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CONSUMER DATA PRIVACY POLICY

EFFECTIVE DATE: 28 JULY 2026

 

1. WHO WE ARE

 

BE UNLIMITED LEARNING AND COACHING (PTY) LTD, registration number 2025/252505/07 (trading as BE UNLIMITED), and administering the My Second50 | Midlife Reimagined, the South African Midlife Women’s Initiative (SAMWI), the South African Midlife Men’s Initiative (SAMMI), is responsible for the personal information described in this Policy.

 

In this Policy, “My Second50”, “SAMWI”, “SAMMI”, “we”, “us” and “our” refer to the legal entity identified above.

 

We process personal information in accordance with the Protection of Personal Information Act, commonly known as POPIA, and other applicable South African laws.

 

 

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2. SCOPE OF THIS POLICY

 

THIS POLICY APPLIES WHEN YOU:

 

  • Visit or use our website;

  • Register for a conversation, event, training, workshop or programme;

  • Purchase a product or service;

  • Complete an assessment, survey or enquiry form;

  • Communicate with us;

  • Join a WhatsApp group or SAMWI/SAMMI Circle;

  • Subscribe to our communications;

  • Participate in photographs or recordings; or

  • Otherwise provide personal information to us.

 

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3. PERSONAL INFORMATION WE MAY COLLECT

 

Depending on your interaction with us, we may collect:

 

3.1 IDENTITY AND CONTACT INFORMATION

 

  • Name and surname;

  • Title or preferred name;

  • Email address;

  • Mobile or telephone number;

  • Age range or life stage;

  • City, province, area or location; and

  • Organisation, occupation or professional role.

 

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3.2 REGISTRATION AND PARTICIPATION INFORMATION

 

  • Selected event, Conversation, programme or session;

  • Booking and attendance information;

  • Dietary requirements;

  • Accessibility requirements;

  • Emergency or participation-related information;

  • Topic interests and preferences;

  • Questions, comments, feedback and survey responses; and

  • Information supplied by a sponsor, employer or person making a booking on your behalf.

 

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3.3 TRANSACTION INFORMATION

 

  • Order and booking details;

  • Billing information;

  • Payment status;

  • Invoice and receipt information;

  • Refunds, cancellations and transfers; 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 your complete payment-card details.

 

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3.4 DIGITAL AND TECHNICAL INFORMATION

 

We may collect limited technical information when you use our website, including:

 

  • Device and browser information;

  • Internet protocol address;

  • Pages visited;

  • Website interactions;

  • Cookies and similar technologies; and

  • General website usage and performance data.

 

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3.5 PHOTOGRAPHS AND RECORDINGS

 

Where you have given permission, we may process identifiable:

 

  • Photographs;

  • Video recordings;

  • Audio recordings; and

  • Participant comments or testimonials.

 

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3.6 SPECIAL PERSONAL INFORMATION

 

Dietary, accessibility or health-related information may constitute special personal information under POPIA.

 

We will collect this information only where it is reasonably necessary and where an appropriate legal basis, including your consent where required, exists.

 

You are not required to provide more health information than is reasonably necessary for us to support your safe and appropriate participation.

 

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4. HOW WE COLLECT PERSONAL INFORMATION

 

We may collect personal information:

 

  • Directly from you;

  • Through our website, forms and surveys;

  • When you register or make a purchase;

  • When you communicate with us;

  • From an employer, sponsor or booking organiser acting on your behalf;

  • From a participant transferring a booking to you;

  • From authorised 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.

 

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5. WHY WE PROCESS PERSONAL INFORMATION

 

We may process personal information to:

 

  • Respond to enquiries;

  • Administer registrations and bookings;

  • Process payments, invoices, refunds and transfers;

  • Supply products, digital resources and services;

  • Communicate event and programme arrangements;

  • Manage attendance, catering and accessibility;

  • Provide coaching, assessments, reports and programme support;

  • 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 website;

  • Undertake research, evaluation and impact measurement;

  • Produce aggregated or de-identified insights;

  • Report on events and initiatives;

  • Use photographs and recordings where appropriate permission exists;

  • Send news, invitations and promotional communications where legally permitted; and

  • Protect our rights, participants, staff, facilitators and service providers.

 

We will not use your personal information for an unrelated purpose unless that use is permitted by law or we have obtained any additional consent that may be required.

 

 

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6. MANDATORY AND OPTIONAL INFORMATION

 

Information required to:

 

  • Identify you;

  • Process your payment;

  • Administer your booking;

  • Provide the product or service; or

  • Meet a legal obligation.

