Privacy Policy

The following is our privacy policy as per the POPI Act, which outlines how we utilise and handle your private information

PRIVACY POLICY

THREEM SOLUTIONS (PTY) LTD | MMO-Learning

Version Date: June 25, 2021

GENERAL
1. ThreeM Solutions (Pty) Ltd ("ThreeM" or "We" or "Us" or "Our") respects the privacy of our clients. This includes users and subscribers to our platform www.MMO-Learning .co.za, as well as other device or online applications related or connected thereto (collectively, the "Sites"). We take Our obligations for the processing of personal information very seriously and We are committed to protecting your privacy.
2. This policy governs the types of personal information that We and Our division MMO-Learning may gather about or collect from you; as well as the conditions under which We use and disclose that personal information.
3. We respect your privacy, your personal information, and your data. For this reason, We take all reasonable measures in accordance with this privacy policy to protect your personal information and personal data and to keep it confidential.
4. The Sites, platforms, and services are hosted in South Africa and are subject to the laws in South Africa. By using The Sites and our platforms, you agree that this privacy policy and our terms of use govern your use of same. If you are accessing our Sites from other jurisdictions, please be advised that you are transferring your personal information to us in South Africa, and by using the Sites, you are agreeing to that transfer and use of your personal information in accordance with this Privacy Notice. You also agree to abide by the applicable laws of South Africa concerning your use of the Sites and your agreements with us. If your use of the Sites would be unlawful in your jurisdiction, please do not use the Sites. All disputes over privacy and your data shall be governed as set out in this privacy policy and our terms of use.
5. The “responsible party”, as referred to in the Protection of Personal Information Act No. 4 of 2013 (“POPI”) is ThreeM Solutions of Unit 43 Inospace, 50 Electron Exchange, Isando, Kempton Park, Gauteng. You may direct your queries regarding the protection of personal information to the information officer at mk@threemsolutions.co.za or +27645267042
HOW WE COLLECT INFORMATION FROM YOU
1. We may collect and process the following data about you through the following methods:
  1. Information that you provide by filling in forms on Our website – www.MMO-Learning .co.za. This includes information provided at the time of registering to use Our Sites, subscribing to Our services, subscribing to our newsletters, registering for our online sessions (webinars, masterclasses, talks, and similar), or requesting further services (consultation, support, meeting, and technical assistance). We may also ask you for information when you enter a competition or promotion sponsored by Us, and when you report a problem with Our site.
  2. ThreeM Solutions may analyse various mentioned personal information gathered from or about users to help ThreeM Solutions better understand how the Sites are used and how to make them better. By identifying patterns and trends in usage, ThreeM Solutions can better design the Sites to improve users’ experiences, both in terms of content and ease of use. From time to time, ThreeM Solutions may also release the anonymized information gathered from the users in the aggregate, such as by publishing a report on trends in the usage of the Sites
  3. Information you provide and record of correspondence during a direct engagement or/consultation with us.
  4. Surveys that We use for research purposes, although you do not have to respond to them.
  5. Details of transactions you carry out through Our Sites and of the fulfillment of your subscriptions and/or orders.
  6. Details of your visits to Our Sites including, but not limited to, traffic data, location data, weblogs, and other communication data, whether this is required for Our billing purposes or otherwise, and the resources that you access. This may also include your Internet Protocol (IP) address, operating system, browser type, and the locations of the Sites the views right before arriving at, while navigating, and immediately after leaving the Sites. It may also include various technical aspects of the user’s computer or browser and the user's browsing habits that are collected through cookies.
HOW WE USE YOUR PERSONAL INFORMATION
1. We use information held about you in the following ways:
  1. To ensure that content from Our site is presented most effectively for you and your computer.
  2. To provide you with information, products, or services that you request from Us or which We feel may interest you, where you have consented to be contacted for such purposes.
  3. To carry out Our obligations arising from any contracts entered into between you and Us.
  4. To allow you to participate in interactive features of Our service when you choose to do so.
  5. To notify you about upcoming events, uploaded content, and changes to Our service.
  6. To send statements, invoices and payment reminders to you, and collect payments from you;
  7. We may also analyse various mentioned personal information gathered from or about you to help Us better understand how our services and the Sites are used and how to make them better. By identifying patterns and trends in usage, We can better design our services, the Sites to improve users’ experiences, both in terms of content and ease of use.
  8. We may also use or permit selected third parties to use your data, or aggregate information to provide you with information about goods and services which may be of interest to you, and We or they may contact you about these by post or telephone.
  9. We may, from time to time, also release the anonymized information gathered from the users in the aggregate, such as by publishing a report on trends in the usage of the Sites.
2. If you are an existing customer, We will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale to you.
3. If you are a new customer, and where We permit selected third parties to use your data, We (or they) will contact you by electronic means only if you have consented to this.
4. We reserve the right to transfer all information in its possession to a successor organization in the event of a merger, acquisition, bankruptcy, or other sale of all or a portion of ThreeM Solutions’ assets. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred information will be subject to this Privacy Notice, or a new privacy notice if you are given notice of that new privacy notice and are given an opportunity to affirmatively opt-out of it.
5. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please let us know using the contact details above or simply tick the relevant box situated on the form on which we collect your data.
DISCLOSURE OF YOUR PERSONAL INFORMATION
1. We may disclose your personal information to any member of Our group, which means Our divisions, Our subsidiaries, Our ultimate holding company, and its subsidiaries, as defined in Section 1 to 3 of the South African Companies Act No. 71 of 2008.
2. When we believe disclosure is appropriate, we may disclose your information to help investigate, prevent or take other action regarding illegal activity, suspected fraud, or other wrongdoing; to protect and defend the rights, property, or safety of ThreeM Solutions, our users, our employees or others; to comply with applicable law or cooperate with law enforcement; to enforce our Terms of Use or other agreements or policies, in response to a subpoena or similar investigative demand, a court order or a request for cooperation from law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us. We will notify you if permitted before undertaking such disclosures.
3. ThreeM Solutions contractually prohibits its contractors, affiliates, vendors, and suppliers from disclosing any personal information received from ThreeM Solutions, other than in accordance with this Privacy Notice. These third parties may include advertisers, providers of games, utilities, widgets, and a variety of other third-party applications accessible through the Sites. ThreeM Solutions neither owns nor controls the third-party websites and applications accessible through the Sites. Thus, this Privacy Notice does not apply to personal information provided to or gathered by the third parties that operate them. Before visiting a third-party, or using a third-party application, whether through a link on the Sites, directly through the Sites or otherwise, and before providing any personal information to any such third party, users should inform themselves of the privacy policies and practices (if any) of the third-party responsible for those Sites or applications, and should take those steps necessary to, in those users’ discretion, protect their privacy.
4. We may use third-party vendors, including Google, who use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize and serve ads based on your past activity on the Sites, including Google Analytics for Display Advertising. The personal information collected may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand online activity. If you do not want any personal information to be collected and used by Google Analytics, you can install an opt-out in your web browser (https://tools.google.com/dlpage/gaoptout/) and/or opt-out from Google Analytics for Display Advertising or the Google Display Network by using Google’s Ads Settings (www.google.com/settings/ads).
5. We may use hyperlinks on the Sites which will redirect you to a social network if you click on the respective link. However, when you click on a social plug-in, such as Facebook’s "Like" button or Twitter’s “tweet” button that particular social network’s plugin will be activated and your browser will directly connect to that provider’s servers. If you do not use these buttons none of your data will be sent to the respective social network’s plugin providers. To illustrate this further, imagine the scenario where you click on the Facebook’s "Like" button on the Sites. Facebook will receive your IP address, the browser version and screen resolution, and the operating system of the device you have used to access the Sites. Settings regarding privacy protection can be found on the websites of these social networks and are not within our control.
MOBILE DEVICE ADDITIONAL TERMS
1. If you use a mobile device to access the Sites or download any of our applications (where applicable), we may collect device personal information (such as your mobile device ID, model, and manufacturer), operating system, version personal information, and IP address.
2. Unless we have received your prior consent, we do not access or track any location-based personal information from your mobile device at any time while downloading or using our mobile application or our services, except that it may be possible for ThreeM Solutions to determine from an IP address the geographic location of your point of connectivity, in which case we may gather and use such general location data.
3. We may send you push notifications if you choose to receive them, letting you know when someone has sent you a message or for other service-related matters. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
4. We may use mobile analytics software to allow us to better understand the functionality of our mobile software (where applicable) on your phone. This software may record personal information, such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the personal information we store within the analytics software to any personal information you submit within the mobile application.
INTERNATIONAL DATA TRANSFERS
1. Information that we collect may be stored and processed in and transferred between any of the countries in which we operate to enable us to use the information in accordance with this policy.
2. Information that we collect may be transferred to countries that do not have data protection laws equivalent to those in force in South Africa.
3. Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.
4. You expressly agree to the transfers of personal information described in this Section 6.
RETAINING PERSONAL INFORMATION
1. This Section 7 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
2. Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
3. Notwithstanding the other provisions of this Section 7, we will retain documents (including electronic documents) containing personal data:
  1. to the extent that we are required to do so by law;
  2. if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
  3. in order to establish, exercise, or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
SECURITY
1. We take the security of your personal information seriously and use reasonable electronic, personnel, and physical measures to protect it from loss, theft, alteration, or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your personal information. We are not responsible for third-party circumvention of any privacy settings or security measures.
