Last updated 24 June 2019

GIBS Online (powered, created and operated by MasterStart Online (Pty) Ltd in partnership with The Gordon Institute of Business Science and the University of Pretoria) (hereafter referred to as "GIBS Online", "our" or "us") is committed to protecting and respecting your privacy. This Privacy Policy explains how information about you is collected, used and disclosed by GIBS Online when you use our website and other online products and services (collectively, the “Services”) or when you otherwise interact with us.

By accepting our Privacy Policy, you agree to let GIBS Online collect, use and disclose information about you in accordance with the purposes listed below. This Privacy Policy, which must be read together with our Website terms and conditions ("Terms"), sets out the basis on which any personal information we collect from you, or that you provide to us, will be collected, used, stored and processed by us ("Process"). Unless defined elsewhere, terms in this Privacy Policy shall bear the same meaning ascribed to them in the Terms.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, depending on the specific changes, we may provide you with additional notice or require a renewed consent (e.g. by adding a statement to our website’s homepage or sending you a push notification or email). We encourage you to review the Privacy Policy whenever you access our Services to stay informed about our information practices and the ways you can help protect your privacy.

In adopting this Privacy Policy, we wish to balance our legitimate business interests and your reasonable expectation of privacy. Accordingly, we will take reasonable steps to prevent unauthorised access to, or disclosure of your Personal Information. However, we do not guarantee that your Personal Information shall be 100% secure.

Collection of Information

INFORMATION YOU PROVIDE TO US

We collect information you provide directly to us when you submit Personal Information via the Site the following principles are observed in the handling of that information:

• We will only collect Personal Information for a purpose consistent with the purpose for which it is required. The specific purpose for which information is collected will be apparent from the context in which it is requested.
• We will only Process Personal Information in a manner that is adequate, relevant and not excessive in the context of the purpose for which it is processed.
• Personal Information will only be processed for a purpose compatible with that for which it was collected, unless you have consented to an alternative purpose in writing or we are permitted by the Protection of Personal Information Act 4 of 2013 (POPI) or in terms of national legislation of general application.
• We will not disclose any Personal Information relating to you to any third party unless your prior written agreement is obtained or we are required to do so by law. In this regard your attention is drawn to the Student Terms and Conditions.
• We will destroy or delete any Personal Information that is no longer needed by us for the purpose it was initially collected, or subsequently processed.
• As permitted by the Protection of Personal Information Act 4 of 2013 (POPI), we may use Personal Information collected to compile profiles for statistical purposes. No information contained in the profiles or statistics will be able to be linked to any specific user.

INFORMATION WE COLLECT AUTOMATICALLY THROUGH OUR SERVICES

When you access or use our Services, we automatically collect information about you, including:

• Log Information:We log information about your use of our Services, including the type of browser you use, access times, pages viewed, your IP address, and the page you visited

before navigating to our Services.

• Device Information: We collect information about the device you use to access our Services, including information about the device’s software and hardware, Media Access

Control (“MAC”) address and other unique device identifiers, device token, mobile network

information and time zone.

• Usage Information: We collect information relating to your use of our Services, including which applications you use and your game progress, scores, achievements and interactions with other players.
• Consumption information: We collect information about your consumption habits relating to your use of our Services, including which purchases you make with both virtual and real Currencies.
• Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, and this may include sending cookies to your computer

or mobile device. Cookies are small data files stored on your computer’s hard drive or in device memory that help us to improve our Services and your experience and see which areas and features of our Services are popular. We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies, and how to disable them, please see “Your Choices” below.

INFORMATION WE COLLECT FROM OTHER SOURCES

We may also obtain information from other sources and combine that with information we collect through our Services. For example, if you log into our Services using a third party site or platform such as Facebook, we may access information about you from that site or platform, such as your screen name, profile information and friend lists, in accordance with the authorization procedures determined by such third party site or platform. We may also collect information from app stores when you download or update one of our applications.

Use of Information

We may use information about you for various purposes, including to:

• Provide, maintain and improve our current Services;
• Develop new Services;
• Provide and deliver the products and services you request and send you related information;
• Facilitate communications between participants;
• Respond to your comments, questions and requests and provide customer service and support;
• Send you technical notices, updates, security alerts and support and administrative messages;
• Communicate with you about products, services, offers, promotions and events offered by GIBS Online and others, and provide news and information we think will be of interest to you;
• Personalize and improve our Services and provide tailored advertisements, content or features;
• Monitor and analyse trends, usage and activities in connection with our Services;
• Link or combine with information we get from others to help understand your needs and provide you with better service; and
• Carry out any other purpose for which the information was collected.