 

may be mandatory.

 

If you do not provide mandatory information, we may be unable to complete your registration, process your purchase or provide the relevant product or service.

Information relating to:

 

  • Marketing;

  • Future SAMWI/SAMMI communications;

  • Photographs and recordings;

  • Optional demographic questions;

  • Research questions; and

  • Participation in a WhatsApp group or SAMWI/SAMMI Circle

 

is generally voluntary unless clearly stated otherwise.

 

Your decision not to consent to optional marketing, photography or WhatsApp participation will not prevent you from attending an event or purchasing an unrelated product or service.

 

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7. 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 with you;

  • 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.

 

You may withdraw consent where processing is based on consent. Withdrawal will not affect processing that took place lawfully before the consent was withdrawn.

 

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8. 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 communications providers;

  • Venues, caterers, facilitators, coaches and event service providers;

  • Delivery and fulfilment providers;

  • Accountants, auditors, insurers, attorneys and professional advisers;

  • Authorised My Second50, SAMWI and SAMMI 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 your personal information.

 

Strategic partners may use identifiable personal information for their own promotional purposes only where an appropriate legal basis or permission exists.

 

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9. WHATSAPP GROUPS AND SAMWI/SAMMI CIRCLES

 

Joining a WhatsApp group is optional.

 

When you join a WhatsApp group:

 

  • Your mobile number may be visible to other members;

  • Your WhatsApp name, profile photograph and profile information may also be visible, depending on your privacy settings;

  • Information you post will be visible to other group members; and

  • WhatsApp and its related service providers will process information in accordance with their own terms and privacy practices.

 

You may leave a WhatsApp group at any time.

 

Consent to join a group for a particular Conversation does not automatically constitute consent to:

 

  • Join a future SAMWI/SAMMI Circle;

  • Be added to another WhatsApp group; or

  • Receive unrelated promotional communications.

 

Separate permission will be obtained where required.

 

 

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10. DIRECT MARKETING

 

We may send information about My Second50, SAMWI and SAMMI programmes, events, products, services, opportunities and initiatives where:

 

  • You have consented; or

  • Another lawful customer relationship permits us to do so.

 

Electronic marketing communications will identify the sender and provide a reasonable method for you to unsubscribe or object.

 

You may withdraw your marketing consent or unsubscribe at any time by:

 

  • Using the unsubscribe option provided;

  • Replying “stop” where applicable;

  • Leaving the relevant WhatsApp group; or

  • Contacting us at connect@mysecond50.info.

 

Withdrawing marketing consent will not affect essential communications relating to a current purchase, booking, event or service.

 

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11. PHOTOGRAPHS, AUDIO AND VIDEO RECORDINGS

 

We will request permission where identifiable photographs, audio recordings or video recordings are intended for event reporting, editorial, awareness or promotional purposes.

 

Photography and recording consent is optional and is not a condition of attendance unless the nature of a particular production or event is clearly disclosed in advance.

 

You 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 we received your withdrawal request.

 

 

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12. INTERNATIONAL PROCESSING

 

Some of our technology, payment, communications, website or cloud-service providers may process 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.

 

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13. INFORMATION SECURITY

 

We use reasonable technical and organisational safeguards to protect personal information against:

 

  • Loss;

  • Unauthorised access;

  • Misuse;

  • Alteration;

  • Disclosure; and

  • Destruction.

 

Access is limited to authorised persons who reasonably require the information.

 

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.

 

 

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14. 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 transaction and attendance 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 or planning purposes.

 

 

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15. YOUR PRIVACY RIGHTS

 

Subject to POPIA and other applicable laws, 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.

 

We may require reasonable proof of identity before responding to a request.

 

Some information may need to be retained despite a deletion request where retention is required by law, contract or legitimate legal purposes.

 

 

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16. 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

 

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17. OUR PRIVACY CONTACT DETAILS

 

RESPONSIBLE PARTY: BE UNLIMITED LEARNING AND COACHING (PTY) LTD
REGISTRATION NUMBER: 2025/252505/07
TRADING NAME: BE UNLIMITED
INFORMATION OFFICER: PRAVIENNA NAIDOO

PHYSICAL ADDRESS: 85 COUNTESSES AVENUE, WINDSOR EAST, 2194
PRIVACY EMAIL: connect@mysecond50.info
TELEPHONE/WHATSAPP: +27 84 983 5918
WEBSITE: www.mysecond50.info

 

 

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18. CHANGES TO THIS POLICY

 

We may update this Policy when our activities, systems or legal obligations change.

 

The latest version will be published on our website with its effective date.

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