Refund policy
Please note: All course offerings are non-refundable. Please contact us at hello@coffeesmart.org. Should you have any questions.
Privacy Policy of Smart Collab (Pty) Ltd trading as Coffee Smart
Effective date: 10 August 2026
Responsible party: Coffee Smart Business ("Coffee Smart")
Email: hello@coffeesmart.org
1.1 Introduction
1.1.1 Coffee Smart respects your privacy and is committed to protecting your personal
information in accordance with the Protection of Personal Information Act, 2013
("POPIA").
1.1.2 This Privacy Policy explains what personal information we collect, why we collect it,
how we use and store it, when we may share it, and what rights you have in relation to your
personal information.
1.1.3 By engaging with our business, purchasing our products, registering for our courses, or
utilising our website, you confirm that you have read, understood, and agree to the Privacy
Policy, and you consent to the collection, use, storage, retention, sharing, and other
processing of personal information in accordance with the Privacy Policy and POPIA.
1.2 Personal Information We Collect
1.2.1 We may collect and process the following categories of personal information, where
reasonably necessary for our products and services:
1.2.1.1 Client name, email address, telephone number, and reswidential
delivery/billing address;
1.2.1.2 In the case of working with minors- student name, age, grade, and school
along with parent or guardian name and contact details;
1.2.1.3 Company name, role, registration details, and industry type (for B2B clients);
1.2.1.4 Information relating to payments, invoices, receipts, and banking details;
1.2.1.5 communications between us, including WhatsApp, email or other messages
relating to the Coffee Smart services
1.2.1.6 any other information voluntarily provided to us that is reasonably required for
the working relationship.
1.2.2 We aim to collect only information that is adequate, relevant, and not excessive for
the purposes for which it is processed.
Privacy Policy of Smart Collab (Pty) Ltd trading as Coffee Smart
August 2026
1.3 Age Restriction and Information About Minors
1.3.1 Our services, training courses, and products are primarily intended for adults aged
18 and older.
1.3.2 If a person under the age of 18 (a minor) wishes to register for our courses or use our
services, explicit, verifiable written consent from a parent or legal guardian is mandatory
before any registration can be completed or personal data processed.
1.3.3 We do not knowingly collect or retain personal information from minors without
obtaining this mandatory parental/guardian verification. If we discover information from a
minor was submitted without appropriate parental authorisation, it will be deleted
immediately.
1.3.4 We do not knowingly request unnecessary personal information from children, and we
take reasonable steps to protect the confidentiality and integrity of children's personal
information.
1.4 How We Collect Personal Information
We may collect personal information:
1.4.1 directly from you through website forms, purchases, registrations, emails, phone
calls, meetings, or messaging apps;
1.4.2 during trainings, consulting and related communications;
1.4.3 from schools, teachers, or other persons where a parent/guardian has authorised this
or where it is reasonably necessary for the Coffee Smar services; and
1.4.4 generated during invoicing, order completions, or subscription management.
1.5 Purposes for Processing Personal Information
We process personal information for the following purposes:
1.5.1.1 to enrol and identify students for Coffee Smart services;
1.5.1.2 to communicate with clients, students, parents, and guardians;
1.5.1.3 to invoice and administer payments;
1.5.1.4 to comply with obligations relating to legal, accounting, tax, and record-keeping
matters;
1.5.1.5 to handle inquiries, updates, order confirmations, and customer support.
1.5.1.6 to resolve queries, complaints or disputes;
Privacy Policy of Smart Collab (Pty) Ltd trading as Coffee Smart
August 2026
1.5.1.7 to satisfy tax, accounting, audit, and legal requirements within South Africa;
1.5.1.8 to protect our rights, the student's interests and the safety of persons involved in our
services; and
1.5.1.9 to improve our tutoring services.
1.6 Legal basis for processing
1.6.1 We process personal information where:
1.6.1.1 the client, student or, where applicable, the parent/guardian or competent
person has consented;
1.6.1.2 processing is necessary to conclude or perform the services Coffee Smart
offers;
1.6.1.3 processing is necessary to comply with a legal obligation;
1.6.1.4 processing protects a legitimate interest of the client, student,
parent/guardian;
1.6.1.5 processing is necessary for our legitimate interests, provided those interests
do not unlawfully infringe privacy rights; or
1.6.1.6 another lawful basis under POPIA applies.
1.6.2 Where processing is based on consent, consent may be withdrawn by contacting us.
Withdrawal of consent will not affect processing that occurred before withdrawal or
processing that is otherwise permitted or required by law.
