July 2021

The drflett.com(“DRFLETT” or “we”) is committed to protecting your information. This Privacy Notice (the “Privacy Notice”) applies to your use of the websites, apps, and digital platforms provided by DRFLETT  (collectively the “Websites”), and describes how DRFLETT collects, uses, and shares your information when you visit the Websites. It does not apply to information collected by the DRFLETT offline or to third party websites, applications, or services (including our affiliates). 

Contact Information

The Drflett.com is located at 8 Village Road Kloof, Durban and Hillcrest private Hospital Hillcrest. Should you have any comments or questions about how we collect and use your personal information, communication can be directed to DRFLETT at DRFLETT’s postal address, via email to support@drflett.com or by telephone to Phone: +27(031) 1000-474.  

Applicability & Eligibility

Applicability
Before accessing, using, or interacting with the Websites  or completion of forms on the website you should carefully review the terms and conditions of this Privacy Notice. Your use of the Websites is further governed by our Terms of Use, which is also incorporated into your agreement with DRFLETT by this reference. In addition, your use of the Websites is governed by the terms of their respective Institutional License Agreements which are incorporated into your agreement with the DRFLETT by this reference and which must be entered into with the DRFLETT prior to using those Websites and their associated services.

Eligibility To Use The Websites
The Websites are not directed to children under the age of 18. You may not use the Websites if you are under the age of 18. If you are under the age of 18, you should not provide any information on our Websites.  

Information Collection & Use

The DRFLETT collects information( including email addresses) about you and your use of the Websites through various means( including forms on the drflett.com, guidelittleminds.com  and schoolingassessment.com), including when you provide information to us and when we automatically collect information about(including email addresses that are supplied by you when completing forms) you when you access, use, or interact with the Websites. Such processing is performed to provide you with the Websites. By accepting our Privacy Notice and Terms of Use, you are confirming you have read and understand our policies including how and why we use your information.

The types of information the DRFLETT may collect about you include:

Information You Provide To Us:
We process information you provide to us on the legal basis of the DRFLETT’s legitimate interests in performing the function or service you requested. Where appropriate, we may rely on alternate legal bases, such as your consent to certain types of processing.

Account Information: Certain Websites users may register for an account (a “Websites Account”). We do not require you to register to use our Websites. However if you do register a Websites Account, you will gain access to those areas and features of the Websites that require registration. The DRFLETT will collect certain information about you in connection with your registration for a Websites Account, which may include personal data and other information such as a username and password.

Payment Transaction Information: We may collect and store information related to purchases and donations made through the Websites. You may provide certain information to complete payments via the Websites, including your credit or debit card number, card expiration date, CVV code, and billing address (collectively, “Payment Information“), along with your name and billing, delivery and shipping address, to complete payment transactions through certain Services.

If you choose to purchase any products or services online via the DRFLETT website using a credit card, your credit card information (i.e., credit card number, CVC code, and expiration date) will be encrypted and securely transmitted to our 3rd party credit card transaction processor.  The DRFLETT works with Service Providers (as defined below) to handle payment transactions. The DRFLETT does not process credit card transactions internally. However, we do store credit card information in our Association Management System’s (AMS) database to allow our customers to re-use credit cards for later purchases by calling our Customer Support Centre. This credit card information is encrypted with 256-bit encryption and is not accessible by the Customer Support Centre staff which facilitate these payments utilizing our Service Provider’s payment system. If you use the “Remember Me” feature at checkout, DRFLETT will encrypt and securely store your email address, payment card number, CVC code, and expiration date in order to conveniently process payments for subsequent purchases using that credit card. 

You are subject to the Privacy Policies and Terms and Conditions of our Service Providers when purchasing an DRFLETT membership, shopping for DRFLETT products, or making donations, the terms of which may differ from those of the DRFLETT for the Websites. Please review the Service Providers’ Privacy Policies and Terms and Conditions before using their services. 

Correspondence Information: If you sign up, email us, subscribe to our blog, newsletters,  completion of any forms by parents, teachers or any relevant persons involved in the care or management of the patient or child, mailing lists, we may keep your message, email address, and contact information to respond to your requests, provide the requested products or Websites, and to provide notifications, relevant educational information as we deem necessary, or other correspondences to you. If you do not want to receive communications from us in the future, please let us know by sending us an e-mail requesting the same to email support@drflett.com  or by following the unsubscribe instructions found in any e-mail we send. All emails are managed by reputable email service providers that comply with ethical international standards. If you supply us with your email, you may receive periodic mailings from us with information on new products and services or upcoming events. If you do not wish to receive such mailings, please let us know by contacting us at support@drflett.com  or by calling our phone number provided above. Please note requests to remove your email address from our lists may take some time to fulfil. We may also still contact you as needed to provide important announcements or notifications regarding the Websites. 