2. We are dedicated to protecting all personal information on our platforms and the Sites as is necessary. However, you are responsible for maintaining the confidentiality of your personal information by keeping your password and computer/mobile device access confidential. If you have an account with ThreeM Solutions or its division MMO-Learning and believe someone has gained unauthorized access to it or your account please change your password as soon as possible. If you lose control of your account, you should notify us immediately.
YOUR RIGHTS
1. You have the right to ask Us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if We intend to use your data for such purposes or if We intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms We use to collect your data. You can also exercise the right at any time by contacting Us at mk@threemsolutions.co.za.
2. Our site may, from time to time, contain links to and from the websites of Our partner networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that We do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
3. You also have the right to request access and obtain a copy of your personal information, the right to request edits or erasure of your personal information, and the right to limit the processing of your personal information.
4. Where your personal information was processed with, following, or based on your consent, you have the right to withdraw such consent at any time. However, please note that this will not alter the validity of the processing before its withdrawal.
5. If you wish to exercise any of the mentioned rights please contact us by email at mk@threemsolutions.co.za, or by referring to the contact details at the bottom of this Policy. ThreeM Solutions has 30 days to respond to your request.
6. When exercising your rights in terms if 9.5 above, you may, where applicable and allowed by law, requested to:
  1. pay a fee; and
  2. supply appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
7. If you are not satisfied with ThreeM Solutions’ handling of your privacy concerns please note that you can contact us or can refer the matter to the Information regulator
8. If you have any questions or comments about your privacy rights, you may email us at mk@threemsolutions.co.za.
UPDATING INFORMATION
1. Please let us know if the personal information that we hold about you needs to be corrected or updated.
COOKIES
1. Our website uses cookies.
2. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
3. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
4. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
5. We use both session and persistent cookies on our website.
6. The purposes for which they are used, are set out below:
  1. To recognise a computer when a user visits the website,
  2. To track users as they navigate the website,
  3. To improve the website's usability,
  4. To analyse the use of the website,
  5. To administer the website,
  6. To prevent fraud and improve the security of the website,
  7. To personalise the website for each user, and
  8. To target advertisements that may be of particular interest to specific users.
7. Most browsers allow you to refuse to accept cookies; for example:
  - in Internet Explorer (version 10) you can block cookies using the cookie handling override settings available by clicking "Tools", "Internet Options", "Privacy" and then "Advanced";
  - in Firefox (version 24) you can block all cookies by clicking "Tools", "Options", "Privacy", selecting "Use custom settings for history" from the drop-down menu, and unticking "Accept cookies from sites"; and
  - in Chrome (version 29), you can block all cookies by accessing the "Customise and control" menu and clicking "Settings", "Show advanced settings" and "Content settings", and then selecting "Block sites from setting any data" under the "Cookies" heading.
8. Blocking all cookies will have a negative impact on the usability of many websites.
9. If you block cookies, you will not be able to use all the features on our website.
10. You can delete cookies already stored on your computer; for example:
  - in Internet Explorer (version 10), you must manually delete cookie files (you can find instructions for doing so at http://support.microsoft.com/kb/278835);
  - in Firefox (version 24), you can delete cookies by clicking "Tools", "Options" and "Privacy", then selecting "Use custom settings for history", clicking "Show Cookies", and then clicking "Remove All Cookies"; and
  - in Chrome (version 29), you can delete all cookies by accessing the "Customise and control" menu, and clicking "Settings", "Show advanced settings" and "Clear browsing data", and then selecting "Delete cookies and other site and plug-in data" before clicking "Clear browsing data".
11. Deleting cookies will have a negative impact on the usability of many websites.
DO-NOT-TRACK NOTICE
1. Most web browsers and some mobile operating systems include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. Because there is not yet a common understanding of how to interpret the DNT signal, the Sites currently do not respond to DNT browser signals or mechanisms.
GOVERNING LAW
1. Disputes over privacy issues contained in this Policy will be governed by the law of the Republic of South Africa. You also agree to abide by any limitation on damages contained in our Terms of Use, or other agreement that we have with you.
PRIVACY NOTICE CHANGES
1. ThreeM Solutions may, in its sole discretion, change this Privacy Notice from time to time. Any and all changes to ThreeM Solutions’ Privacy Notice will be reflected on this page and the date of the new version will be stated at the top of this Privacy Notice. Unless stated otherwise, our current Privacy Notice applies to all personal information that we have about you and your account. Users should regularly check this page for any changes to this Privacy Notice. ThreeM Solutions will always post new versions of the Privacy Notice on the Sites. However, ThreeM Solutions may, as determined in its discretion, decide to notify users of changes made to this Privacy Notice via email or otherwise. Accordingly, users must always maintain and update their contact personal information.
CONTACT

If you have any questions regarding our Privacy Policy, please contact our Information Officer at:

ThreeM Solutions

Maemo Kobe

Unit 43 Inospace, 50 Electron Exchange, Isando

Kempton Park, Gauteng, SA,1619

Email: mk@threemsolutions.co.za

Phone: +27645267042