PRIVACY POLICY

1. General

This privacy notice explains how Nauki Care (Pty) Ltd. (“Nauki”, “we”, “our”, or “us”) collects, uses, shares, retains, and disposes of personal data obtained through nauki.co.za family of websites and our associated digital platform (“website” and/or “Platform”) and our branded social media pages (such as LinkedIn, Facebook, and Instagram) (“social media”). Collectively, our website, Platform, and social media pages are referred to as our “online platform.”

Customer interactions with our online platform necessitate the processing of personal data over the local websites (or apps / Platform). If you voluntarily provide personal information such as your name, email address, or other details, we will process this data. This privacy notice only governs instances of data processing on our online platform.

We may update this privacy notice occasionally. We encourage you to periodically review this privacy notice to stay informed about what data we collect, how we process it, and the circumstances under which we disclose it. If we decide to use your information differently from what was stated at the time of collection, we will notify you by email.

2. Types of Personal Data We Obtain

We will clearly inform you when information that personally identifies you (“personal information” or “personal data”) is asked for. Typically, this occurs when you log in to our online platform to complete the profile section or subscribe to newsletters or other online services.

We may collect and receive the following personal data from you:

• Personal data needed to set up your profile on the online platform (such as, but not limited to, your name, address, email, phone numbers, department, health-related data, emergency contact).
• Account details (such as, but not limited to, username and password).
• Personal data included in your traffic data (such as your browser, IP address of your computer or other device, internet service provider, referring site, visit duration, device type, and operating system).

We may also collect other types of personal data as required by applicable law, or as necessary for the purposes listed below.

3. Purposes and Legal Bases for Processing

We may process your personal data for the following purposes and legal bases:

• Providing our online platform and delivering the services you have requested: We process your personal data to perform our contract with you for using our online platform and to fulfil our obligations under the applicable Terms of Use. If we do not have a contract with you, we base the processing on our legitimate interest in operating and administering our online platform and providing you with content you access and request.

• Managing account registrations: If you register for an account with us, we process your personal data to manage your user account under the applicable Terms of Use. For this purpose, providing personal data is mandatory; failure to do so will prevent us from managing your account and performing the contract.

• Handling contact and user support requests: If you request user support, or if you contact us by other means including via a phone call, we may process your personal data to perform our contract with you and to the extent it is necessary for our legitimate interest in fulfilling your requests and communicating with you. For this purpose, the provision of personal data is optional, and in cases of failure to provide personal data, it will be impossible to contact you and give the requested support.

• Developing and improving our online platform: We may process your personal data to analyse trends and to track your usage of and interactions with our online platform to the extent it is necessary for our legitimate interest in developing and improving our online platform and providing our users with more relevant content and service offerings, or where we seek your consent.

• Reviewing compliance with the applicable Terms of Use, ensuring the security of our business, preventing or detecting fraud or abuses of our online platform: We may process your personal data by tracking the use of our online platform, verifying accounts and activity, investigating suspicious activity, and enforcing our Terms of Use to the extent it is necessary for our legitimate interest in promoting the safety and security of the online platform and in protecting our rights and the rights of others.

• Defence and enforcement of claims: We may use online data for civil and criminal legal action or defence in such proceedings. Within the scope of such procedures, your IP address may also be used for identification by the competent authorities, even if this initially has no personal reference to us.

• Complying with legal obligations: We may process your personal data when cooperating with public and government authorities, courts, or regulators as required by law. This includes processing or disclosing personal data to protect our rights, prevent misuse of our online platform, protect personal property or safety, pursue remedies available to us to limit our damages, complying with judicial proceedings, court order or legal processes, response to lawful requests, or for auditing purposes.

4. Data Sharing

We may share personal data we collect and receive on a need-to-know basis with the following parties:

1. Other affiliates of Nauki or its agents.
2. Third-party service providers that perform services for us. For example, we procure IT services such as hosting, support and maintenance, and testing from service providers. Our service providers are each subject to contractual and/or statutory confidentiality and data protection obligations.
3. Competent public authorities or other third parties (if required by law or reasonably necessary to protect the rights, property, and safety of ourselves or others).

We may also transfer your personal data if we sell or transfer all, or a portion, of our business or assets, on a need-to-know basis. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use personal data you have provided to us in a manner that is consistent with applicable law and this privacy notice.

