Privacy Policy - Nurture Network

Nurture Network ("Nurture Network", "we", "us", "our") is committed to protecting your privacy and ensuring that your Personal Information is collected and processed lawfully, fairly, and transparently. This Policy applies to all Users of our Learning Management System ("LMS", "Platform", "Service") including learners, instructors, administrators, and visitors.

1. Definitions

In this Privacy Policy:

1.1. "Personal Information" has the meaning ascribed to it in POPIA and includes any information relating to an identifiable, living natural person or existing juristic person.

1.2. "Processing" means any operation or activity concerning Personal Information, including collection, receipt, recording, storage, updating, use, distribution, or deletion.

1.3. "Responsible Party" means the party who determines the purpose and means of processing Personal Information. For the purposes of this Policy, the Responsible Party is Nurture Network.

1.4. "User" means any individual or entity that accesses or uses the Platform, including learners, instructors, administrators, and guests.

1.5. "POPIA" means the Protection of Personal Information Act 4 of 2013 and any regulations issued under it.

2. Responsible Party and Contact Details

The Responsible Party for the purposes of this Privacy Policy is:

Company Name: Nurture Network

Registered Address: Brackenfell South City Cape Town

Email: colleennurture@gmail.com

Telephone: +27843250513

If you have any questions about this Privacy Policy or our processing of your Personal Information, please contact us using the details above.

3. Scope of this Privacy Policy

3.1. This Privacy Policy applies to all Personal Information that we process when you:

Register an account on the Platform;
Use the LMS or any of our related services;
Access our website or associated pages;
Receive communications or marketing from us; or
Interact with us in any other way (for example, support requests or feedback).

3.2. By accessing or using the Platform, you acknowledge that you have read and understood this Privacy Policy and agree to the processing of your Personal Information in accordance with it.

4. Personal Information We Collect

We may collect and process the following categories of Personal Information, depending on how you interact with us and which services you use:

4.1 Information You Provide Directly

Identification details, such as full name and, where applicable, school or institution name.
Contact details, such as email address and telephone number.
Account credentials, such as username and password.
Profile information, such as role (learner, educator, administrator), school affiliation, and preferences.
Billing and payment-related details (processed via our payment providers), such as subscription plan and transaction references.
Support requests, feedback, or other communications you send to us.

4.2 Information Collected Automatically

When you use the Platform, we may automatically collect certain information, including:

Technical information such as IP address, device type, browser type and version, time zone setting, and operating system.
Usage data such as pages visited, features used, time spent on the Platform, clicks, and interactions.
Log information such as access times, error logs, and system activity for security and performance monitoring.

4.3 Information from Third Parties

We may receive Personal Information about you from third parties, for example:

Your school, institution, or employer when they register you for training or provide your details to us as part of a group subscription.
Payment service providers for confirmation of successful or failed payments.
Integrated learning platforms or tools that are connected to our LMS, where applicable.

5. Legal Basis for Processing

We process your Personal Information in accordance with POPIA's conditions for lawful processing. Depending on the context, our legal basis may include:

Consent – where you have given us explicit consent to process your Personal Information for specific purposes (for example, receiving marketing communications).
Contractual necessity – where processing is necessary to enter into or perform a contract with you or your institution (for example, providing access to training programs, issuing certificates, or managing subscriptions).
Legal obligation – where we are required to process Personal Information in order to comply with applicable laws and regulations (for example, tax, accounting, or regulatory obligations).
Legitimate interests – where processing is necessary for our legitimate interests or those of a third party, and such interests are not overridden by your rights and interests (for example, improving our services, protecting the security of our systems, or preventing misuse of the Platform).

6. Purposes for Which We Use Personal Information

We process your Personal Information for the following purposes:

To register and manage User accounts on the Platform.
To provide access to courses, assessments, and training materials.
To track learning progress, completion, and performance for you and, where applicable, your institution.
To process payments, manage subscriptions, and handle billing queries.
To communicate with you regarding your account, training programs, updates, and support.
To send notifications, reminders, and administrative messages related to your use of the Platform.
To personalise your experience on the Platform, including recommended courses and content.
To monitor and maintain the security and integrity of the Platform, including detecting and preventing fraud, abuse, or unauthorised access.
To generate aggregated, de-identified analytics and reports to improve our courses and services.
To comply with legal and regulatory obligations and respond to lawful requests from authorities.

7. Retention of Personal Information

7.1. We retain Personal Information only for as long as is necessary to fulfil the purposes for which it was collected or as required by law or regulation.

7.2. When we no longer need Personal Information, we will take reasonable steps to delete, de-identify, or anonymise it in a secure manner.

7.3. Retention periods may differ depending on:

Contractual obligations with you or your institution;
Statutory requirements (for example, financial record-keeping);
Handling of disputes, complaints, or investigations;
Our need to maintain system and security logs for a reasonable period.

8. Security Safeguards

8.1. We implement appropriate, reasonable technical and organisational measures to protect Personal Information against loss, unauthorised access, disclosure, alteration, or destruction.

