CONSUMER PRIVACY AND PERSONAL INFORMATION POLICY
EFFECTIVE DATE: 21 SEPTEMBER 2026
1. WHO WE ARE
BE UNLIMITED LEARNING & COACHING (PTY) LTD, registration number 2025/252505/07, trading as BE UNLIMITED, is responsible for the personal information described in this Policy.
This Policy applies to personal information processed through any programme, initiative, platform, brand, product, service or offering operated, managed or delivered by BE UNLIMITED.
In this Policy, “BE UNLIMITED”, “we”, “us” and “our” refer to the legal entity identified above.
We process personal information in accordance with the Protection of Personal Information Act, 4 of 2013 (POPIA)and other applicable South African laws.
2. SCOPE OF THIS POLICY
This Policy applies when you:
■ Visit or use one of our websites or digital platforms;
■ Register for a workshop, training, event, course, coaching engagement or programme;
■ Purchase a product or service;
■ Complete an assessment, survey, enquiry or registration form;
■ Communicate with us;
■ Join a WhatsApp group, community or programme communication channel;
■ Subscribe to our communications;
■ Participate in photographs, audio or video recordings where applicable;
■ Participate in research, evaluation or impact measurement; or
■ Otherwise provide personal information to us.
This Policy applies both to:
■ The person making or paying for a booking or purchase; and
■ The person participating in or receiving the relevant product, programme or service.
Where these are different people, we may process information relating to both.
3. CHILDREN AND PARTICIPANTS UNDER 18
Some of our programmes and services may be offered to children or young people under 18 years of age.
Where a participant is under 18:
■ Registration must be completed or authorised by a person legally authorised to act on the participant’s behalf;
■ We will collect only information necessary to administer the booking, support, and provide the relevant service;
■ Any consent required for optional processing will ordinarily be obtained from the parent or guardian;
■ A learner’s or minor participant’s contact details will not be used without lawful consent;
■ Participation in communication will require appropriate parent or guardian permission; and
■ Any photography, audio or video recording involving an identifiable minor will require appropriate permission.
We encourage parents and guardians not to provide unnecessary personal, medical or sensitive information about a child unless there is a specific reason for such information.
4. PERSONAL INFORMATION WE MAY COLLECT
Depending on your interaction with us, we may collect the following information.
4.1 Identity and Contact Information
This may include:
■ Name and surname;
■ Preferred name;
■ Email address;
■ Mobile or telephone number;
■ Age or age range;
■ Grade, where relevant;
■ City, province, area or general location;
■ Organisation, occupation or professional role, where relevant; and
■ Parent or guardian details where the participant is under 18.
We do not ordinarily require identity numbers, home addresses or other identifying information unless there is a specific lawful or operational reason to collect them.
4.2 Registration and Participation Information
This may include:
■ Selected event, programme, workshop or session;
■ Booking and attendance information;
■ Participant eligibility information;
■ Relevant accessibility or participation requirements;
■ Emergency information where reasonably necessary;
■ Certificate or completion-record information;
■ Topic interests and preferences;
■ Questions, comments, feedback and survey responses;
■ Information supplied by a person or organisation making a booking on someone else’s behalf; and
■ Information relating to an additional participant or family member included in the same booking.
Where dietary, health or accessibility information is not relevant to the particular programme or service, we will not routinely request it.
4.3 Transaction Information
This may include:
■ Order and booking details;
■ Billing information;
■ Payment status;
■ Invoice and receipt information;
■ Refunds, cancellations, transfers and rescheduling requests; and
■ Related financial and transaction records.
Where payments are processed through iKhokha or another authorised payment provider, payment-card information is handled through the provider’s secure payment system.
We do not intentionally collect or store complete payment-card details.
4.4 Digital and Technical Information
When you use our websites or digital platforms, we may collect limited technical information such as:
■ Device and browser information;
■ Internet protocol address;
■ Pages visited;
■ Website interactions;
■ Cookies and similar technologies; and
■ General website usage and performance information.