1.7 Storage, Security, and Cloud Providers
1.7.1 We store information in secure physical and electronic formats. Electronic records may
be stored on devices, email accounts, and cloud-based systems, including Google Drive
1.7.2 We take reasonable technical and organisational measures to protect personal
information against loss, damage, unauthorised access, unauthorised disclosure, and
unlawful processing. These measures may include access controls, passwords, secure
storage practices, limiting access to persons who need the information, and reviewing
security practices from time to time
1.7.3 Some software vendors or backup servers may host data outside of South Africa. By
engaging with us, you consent to this cross-border transfer, provided the recipient satisfies
adequate data privacy safeguards matching POPIA guidelines.
Privacy Policy of Smart Collab (Pty) Ltd trading as Coffee Smart
August 2026
1.7.4 Although we take reasonable security precautions, no electronic storage or
transmission method is completely secure. We will respond to suspected or actual security
compromises in accordance with applicable law.
1.8 Use of Google Drive and other service providers
1.8.1 We may use Google Drive to store and manage records and documents. Google Drive
may involve storage or processing of information on servers outside South Africa.
1.8.2 By using our services and providing personal information, you acknowledge that your
personal information and/or the personal information of the student may be stored using
Google Drive or similar reputable cloud-based service providers. We will take reasonable
steps to ensure that any service provider used by us is subject to appropriate confidentiality
and security measures.
1.8.3 Where required, we will ensure that operators or service providers process personal
information only with our knowledge or authorisation and apply appropriate security
safeguards.
1.9 Sharing of Personal Information
1.9.1 We will not sell personal information.
1.9.2 We may share personal information only where reasonably necessary, including with:
1.9.2.1 the student's parent or guardian, where applicable;
1.9.2.2 the student, where appropriate;
1.9.2.3 authorised persons involved in providing or administering the Coffee Smart
services;
1.9.2.4 payment, accounting, scheduling, email, cloud storage, or technology service
providers;
1.9.2.5 professional advisers, where necessary;
1.9.2.6 schools or teachers, where authorised or reasonably required for the Coffee
Smart services;
1.9.2.7 regulators, public authorities, or other persons where required or permitted by
law; and
1.9.2.8 any person necessary for the establishment, exercise, or defence of legal
rights;
1.9.2.9 third-party delivery couriers and logistics partners to deliver your products
and/or offer our service.
Privacy Policy of Smart Collab (Pty) Ltd trading as Coffee Smart
August 2026
1.10 International transfers
Some service providers may store or process personal information outside South Africa. By
using the website and/or the services of Coffee Smart and/or by providing any personal
information to Coffee Smart, you consent to cross-border storage and/or transfer of
information where applicable. Where personal information is transferred outside South
Africa, we will take reasonable steps to ensure that the recipient is subject to appropriate
privacy, confidentiality and security obligations.
1.11 Retention of personal information
1.11.1 We will retain personal information only for as long as reasonably necessary for the
purposes for which it was collected, unless a longer retention period is required or permitted
by law.
1.11.2 We may retain certain records after our services end where necessary for legal, tax,
accounting, dispute resolution, or legitimate business purposes. When personal information
is no longer required, we will take reasonable steps to delete, destroy, de-identify or restrict
further processing of the information.
1.12 Direct marketing
We will not send direct marketing communications unless permitted by law. Where we send
newsletters, updates, or promotional communications, recipients may opt out or unsubscribe
at any time.
1.13 Your rights
1.13.1 Subject to POPIA and any applicable legal limitations, you may:
1.13.1.1 ask what personal information we hold about you or a student;
1.13.1.2 request access to that personal information;
1.13.1.3 request correction or updating of inaccurate, incomplete, or outdated information;
1.13.1.4 request deletion or restriction of personal information where permitted by law;
1.13.1.5 object to processing where permitted by law;
1.13.1.6 withdraw consent where processing is based on consent; and
1.13.1.7 lodge a complaint with the Information Regulator.
1.13.2 Requests may be sent to the email address indicated on the first page of this policy.
1.13.3 We may need to verify your identity before responding to a request.
Privacy Policy of Smart Collab (Pty) Ltd trading as Coffee Smart
August 2026
1.14 Accuracy of information
Clients, students, parents and guardians must provide accurate and up-to-date personal
information and must notify us if any information changes. This helps us provide our services
and communicate effectively.
1.15 Security compromises
If we have reasonable grounds to believe that personal information has been accessed or
acquired by an unauthorised person, we will take appropriate steps as required by law. This
may include notifying affected persons and/or the Information Regulator where required.
1.16 Complaints
1.16.1 If you have a privacy-related question or complaint, please contact us first at:
Coffee Smart
Email:hello@coffeesmart.org
1.16.2 You may also lodge a complaint with the Information Regulator of South Africa.
1.17 Changes to this Privacy Policy
We may update this Privacy Policy from time to time. The latest version will be published on
our website and will apply from the effective date stated above.
Privacy Policy of Smart Collab (Pty) Ltd trading as Coffee Smart
August 2026