Cape Nail and Beauty Academy Privacy Policy

Last updated: April 2025

1. Introduction

Cape Nail and Beauty Academy (“we”, “us”, “CNBA”) is committed to protecting the personal information of all visitors, learners and enquirers in accordance with the Protection of Personal Information Act, 2013 (“POPIA”). This Policy describes how we collect, use, disclose, transfer and store your personal information when you interact with:

  • Our public website at https://cnba.co.za

  • Our Moodle LMS at https://lms.cnba.co.za

  • Zoho-powered forms and portals

  • WhatsApp Business conversations

  • Social-media channels (Facebook, Instagram, Google Lead Ads)

By using our services you acknowledge the practices described in this Policy.

2. Responsible Party & Information Officer

Legal entity:
Cape Nail and Beauty Academy
Registration number: [insert if applicable]
Address: 79 Victoria Road, Woodstock, Cape Town, 7925, South Africa
Main contact: info@cnba.co.za | +27 21 465 4542

Information Officer:
Jamie Kawalsky
jamie@cnba.co.za | +27 21 465 4542

3. Definitions

  • Personal Information: Any information that identifies or could identify an individual.

  • Processing: Any operation or set of operations performed on Personal Information.

  • Data Subject: The individual to whom Personal Information relates (e.g., website visitor, learner).

4. Categories of Personal Information Collected

  1. Website (cnba.co.za)

    • Name, email, phone number, message content, course interests

    • Technical data: IP address, device type, browser, geolocation

  2. LMS (lms.cnba.co.za)

    • Full name, email, South African ID number, cell number, physical address

    • Qualifications and educational history

    • Uploaded documents (e.g., certificates, ID scans), profile photo

    • Payment details (e.g., Yoco transaction references)

  3. Zoho Forms & Portals

    • Same as Website: name, email, phone, message content, course interests

    • Technical data: IP, device, browser, location

  4. WhatsApp Business

    • Phone number, chat transcripts, profile picture, display name

  5. Social-media Channels

    • Lead-gen contacts from Facebook, Instagram DMs, Google Lead Ads

5. Purposes of Processing

We collect and process your Personal Information to:

  • Respond to website enquiries and send marketing communications

  • Enrol learners, manage course delivery, assessments and certification in the LMS

  • Provide administrative support via WhatsApp and Zoho Forms

  • Run social-media campaigns and retargeting adverts

  • Comply with legal and regulatory obligations

6. Legal Basis & Consent

  • Consent: Obtained via tick-box during enrollment, cookie banners on our sites, explicit opt-ins on forms and pop-ups.

  • Contract: Necessary to perform educational and payment services you’ve requested.

  • Legal obligation: To retain records for compliance or financial audit.

  • Legitimate interest: For internal quality control, marketing analysis and fraud prevention (balanced against your rights).

7. Data Sharing & Third-Party Processors

We share your Personal Information only with trusted service-providers who process data on our behalf, including:

  • Moodle hosting: Self-hosted by Code & Copy (Cape Town)

  • Zoho services: Forms, CRM, Analytics, Marketing Campaigns, Bigin, SalesIQ, Social integrations

  • WhatsApp Business API: Meta and Zoho integration

  • Social platforms: Meta (Facebook, Instagram), Google (Analytics, Ads)

  • Payments: Yoco Financial Technologies

  • Email: Microsoft Exchange Online

  • Web hosting & infrastructure: Code & Copy

All processors are bound by POPIA-level confidentiality and security obligations.

8. Cross-Border Transfers

We do not transfer your Personal Information outside South Africa except where it is necessary for the above processors (e.g., Zoho’s regional data centres). All transfers are subject to adequate safeguards.

9. Data Retention & Deletion

  • Your records are retained indefinitely for audit and certification verification.

  • We apply our standard archiving and deletion procedures when data becomes obsolete or upon valid deletion requests.

10. Data-Subject Rights & Requests

Under POPIA you have the right to:

  • Access and receive a copy of your Personal Information

  • Request correction or deletion of inaccurate or unnecessary data

  • Object to or restrict processing

  • Lodge a complaint with our Information Officer or the Information Regulator

To exercise any right, please contact Jamie Kawalsky at jamie@cnba.co.za or +27 21 465 4542. We will respond within 30 days.

11. Security Measures

We implement appropriate technical and organizational measures, including:

  • SSL/TLS encryption on all websites and LMS portals

  • IMAP over TLS for email communications

  • Two-factor authentication (2FA) on hosting and administrative accounts

  • Secure password storage for cloud-hosted files and databases

  • Regular vulnerability scans and patch management

12. Cookies & Tracking

  • We use Google Analytics and Zoho Analytics to monitor site performance and user behaviour.

  • Cookie consent banners allow you to accept or decline non-essential cookies.

  • You can manage or withdraw your cookie preferences at any time via the pop-up settings.

13. Breach Notification

In the event of a data breach, we will notify affected Data Subjects and the Information Regulator within 72 hours of becoming aware, and provide details of remediation steps.

14. Changes to this Policy

We may update this Policy to reflect changes in our practices or legal requirements. The “Last updated” date above will indicate when a revision occurred.

Questions or Concerns?
Contact our Information Officer:
Jamie Kawalsky
jamie@cnba.co.za | +27 21 465 4542

Thank you for trusting Cape Nail and Beauty Academy with your Personal Information. We’re committed to keeping it safe and used only as you’ve authorized.