Privacy Policy

Effective Date: 25 November 2025
Last Updated: 25 November 2025

THIS PRIVACY POLICY IS SUBJECT TO THE TERMS AND CONDITIONS ON THIS WEBSITE.

BY CONTINUING TO USE THIS WEBSITE, YOU AGREE TO THE TERMS AND CONDITIONS SET OUT IN THIS PRIVACY POLICY. PLEASE NOTE THAT BY SUBMITTING INFORMATION VIA THIS WEBSITE, YOU CONSENT TO THE COLLECTION, COLLATION, PROCESSING AND STORING OF SUCH INFORMATION AND THE USE AND DISCLOSURE OF SUCH INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY.

WE RECOMMEND THAT YOU READ THIS PRIVACY POLICY TOGETHER WITH OUR TERMS AND CONDITIONS PRIOR TO SUBMITTING INFORMATION TO THIS WEBSITE.

1. INTRODUCTION

This is the Privacy Policy of NEOSPECTIVES CONSULTING (PTY) LTD (hereinafter referred to as ‘us’, ‘we’ or ‘our’ and “Neospectives”’ as required by the context).

In this Privacy Policy we list our policies regarding the collection, use, and disclosure of Personal Information or data when you use our service and the choices you have associated with that data. We use your data to provide and improve our service. By using the service, you agree to the collection and use of information in accordance with this Privacy Policy.

We are committed to protecting the privacy and security of the personal information we process.

This Privacy Policy outlines our practices concerning the collection, use, and disclosure of your personal information in compliance with the Protection of Personal Information Act, 2013 (POPIA) of South Africa, and in consideration of international data protection standards, including the General Data Protection Regulation (GDPR – EU 2016/679) where applicable to international operations or data transfers.

By engaging with our services, you acknowledge that you have read and understood this Privacy Policy.

2. DEFINITIONS (KEY TERMS)

The following words expressions and abbreviations shall have the meaning hereinafter assigned to them:

  1. ‘Service’ means the service(s) and/or products provided on our website as advertised on the website by email or other marketing campaigns under the same domain operated by the proprietor and/ or local proprietor of this website;
  2. ‘Personal Information’ means data about a living individual (you) who can be identified from that data (or from those and other information either in our possession or likely to come into our possession), such as your name, contact details, your company details and service history. It may also contain information of your browsing habits on our Website;
  3. ‘Data or Content’ means data collected automatically either generated by the use of service and providing certain information or from the service infrastructure itself which includes Personal Information;
  4. ‘Cookies’ means small pieces of data stored on your device;
  5. ‘Data Controller’ means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and manner in which any personal information is, or are to be, processed.
    For the purpose of this Privacy Policy, we are a Data Controller of your Personal Information, Content or Data;
  6. ‘Data Processors or Service Providers’ means any natural or legal person who processes the data on behalf of the data controller. We may use the services of various Service Providers in order to process your data more effectively; and
  7. ‘Data Subject or user’ means any living individual who is using our service and is the subject of Personal Information.

3. INFORMATION OFFICER DETAILS

  • Name of Information Officer : Dineshrie Pillay
  • Contact Number : 087 655 2771
  • Email Address : info@neospectives.com
  • Appointed Physical Address: Corobay Corner Building, Second Floor, Block B, 169 Corobay Avenue, Menlyn Maine, Pretoria, Gauteng, 2191

4. COLLECTION OF PERSONAL INFORMATION

  1. We collect personal information primarily to provide our services. The types of personal information we collect depend on the nature of the service and may include, but shall not be limited to:
    1. Identity Data: Names, dates of birth, identification numbers (e.g., ID, passport, employee numbers), photographs.
    2. Contact Data: Residential addresses, email addresses, telephone numbers.
    3. Professional Data: Employment history, educational background, professional qualifications, financial records, directorships, criminal records (where lawful and relevant), public domain information (e.g., social media profiles, news articles).
    4. Special Personal Information: Where strictly necessary and lawful for our services (e.g., criminal records for recruitment due diligence, or biometric information where publicly available and relevant for identity verification in limited circumstances), and with explicit consent or as otherwise legally permitted.
    5. Unique Identifiers: Where used for purposes other than their original collection, we seek prior authorization from the Information Regulator.
  2. How we collect personal information:
    1. From Clients: Information provided by our clients for the purpose of initiating and engaging our services request on request.
    2. Publicly Available Sources: Information lawfully obtained from public records, open-source intelligence (OSINT), news archives, and professional networking sites.
    3. Third-Party Sources: Where lawful and necessary, we may obtain information from reputable third-party data providers or legal entities, always ensuring such collection adheres to relevant data protection laws.
    4. Directly from Data Subjects: In specific, limited circumstances, we may engage with data subjects directly to verify information, always with transparency about our identity and purpose, and only when legally permissible.
  3. How do I withdraw my Consent to my information? If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, by contacting us at info@neospectives.com.
  4. Age of Consent: By using this Website you represent that you are at least the age of majority in your province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this Website.

