Boston Online Home Education
1.1 We, Boston Online Home Education, a company incorporated in accordance with the laws of the Republic of South Africa, (“Boston Online Home Education“, “we” or “us“) respect and recognise the importance of protecting the privacy of all persons whose Personal Information (as defined in paragraph 2.1 below) comes into our possession, and we will take all reasonable measures to protect it.
1.2 Boston Online Home Education (formerly Boston Online High School) is a registered Cambridge International Education Associate. We are a home education partner for high school equivalents/alternatives and support parents/guardians of home schooled learners towards Cambridge International Education single subject or group awards.
1.4 For purposes of the applicable data protection legislation in the Republic of South Africa, we are the “responsible party” in respect of the Personal Information submitted to us by you and/or that may be collected by us through our Website, any correspondence and/or communication with you. However, there may be certain instances where we process Personal Information on behalf of a third party, in these instances we are an “operator” in respect of the Personal Information submitted to and/or collected by us for this purpose. Please note paragraph 4 below as it deals with Personal Information disclosed to third parties.
2 INFORMATION WE MAY COLLECT FROM YOU
2.1 When you visit the Website, we may collect certain information that is not Personal Information such as your Internet Protocol (“IP“) address, operating system, browser type and internet service provider. This type of information does not identify you personally.
2.2.1 information that you provide by completing certain application forms on our Website or platforms. This includes (but is not limited to) information provided by you when enquiring, applying and/or enrolling in any of our Education Services (such as your name, surname, identity number, email address, contact number and banking details) or enquiring about any of our Education Services;
2.2.2 information collected through user satisfaction surveys that we may ask you to complete and that we use for research purposes;
2.2.3 information collected during promotional competitions that we run or for prizes or gifts awarded by us;
2.2.4 information collected during promotional or student events and/or school visits undertaken by us;
2.2.5 details of your visits to our Website (including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise) and the resources that you access;
2.2.6 information provided by you in respect of the bursaries offered by Boston Online Home Education;
2.2.7 information provided by you during any telephonic discussions which may be held with you and one of our staff members;
2.2.8 information provided in respect of any scholarship applications, which includes (but is not limited to) your name, surname, identity number, matric certificate, academic results and any additional information which may be required by the institution providing the scholarship);
2.2.9 information provided by you in respect of your submission of a bursary application, which includes (but is not limited to) your name, surname, identity number, matric certificate, motivational letter and academic results; and
2.2.10 recording of telephone calls, you make to us, unless you specifically request us not to.
2.3 The supply of all Personal Information by you is voluntary; however, you acknowledge that we cannot make the Education Services available to you if you do not wish to supply such Personal Information.
2.6 Where you provide us with Personal Information relating to a third party data subject (for example, details of a child who is a minor), you warrant that you have obtained all necessary consents from such third party and/or their guardian(s) or parent(s) to the extent required by law, for you to share such Personal Information with us to process on your behalf. Where you are a child who is a minor, you warrant that you have obtained the consent of your parent/guardian to the fullest extent required by law, to permit us to process your Personal Information.
3 HOW YOUR PERSONAL INFORMATION IS USED
3.1 If you wish to use our Website and/or make use of the Education Services, we will need to collect basic information about you, including your Personal Information.
3.2 We use the Personal Information we collect about you for a number of purposes, namely –
3.2.1 to provide you with information on our Education Services or to market the Education Services which we feel you may be interested in, provided that you have consented to being contacted for such purposes or, where you are a child who is a minor, your parent/guardian has consented to you being contacted for such purposes;
3.2.2 to carry out market research and for forecasting purposes;
3.2.3 to carry out any contracts that may be formed between us, you and/or any third parties (in particular, in order to be able to provide you with the Education Services);
3.2.4 to provide you with communications in respect of our Education Services (including, but not limited to, communications regarding special offers which you may be entitled to, new courses which may be available, associated courses and others which we feel may be of interest to you);
3.2.5 to respond to any queries, you may make either through our Website or by contacting us telephonically or via email;
3.2.6 to notify you of any changes to our Education Services offered by us (including, but not limited to, any additional services which we may offer in the future or any changes pertaining to the manner in which such Education Services will be made available to you, either through physical classes or virtually);
3.2.7 to improve the Education Services we offer or generally to improve your experience any of our campuses (whether in relation to our online or physical campus) – for example, you may be asked to complete a survey in this regard;
3.2.8 to provide you with communications regarding any amounts owed by you as a consequence of us rendering the Education Services or for any other reason not relating to the provision of the Education Services;
3.2.9 to provide communications to third parties including (without limitation) debt collection agencies, the South African Revenue Services and/or credit bureaus; and
3.2.10 to include within our marketing communications or any marketing campaign which we may run (this includes any comments made by you or photos provided by you.
