Data Processing Addendum

1. Who we are and our roles

delvoroq.site is the service provider responsible for providing course and lead-related services. Depending on the specific processing, delvoroq.site acts as a responsible party (controller) when it determines the purpose of and means for processing, and/or as an operator (processor) when it processes personal data on behalf of another responsible party, as these terms are used in POPIA.

Business details (ZA): delvoroq.site; 87 Commercial Rd, Sidwell, Gqeberha, 6001, South Africa; [email protected]; +27 41 521 0112; legal representative: Thandiwe Mokoena, Managing Director.

2. Types of personal data

We may process the following categories of personal data when you request course information, register for a course, or submit a contact/lead form:

• Contact details: name, email address, phone number (where provided/required).
• Request details: information you enter in the form (e.g., course selection, questions).
• Communication and support history.
• Technical and usage data related to form submissions and website interaction (e.g., IP address, browser/device identifiers, timestamps), to maintain service availability and security.

3. Purposes of processing

• To respond to and manage lead/contact inquiries and provide requested course information.
• To administer course registration and, where applicable, conclude and perform distance arrangements.
• To provide customer support and handle service-related requests.
• To ensure security, fraud prevention, and compliance with applicable legal obligations.

4. Lawful basis for processing (ZA)

Where required, processing is carried out on lawful grounds under the relevant South African data protection, consumer and electronic transactions rules, including:

• Personal information: Protection of Personal Information Act 4 of 2013 (POPIA), including the conditions for lawful processing and the justifications in section 11.
• Consumer protection: Consumer Protection Act 68 of 2008 (including the right to information in plain and understandable language).
• Electronic transactions: Electronic Communications and Transactions Act 25 of 2002 (ECTA), including mandatory information for consumers before they commit, where online agreements or distance transactions are concluded.
• Supervisory authority: the Information Regulator (South Africa), which oversees compliance with POPIA and handles complaints from data subjects.

If processing requires consent under applicable law, we present the relevant consent choices at the time of collection, consistent with POPIA.

5. Disclosure to subprocessors and safeguards

We may share personal data with subprocessors that provide services necessary to deliver courses and manage leads (for example, hosting, email/communications, analytics, customer support tools, and other operational services). Where we use subprocessors (operators), we apply written contractual and organisational measures designed to protect personal data, as required by sections 20 and 21 of POPIA, including confidentiality obligations and security controls appropriate to the risks.

We do not sell personal data. We share personal data only to the extent necessary for the purposes described in this Addendum and in accordance with applicable law.

6. Cross-border transfers

If personal data is processed or stored outside South Africa as part of using subcontractors or technical infrastructure, we ensure that such transfer is lawful and supported by appropriate safeguards under section 72 of POPIA.

7. Data retention

We retain personal data only for as long as necessary for the purposes described above, including to provide services, handle inquiries, resolve issues, maintain security, and comply with legal obligations. Retention periods may vary by processing purpose and system requirements.

8. Security measures

We implement reasonable technical and organisational security measures to protect personal data against unauthorised access, loss, destruction, alteration, and disclosure, taking into account the nature of the data and the risks associated with processing, as required by section 19 of POPIA.

9. Your rights

If you are a data subject, you may have rights under POPIA regarding access to your personal data, correction, deletion or objection to processing in cases provided by law, and the right to lodge a complaint with the Information Regulator (South Africa). To exercise your rights, contact us using the details below.

10. Contact

For questions about personal data processing, subprocessors, or your rights, contact:

delvoroq.site
87 Commercial Rd, Sidwell, Gqeberha, 6001, South Africa
[email protected]
+27 41 521 0112