4.5 Photographs, Audio, Video and Testimonials
Where appropriate permission exists, we may process:
■ Photographs;
■ Video recordings;
■ Audio recordings; and
■ Participant comments or testimonials.
Not all programmes are photographed or recorded.
Where a particular workshop or programme is not recorded, we will not create an audio or video recording of that session.
4.6 Special Personal Information
Health, accessibility, dietary or similar information may constitute special personal information under POPIA.
We will collect such information only where:
■ It is reasonably necessary;
■ There is an appropriate lawful basis; and
■ Consent is obtained where required.
You are not required to provide more health or personal information than is reasonably necessary for safe and appropriate participation.
Your existing policy already recognises this data-minimisation principle for health and accessibility information.
5. HOW WE COLLECT PERSONAL INFORMATION
We may collect personal information:
■ Directly from you;
■ Through our websites, forms and surveys;
■ When you register or make a purchase;
■ When you communicate with us;
■ From a parent or guardian registering a participant;
■ From an employer, sponsor or booking organiser acting on your behalf;
■ From a participant transferring a booking to you;
■ From authorised programme, event or service partners; and
■ Automatically through website technologies.
Where another person provides your information to us, that person must be authorised to do so and should ensure that you are made aware of this Policy where appropriate.
6. WHY WE PROCESS PERSONAL INFORMATION
We may process personal information to:
■ Respond to enquiries;
■ Administer registrations and bookings;
■ Verify participant eligibility where applicable;
■ Process payments, invoices, refunds, transfers and rescheduling;
■ Supply products, digital resources and services;
■ Communicate workshop, event and programme arrangements;
■ Manage attendance and participation;
■ Provide coaching, assessments, reports and programme support;
■ Produce certificates or records of participation or completion;
■ Maintain financial, legal and operational records;
■ Prevent fraud, misuse and unlawful activity;
■ Comply with legal, tax, accounting and regulatory obligations;
■ Improve our products, programmes, services and websites;
■ Undertake research, evaluation and impact measurement;
■ Produce aggregated or de-identified insights;
■ Report on programmes and initiatives;
■ Use photographs, recordings or testimonials where appropriate permission exists;
■ Send news, invitations and promotional communications where legally permitted; and
■ Protect our rights, participants, staff, facilitators, coaches and service providers.
We will not use personal information for an unrelated purpose unless that use is permitted by law or we have obtained any additional consent that may be required.
7. MANDATORY AND OPTIONAL INFORMATION
Some information may be mandatory where it is required to:
■ Identify the purchaser or participant;
■ Process a payment;
■ Administer a booking;
■ Confirm eligibility;
■ Provide the product, programme or service;
■ Communicate essential participation information; or
■ Meet a legal obligation.
If mandatory information is not provided, we may be unable to complete a registration, process a purchase or provide the relevant product or service.
Information relating to the following will generally be optional unless clearly stated otherwise:
■ Direct marketing;
■ Future programme communications;
■ Participation in WhatsApp groups or similar communication channels;
■ Photographs and recordings;
■ Testimonials;
■ Optional demographic information;
■ Research questions; and
■ Other non-essential programme or community activities.
Choosing not to consent to optional marketing, photography, recording or WhatsApp participation will not ordinarily prevent a person from purchasing or participating in an unrelated product, workshop, programme or service.
8. LEGAL GROUNDS FOR PROCESSING
Depending on the circumstances, we may process personal information because:
■ You have consented;
■ Processing is necessary to conclude or perform an agreement;
■ Processing is required by law;
■ Processing protects your legitimate interests;
■ Processing protects our legitimate interests or those of a third party; or
■ Another lawful justification under POPIA applies.
Where processing is based on consent, you may withdraw that consent.
Withdrawal will not affect processing that took place lawfully before consent was withdrawn.
