Hilton College

1928/001172/08

PRIVACY POLICY

THIS PRIVACY POLICY (“POLICY”) GOVERNS THE PROCESSING OF PERSONAL INFORMATION BY Hilton College IN CONNECTION WITH Hilton College’S ARCHIVE WEBSITE (“WEBSITE”) LOCATED AT http://hiltoncollege.africamediaonline.com/. YOUR USE OF THE WEBSITE IS SUBJECT TO THIS POLICY. BY USING THIS WEBSITE, YOU SIGNIFY YOUR CONSENT TO PROCESSING OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY.

Hilton College MAY AMEND THIS POLICY AT ANY TIME. AMENDED TERMS SHALL BE EFFECTIVE IMMEDIATELY UPON THE POSTING OF THE REVISED POLICY AND ANY SUBSEQUENT ACTIVITY IN RELATION TO THE WEBSITE SHALL BE GOVERNED BY SUCH AMENDED TERMS. IF YOU DO NOT AGREE WITH ANY TERM IN THIS POLICY, PLEASE DO NOT USE THIS WEBSITE.

This Agreement was last revised on [Revised date].
Enquiries: Bev Davidge

1. PERSONAL INFORMATION COLLECTION AND USE
   1. Subject to consent, Hilton College collects, stores and uses information from Archive Content Subjects (persons whose personal information is determined from the digitisation or digital processing of records belonging to Hilton College) for the following purposes:
      1. to compile and maintain an archive for Hilton College,
      2. to be published in marketing and communications materials, including but not limited to, school magazines, brochures, newsletters and published photographs on the Website or otherwise,
      3. to provide the Archive Content Subjects with direct marketing communications regarding Hilton College’s activities and news.
   2. We collect Personal Information from the following persons:
      1. natural persons over 18,
      2. natural persons under 18 with the consent of a competent person,
      3. juristic persons such as companies duly represented by a representative,
      4. people who send enquiries or requests to our contact email address.
   3. Categories of persons listed in clause 1.4 may include Website Users and Archive Content Subjects and in certain instances persons may categorised as both.
   4. Hilton College may also automatically collect and store non-personally identifiable information from Your use of the Website.
   5. Hilton College may collect the following personal information from Website Users:
      1. name,
      2. surname,
      3. username and password,
      4. job description,
      5. organisation name,
      6. organisation type,
      7. organisation URL,
      8. email address,
      9. telephone number,
      10. mobile telephone number,
      11. facsimile number,
      12. address,
      13. city and province,
      14. postal code,
      15. country,
      16. type of organisation,
      17. the market the organisation serves,
      18. non-personal browsing habits and click patterns,
      19. IP address,
      20. purchasing information and buying patterns,
      21. any additional information necessary to deliver our services,
      22. details of responses to Your enquiries and any online communications between us and You, and
      23. any information provided to us by You.
   6. Hilton College may collect the following personal information from Archive Content Subjects: 1.8.1 name,
      1. name,
      2. surname,
      3. date of birth,
      4. age,
      5. gender,
      6. race,
      7. language,
      8. culture,
      9. physical health,
      10. ethnic origin,
      11. education information,
      12. religion,
      13. disability,
      14. marital status,
      15. pregnancy,
      16. mental health,
      17. biometric information,
      18. location information,
      19. employment history,
      20. personal opinions, views or preferences,
      21. The views or opinions of another individual about the person;
      22. videos recordings,
      23. audio recordings,
      24. manuscripts,
      25. photographs, and
      26. any additional information that can form part of the archive of Hilton College.
   7. We may use cookies or other tracking technologies to collect information such as the pages You visit or the information You request. The Website hosting agents and/or service providers may automatically log Your “IP address” which is a unique identifier for Your computer and/or other access device. Such information collected is for aggregate purposes only.
2. CONSENT TO PROCESS YOUR PERSONAL INFORMATION
   1. If You are a Website User, You consent to the processing of Your Personal Information specifically including (i) to greet the User when he/she accesses the Website, (ii) to inform the Website User of facts relating to his/her access and use of the Website as well as to assist with problems, (iii) to provide the Website User with access to the Website and the associated Website services, (iv) to provide the Website User with direct marketing communications regarding Hilton College’s activities and news, and/or (v) to compile non-personal statistical information about browsing habits, click-patterns and access to the Website.
   2. If You are an Archive Content Subject, You consent to the processing of Your Personal Information specifically including (i) to compile and maintain an archive for Hilton College, (ii) to be published in marketing and communications materials, including but not limited to, school magazines, brochures, newsletters and published photographs on the Website or otherwise, and/or (iii) to provide the You with direct marketing communications regarding Hilton College’s activities and news.
   3. The processing of Your Personal Information shall include the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation, use; dissemination by means of transmission, distribution or making available in any other form; or merging, linking, as well as blocking, degradation, erasure or destruction of information.
   4. By using our Website, You represent that You are of the age of 18 or older or that you have necessary authorisation from a competent person and that you consent to Your Personal Information to be processed by Hilton College.
   5. You expressly consent to Hilton College retaining Your Personal Information once Your relationship with Hilton College has been terminated for: aggregate, statistical, reporting and historical purposes.
