Data Deletion and Privacy Requests

1. Requests you may make

Subject to applicable law, programme relationships and verification, you may request:

• Confirmation of whether Camblish holds personal information about you.
• Access to personal information linked to your account or programme.
• Correction or completion of inaccurate information.
• Deletion or destruction of eligible information.
• Account deletion or deactivation.
• Deletion of an enrolled face template or other eligible biometric information.
• Objection to or restriction of certain processing.
• Withdrawal of consent for future consent-based processing.
• Review of an attendance, profile or programme record that you believe is incorrect.

2. How to submit a request

In the Xcelerate app

If available for your role and app version, open the Privacy Centre and select the relevant access, correction, objection, consent withdrawal, account deletion or biometric deletion request. Submission in the app associates the request with the authenticated account.

By email

Email [email protected] with the subject Privacy request or Data deletion request. Include:

• Your full name and the email address or username used for Camblish.
• The relevant employer, project or training programme, if known.
• The type of request and the information concerned.
• Enough detail to locate the records and understand the requested outcome.

Do not send passwords, one-time codes, private keys, biometric templates or a full identity document by ordinary email unless Camblish first provides a secure method.

By telephone

Call 011 024 9246 or 061 035 8120 for assistance. Camblish may still require a written request and identity verification.

3. Identity and authority verification

Camblish must prevent unauthorised access and deletion. It may therefore request reasonable information to confirm the requester, account, programme relationship and authority to act for another person. Verification will be proportionate to the sensitivity and risk.

If an employer, parent, guardian, representative or programme administrator submits a request for another person, Camblish may require proof of authority and may consult the responsible programme party.

4. What an eligible deletion may cover

Depending on the request and applicable obligations, deletion or de-identification may cover:

• An inactive app device registration and obsolete push token.
• Optional profile information that is no longer needed.
• Eligible support attachments, messages or technical records that are not required for an active case, safety matter or audit record.
• An enrolled Camblish face descriptor or biometric template where retention is no longer authorised or required.
• An account that is no longer needed, usually by deactivation followed by deletion or de-identification of eligible records.
• Consent-based communication preferences and future optional processing.

Deleting the app from a phone does not itself delete the Camblish account or server records. A separate request is required.

5. Information that may need to be retained

Camblish may refuse, limit or defer deletion where information is reasonably required for:

• Training, enrolment, assessment, moderation, certification and learner achievement records.
• Attendance, workplace, employer, SETA, QCTO, funding, accreditation, audit or evidence obligations.
• Contractual, employment, tax, financial, statutory or regulatory requirements.
• Security, fraud prevention, safeguarding, legal claims, complaints, investigations or dispute resolution.
• Protecting the rights of another person or maintaining an accurate record of a completed transaction.

Where full deletion is not permitted, Camblish may restrict access, correct the record, de-identify optional information or explain the lawful retention reason.

6. What happens after submission

1. Camblish records and acknowledges the request through the available channel.
2. Identity, authority and scope are verified.
3. Relevant website, LMS, Xcelerate, programme and service-provider records are identified.
4. Camblish considers legal, contractual, audit and programme-retention duties.
5. Eligible information is accessed, corrected, restricted, deleted or de-identified.
6. Camblish communicates the outcome, any retained categories and available next steps.

Requests are handled within the periods required by applicable law and may take longer where they are complex, involve several programme parties or require additional verification. Camblish will not charge a fee unless a fee is permitted and communicated in advance.

7. Contact, follow-up and complaints

If you are dissatisfied with the response, ask Camblish to review the request. You may also lodge a complaint with the Information Regulator of South Africa where applicable.