9. SHARING PERSONAL INFORMATION
We may share relevant personal information with authorised parties where reasonably necessary, including:
■ iKhokha and other payment-service providers;
■ Wix and other website, hosting and technology providers;
■ Email, cloud-storage, booking and communication providers;
■ Venues, facilitators, coaches and programme service providers;
■ Delivery and fulfilment providers;
■ Accountants, auditors, insurers, attorneys and professional advisers;
■ Authorised programme, delivery or strategic partners;
■ Regulators, courts, law-enforcement bodies or public authorities where required; and
■ Another party involved in a lawful business restructuring or transfer.
We will limit the information shared to what is reasonably necessary for the relevant purpose.
We do not sell personal information.
Participant information will not ordinarily be shared with schools, other parents, other participants or unrelated organisations unless:
■ It is necessary for the relevant programme;
■ The person has consented;
■ Another lawful basis exists; or
■ Disclosure is required by law.
Strategic or programme partners may use identifiable personal information for their own promotional purposes only where an appropriate lawful basis or permission exists.
The existing policy already provides that information shared with third parties should be limited to what is reasonably necessary and that personal information is not sold.
10. WHATSAPP GROUPS AND OTHER GROUP COMMUNICATION CHANNELS
Participation in a WhatsApp group or similar group communication channel is optional unless clearly stated otherwise.
When you join a WhatsApp group:
■ Your mobile number may be visible to other members;
■ Your profile information may be visible depending on your privacy settings;
■ Information you post will be visible to other group members; and
■ WhatsApp and its service providers process information according to their terms and privacy practices.
You may leave a WhatsApp group at any time.
Where the participant is under 18:
■ The parent or guardian may choose to use their own number for communication;
■ The learner’s number will only be added if the parent or guardian has provided consent; and
■ The parent or guardian is informed that other group members are able to see the learner’s profile information.
Consent to join one WhatsApp group does not automatically constitute consent to:
■ Join another or future group;
■ Participate in an unrelated community;
■ Receive unrelated promotional communications; or
■ Have the number retained for future marketing purposes.
Separate permission will be obtained where required.
These disclosures preserve the protections already contained in your current WhatsApp provisions.
11. DIRECT MARKETING
Registration for a product, workshop, event or programme does not automatically subscribe a purchaser, parent, guardian or participant to unrelated future marketing.
We may send information about BE UNLIMITED programmes, events, products, services, opportunities and initiatives where:
■ You have consented; or
■ Another lawful customer relationship or lawful basis permits us to do so.
Where marketing consent is requested during registration, it will be presented separately from consent required to administer the current booking.
Electronic marketing communications will identify the sender and provide a reasonable method to unsubscribe or object.
You may withdraw marketing consent or unsubscribe at any time by:
■ Using the unsubscribe option provided;
■ Replying “STOP” where applicable;
■ Leaving the relevant optional marketing group; or
■ Contacting us using the details in this Policy.
Withdrawing marketing consent will not affect essential communications relating to a current purchase, booking, programme or service.
Your existing policy already distinguishes essential programme communications from marketing consent; that separation should be retained.
12. PHOTOGRAPHS, AUDIO AND VIDEO RECORDINGS
We will request appropriate permission where identifiable photographs, audio recordings or video recordings are intended for:
■ Programme or event reporting;
■ Editorial use;
■ Awareness activities;
■ Research or evaluation;
■ Testimonials; or
■ Promotional purposes.
Photography and recording consent is optional unless the nature of a particular production or event has been clearly disclosed in advance.
Where the participant is under 18, appropriate parent or guardian consent will be obtained where required.
A participant or parent/guardian may withdraw consent for future use by contacting us.
Withdrawal will not ordinarily affect material that was lawfully created, published, printed, distributed or supplied to a third party before the withdrawal request was received.
