Privacy Policy

Last updated: 2026

⚖️ LEGAL DRAFT – NOT FINAL

This document is a comprehensive draft prepared in alignment with the Protection of Personal Information Act (POPIA) of South Africa. It is provided for review by Spot Reaction's legal counsel before final approval and public publishing.

1. Introduction

Spot Reaction (Pty) Ltd, registration number [INSERT COMPANY REG NUMBER], is committed to protecting the privacy and personal information of our clients, students, employees, and website visitors. We adhere to the Protection of Personal Information Act (POPIA) No. 4 of 2013.

This policy outlines how we collect, use, store, and protect your personal information.

2. Information We Collect

We collect personal information directly from you when you use our website, register for training, enquire about services, or contact us. This may include:

  • Identity & Contact Data: Full name, ID/passport number, physical address, email address, and phone numbers.
  • Professional Data: Employment history, qualifications, and previous PSIRA registration details (if applicable).
  • Transactional Data: Payment information, course enrollment history, and certification records.
  • Technical Data: IP addresses, browser type, and usage data collected via cookies (for website optimization).

3. Purpose of Processing

We process your personal information for the following specific, lawful purposes:

  • To enroll you in training courses and issue certificates.
  • To communicate with you regarding your training, security services, or inquiries.
  • To fulfill legal and regulatory obligations to PSIRA, QCTO, SAPS, and PFTC.
  • To process payments and manage invoices.
  • To improve our website, services, and customer experience.

4. Data Security and Storage

We implement appropriate technical and organizational measures to protect your personal information against unlawful access, loss, or damage. These include secure databases, encrypted payment gateways, and restricted internal access.

Your data will be retained for the period necessary to fulfill the purposes outlined in this policy, or as required by South African law (including PSIRA and QCTO record-keeping requirements), whichever is longer.

5. Sharing of Information

We do not sell or rent your personal information to third parties. We may, however, share your information with:

  • Regulatory Bodies: PSIRA, QCTO, SAPS, and PFTC, as required by law for accreditation and certification.
  • Payment Processors: Secure third-party payment gateways for transaction processing.
  • Professional Advisors: Auditors and legal advisors bound by confidentiality agreements.

6. Your Rights (Data Subject Participation)

Under POPIA, you have the right to:

  • Access: Request a copy of the personal information we hold about you.
  • Rectification: Request that we correct any inaccurate or incomplete information.
  • Erasure: Request that we delete your personal information (subject to legal retention requirements).
  • Withdrawal of Consent: Withdraw your consent to processing at any time, where applicable.
  • Objection: Object to the processing of your information for marketing purposes.

To exercise any of these rights, please contact our Information Officer at info@spotreaction.co.za.

7. Data Breaches

In the event of a data breach that may compromise your personal information, we will notify you and the Information Regulator as required by POPIA, detailing the nature of the breach and the steps taken to mitigate it.

8. Cookies and Website Tracking

Our website uses cookies to enhance user experience and analyze site traffic. You may choose to disable cookies via your browser settings, though this may affect certain functionalities of the site.

9. Third-Party Links

Our website may contain links to third-party sites (e.g., PSIRA, QCTO, payment gateways). We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies.

10. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy, please contact us:

11. Policy Updates

We reserve the right to update this Privacy Policy periodically. Changes will be posted on this page with a revised "Last Updated" date. We encourage you to review this policy regularly.