1. Who we are and what this policy covers
This policy explains how Seedway Capital (Pty) Ltd (registration number 2016/030510/07, trading through Seedway Academy ("Seedway", "we", "us"), processes personal information when you use our website, make an enquiry, buy a course, attend an event or receive our marketing.
- Responsible party: Seedway Capital (Pty) Ltd, CMA Office and Conference Park, No 1, 2nd Road, Halfway House Estate, Midrand, 1685
- Information Officer: Mr Abe Sibiya
- Privacy contact: info@seedwaycapital.co.za · 079-534-9239
We process personal information in line with the Protection of Personal Information Act 4 of 2013 (POPIA). Our Seedway LMS (learning platform) has its own privacy notice for learner accounts; where this policy and the LMS notice overlap, both apply.
2. Personal information we collect
| Category | Examples | How we get it |
|---|---|---|
| Contact details | Name, email address, phone or WhatsApp number | You, via enquiry forms |
| Enquiry details | Course of interest, coaching interests, preferred contact method, free-text messages | You |
| Organisation details | Company, job title, headcount, training needs (corporate enquiries) | You |
| Consent records | Your processing and marketing choices, with date and time | Generated when you submit a form |
| Marketing attribution | UTM parameters, ad click IDs (Google, Meta, LinkedIn), referrer, landing page | Your browser, with your consent where required |
| Technical data | IP address, device and browser type, pages visited | Automatically |
| Enrolment and payment data | Name, email, course purchased, payment status and reference | Seedway LMS and PayFast (we do not see or store your full card details) |
| Learner data | Progress, quiz results, certificates | Seedway LMS |
| Minors' data | Learner's name, age or date of birth, guardian's details and consent | Parent or guardian |
We do not knowingly collect special personal information (such as health or religious beliefs) and ask you not to put it in free-text fields.
3. Why we use it and our lawful basis
| Purpose | Basis under POPIA |
|---|---|
| Respond to enquiries and quote | Needed to take steps before a contract (s11(1)(b)); legitimate interest |
| Enrol you, provide courses and certificates, process payments | Performance of a contract (s11(1)(b)) |
| Send you marketing by email, WhatsApp or SMS | Your consent (s69), or our existing customer relationship for similar offers with a free opt-out |
| Show and measure ads, build audiences | Your consent (marketing cookies and pixels) |
| Site analytics and improvement | Your consent (analytics choice) and legitimate interest |
| Prevent spam, fraud and abuse (honeypot, Turnstile) | Legitimate interest |
| Keep financial and legal records, respond to legal claims | Legal obligation; legitimate interest |
Providing your details is voluntary, but we may not be able to respond to an enquiry or enrol you without them.
4. Direct marketing
- We send marketing by email, WhatsApp and SMS only if you opted in on a form or checkbox for that channel, or you are an existing customer and the message relates to similar offers.
- Each channel is a separate choice. Consent for one channel does not cover the others.
- Every message includes a free and simple way to opt out (an unsubscribe link, or reply STOP). You can also email info@seedwaycapital.co.za.
- We keep a suppression record of people who opted out so we do not contact them again, and we screen against the national opt-out register.
- We do not send marketing during restricted hours.
- We do not direct marketing to anyone under 18.
5. Children (under 18)
Some of our agriculture courses are open to learners under 18. We process a child's personal information only with the consent of a parent or legal guardian, and only to register and teach the learner. We do not use children's information for marketing, ad targeting or profiling. Parents and guardians can ask us to access, correct or delete a child's information at any time using the contact details in section 13.
6. Who we share information with
We share personal information only with service providers ("operators") who process it on our behalf under written agreements, and with others where the law requires or you ask.
| Recipient | Purpose | Location |
|---|---|---|
| Mailtrap | Sending enquiry notifications, acknowledgements and email campaigns | Provider-dependent |
| Our lead management provider | Storing and managing leads | Provider-dependent |
| PayFast | Payment processing for courses | South Africa |
| Seedway LMS | Learner accounts, course delivery | Provider-dependent |
| Vercel | Website hosting and analytics | Outside SA |
| Cloudflare | Spam protection (Turnstile) | Outside SA |
| Google, Meta, LinkedIn | Advertising and measurement (with consent) | Outside SA |
| Quicket | Ticketing for seminars | South Africa |
| YouTube, Vimeo | Embedded videos | Outside SA |
| WhatsApp and SMS providers | Delivering messages you opted into | Provider-dependent |
| Our professional advisers, regulators, courts | Legal and compliance purposes | South Africa |
We do not sell personal information.
7. Transfers outside South Africa
Some providers above store or process information outside South Africa. We transfer personal information abroad only where the recipient is bound by law, binding rules or an agreement that gives substantially similar protection to POPIA, or where you consent, or where it is necessary to perform a contract with you (POPIA section 72).
8. How long we keep information
| Information | Retention period |
|---|---|
| Enquiries that do not lead to enrolment | 24 months after our last interaction, then deleted or anonymised |
| Marketing subscriber details | Until you withdraw consent, or 24 months of inactivity, whichever comes first |
| Opt-out (suppression) records | Kept indefinitely in minimal form (contact detail only) so we honour your choice |
| Marketing consent records (proof of consent) | For the life of the consent plus 3 years |
| Ad attribution data held with a lead | 24 months, along with the lead record |
| Enrolment, invoice and payment records | 7 years after the transaction |
| Learner progress and certificate records | 5 years after last activity; certificate verification records may be kept longer so we can confirm your qualification |
| Minors' learner records | 12 months after the course ends, unless a guardian asks otherwise or a legal duty applies; earlier on request |
| Website and server logs | 90 days |
| Email delivery logs at our email provider | Per provider setting, no longer than 90 days |
| Browser storage (consent choice) | Until you clear it or change your choice; attribution data lasts only for your browsing session |
We delete or de-identify information when the period ends, unless the law requires us to keep it longer.
9. Security and breaches
We use reasonable technical and organisational measures: encrypted connections (HTTPS), restricted access to enquiry mailboxes and lead systems, origin and size checks, spam controls, and written agreements with operators. If personal information is accessed or acquired by an unauthorised person, we will notify the Information Regulator and affected people as POPIA requires.
10. Your rights
You may:
- ask whether we hold your information and request a copy;
- ask us to correct or delete information that is inaccurate, outdated, excessive or unlawfully held;
- object to processing, including direct marketing, and withdraw consent at any time (withdrawal does not affect earlier lawful processing);
- ask for deletion of data connected to our advertising tools. Email info@seedwaycapital.co.za with the subject "Data deletion request" and tell us the email address or phone number you used. We confirm within 10 business days;
- lodge a complaint with the Information Regulator: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001; complaints.IR@inforegulator.org.za.
We may ask you to verify your identity before acting on a request. We respond within a reasonable time, and within 30 days wherever possible.
11. Advertising, profiling and automated decisions
With your consent we use Google, Meta and LinkedIn tools to measure ads and build audiences. We do not make decisions that have legal effect on you using purely automated processing.
12. Changes to this policy
We will post updates here with a new version and date. For material changes affecting marketing consent, we will ask for your consent again.
13. Contact
Information Officer: Mr Abe Sibiya · info@seedwaycapital.co.za · 079-534-9239 · Seedway Capital (Pty) Ltd, CMA Office and Conference Park, No 1, 2nd Road, Halfway House Estate, Midrand, 1685.