Commitment

Tonex Management Solutions Pty Ltd, which operates under the name "Tonex Management Solutions," is deeply committed to the protection of its users' privacy and personal data. As an international organisation, Tonex Management Solutions adheres to the European Union's regulations, specifically the EU GDPR (General Data Protection Regulation, May 2018), and follows guidelines from the South Africa's Protection of Personal Information Act (POPIA) to ensure the security of personal information for individuals within South Africa & the EU and to fulfill its legal responsibilities. This dedication to privacy protection is extended to all Tonex Management Solutions users around the globe. Our privacy policy aligns with POPIA & the EU's GDPR requirements and with similar international laws, including the California Consumer Privacy Act in the USA, demonstrating our commitment to safeguarding user data worldwide.

Data Management

During its operations, the Tonex Management Solutions platform gathers and manages the personal information of both its current and past users and learners. This data collection can occur directly through the information users provide or indirectly via automated technologies like system logs, cookies, web beacons, and through connections with external service providers. The range of data processing activities Tonex Management Solutions engages in encompasses gathering, documenting, preserving, modifying, sharing, erasing, and restricting access to data. This policy details the methods Tonex Management Solutions employs for handling data and is relevant exclusively to the data processing activities within Tonex Management Solutions. It does not apply to external entities that might link their systems with the Tonex Management Solutions platform.

PII

During the sign-up process, Tonex Management Solutions may gather Personally-Identifying Information (PII) from users, such as personal email addresses. To complete transactions and issue certifications upon request, further details may be needed. Users are also encouraged to develop a personal profile and resume, sharing details like birth date, educational background, employment history, and career goals, as well as submitting personal data through personality and psychometric tests to tailor their learning experience. Users have the discretion to choose which personal details to display on their public profiles. Tonex Management Solutions ensures the security of all personal data stored in user accounts on the platform, protected by encryption and strict access controls to guarantee privacy and security. Tonex Management Solutions prohibits its employees and any third parties from exporting or extracting any personal data from the platform, with only authorised staff having online access to user account information.

When users decide to post comments on the Tonex Management Solutions Blog or engage publicly with others by sharing course feedback, testimonials, or commenting across the platform, such interactions become accessible to the public or other users, and Tonex Management Solutions will archive this information. By sharing or posting publicly, users give Tonex Management Solutions a non-exclusive right to use, distribute, and leverage the content in various ways. However, Tonex Management Solutions is not liable for how other users may utilise this publicly shared information. Users are advised to be mindful of their public disclosures.

Should a user be highlighted as "Learner of the Day" or "Learner of the Month," Tonex Management Solutions may feature their Registration Information (email address excluded), Profile Data, and Course Details, along with their reaction to the honor, for promotional activities and/or through Tonex Management Solutions Services.

Course Data

When a user signs up, they gain access to courses offered by Tonex Management Solutions or its partner Publishers. Tonex Management Solutions shares collective data regarding users' ages, genders (when provided), and countries of origin with these Publishers under a strict legal contract, ensuring individual user details remain confidential and are not accessible from this summarised information.

Tonex Management Solutions handles specific data essential for the distribution and viewing of course materials by both publishers and learners. This collection of data aids in the unique recognition of users and publishers, tracking learner progress, and maintaining precise records for the delivery of the Tonex Management Solutions educational service, in addition to meeting applicable legal obligations. Users receive regular email updates about their course progress, alongside tailored advice and recommendations. Furthermore, Tonex Management Solutions and its Publishers collect and analyse patterns in user interaction and course evaluations, storing this information as metadata. This process helps both Tonex Management Solutions and its Publishers to enhance their offerings and recommend the most relevant content and courses to users.

Third Party Risk

User Data Storage and Handling

Tonex Management Solutions securely stores all user personal information on third-party, cloud-based servers. For the shipment of physical products, Tonex Management Solutions collects home delivery addresses. Partners in payment processing and order fulfilment might access sensitive personal identification information to assist in payment collection and the delivery of goods. Tonex Management Solutions does not handle highly sensitive data like credit card details and passwords directly when users utilise third-party authentication methods (such as social media logins) or choose external payment services (like PayPal or Apple Pay). Recurring payment information is maintained by the third-party payment service chosen by the user. Upon using social media accounts for single sign-on registration, Tonex Management Solutions only accesses essential data such as the user's name, email, and country, without collecting information on the user's social network and contacts. The data available through these third-party services is subject to their terms and privacy practices.

Analytical Tools and User Tracking

Tonex Management Solutions employs various analytical tools and tracking mechanisms, including tags, scripts, and pixels provided by third-party services like Google, Facebook, Bing, and Hotjar. These tools enable the analysis of browser and mobile app usage, tracking page visits and user sessions, which assists Tonex Management Solutions in understanding user interactions within its platform.

Advertisement and External Cookies

To support its free learning services, Tonex Management Solutions utilises advertising facilitated by external agencies. It engages in both purchasing and offering online advertisements through third-party channels, including Google AdWords, Bing, Facebook Ads, and Google AdSense. These advertising providers deploy cookies and tracking pixels, acting as independent data controllers, to deliver personalised ads to users based on their browsing intentions, search history, and accumulated demographic profiles. Tonex Management Solutions lacks access to and influence over these third-party cookies or the tracking methods employed by advertising service providers, and does not control the use of data collected by them.

Usage Information

Tonex Management Solutions, as a digital education platform, analyses web server logs to gain insights into user engagement and trends. This involves capturing data like device specifics and IP addresses to monitor site traffic and user activities, which aids in optimising technical support and customer services.

To enhance user interaction, Tonex Management Solutions employs cookies, which are small text files placed on the user's device. These cookies facilitate the tracking of individual sessions and the customisation of the user experience on Tonex Management Solutions. Various types of cookies, including those for preferences, security, functionality, and sessions, are utilised to personalise the interface, streamline the login process, and support transactional processes.

Additionally, Tonex Management Solutions uses web beacons in emails to track if messages have been opened and interacted with by recipients, aiding in the assessment of communication effectiveness. Tonex Management Solutions prioritises the privacy of its users and ensures that information collected through cookies or web beacons is not disclosed to external parties.

Digital Rights

By engaging with Tonex Management Solutions Services and submitting your data, you agree to its collection and utilisation by Tonex Management Solutions. You must maintain the accuracy of your personal information on the platform, and you have the liberty to alter or remove your data and account whenever you choose. Additionally, you can adjust settings related to cookies, beacons, and other external services through your email application, web browser, or the operating system of your mobile device. Be mindful that altering these settings or opting out of certain advertising preferences may impact the performance or accessibility of various PledgePoint services.

If you are interested in managing how your data is used by the digital advertising sector, you can explore the opt-out options provided by the Network Advertising Initiative or the Digital Advertising Alliance. For those wishing to opt out of Google Analytics for display advertising or to modify Google Display Network ads, the Google Ads Settings page offers relevant choices. Opting out of targeted advertising does not eliminate ads, but rather the personalisation aspect. PledgePoint is not associated with these industry efforts and bears no responsibility for their use; how you choose to use these tools is up to you.

Tonex Management Solutions is committed to protecting the privacy of young users and stipulates that children under 13, or 16 in the European Economic Area, must have continuous supervision by a parent or guardian to use its services. Should Tonex Management Solutions become aware of an account created by a child without appropriate consent, it will be terminated immediately. Parents or guardians who discover that Tonex Management Solutions has inadvertently collected personal information from a child are encouraged to reach out to our data protection officers, who will ensure the information is promptly removed.

Data Archiving

Tonex Management Solutions is legally required to preserve certain information for a designated duration. Furthermore, Tonex Management Solutions anonymises and consolidates data from deactivated user accounts for business analytics and other pertinent objectives, retaining this information for as long as necessary. This retention includes maintaining Other Information beyond the deletion of a user's account, for a timeframe sufficient to support legitimate business endeavours, carry out audits, comply with legal responsibilities, address disputes, and uphold business contracts.

Data Protection

Tonex Management Solutions prioritises the security and privacy of data stored electronically. Despite being a widely used platform and potentially targeted by hackers, Tonex Management Solutions has implemented robust security measures to protect against unauthorised access. These measures include access restrictions to safeguard against the unauthorised viewing, modifying, disclosing, or deleting of personal data, strict adherence to data retention schedules, logs to track data access and modifications, and the use of pseudonymisation, anonymisation, and encryption techniques.