Support Information: You may provide information to us via a support request submitted through the Websites. We will use this information to assist you with your support request and may maintain this information to assist you or other users with support requests. Please do not submit any information to us via a support submission, including confidential or sensitive information that you do not wish for the DRFLETT or our Service Providers to have access to or use in the future. 

Form Information: We may use forms to request certain information from you on the Websites, such as your contact information to assist with contacts or service requests. This information may include personal data. Based on your information and email supplied in completion of the online forms on this website we may from time to time email you useful information regarding a wide range of medical topics. If you do not wish to receive these emails please unsubscribe and your email will be removed from the data base.

Information We Collect Automatically:
We use automatic data collection and analytics technologies to collect aggregate and user-specific information about your equipment, domain name, patterns of use, communication data and the resources that you access and use on the Websites, including your IP address, browsing and navigation patterns. This information is used to improve our Websites. We process information collected automatically on the legal basis of the DRFLETT’s legitimate interests in assessing the use of its Websites. Information we collect automatically through your use of the Websites includes:

Cookies, Web Beacons, Links, And Other Tracking Technologies: DRFLETT may keep track of how you use and interact with the Websites through the use of cookies, web beacons, links, and other tracking technologies.  We do this to help analyze the use of and improve the Websites. Through these technologies we may automatically collect information about your use of the Websites and other online activities, including our email correspondences, third-party services, and client applications, and certain online activities after you leave the Websites. Link information is generally only analyzed on an aggregate basis. Some Websites may not function properly if you disable cookies. Such data may include analytics information, sites visited before visiting the Websites, browser type, operating system, and tracking of your interactions with our content and emails. 

We partner with third parties to manage our advertising on other sites. Our third-party partners may use cookies or similar technologies in order to provide you with advertising based upon your browsing activities and interests. 

Unique Identifiers: When you use or access the Websites, we may access, collect, monitor, store on your device, and/or remotely store one or more “Unique Identifiers,” such as a universally unique identifier (“UUID”). A Unique Identifier may remain on your device persistently, to help you log in faster and enhance your navigation through the Websites. Some features of the Websites may not function properly if use or availability of Unique Identifiers is impaired or disabled. 

Analytics Information: We use data analytics to ensure site functionality and improve the Websites. We use mobile analytics software to allow us to understand the functionality of the Websites on your phone. This software may record information such as how often you use the Websites, what happens within the Websites, aggregated usage, performance data, app errors and debugging information, and where the Websites were downloaded from. We do not link the information we store within the analytics software to any personally identifiable information that you submit within the mobile application.

Log File Information: When you use our Websites, we may receive log file information such as your IP address, browser type, access times, domain names operating system, the referring web page(s), pages visited, location, your mobile carrier, device information (including device and application IDs), search terms, and cookie information. We receive log file data when you interact with our Websites, for example, when you visit our websites, sign into our Websites, or interact with our email notifications. The DRFLETT uses log file data to provide, understand, and improve our Websites, and to customize the content we show you. The DRFLETT may link this log file to other information the DRFLETT collects about you via the Websites. 

Public Information: TheDRFLETT may also collect information about you from publicly available sources. Information you make publicly available in any public or open forum, such as on a social network, may be considered public information for the purposes of this Privacy Notice, and may be accessed and collected by the DRFLETT. Please be aware that any content or information you share with or provide to third parties using or related to your use of the Websites is neither private, nor confidential. The DRFLETT is not responsible for any content or information you post or share with third parties. If you do not wish for certain information to be public, please do not share it publicly.

­­­­Information Use

The DRFLETT uses the information we receive about you for the purposes described in this Privacy Notice. We process personal data received about you through our Websites on the legal basis of the DRFLETT’s legitimate interests in providing the Websites and their functionality to you. Such processing is necessary for the purposes of the legitimate interests pursued by the DRFLETT or by our Service Providers related to the Websites.Where appropriate, we may rely on alternate legal bases, such as your consent to certain types of processing. 