4.1 We will not use Personal Information for any purpose (other than those stated in paragraph 3 above) without your express consent. We will not use or disclose any Personal Information to third parties without your consent, unless the use or disclosure is –
4.1.1 required in order to comply with any applicable laws, orders of court or legal processes served on Boston Online Home Education (including, without limitation, any legislation, requirements or processes imposed by the Department of Education, the Council on Higher Education, the South African Qualifications Authority; any Services Sector Education and Training Authority, the National Credit Regulator and/or our overseas accreditation bodies) and/or
4.1.2 disclosure is necessary to protect and defend the rights or property of Boston Online Home Education.
4.2 We work closely with trusted partners with whom we need to share Personal Information to help us provide you with the Education Services. A list of our partners may be provided upon written request.
4.3 We may share your Personal Information with –
4.3.3 our student material suppliers or service providers under contract who help supply certain academic material or help with parts of our business operations, including fraud prevention, bill collection, marketing, technology services;
4.3.4 credit bureaus to report account information, as permitted by law;
4.3.5 advertising and/or marketing agencies;
4.3.6 banking partners as required by credit card association rules for inclusion on their list of terminated merchants (in the event that you utilise the services to receive payments and you meet their criteria); and
4.3.7 third parties (including, without limitation, the Department of Higher Education and Training, the Council on Higher Education, the South African Qualifications Authority; any Services Sector Education and Training Authority, the National Credit Regulator, our overseas accreditation bodies and/or software services providers which may be required to provide certain of the Education Services to you).
4.5 We may also provide information to third party service providers who process information on our behalf to help run some of our internal business operations including email distribution, IT services and customer services.
4.7 You understand that we may disclose or share Personal Information with third parties as outlined above in order for us to be able to provide you the Education Services. If you are concerned about these arrangements, please do not continue to make use of the Education Services.
4.8 We will be entitled to disclose your Personal Information to those of our affiliates, agents, advisors, employees and/or third-party service providers and suppliers who assist us to interact with you via mobile communications and/or email, and thus need to know your Personal Information in order to assist us to communicate with you properly and efficiently. We will ensure that all such employees and/or third-party service providers having access to your Personal Information are bound by appropriate and legally binding confidentiality and non-use obligations in relation to your Personal Information.
4.9 On occasions, we may be required to disclose your Personal Information due to legal or regulatory requirements. In such instances, we reserve the right to disclose this Personal Information as required in order to comply with our legal obligations, including but not limited to complying with court orders, warrants, subpoenas, service of process requirements or discovery requests. This includes, but is not limited to, any legal or regulatory requirements or processes imposed by the Department of Higher Education and Training, the Council on Higher Education, the South African Qualifications Authority; any Services Sector Education and Training Authority, the National Credit Regulator and/or our overseas accreditation bodies.
5 COMMUNICATIONS FROM US
5.1 Where you have indicated that you would like to receive direct marketing communications from us and provided your consent thereto, we may send email or mobile communications to you concerning our Education Services or such other products as may be provided by us from time to time and to which you have consented to receiving.
5.2 You can also unsubscribe from receiving electronic direct marketing messages by following the “unsubscribe” instructions included in our communication (and you may change your preferences and cease receiving direct marketing from us through your account settings). We will not change your preferences without your consent.
6 PROTECTION OF YOUR PERSONAL INFORMATION
6.1 You are our valued customers, and we recognise that protecting your privacy is important to you and to us. For this reason, we are committed to protecting the Personal Information that you provide in a variety of ways.
6.2 We will –
6.2.1 treat all Personal Information as strictly confidential;
6.2.2 take appropriate technical and organisational measures to ensure that all Personal Information is kept secure and is protected against unauthorised or unlawful processing, accidental loss, destruction or damage, alteration, disclosure or access;
6.2.3 promptly notify you if we become aware of any unauthorised use, disclosure or processing of your Personal Information;
6.2.5 upon request, promptly return or destroy any and all of your Personal Information in our possession or control.
