1. INTRODUCTION AND SCOPE
1.1. Commitment: MESHED Learning ("we," "us," or "our") is committed to protecting
the privacy and security of the personal information of our students, corporate clients, and website
visitors.
1.2. Compliance: This Privacy Policy complies with the Protection of Personal
Information Act 4 of 2013 (POPIA) and the Electronic Communications and Transactions Act 25 of 2002
(ECTA).
1.3. Consent: By using the MESHED Learning platform
(https://sharingeducation.co.za/), you explicitly consent to the data processing practices described
in this policy. If you do not agree, you must discontinue use immediately.
2. INFORMATION OFFICER
In accordance with POPIA, we have appointed an Information Officer to oversee data protection and
regulatory compliance.
- Information Officer: Stephen Mahanaim Motimele
- Contact Email: admin@sharingeducation.co.za
- Physical Address: Vorna Valley, Midrand, Johannesburg
3. THE PERSONAL INFORMATION
WE COLLECT
We collect specific categories of personal information to deliver our educational services. This
collection happens directly from you or through your employer (in Corporate B2B cases).
3.1.
General Account Information
- Identifiers: Full Name, Email Address.
- Profile Data: Optional Bio, Profile Picture (Avatar).
- Security: Hashed passwords (we do not see your actual password).
3.2.
Academic and Competency Data
- Progress Tracking: Chapters viewed, video watch duration, login frequency
(chapter_views).
- Assessment Data: Quiz scores, specific answers to Multiple Choice/True-False
questions (student_quiz_answers).
- Reflections (Special Category): Written journal entries submitted after
modules. Note: While these are subjective, we treat them as academic submissions.
3.3.
Logistics and Financial Data (The "Hybrid" Collection)
- Delivery Information: Physical address and contact number. Note: Even if not
stored in our primary database, we collect this via email or separate forms to facilitate the
courier delivery of your certificate.
- Payment Information (PayFast): We store transaction references (e.g.,
ORD-12345). We do not store your credit card number or CVV.
- Payment Information (EFT): We store proofs of payment and bank notifications
sent by you for reconciliation.
4. HOW WE USE YOUR
INFORMATION (PURPOSE OF PROCESSING)
We process your data strictly for the following purposes:
- 4.1. Contractual Performance: To deliver the course content, grade your
assessments, and issue your certificate.
- 4.2. Logistics: To utilize third-party couriers to deliver your physical
certificate.
- 4.3. Academic Integrity: To verify your identity and ensure that the person
taking the course is the person receiving the certificate.
- 4.4. Moderation (Human Review):
- Reflections: Your written reflections are read by human Instructors for grading and
context verification. You have no expectation of privacy regarding the content of these
academic submissions vis-à-vis our staff.
- Automated Checks: To run your text answers through synonym-checking algorithms.
- 4.5. Corporate Reporting (B2B): If your account was purchased by your employer
or a corporate sponsor, we share your Progress, Attendance, and Grades with that entity as part
of our service agreement with them.
5. SHARING OF INFORMATION
(OPERATORS)
We do not sell your data. However, we share necessary data with trusted third-party service providers
("Operators") who process data on our behalf. We have agreements in place to ensure they comply with
POPIA.
- Payment Processors: PayFast (to process payments).
- Logistics Partners: Courier Guy / Aramex / PostNet (to deliver certificates).
They receive your Name, Address, and Phone Number.
- Hosting Providers: Our servers (where the database resides) are secured in data
centers that comply with international security standards.
- Instructors/Moderators: Contracted subject matter experts who grade your
open-text answers and reflections.
6. TRANSBORDER INFORMATION
FLOW
Some of our technology infrastructure (cloud hosting or backup servers) may be situated outside the
borders of South Africa. By using the Platform, you consent to the transfer of your personal
information to these foreign jurisdictions, provided that the recipient country has data protection
laws similar to POPIA.
7. DATA SECURITY
7.1. Measures: We implement technical and organizational measures to secure your
data, including encryption (SSL), access control (role-based access), and regular security audits.
7.2. User Responsibility: You are responsible for keeping your password
confidential. MESHED Learning is not liable for data breaches resulting from compromised user
credentials (e.g., weak passwords or phishing).
8. DATA RETENTION
8.1. Academic Records: We retain your Name, Grades, and Certification status
indefinitely. This is to allow for future verification of your credentials should a prospective
employer contact us (with your consent).
8.2. Financial Records: We retain transaction records for 5 years as required by
SARS and South African tax law.
8.3. Inactive Accounts: We reserve the right to anonymize or delete non-academic
data (e.g., bios, avatars) of accounts that have been inactive for more than 3 years.
9. YOUR RIGHTS AS A DATA
SUBJECT
Under POPIA, you have the right to:
- 9.1. Access: Request a copy of the personal information we hold about you.
- 9.2. Correction: Request that we update or correct your personal information
(e.g., change of address).
- 9.3. Objection: Object to the processing of your personal information for
direct marketing purposes.
- 9.4. Deletion: Request the deletion of your personal information, subject to
our legal obligation to retain academic and financial records.
10. COOKIES AND TRACKING
TECHNOLOGIES
10.1. Usage: We use cookies to maintain your login session and track your progress
through the course materials (e.g., remembering which video you last watched).
10.2. Refusal: You can block cookies via your browser settings, but this will render
the Platform unusable (you will not be able to log in or save progress).
11. AMENDMENTS
We reserve the right to amend this Privacy Policy at any time. The version date at the top of this
policy indicates the current iteration. Continued use of the Platform after changes constitutes
acceptance of the new terms.
12. CONTACT AND COMPLAINTS
If you believe we are processing your personal information unlawfully, please contact our Information
Officer at admin@sharingeducation.co.za.
If you are unsatisfied with our response, you have the right to lodge a complaint with the
Information Regulator of South Africa: