shared with these Third Party Communication Providers, and processed and stored within their Data Centres in their relevant countries. Should you not wish to have your Personal Information processed by these Third Parties in countries outside of the Republic of South Africa, WaFunda may not be able to provide our services to you, nor may the platforms we develop and administer be available to you.

Data Subjects may withdraw their consent to receiving electronic communications from us at any time by contacting us at data@wafunda.com but, should consent be withdrawn, you may not receive further communications regarding any current or future services from us, nor related to any platforms that we develop or administer in support of our services.

Where electronic communications form part of the services we offer to our Data Subjects and we are required to send electronic communications in order to fulfil contractual obligations, we may not be able to action a request directly from a Data Subject’s employees, student, learner or youth beneficiary, or from a student champion, nor may they be able to withdraw consent to receive electronic communications. Any requests received in this regard will be dealt with on a case by case basis and will be communicated to the Data Subject or the relevant Responsible Party of the requester’s Personal Information.

Personal Information Accuracy and Incomplete Personal Information

Whilst we take reasonable measures to maintain the quality and accuracy of all our Personal Information in our possession, all Personal Information provided to WaFunda via our website, or any other methods of collection as outlined above, should be accurate, complete, and up to date.  Should this Personal Information change, we encourage you to notify us of the change and provide us with up to date information.

Where indicated, it is necessary for us to be provided with accurate Personal Information to enable us to provide our services and administer the platforms that support these services. Should anyone decline to provide such information, or should such Personal Information be incomplete, we may not be able to provide our services or platforms to these individuals or entities.

Security Of Personal Information

WaFunda places great importance on ensuring the security of all Personal Information in our possession. WaFunda’s Privacy Policy is to meet all local requirements for security measures for the integrity and confidentiality of Personal Information as specified in Section 19 of POPIA.

We promote the protection of Personal Information by maintaining and continuously improving our privacy and security culture. We ensure all employees, contractors, business partners and service providers processing Personal Information are advised on how to handle Personal Information securely, with the utmost respect, and in compliance with POPIA. We provide regular privacy and security training and awareness sessions to all our employees and contractors and, where relevant, to business partners and third party service providers as well. All employees, contractors, business partners and third party service providers are made aware of their responsibilities in terms of laws and rules that apply to the processing and to the protection of the Personal Information of our Data Subjects and our customer’s Data Subjects, and with regards to our expectations of them when processing Personal Information on our behalf.

We make use of appropriate physical, administrative and technical security measures to protect all Personal Information that we collect and in our possession, and when we share Personal Information with other entities as outlined above. We regularly review our organisational security measures and ensure they are effective, up to date and follow best practices.

Transborder Flow Of Personal Information

We may transfer Personal Information to recipients, business partners, entities, third party service providers, third party platform providers or affiliates outside of the Republic of South Africa, as outlined in this Privacy Policy, in order to provide our services.

Our Privacy Policy is to meet local country requirements for the flow of information and comply with the Data Protection, Privacy and other related laws and codes of conduct that apply in the countries where we transfer Personal Information to. 

Personal Information may be transferred to a third party outside of the Republic of South Africa provided that the third party is subject to a law, binding corporate rules or a binding agreement that seeks to protect the Personal Information in line with this Privacy Policy and the transfer is necessary in order to provide the services that are agreed upon with our Data Subjects.

We will take reasonable actions to make sure that appropriate measures are in place before we transfer Personal Information to other countries if the transfer is necessary to provide our services and administer any platforms. 

Individuals and entities may withdraw their consent to us processing or transferring their Personal Information across borders, however, this may mean that we are no longer able to offer our services or platforms to them.

Retention Of Personal Information

WaFunda will retain Personal Information in compliance with this Privacy Policy, and in accordance with our Terms and Conditions or any contractual arrangements in relation to the services we provide and administer, as agreed to with our Data Subjects or other individuals or entities. 

We will retain Personal Information:

  • for as long as is necessary to fulfil the purposes for which it was collected
  • for the duration of an individual or entity’s relationship with us
  • for such a period after conclusion of our agreement to provide our services to an individual or entity as may be necessary for our legitimate business purposes and for our legal, financial, compliance, and other statutory obligations
  • for the purposes of preventing fraud, resolving disputes and enforcing agreements
  • as defined by any contractual agreement that we have in place with our Data Subjects when providing the services, and the platforms that support those services, to our Data Subjects

Children

Where the services we provide to our Data Subjects, such as a learning institutions or youth programmes, has been contractually agreed upon and the students, learners and youth beneficiaries of these entities includes Children under the age of 18 (eighteen) years, the Responsible Party warrants to and in favour of WaFunda that they have procured the requisite permission and/or authorization to process (and allow WaFunda to process) any Personal Information in circumstances where such Personal Information relates to a minor child under the age of 18 (eighteen) years from the parents and/or guardians of such minor child. The Responsible Party shall further procure that the parents and/or guardians of minor children shall supervise any child’s use of the third party platform.

For all other learners, students, youth beneficiaries who have independently elected to make use of any of the services WaFunda provides, and who have contractually agreed to avail of these services and utilise the platforms that we provide in support of these services, we generally do not engage with or knowingly collect Personal Information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from children without verification of parental consent, we take steps to remove that information from our systems and servers.

Cookies

The WaFunda website utilises cookies. Cookies are small data files that are placed on your computer (or other devices) when you visit a website. Cookies (and other similar technologies) help us give you the best experience of using our website. Cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A Cookie in no way gives us access to your computer, device or any information about you, other than the data you choose to share with us.