5. DATA

  1. Neospectives Consulting processes personal information only for specific, explicit, and legitimate purposes that are directly related to the coaching, training, facilitation, and consulting services we provide. The legal bases for our processing activities include:
    1. Performance of a Contract: We may process personal information when necessary to deliver our services under a contract or agreement with you, for example, when you enroll in a training programme, workshop or coaching session, or when we provide follow-up support or assessment as part of our services.
    2. Legitimate Interests: We may process personal information when it is necessary for our legitimate business interests, such as managing our training programmes, enabling group or peer-feedback processes, improving internal administration, or measuring and improving the quality of our services. We ensure that such interests do not override your rights and freedoms.
    3. Consent: Where required under applicable law, for instance if we collect sensitive personal data, or if we want to use your personal information for new purposes (e.g. marketing, testimonials, promotional materials), we will obtain your explicit consent. You can withdraw your consent at any time, subject to any legal or contractual restrictions, without affecting the lawfulness of processing carried out before withdrawal.
    4. Legal Obligation: If required by law (for example in relation to record-keeping, tax, regulatory or compliance requirements), we may process personal information to comply with such obligations. Our purposes for processing personal information include (but are not limited to):
      1. Enrolling you in training, coaching or facilitation programmes, and administering those services.
      2. Managing participation in courses or workshops (e.g., registration, scheduling, communications).
      3. Providing feedback, support or follow-up services (e.g., peer-group feedback sessions, ongoing coaching).
      4. Communicating with clients about our offerings, updates, invoices, or other administrative matters.
      5. Internal record-keeping and administrative purposes (e.g., attendance logs, performance tracking, customer records).
      6. Improving and refining our programmes, content and delivery methods based on feedback and outcomes.
      7. Potentially marketing, communications or promotional activities (only with explicit consent).
  2. You may be asked or be required to provide limited personal information in order to enable us to provide certain services to you. We may store this information manually or electronically. We will only use it for purposes for which it was provided if you have consented to it. Information provided will be kept for as long as necessary to fulfill that purpose.
  3. We may also collect information about your computer including, where applicable, your IP address, operating system and browser type, for system administration purposes and to report aggregate information to our webmasters. This information reveals nothing personal about you. It is statistical data about our users’ browsing actions and patterns which do not identify individuals and allows us to ensure that content from our site is presented in the most effective manner for you and for your computer.
  4. We may use cookies and similar tracking technologies to track the activity on our Service and hold certain information.
  5. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a Website and stored on your device. Tracking technologies also used are beacons, tags and scripts to collect and track information and to improve and analyse our Service to you.
  6. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our service.

6. DISCLOSURE OF PERSONAL INFORMATION

We do not sell, rent, or trade your personal information.

  1. We only share personal information where necessary for legitimate business purposes, to deliver our services, or where required by law. Personal information may be disclosed to the following categories of recipients:
    1. Corporate Clients / Programme Sponsors: Where a company engages Neospectives to provide coaching, training, or facilitation services to its employees or teams, we may share relevant attendance information, progress summaries, or programme-related outcomes strictly as agreed with the client. Such disclosure is always limited to what is necessary, appropriate, and contractually authorised.
    2. Service Providers (Operators/Processors): We may engage trusted third-party service providers to support our operations, including IT hosting, learning management systems, communication platforms, analytics tools, payment processors, and administrative support. These operators are bound by written agreements requiring them to keep personal information confidential, secure, and to process it only according to our instructions and applicable data protection laws.
    3. Professional Coaches, Facilitators, or Consultants Contracted by Neospectives: Where external or associate facilitators support delivery of a programme, they may access limited personal information necessary for preparing, tailoring, and delivering sessions. All facilitators are bound by confidentiality and professional ethics obligations.
    4. Professional Advisors: Such as auditors, accountants, or legal advisors, where such disclosure is necessary for compliance, reporting, dispute resolution, or the protection of our rights. These advisors are subject to strict confidentiality obligations.
    5. Law Enforcement or Regulatory Authorities: Where required by law, regulation, court order, or where necessary to protect Neospectives’ legal rights, safety, or the rights and safety of others.
    6. Public Bodies: If compelled by law or authorised under POPIA or other applicable legislation.