13. MULTIPLE-PARTICIPANT AND FAMILY BOOKINGS
Where one purchaser registers more than one participant:
■ Information relating to each participant will be treated as personal information relating to that individual;
■ The booking and payment records may be linked;
■ Participant-specific information will be used only as reasonably necessary for the relevant service;
■ Information relating to one participant will not automatically be treated as consent on behalf of another; and
■ Where a participant is under 18, the relevant parent or guardian authorisation requirements will apply.
14. RESEARCH, EVALUATION AND IMPACT MEASUREMENT
We may collect feedback, survey responses, participation information and other data to:
■ Evaluate programme effectiveness;
■ Improve future offerings;
■ Understand participant experiences;
■ Measure outcomes or impact; and
■ Produce research, statistical or planning information.
Where possible and appropriate, information used for reporting, research or analysis will be aggregated or de-identified.
Identifiable information will not be published in research or evaluation outputs without an appropriate lawful basis or permission.
15. INTERNATIONAL PROCESSING
Some of our technology, payment, communication, website or cloud-service providers may process personal information outside South Africa.
Where personal information is transferred outside South Africa, we will take reasonably practicable steps to ensure that the transfer is permitted under POPIA and that appropriate protection is in place.
16. INFORMATION SECURITY
We use reasonable technical and organisational safeguards to protect personal information against:
■ Loss;
■ Unauthorised access;
■ Misuse;
■ Alteration;
■ Disclosure; and
■ Destruction.
Access to personal information is limited to authorised persons who reasonably require it.
No electronic system can be guaranteed to be completely secure.
Where a security compromise occurs, we will take appropriate action and provide any notifications required by law.
These safeguards are consistent with the security framework in your current policy.
17. RETENTION OF PERSONAL INFORMATION
We retain personal information only for as long as reasonably necessary to:
■ Fulfil the purpose for which it was collected;
■ Provide products and services;
■ Maintain booking, attendance and participation records;
■ Maintain financial and transaction records;
■ Meet legal, tax, accounting and regulatory obligations;
■ Resolve disputes;
■ Enforce agreements; or
■ Establish, exercise or defend legal rights.
When information is no longer required, we will delete, destroy or de-identify it where reasonably practicable and legally permissible.
De-identified information may be retained for research, statistical, historical, evaluation or planning purposes.
18. YOUR PRIVACY RIGHTS
Subject to POPIA and other applicable law, you may ask us to:
■ Confirm whether we hold personal information about you;
■ Provide access to your personal information;
■ Correct or update inaccurate information;
■ Delete information that we are no longer authorised to retain;
■ Restrict certain processing;
■ Object to processing in appropriate circumstances;
■ Stop using your information for direct marketing; or
■ Withdraw consent where processing is based on consent.
Where a request relates to a participant under 18, we may need to verify the authority of the person making the request.
We may require reasonable proof of identity before responding.
Some information may need to be retained despite a deletion request where retention is required by law, contract or legitimate legal purposes.
19. COMPLAINTS
Please contact us first if you have a privacy concern so that we can attempt to resolve it.
You also have the right to lodge a complaint with the Information Regulator of South Africa.
INFORMATION REGULATOR TELEPHONE | 010 023 5200
INFORMATION REGULATOR EMAIL | POPIAComplaints@inforegulator.org.za
20. OUR PRIVACY CONTACT DETAILS
RESPONSIBLE PARTY | BE UNLIMITED LEARNING AND COACHING (PTY) LTD
REGISTRATION NUMBER | 2025/252505/07
TRADING NAME | BE UNLIMITED
PHYSICAL ADDRESS | 85 COUNTESSES AVENUE, WINDSOR EAST, 2194
EMAIL | connect@mysecond50.info
TELEPHONE / WHATSAPP | +27 84 983 5918
WEBSITE | www.mysecond50.info
21. CHANGES TO THIS POLICY
We may update this Policy when our activities, programmes, systems, technology or legal obligations change.
The latest version will be published on our website with its effective date.