8.2. These measures may include, among others:

Access controls and authentication mechanisms.
Encryption of data in transit and, where appropriate, at rest.
Regular security monitoring, logging, and auditing.
Secure development and testing practices.
Backup and recovery procedures.

8.3. While we take reasonable steps to protect your Personal Information, no system is completely secure. You are responsible for keeping your account credentials confidential and notifying us immediately if you suspect any unauthorised access to your account.

9. Sharing and Disclosure of Personal Information

We may share your Personal Information with the following categories of recipients, where necessary and in accordance with POPIA:

Educational institutions and administrators – for example, your school or organisation that enrolled you, to manage training programs, view progress, and generate reports.
Service providers and operators – such as cloud hosting providers, email service providers, learning technology platforms, and payment processors who assist us in delivering the Platform and related services.
Professional advisers – such as legal, financial, or security consultants where necessary to protect our legitimate interests or comply with legal obligations.
Regulatory and law enforcement authorities – where required by law or to protect our rights, Users, or the public.

We require third parties who process Personal Information on our behalf to do so in accordance with written agreements and to maintain adequate security and confidentiality safeguards.

10. Cross-Border Transfers

10.1. Some of our service providers and systems may be located outside of the Republic of South Africa. This means that your Personal Information may be transferred to and processed in other countries.

10.2. Where we transfer Personal Information across borders, we will take reasonable steps to ensure that:

The recipient is subject to a law, binding corporate rules, or binding agreement that provides an adequate level of protection for Personal Information; or
You have consented to the transfer; or
The transfer is otherwise permitted in terms of POPIA.

11. Your Rights Under POPIA

As a data subject, you have the following rights under POPIA, subject to certain limitations and conditions:

Right of access – to request confirmation of whether we hold Personal Information about you and to obtain a copy of such information.
Right to correction – to request that we correct or update any inaccurate, incomplete, or outdated Personal Information.
Right to deletion – to request that we delete your Personal Information where there is no lawful reason for us to continue processing it.
Right to object – to object, on reasonable grounds, to the processing of your Personal Information where our processing is based on legitimate interests or for direct marketing purposes.
Right to withdraw consent – where processing is based on your consent, you may withdraw your consent at any time. This will not affect the lawfulness of processing that took place before withdrawal.
Right to complain – to lodge a complaint with the Information Regulator if you believe that we are not complying with POPIA.

To exercise any of these rights, please contact us using the details set out in section 2 above. We may request proof of identity to verify your request.

12. Cookies and Tracking Technologies

12.1. We may use cookies and similar tracking technologies to:

Recognise you when you log into the Platform;
Remember your preferences and settings;
Improve the performance, security, and usability of the Platform; and
Generate anonymous or aggregated analytics about how the Platform is used.

12.2. You can manage cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality or performance of the Platform.

13. Direct Marketing and Communication Preferences

13.1. We may use your contact details to send you information about courses, features, and services that may be of interest to you, in accordance with POPIA and other applicable laws.

13.2. You may opt out of direct marketing communications at any time by using the unsubscribe link in our emails or by updating your communication preferences where such functionality is provided.

13.3. Even if you opt out of marketing, we may still send you essential service-related communications, such as account notifications, security alerts, or important updates about the Platform.

14. Children and Minors

14.1. Our Platform may be used as part of educational programs involving minors, typically under the supervision of schools, institutions, or parents/guardians.

14.2. Where required by law, we will ensure that appropriate consent is obtained from a competent person (such as a parent or legal guardian) before processing the Personal Information of minors.

14.3. We encourage parents and guardians to be actively involved in their children's online learning and to contact us if they have any concerns about the processing of a minor's Personal Information.

15. Links to Other Websites

15.1. The Platform may contain links to third-party websites or services that are not operated by us.

15.2. We are not responsible for the privacy practices or content of such third-party websites. We encourage you to review their privacy policies before providing any Personal Information.

16. Changes to this Privacy Policy

16.1. We may update or amend this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the functionality of the Platform.

16.2. When we make material changes, we will take reasonable steps to notify you, such as by posting a prominent notice on the Platform or sending you an email.

16.3. The updated version will be indicated by an updated "Last Updated" date. Your continued use of the Platform after changes have been made constitutes your acceptance of the updated Policy.

17. Complaints

17.1. If you believe that we are not processing your Personal Information in accordance with this Privacy Policy or applicable law, please contact us first so that we can attempt to resolve your concern.

17.2. You also have the right to lodge a complaint with the Information Regulator in South Africa. Details of the Information Regulator can be found at https://www.justice.gov.za/inforeg/.

18. Contact Information

If you have any questions, requests, or concerns regarding this Privacy Policy or our processing of your Personal Information, please contact us:

Company Name: Nurture Network

Registered Address: Brackenfell South City Cape Town

Email: colleennurture@gmail.com

Telephone: +27843250513

Effective Date and Version

Last Updated: 1 January 2026

Version: 1.0