   6. In the event that You wish to revoke all consent pertaining to Your Personal Information and/or You would like Hilton College to remove and/or delete Your Personal Information entirely, You may contact Hilton College via email to museum@hiltoncollege.com
3. HANDLING OF PERSONAL INFORMATION
   1. Hilton College endeavours to comply with all laws and regulations applicable to Hilton College pertaining to information and communications privacy including, but not limited to, the 1996 South African Constitution and the Protection of Personal Information Act 4 of 2013 (“the Act”). Hilton College applies the principles of protection of Personal Information under such Act and further legislation referred to in the Act.
   2. Hilton College seeks to ensure the quality, accuracy and confidentiality of Personal Information in its possession. You warrant that all personal information supplied by You is both true and correct at the time of provision. In the event of any aspect of Your personal information changing post submission, it is Your responsibility to immediately notify Hilton College of the said changes by email to Bev Davidge. You agree to indemnify and hold Hilton College, its officers, directors, employees, agents, and suppliers harmless from and against any claims, damages, actions and liabilities including without limitation, indirect, incidental, special, consequential or punitive damages arising out of Hilton College’s reliance on Your personal information should Your personal information contain any errors or inaccuracies.
   3. You warrant that You have the authority, permissions and consents to provide Hilton College with any third party information submitted to Hilton College.
   4. Hilton College will take all reasonable measures in order to ensure Your Personal Information is appropriately safeguarded, these precautions include, but are not limited to: access control mechanisms via username and password, and software protection for information for security.
   5. Should an unauthorised person/s gain access to Your Personal Information Hilton College will contact You within a reasonable time to inform You of such access.
   6. Hilton College may share Your PersonaI Information with authorised third parties such as service providers to Hilton College. These include, but are not limited to digital archiving service providers. Hilton College does not permit these parties to use such information for any other purpose than to perform the services that Hilton College has instructed them to provide. All processing is compatible with such purpose.
   7. Hilton College may appoint certain agents, third parties and/or service providers which operate outside the borders of the Republic of South Africa. In these circumstances Hilton College will be required to transmit Your Personal Information outside South Africa. The purpose of the trans-border transfer of Your Personal Information may include, but is not limited to: data hosting and storage. You expressly consent to the trans-border flow of Your Personal Information.
   8. The Website may contain links to other websites. Hilton College is not responsible for the privacy practices of such third party websites.
4. RECORDS OF PERSONAL INFORMATION
   1. Records relating to the provision of Hilton College products and/or services by Hilton College to You and the Personal Information submitted by You is retained for publication on the Website and/or to provide you with the Website services.
   2. Such records may be required to be retained in terms of legislated records retention requirements, Hilton College’ operational purposes and/or for production as evidence by Hilton College in legal proceedings.
   3. In terms of Section 14(2) of the Act records of personal information may be retained for periods in excess of those contemplated in 4.1 for historical purposes. Hilton College warrants that appropriate safeguards are in place to prevent the records being used for any other purpose.
   4. Hilton College may disclose Your Personal Information under the following circumstances: 4.4.1 To comply with the law or with legal process;
      1. To protect and defend Hilton College’s rights, equipment, facilities and other property;
      2. To protect Hilton College against misuse or unauthorised use of the Website and/or products and/or services; and/or
      3. To protect other Website Users or third parties affected negatively by Your actions in use of the products/services and/or the Website.
5. ACCEPTABLE USE
   In connection with the Digital Archive Material (as made available through the Website) You agree that:
   1. No Item containing the image of or reference to a person is to be used for a purpose other than for which rights are granted by Hilton College, without prior express written permission of Hilton College.
   2. Only a single digital copy of an Item may be stored on a single computer, hard drive, or any other storage device, and that that copy may not be duplicated in any way whatsoever, except for a single backup copy which may only be used in the event of the original being deleted, lost, or irreparably damaged.
   3. Once the Item has been used for the purpose for which use rights were granted, all copies of the Item must be deleted, apart from where it forms part of the archive of what was published.
6. OBJECTIONS, COMPLAINTS AND QUERIES
   1. Should You have any questions about this Privacy Policy, require a correction to be made to Your Personal Information that Hilton College keeps on record, request a copy of the record itself, lodge an objection to the collection, Use or processing of Your Personal Information by Hilton College, or delete Your personally identifiable information, you may send an e-mail to museum@hiltoncollege.com
   2. There may be instances where we cannot grant You access to the Personal Information we hold. We may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. Should this be the case, we will give You written reasons for any refusal.