­­­­Information Sharing

When you access or use the Websites, we collect, use, share, and otherwise process your personal information as described in this Privacy Notice. The DRFLETT will not share, sell, rent, or otherwise disclose your private personal information to third parties without your consent, except in the limited circumstances described in this Privacy Notice, including to:

Aggregated Non-Personal Data: We may disclose aggregated, non-personal data received from providing the Websites, including information that does not identify any individual, without restriction. The DRFLETT may share demographic information with business partners, but it will be aggregated and de-personalized, so that personal information is not revealed. 

Within The DRFLETT: We may share and process information internally within the DRFLETT and with our subsidiaries and affiliates. The DRFLETT’s personnel may have access to your information as needed to provide and operate the Websites in the normal course of business. This includes information regarding your use and interaction with the Websites.

Service Providers: The DRFLETT works with various organizations and individuals to help provide the Websites to you (“Service Providers“), such as website and data hosting companies and companies providing analytics information, like Google Analytics. The DRFLETT needs to engage such third-party Service Providers to help us operate, provide, and market the Websites. These third parties have only limited access to your information and may use your information only to perform these tasks on our behalf. Information we share to our Service Providers may include both information you provide to us and information we collect about you, including personal data and information from data collection tools like cookies, web beacons, and log files.

The DRFLETT takes reasonable steps to ensure that our Service Providers are obligated to reasonably protect your information on the DRFLETT’s behalf. If the DRFLETT becomes aware that a Service Provider is using or disclosing information improperly, we will take commercially reasonable steps to end or correct such improper use or disclosure. 

We share personal information with our Service Providers on the legal basis of the DRFLETT’s legitimate interests in providing you with the Websites. Our engagement of Service Providers is often necessary for us to provide the Websites to you, particularly where such companies play important roles like helping us keep our Websites operating and secure. In some other cases, these service providers aren’t strictly necessary for us to provide the Websites, but help us make it better, like by helping us conduct research into how we could better serve our users. In these latter cases, we have a legitimate interest in working with service providers to make our Websites better. 

Business Transactions: The DRFLETT may purchase other businesses or their assets, sell our business assets, or be involved in a bankruptcy, merger, acquisition, reorganization or sale of assets (a “Business Transaction“). Your information, including personal data, may be among assets sold or transferred as part of a Business Transaction. 

Safety and Lawful Requests: We may be required to disclose Websites user information pursuant to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws. We generally do not disclose user information unless we have a good faith belief that an information request by law enforcement or private litigants meets applicable legal standards. We may share your information when we believe it is necessary to comply with applicable laws, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through the Websites or using the DRFLETT name, or to protect the safety of any person. This may include sharing information with other companies, lawyers, agents, or government agencies. Nothing in this Privacy Notice is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your information.

Your Rights and Choices Regarding Your Information

Your Rights
The DRFLETT seeks to ensure all individuals are provided with the rights mandated by their governing jurisdiction. Not all of the rights discussed herein will apply to each individual data subject and may not apply to you depending upon your jurisdiction.

You may benefit from a number of rights in relation to your information that we process. Some rights apply only in certain limited cases, depending on your location. If you would like to manage, change, limit, or delete your personal information, you can do so by contacting us. Upon request, the DRFLETT will provide you with information about whether we hold any of your personal information.   In certain cases where we process your information, you may also have a right to restrict or limit the ways in which we use your personal information. In certain circumstances, you also have the right to request the deletion of your personal information, and to obtain a copy of your personal information in an easily accessible format.

To the extent that such rights are mandated by the laws applicable to the individual data subject, such as all data subjects residing in the European Union (“EU”), the following rights may apply:  the right to access (GDPR, Article 15); the right to rectification (GDPR, Article16); the right to erasure (GDPR, Article 17); the right to restrict processing (GDPR, Articles 18); the right of object (GDPR, Article 21); and if applicable, the right to data portability (GDPR, Article 20). You may also have a right to lodge a complaint with an appropriate data privacy regulatory authority (GDPR, Article 77).

If we process your information based on our legitimate interests as explained in this Privacy Notice, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your data for direct marketing purposes, you can always object using the unsubscribe link in such communications or changing your account settings.

Where you have provided consent to certain data processing, you have the right to withdraw that consent at any time by contacting the DRFLETT at: support@drflett.com . A withdrawal of consent will not affect the validity of our use of your personal data up until the point you have withdrawn your consent.

