1. Introduction

The following statement is in terms of the Protection of Personal Information Act, 2013 (“POPI”) and is intended to govern your interactions and business dealings with Dolphins Swim School.

Please note that in this statement, “Third Parties” include, but are not limited to; Operators, shareholders, subsidiaries, affiliated companies or joint ventures, suppliers and parties providing products, goods, equipment, systems and services, such as information technology.

“Personal Information” means any information or set of information that identifies a person and is processed by or on behalf of Dolphins Swim School, as described in Chapter 1, section 1 of POPIA.

2. Processing of Customer Personal Information

Dolphins Swim School may only process customer Personal Information on its systems, in accordance with POPIA, insofar as it is given consent by customers; is necessary to carry out action for the conclusion or performance of a contract to which the customer is a party; as part of an obligation imposed by law on Dolphins Swim School; protects a legitimate interest of a customer; is necessary for pursuing the legitimate interests of Dolphins Swim School or a Third Party to whom information is supplied.

3. Distribution of Personal Information to Third Parties

Dolphins Swim School may provide access or transfer Personal Information to Third Parties where it is necessary in the course of and for the purpose of giving effect to Dolphins Swim School business activities with its customers, in accordance with that expressed above viz-a-viz its terms and conditions, or as otherwise required by law.

Dolphins Swim School undertakes to take reasonable practicable steps to ensure that customer Personal Information that may be transferred to Third Parties is dealt with confidentially and in accordance with applicable legal requirements by those Third Parties.

Dolphins Swim School shall only transfer Personal Information to Third Parties in other jurisdictions where such Third Parties are subject to and comply with such laws, policies or agreements regarding privacy, data protection and confidentiality of Personal Information as may legally be required from time to time.

Dolphins Swim School may disclose customers’ Personal Information to any Third Party service providers whose services or products customers elect to use provided that it has obtained the necessary consent, or it is in terms of the conclusion and/or performance of contract between Dolphins Swim School and the customer, or there is another justification to the disclosure and processing. Dolphins Swim School will have agreements in place to ensure that they comply with confidentiality and privacy conditions.

Dolphins Swim School aims to have undertakings in place with relevant Third Parties to ensure there is a mutual understanding with regard to the protection of Personal Information, such Third Parties will be required to comply with the same or substantially similar regulations as Dolphins Swim School is subjected to.

4. Receiving Personal Information as a Third Party

During the course of conducting its business as a hosting service provider, Dolphins Swim School will collect Third Parties’ Personal Information from time to time. Dolphins Swim School will Process the Personal Information received from customers on behalf of the customer’s data subjects in conjunction with its terms and conditions and in respect of legislative requirements.

Dolphins Swim School will accordingly ensure that in Processing or storing (as a hosting service provider) a Third Party’s Personal Information, it will adhere to its obligations in terms of POPIA.

In the capacity of a Third Party, Dolphins Swim School will comply with all of its obligations as provided for in POPI.