By accepting our Privacy Policy or otherwise providing information to us, you consent to the processing and transfer of information in and to the Republic of South Africa.

Sharing of Information

We may share information about you as follows or as otherwise described in this Privacy Policy:

• With vendors, consultants and other service providers who need access to such information to carry out work on our behalf;
• With other participants in order to creating syndicate groups
• In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation;
• If we believe your actions are inconsistent with the spirit or language of our terms and conditions or policies, or to protect the rights, property and safety of GIBS Online or others;
• In connection with, or during negotiations of, any merger, sale of company assets, financing or

acquisition of all or a portion of our business to another company; and

• With your consent or at your direction.

We also may share aggregated information or de-identified information, which cannot reasonably be used to identify you.

Social Sharing Features

Our Services may offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take on our Services with other media, and vice versa. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

Advertising and Analytics Services Provided by Others

We may allow third parties to serve advertisements and provide analytics services in connection with our Services. These entities may use cookies, web beacons and other tracing technologies to collect information about your use of our Services, including your IP address, MAC address, device identifiers, software and hardware information, browser information, time zone and usage information. This information may be used by GIBS Online and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests and better understand your activity on our Services.

Third-party ad serving and analytics technologies are integrated into our Services, so if you do not want to be subject to these technologies, do not use or access our Services.

Our Services may also integrate third party Application Program Interfaces (APIs), which allow others to collect and process information about you, including your geo-location information, to provide you with tailored advertisements, offers and other content. You have the ability to control the collection and use of your geo-location information at all times. We will not allow third parties to access this information without your opt-in consent, and you may disable location-based services at any time by adjusting the settings of your mobile device.

Direct Marketing

If we obtain your prior consent, we may use your Personal Data for the purposes of:

• direct marketing of our own services and on behalf of other companies within GIBS Online;
• research marketing; and
• direct marketing of products and services on behalf of selected third parties, if you have agreed to your details being passed onto third parties.

You are entitled to request that we desist from using your Personal Data for the purposes of direct marketing, and we will provide you with the necessary functionality for you to do so with ease, each time we market to you.

Security

Although absolute security cannot be guaranteed on the Internet, we have in place up-to-date, reasonable technical and organisational security measures to protect your Personal Data against accidental or intentional manipulation, loss, misuse, destruction or against unauthorised disclosure or access to the information we Process online.

While we cannot ensure or warrant the security of any Personal Data you provide us, we will continue to maintain and improve these security measures over time in line with legal and technological developments.

Your Choices ACCOUNT INFORMATION

You may request that we update, correct or delete information about you at any time by emailing us at [email protected], but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period.

COOKIES

Cookies are pieces of information a Website transfers to a user’s hard drive for record-keeping purposes. Cookies make surfing the web easier for you by saving your preferences and, tracking your online habits, traffic patterns, and making sure you do not see the same advertisement too often. The use of cookies is an industry standard. We may place a "cookie" on your browser to store and sometimes track information about you.

While most browsers are initially set up to accept cookies you can reset your browser to refuse all cookies or indicate when a cookie is being sent. Further, please note that some aspects of the Website will not function properly if you refuse cookies.

Most device browsers are set to accept cookies by default. If you prefer, you can usually choose

to set your device browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of certain features of our Services.

IP ADDRESSES

An IP address is a number that is automatically assigned to a computer whenever it is connected to the Internet. We log IP addresses, or the location of computers on the Internet.

We collect IP addresses for the purposes of system administration and to audit the use of the Website. We do not ordinarily link IP addresses to personal information, which means that your session may remain anonymous. However, we cannot guarantee that this will always be the case, as it may be necessary to identify a particular user when it is necessary to enforce compliance with the Terms or to protect our Website, its users or other interests.

PUSH NOTIFICATIONS

With your consent, we may send push notifications or alerts to your mobile device to provide programme related information, service updates, promotional communications and other related messages. You can deactivate these notifications by changing your notification settings on your device.

PROMOTIONAL COMMUNICATIONS

You may opt out of receiving promotional communications from GIBS Online by following the instructions in those communications or by emailing [email protected]

If you opt out, we may still send you non-promotional communications, such as those about our ongoing business relations.

STORAGE OF INFORMATION

GIBS Online will store your information for as long as necessary in order to provide you with our Services.

CONTACT US

If you have any questions about this Privacy Policy, please contact us at [email protected] or on +27 21 569 0078.