6.3 Due to the nature of the Personal Information within our possession or under our control, there may be instances where your Personal Information is retained indefinitely by us. Any Personal Information which is not kept indefinitely by us, will not retain for longer than –
6.3.1 a period of 10 consecutive years after your last interaction with us; or
6.3.2 the period for which it was originally required,
unless we are required by law to do so, or you consent to us retaining such Personal Information for a longer period. Where your information is no longer required or the period of  consecutive years has expired (whichever occurs last in time), we will ensure that either (i) it is disposed of in a secure manner or (ii) it is encrypted with limited individuals within Boston Online Home Education having access to the encryption key and, where required by applicable law, we will notify you when such information has been disposed of or encrypted.
6.4 If you register an account with us, please do keep your details up to date and notify us of any changes to your Personal Information. You can do this by contacting us using the details set out in paragraph 13.3 below.
7 STORAGE AND SECURITY OF YOUR PERSONAL INFORMATION
7.1 We will take appropriate, reasonable technical and organisations measures to protect your Personal Information, and we will use technology that will help us to do this, however, the transmission of information via the internet is not completely secure and we cannot guarantee the security of your information transmitted to us. Any transmission of your information is entirely at your own risk. Once your information is received by us, we or the applicable third party service providers shall use strict procedures and security features to try and prevent unauthorised access.
7.2 You hereby consent to the transfer, storage or hosting of your Personal Information on servers within and outside of South Africa. We will at all times ensure that appropriate security safeguards are in place to secure and protect such Personal Information.
8 COOKIES AND IP ADDRESSES
8.1 We may collect information about your computer including, where available, your IP address, operating system and browser type or for system administration. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.
8.4 Cookies enable us to –
8.4.1 estimate our Website’s audience size and usage pattern;
8.4.2 store information about your preferences, which allows us to customise the Website according to your individual interests;
8.4.3 speed up your searches; and
8.4.4 recognise you when you return to the Website.
9 ACCESS RIGHTS
9.1 In some jurisdictions you may have the right to request copies of your Personal Information which is within our custody and control together with details about how we use that information. If you think any of the Personal Information, we hold about you is inaccurate, you may also request us to correct it. You may also have a right, in certain circumstances, to require us to stop processing your Personal Information.
9.2 In relation to all of these rights, you should please email or write to us at the address set out in paragraph 15 below. Please note that we may, where permitted under applicable law, charge a small administrative fee and/or request proof of identity. We will respond to requests within all applicable timeframes.
9.3 In certain circumstances (for example where required or permitted by law) we might not be able to provide you with access to some of your Personal Information, but where appropriate we will notify you of the reasons for this.
9.4 You may request access to your Personal Information by sending an email to us at PoPI@Boston.co.za.
9.5 You have the right to lodge a complaint with the Information Regulator if you think that we are in breach of any applicable data protection legislation. The office of the Information Regulator’s details are as follows:
Tel: 012 406 4818
Fax: 086 500 3351
10 THIRD PARTIES
11 CHANGE OF OWNERSHIP
11.1 If we undergo a change of ownership, or a merger with, acquisition by, or sale of assets to, another entity, we may cede, delegate, transfer and/or assign our rights and obligations to your Personal Information we have in our possession to the successor, purchaser or separate entity.
11.2 We will disclose the cession, delegation, transfer and/or assignment on our Website.
12 RETENTION OF PERSONAL INFORMATION
13.2 You agree to provide accurate, truthful and current information, and not to impersonate or misrepresent any person or entity or falsely state or otherwise misrepresent your affiliation with anyone or anything. Failure to adhere to this requirement will entitle Boston City Campus, among other things, permit us to refuse to provide you with the Education Services.
13.3 You may access, remove, review, and/or make changes to Personal Information which you have provided to us. We may also send you any legally required notifications and certain notifications, including but not limited to, service-related notices or notices regarding a change to any of our policies. For example, we may send you a notice regarding server problems or scheduled maintenance of our Website. You can opt out of receiving these notifications or any other email communications from us by emailing us at PoPI@Boston.co.za.
14 NOTIFICATION OF CHANGES
15 HOW TO CONTACT US
Suite 287, Private Bag X5
Last edited on 8/06/2022