Access to platform databases is limited to certified DevOps administrators, who must pass multi-factor authentication to access sensitive data, ensuring stringent control. Security protocols are regularly evaluated and updated based on new technology, cost considerations, and the risk landscape.

Customer Support staff are granted minimal access to personal and third-party data, which they are prohibited from sharing or removing unless required by their job duties or legal obligations. Violations of data protection guidelines are treated seriously and can result in disciplinary actions, including termination. All PledgePoint employees are expected to comply with data protection standards, such as processing data in a fair, legal, and transparent manner, maintaining data accuracy, securing data, limiting data retention, and ensuring data is used only for its intended purpose.

Users also play a crucial role in maintaining the security of their accounts by using strong, private credentials and monitoring account activity. In case of suspected unauthorised access, users should immediately change their password and notify Tonex Management Solutions customer support to mitigate potential risks.

Should a data breach occur that may compromise personal rights and freedoms and cannot be adequately contained, affected individuals will be promptly notified. Additionally, Tonex Management Solutions' data protection officers will report the incident to the Data Protection Commissioner in Ireland to ensure oversight and management of the response.

Privacy Officers

The ultimate accountability for the management of your data rests with the company's directors, who have designated a specific Data Protection Officer (DPO) for Tonex Management Solutions. The role of the DPO is to assist the organisation in maintaining adherence to and overseeing compliance with data protection regulations.

Should you have any questions or concerns about data protection and privacy, you are encouraged to contact us at info@tonexms.co.za.

Data Requests

Tonex Management Solutions recognises that individuals globally have legal rights concerning their personal information. Under relevant laws, subject to certain conditions, users can access, amend, or erase their data through the self-service options available in their Tonex Management Solutions User Account. For those seeking a comprehensive extract of their electronic data as registered users, Tonex Management Solutions Customer Services can be contacted.

Upon a user's request for account deletion, Tonex Management Solutions commits to removing all personally identifiable information (PII), including profile and resume details, and permanently anonymising the user's learning history. Utilising Tonex Management Solutions' self-service features is complimentary, although the company maintains the right to impose a fee for processing additional requests for data access. Typically, Tonex Management Solutions aims to fulfil these requests within a month, though some cases may necessitate up to an additional three months.

Users have the right to access solely their data and will not receive information related to other users or third parties, except data publicly shared on Tonex Management Solutions forums. In such instances, the organisation might take steps to anonymise the user's identity or redact third-party information. Should a user be dissatisfied with the handling of their data access request, they have the right to lodge a grievance with the Data Protection Commissioner in South Africa.

Right To Opt-out

Users are entitled to oppose the processing of their data if it leads to distress, or to seek amendment of any incorrect personal data. Should the objection be justified, the organisation will cease data processing, except in cases where it possesses a compelling legitimate reason that surpasses this right. Tonex Management Solutions is dedicated to resolving any issues raised by individuals and will strive to alleviate any discomfort resulting from data processing activities. To object, users are advised to send a written request to the Data Protection Officer, including specifics of the concerned data and the nature of the distress it is causing.

Global Data Transfer

International operations, Tonex Management Solutions may need to collect or transfer user personal data across international borders, including to group companies in and outside the European Economic Area and to third-party service providers. This transfer of data is crucial for managing user accounts effectively and providing Tonex Management Solutions services. However, it's acknowledged that not all countries have data protection laws as robust as those in South Africa or the EU. Tonex Management Solutions is committed to ensuring that any data transferred is afforded a level of protection on par with that provided in Tonex Management Solutions or other leading jurisdictions globally. Data is only shared with entities that commit to upholding this standard of data protection. For more details, users are encouraged to reach out to Tonex Management Solutions' Data Protection Officers.

Compliance review

Tonex Management Solutions has carried out an extensive Data Protection Impact Assessment and put in place suitable policies and procedures to minimise risks to user data privacy and strengthen data security. This policy will be regularly updated to incorporate legal developments and practical insights. Updates will be posted on our website, and significant changes will be directly notified to users through the email address associated with their User Account. Continued use of the Tonex Management Solutions Service implies that users have acknowledged and consented to this policy by relevant laws.