Access To The Information DRFLETT Has Collected About You

The DRFLETT provides certain tools and settings to help you access, correct, delete, or modify your personal information associated with the Websites.  The DRFLETT welcomes you to contact us regarding the information we have collected about you, including regarding the nature and accuracy of the data that has been collected about you, to request an update, modification, or deletion of your information, to opt-out of certain Websites uses of your information, or to withdraw any consent you may have granted to the DRFLETT. 

Please note requests to delete or remove your information do not necessarily ensure complete or comprehensive removal of the content or information posted, and removed information may persist in backup copies indefinitely. Please note that if you choose to delete your information or opt-out of the collection and use of your information, you understand that certain features, including but not limited to access to the Websites, may no longer be available to you. 

We retain the information we receive about  DRFLETT members and Websites users for as long as necessary to fulfil our contractual and legal obligations, or as otherwise required by law. We retain information we receive from members and Websites users indefinitely where allowed by law. We may delete your personal data from our systems as part of a data retention plan or where required.  Following termination or deactivation of a Websites Account, the DRFLETT may retain your information and content for a commercially reasonable time for backup, archival, and audit purposes. Please contact us at support@drflett.com  for more information about the data we’ve received about you, or to request deletion of your information.

Opting-Out Of Communications From The DRFLETT

Users may opt-out of receiving certain communications from the DRFLETT by following the unsubscribe process described in an email communication, or by contacting us using the contact information provided above. However, please note you may not opt-out of Websites-related communications, such as account verification, changes or updates to features of the Websites, or technical and security notices.

Do Not Track
The DRFLETT does not currently employ a process for automatically responding to “Do Not Track” (DNT) signals sent by web browsers, mobile devices, or other mechanisms. Per industry standards, third parties may be able to collect information, including personal data, about your online activities over time and across different websites or online services when you use Websites. You may opt out of online behavioural ads by email support@drflett.com . You also may limit certain tracking by disabling cookies in your web browser.

Information Security

Security Of Your Information
The DRFLETT takes reasonable efforts to secure and protect the privacy, accuracy, and reliability of your information and to protect it from loss, misuse, unauthorized access, disclosure, alteration and destruction. The DRFLETT implements security measures as we deem appropriate and consistent with industry standards. As no data security protocol is impenetrable, the DRFLETT cannot guarantee the security of our systems or databases, nor can we guarantee that personal information we collect about you will not be breached, intercepted, destroyed, accessed, or otherwise disclosed without authorization. Accordingly, any information you transfer to or from Websites is provided at your own risk.

Please do your part to help us keep your information secure. You are responsible for maintaining the confidentiality of your password and Websites Account, and are fully responsible for all activities that occur under your password or Websites Account. The DRFLETT specifically reserves the right to terminate your access to the Websites and any contract you have with the DRFLETT related to the Websites in the event it learns or suspects you have disclosed your Websites Account or password information to an unauthorized third party.

Additional Provisions Regarding The Websites & Your Information

Transfer And Storage Of Your Information
Please be advised information the DRFLETT collects about you may be transferred, processed and/or accessed by us in the South Africa, or another country where we, or our Service Providers operate. Please be aware that the privacy laws and standards in certain countries, including the rights of authorities to access your personal information, may differ from those that apply in the country in which you reside. If you are located outside the South Africa and choose to allow us to collect information about you, please be aware that the DRFLETT may transfer your personal data to the South Africa and process and store it there. We will transfer personal information only to those countries to which we are permitted by law to transfer personal information, and we will take steps to ensure that your personal information continues to enjoy appropriate protections.

If you are located in the European Economic Area (“EEA”) or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information to a country or jurisdiction that does not have the same data protection laws as your jurisdiction, as disclosed in this Privacy Notice. It may also be processed by staff operating outside the EEA who work for us or for one of Service Providers, also as disclosed. 

Safely Using The DRFLETT’s Websites
Despite the DRFLETT’s safety and privacy controls, we cannot guarantee the Websites are entirely free of illegal, offensive, or otherwise inappropriate material, or that you will not encounter inappropriate or illegal conduct from other users when using the Websites. You can help the DRFLETT by notifying us of any unwelcome contact by contacting us using the information below. 

Changes to Our Privacy Notice

The DRFLETT may modify this Privacy Notice from time to time. The most current version of this Privacy Notice will govern our use of your information. You may contact us to obtain prior versions. We will notify you of material changes to this policy by posting a notice at the Websites.  July