For further information, please visit the  WaFunda Cookie Policy webpage here.

Website Links

When you visit our website or view the information on our website, you may be able to access or click on links that direct you to other websites that are beyond our control. These websites may send their own cookies to you, collect Personal Information, technical or website usage information from you, or request Personal Information from you in performance of another service. We do not control the Privacy Policies of these Third Parties and we cannot be held liable for the use of any Personal Information provided by you to them for any reason whatsoever.

Data Subject Rights

The Personal Information WaFunda collects, and the ways in which we use it, are necessary for us to provide our services, and the platforms we develop and administer, to our Data Subjects.

Where we are the Responsible Party

Where we are the Responsible Party of Personal Information, you may request access to any and all the Personal Information that WaFunda has in their possession about you upon provision of sufficient proof and verification of your identity.

Our Data Subjects have the right to:

  1. Request their Personal Information – This allows you to receive a copy of all your Personal Information held by us and to check that we are lawfully processing it.
  2. Correct their Personal Information – This allows you to have any of your incomplete or inaccurate information corrected, although we may need to verify the accuracy of the new information that is provided.
  3. Delete their Personal Information – This allows you to request that we delete or remove your Personal Information where there is no justifiable reason for us to continue processing the information. In addition, you have the right to request us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your Personal Information unlawfully or where we are required to erase your Personal Information in order to comply with a legal requirement. Please note that for specific legal reasons, which will be advised, we may not always be able to comply with all requests for erasure.
  4. Object to the processing of their Personal Information – You may object to our processing of your information where we are relying on a legitimate interest (or those of a third party) and there is something about their particular situation which makes you want to object to processing on this ground as they feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may be able to demonstrate that we have compelling legitimate grounds to process your Personal Information which may override your rights and freedoms.
  5. Restrict the processing of your Personal Information – This allows you to request that we suspend the processing of your Personal Information in the following scenarios:
  • if you want us to establish the accuracy of the Personal Information 
  • where our use of the Personal Information  is unlawful but you do not want us to erase it
  • where you need us to hold the Personal Information even if we no longer require it as you need it to establish, exercise or defend legal claims
  • you have objected to our use of your Personal Information  but we need to establish whether we have overriding legitimate grounds to use it
  1. Withdraw consent to the processing of your Personal Information – You may withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before the withdrawal of your consent. If you withdraw your consent, we may not be able to provide certain services or platforms to you. We will advise you if this is the case at the time you withdraw your consent.

The above rights are limited in some situations, such as where we are legally required to process or store your Personal Information, and may limit your ability to use our platforms and services. We will advise you about this at the time of the submission of a Data Subject Access Request and taking into consideration the type of request.

In order to enact your Data Subject Rights, you will normally not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, WaFunda may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with a request in these circumstances.

We may need to request specific information from you to assist us in confirming your identity and ensure your right to access your Personal Information (or to exercise any of the other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to request further information in order to speed up our response.

We will endeavour to respond to all legitimate requests within 30 days. Occasionally it may take us longer than if the request is particularly complex or if a number of requests, in which case, we will ensure that we notify you and keep you updated.

If you would like to exercise any of your Data Subject Rights, please contact data@wafunda.com with your request. 

Where we are the Operator

Where we act as an Operator and process the Personal Information of our Data Subject’s employees, students, learners and youth beneficiaries, as agreed to contractually regarding the service we are providing to our Data Subjects and within the platforms required to support these services, Data Subject Rights requests must be made directly to the Responsible Party of this Personal Information for further evaluation and consideration in accordance with the Responsible Party’s privacy terms. The Responsible Party will advise WaFunda, as the Operator and service provider, of any Data Subjects Requests where we process Personal Information on their behalf and we will respond accordingly to provide them with the Personal Information in our possession, and take any actions necessary with regards to this Personal Information upon their instruction only.

Data Breaches

As a Responsible Party, we will notify our Data Subjects and the relevant supervisory authority as soon as we become aware of any data breach that is likely to result in a risk to the privacy rights and freedoms of any of our Data Subject’s privacy rights and freedoms.

As an Operator acting on behalf of our Data Subjects when collecting, processing, storing, sharing and creating Personal Information, we will notify the Responsible Party and the relevant supervisory authority as soon as we become aware of any data breach that is likely to result in a risk to any of their Data Subject’s privacy rights and freedoms.

WaFunda has contractual agreements in place with our technical, hosting and third party platform providers in order to ensure that we are advised as soon as possible of any incidents or data breaches that may impact any end users who have registered on the platforms we develop and administer. In the event of any platform related incidents that may result in a risk to any end users’ privacy rights and freedoms, WaFunda will advise the relevant supervisory authority along with the end users and the Responsible Party where applicable.

General

If you believe your Personal Information has been accessed or acquired by any unauthorised person, please notify us immediately at the below email address.

Revisions To This Privacy Policy

We may amend this Privacy policy from time to time. You should visit the website regularly to check when this Privacy policy was last updated and to review the current policy.

Privacy Queries

Should you have any queries with regards to this Privacy Policy, our privacy practices or how we handle your Personal Information, please contact us via email at the below email address.

Information Officer

WaFunda’s Information Officer is:

Name: Sophia Campello Beckwith

Email: data@wafunda.com

Phone Number: +2721 007 5786