PRIVACY POLICY
Effective Date:
4 February 2026
Data Controller:
Avril Fortuin Training Services Pty Ltd
Contact: avril@avrilfortuin.com

Information We Collect
Personal Data:
Name, email address, phone number, business details, and payment information when you register, purchase, or contact us
Usage Data:
IP address, browser type, pages visited, and time spent on our site
Cookies:
See Section 4 for detailed cookie information

2. Legal Basis & Purpose
We process your data under these lawful bases:
Contract Performance: Processing transactions, delivering services, managing your account
Consent:
Marketing communications (you may withdraw consent anytime)
Legitimate Interest:
Website improvement, fraud prevention, and customer service

3. Data Retention
Active customer data: Duration of business relationship plus 7 years (tax/legal requirements)
Marketing contacts: Until you unsubscribe or request deletion
Website analytics: 26 months maximum

4. Cookies
We use cookies to improve functionality and analyse site performance. You can manage preferences via our cookie banner or browser settings.
Essential Cookies: Necessary for site operation (login, security)
Analytics Cookies: Track site usage and performance (requires consent)
Marketing
Cookies: Enable targeted content (requires consent)
Declining non-essential cookies may limit some features.

5. Third-Party Sharing
We share data only when necessary:
Payment processors (PayStack) for transaction processing
Analytics providers for site performance
Email service providers for communications
Legal requirements that are obligatory by law
All third parties are GDPR-compliant and operate under data processing agreements.

6. International Transfers
Some service providers may process data outside South Africa. We ensure adequate safeguards through standard contractual clauses and adequacy decisions.

7. Your Rights
You may:
Access your personal data
Rectify inaccurate information
Erase your data (right to be forgotten)
Restrict processing
Object to processing based on legitimate interests
Port your data to another organisation
Withdraw consent for marketing communications.
Lodge a complaint with the Information Regulator (South Africa)
Contact avril@avrilfortuin.com exercise any rights.

8. Security
We implement industry-standard technical and organisational measures to protect your data. However, no internet transmission is completely secure.

9. Policy Updates
We'll notify you of material changes via email or prominent site notice. Continued use constitutes acceptance.