7. INTERNATIONAL DATA TRANSFERS

  1. We may transfer personal information to recipients in countries outside South Africa where it is necessary for the provision of our services or for legitimate business purposes. Such transfers will only occur where adequate protections are in place, as required under POPIA. When transferring personal information across borders, we will ensure that adequate safeguards are in place to protect the information, including:
    1. Binding Corporate Rules (BCRs).
    2. Standard Contractual Clauses (SCCs) approved by the relevant authorities (e.g., Information Regulator of SA, European Commission).
    3. Adherence to binding arrangements between public bodies.
    4. Transfer to a country recognized as providing an adequate level of protection by the relevant authority.
    5. Obtaining the data subject’s explicit consent to the proposed transfer after being informed of the possible risks.
  2. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
  3. We will take reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of data will take place to an organization or a country unless there are adequate controls in place (as aforesaid) including the security of your data and other personal information.

8. THIRD PARTY SERVICES

  1. In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.
  2. In particular, remember that certain providers may be located in or have facilities that are located in a different jurisdiction to either you or us. If you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
  3. Once you leave our Website or are redirected to a third-party Website or website, you are no longer governed by this Privacy Policy or our Website’s Terms and Conditions.
  4. Links: when you click on links on our website, they may direct you away from our website. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.
  5. We do not support “Do Not Track” (‘DNT’). DNT is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

9. USE OF PHOTOGRAPHS AND CONSENT FOR MARKETING

  1. From time to time, Neospectives may take photographs or record images of participants during workshops, training sessions, or events.
  2. By participating, you consent to the use of such photographs or recordings for marketing, promotional, and educational purposes, including on our website, social media, newsletters, and printed materials.
  3. Notwithstanding the above, you may be asked to fill out a form indicating your consent to such materials being used for the purposes set forth.
  4. You may withdraw your consent at any time by contacting us at info@neospectives.com.
  5. Withdrawal of consent will not affect the lawfulness of any processing carried out prior to withdrawal.

10. SECURITY SAFEGUARDS

We are committed to protecting personal information from loss, misuse, unauthorized access, disclosure, alteration, and destruction. We implement appropriate technical and organizational measures, including:

  • Physical security measures for our premises and data storage.
  • Cybersecurity measures, such as firewalls, encryption, and intrusion detection systems.
  • Access controls and authentication protocols to restrict access to personal information to authorized personnel only.
  • Regular security assessments and vulnerability testing.
  • Employee training on data privacy and security best practices.
  • Procedures for handling and reporting data breaches.

11. DATA RETENTION

We retain personal information for no longer than is necessary to fulfill the purposes for which it was collected, or as required by applicable laws or for the establishment, exercise or defence of legal claims. Once the purpose for retaining the information has expired, we will securely destroy or de-identify the information.

12. YOUR RIGHTS AS A DATA SUBJECT

Under POPIA and GDPR, data subjects have certain rights regarding their personal information. These rights may include:

  • Right to be informed: The right to know about the collection and use of your personal information.
  • Right of access: The right to request access to the personal information we hold about you.
  • Right to rectification: The right to request that inaccurate or incomplete personal information about you be corrected or completed.
  • Right to erasure (“Right to be forgotten”): The right to request the deletion or removal of your personal information under certain circumstances.
  • Right to restriction of processing: The right to request that we limit the way we use your personal information.
  • Right to data portability: The right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit it to another responsible party (primarily under GDPR).
  • Right to object to processing: The right to object to the processing of your personal information, including for direct marketing purposes.
  • Rights in relation to automated decision-making and profiling: The right not to be subject to a decision based solely on automated processing (including profiling) which produces legal effects concerning you or similarly significantly affects you, save in limited circumstances.
  • Right to withdraw consent: Where processing is based on consent, the right to withdraw that consent at any time.

To exercise any of these rights, please contact our Information Officer using the details provided in Section 3. We may require proof of identity to verify your request.

13. COMPLAINTS

If you believe that your personal information has been unlawfully processed, you have the right to lodge a complaint with the relevant supervisory authority:

14. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. The “Last Updated” date at the top of this policy indicates when it was last revised. We encourage you to review this policy periodically. Material changes will be communicated through appropriate channels.

15. APPLICABLE LAWS

This Privacy Policy is governed by the laws of the Republic of South Africa, and you consent to the jurisdiction of the South African courts in respect of any dispute which may arise out of or in connection with the formation, interpretation, substance or application of this Privacy Policy.