Our online platform may contain links to third-party websites. Nauki is not responsible for the actions of these third parties, including their privacy practices and any content posted on their websites. We encourage you to review their privacy policies to learn more about what, why and how they collect and use personal information. Nauki adheres to industry recognized standards to secure any personal information in our possession, and to secure it from unauthorized access and tampering.

In very rare instances Nauki may disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Nauki or the site; (b) protect and defend the rights or property of Nauki and its family of websites and properties; and (c) act in urgent circumstances to protect the personal safety of users of Nauki, its websites, or the public.

5. Use of Cookies and Similar Technologies

We collect personal data using cookies and similar technologies when you visit our online platform. The use of cookies is governed by a separate Cookie Policy.

6. Consent

By providing your personal information, you consent to its use for the above purposes, and that Nauki is an authorized holder of such information. If you choose not to register or provide personal information, you can still use our website and/or Platform but will not be able to receive additional services or access certain areas that require registration.

7. Security of Information

Nauki is strongly committed to protecting your information and ensuring that your choices are honoured. We handle our online platform data securely and take appropriate technical and organisational security measures to protect the confidentiality, integrity and availability of your personal data, to protect it against unauthorised or unlawful processing and to protect it against the risk of loss, misuse, accidental alteration, unauthorised disclosure or access. However, security risks cannot generally be ruled out completely; certain residual risks are unavoidable.

When transmitting personal data via our online platform, we use suitable encryption mechanisms. However, we can only secure areas under our control. If you contact us by email, you do so at your own risk, and agree that we may respond to you at the sender’s address via the same channel. If you send us e-mails via the internet in unencrypted form, third parties may be able to access, view and manipulate them, and data can be lost or intercepted and/or manipulated by third parties.

We take appropriate measures to reduce risks on our online platform, but your end device is outside our security control. You are therefore required to learn about the necessary safety precautions and to take appropriate measures in this regard.

Use of Microsoft E5 License for Advanced Security: To bolster the protection of your personal data, we employ a Microsoft 365 E5 License for our core e-mail, collaboration, and cloud services. In line with Microsoft’s security and compliance guidance, this E5 license delivers an integrated suite of advanced threat protection, data governance, and compliance tools, helping us detect, investigate, and respond to emerging cyber threats in real time. By utilising features such as endpoint detection and response, data loss prevention, and advanced auditing, Nauki aims to minimise unauthorised access and safeguard your personal information throughout its life cycle.

We take pride in implementing a variety of defences that align with best practices recommended by Microsoft 365 Security and Compliance Licensing. While no security strategy can be 100% guaranteed against every risk, our layered E5 security approach significantly enhances our ability to protect your data. We remain committed to periodically reviewing and refining our cybersecurity measures, ensuring that we maintain robust security aligned with relevant regulations and industry standards.

8. Your rights

You have various rights in connection with our data processing subject to applicable law:

• The right to request information from us as to whether we are processing your data, and which data we are processing,
• The right of data rectification (if your data is inaccurate),
• The right to object to our processing for specific purposes and to request the restriction or deletion of data unless we are obliged or entitled to continue processing it,
• The right to withdraw your consent at any time, provided our processing is based on your consent. The right to withdraw your consent is not retroactive, that is, any processing operations which took place before you withdrew your consent will not become illegal on withdrawal,
• The right to data portability, and
• The right to lodge a complaint with the competent supervisory authority.

To exercise these rights, please contact us using our contact details as set out below. We may request identification evidence. To protect the rights and freedoms of other data subjects and safeguard sensitive interests, we may reject your request in whole or part (e.g., blocking out third-party content or trade secrets).

We will respond to your request within the applicable statutory term.

If you are located in South Africa, the Promotion of Access to Information Act 2 of 2000 (PAIA) applies. PAIA grants South African residents the right to access information held by either a Private or Public body, subject to certain limitations.

This right is extended in Protection of Personal Information Act, 2013 (POPIA) as it grants the right to request access to information or records, in accordance with the provisions of PAIA from any Responsible Party.

To exercise the right of access, the requesters must use the following forms provided by the Information Regulator of South Africa:

1. PAIA: PAIA Forms – Information Regulator (inforegulator.org.za)
2. POPIA: POPIA Forms – Information Regulator (inforegulator.org.za)

9. Enforcement of policy

If you believe Nauki has not adhered to these principles, please notify us, and we will promptly address the issue.

10. Contact Details

For comments or inquiries about this privacy policy, or to exercise your rights, please contact us by email at privacy@nauki.co.za.

Last modified April 2025.