Privacy Policy
Cleared Mind is committed to preserving the confidentiality and integrity of all information it holds and processes and to operating its business in compliance with the requirements of the Protection of Personal Information Act, 2013 (“POPI”), and all other applicable laws relating to the processing of Personal Information.
We recognize the importance of Personal Information and of respecting the privacy rights of individuals. This Privacy Notification sets out the principles which we apply to our Processing of Personal Information so that we not only safeguard one of our most valuable assets, but also that which belongs to our partners and employees. For the most part, we process this information in one of two capacities, either:
1. as a Responsible Party for our internal business operations, such as human resources, administration, marketing, sales etc.,
2. as an operator when carrying out our service operations for our clients.
For the Protection of Personal Information Act, 2013 (the “POPI Act”), the Responsible Party is the House of Experts, telephone: +27 12 955 1111, email: tshepo@clearedmind.com, website: https://www. https://clearedmind.com/.
It is the responsibility of all Cleared Mind employees to apply the provisions of this notification to all Processing of Personal Information, whether Cleared Mind is acting as Responsible Party or Operator (or both). Cleared Mind provides employees with regular instruction concerning such matters.
Personal Information Collected and Sources of Data
Personal information collected by Cleared Mind may include:
1. Customer Relationship Data: Information relating to identifying particulars, including first name, last name, identification number, e-mail address, physical address, telephone number, employer, the information contained in communications between us and clients or their University or Employer, etc.
2. Usage data: Data about use of our website and services, which may include IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of service use.
3. Payment Information: This includes details about the payment method, transaction details, billing address, and other information necessary to process payments.
4. Health Data: As a health app, Cleared Mind may collect information related to the user’s physical and mental health. This could include data about the user’s lifestyle, fitness level, dietary habits, mental health status, and other health-related information.
5. Device Information: Information about the user’s device, including the device model, operating system, unique device identifiers, and mobile network information.
6. Preferences and Interests: Information about the user’s preferences and interests, such as preferred language, preferred topics of interest, and other preferences related to the use of the app.
7. Customer Feedback: This includes information that users provide as part of surveys, feedback, reviews, or other forms of user engagement.
The purpose for which the Information is being Collected
Personal information is processed by Cleared Mind for the following purposes:
To provide our services and carry out our contractual obligations. We process personal information in the first place to be able to offer the Services to our applicant online clients and to run, maintain and develop our business. Personal information may be processed to carry out our contractual obligations towards the client. We may use the data for example to offer essential functionalities of the Services and to provide access to the Services. If a client contacts our call centre, we will use the provided information for answering questions and solving possible issues.
For clients communication and marketing:
We may process personal information to manage our relationships with clients, communicating with clients, keeping records of those communications and promoting our products and services to clients.
For quality improvement and trend analysis:
We may process information regarding the use of the Services to improve the quality of our Services e.g. by analysing any trends in the use of our Services. When possible, we will do this using only aggregated, non-personally identifiable data.
Keeping a proper record of transactions:
We may process personal information to keep records of transactions.
Whether or not the supply of the Information by that Data Subject is Voluntary or Mandatory and the Consequences of Failure to Provide the Information
To use our services, there is some information which we required clients to provide us either because of legal requirements or because we need that information to provide our services.
We will inform the client when the personal information requested is mandatory, or if it is voluntary. If the client does not provide mandatory personal information, we will be unable to properly provide our services.
Transferring of Information to a Third Country or International Organisation and the Level of Protection Afforded
We primarily store personal information within the Republic of South Africa.
However, Cleared Mind uses service providers in several geographic locations. As such, we or our service providers may transfer personal information to, or access it in, jurisdictions outside the clients residency.
Where we transfer your personal information outside of the Republic of South Africa, the safeguards that we will use to protect your student’s personal information include contractual obligations imposed on the recipients of the personal information. Those obligations require the recipient to protect the personal information to the standard required in the Republic of South Africa. Safeguards also include requiring the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing and where the framework is the means of protection for the personal information.
Recipient or Category of Recipients of the Information
Personal Information we process during the initial contact is not shared.
We may disclose a client’s personal information to our service providers who are involved in the delivery of products or services to you. We have agreements in place to ensure that they comply with the privacy requirements as required by the POPI Act. The categories of recipients that we will share your information with are:
1. our service providers, agents and sub-contractors who administer or process information on our behalf (such as our cloud service provider);
2. our partners, University’s or Employer.
3.Affiliates and Subsidiaries: Personal information may be shared within a corporate structure, such as with affiliates or subsidiaries, for internal administrative purposes.
4.Legal Advisors: In the event of a dispute, personal information may be shared with legal advisors to protect the organization’s rights and interests.
Existence of the Right of Access to and the Right to Rectify the Information Collected and Objection
Under the POPI Act, clients have several rights. Please note that these rights are not without limitation, and in some instances may not be available. Where applicable, clients have the right to:
1. request access to personal information and to obtain information about how we process it;
2. have inaccurate/incomplete personal information corrected/completed;
3. object to the processing of your personal information; and
4. have personal information erased.
To exercise these rights as set out above, clients must please write to us using email: complaint@clearedmind.com or call telephone: +27 (0)12 955 1111. There is no fee for making these requests. However, if a request is excessive or unfounded, we can charge a reasonable fee or refuse to comply with it.