Privacy Policy

1. Introduction

McKaynine Honeydew ("we", "us", "our") is committed to protecting your personal information. This Privacy Policy explains how we collect, use, store, share and protect your personal information in accordance with the Protection of Personal Information Act 4 of 2013 ("POPIA").

By using our services or providing your personal information to us, you acknowledge that you have read and understood this Privacy Policy.

2. Information Officer

Our Information Officer is responsible for ensuring compliance with POPIA and can be contacted at:

3. Personal Information We Collect

We may collect and process the following categories of personal information about you:

Handler / Account Information

• Full name and surname
• Email address and telephone number
• Physical address
• Payment and billing information

Dog Information

• Dog's name, breed, age and gender
• Vaccination status and veterinary clearance documentation
• Veterinary practice name and contact details
• Known health conditions or behaviour notes relevant to training safety

Platform Activity

• Login activity and account preferences
• Class attendance and progress records
• Messages sent via our platform

We do not intentionally collect sensitive personal information (as defined in POPIA) beyond what is necessary for health and safety in our classes.

4. How We Collect Your Information

• Through online enrolment and registration forms on this platform
• Through direct correspondence with you (email, WhatsApp, telephone)
• From veterinary practices (with your consent, for vet clearance purposes)
• Through the use of our platform (attendance records, progress notes)

5. Purpose of Processing

We process your personal information for the following purposes (POPIA s13):

• Processing and administering your enrolment in our classes
• Communicating with you about your classes, schedules and training progress
• Ensuring the health and safety of all dogs and handlers in our classes
• Processing payments and maintaining financial records
• Sending you relevant updates, reminders and class content
• Complying with our legal and regulatory obligations
• Improving the quality of our services
• Marketing our services to you, where you have consented or where permitted under POPIA

6. Lawful Basis for Processing

We process your personal information on one or more of the following lawful grounds (POPIA s11):

• Contract: processing is necessary to perform our services to you under our enrolment agreement.
• Legal obligation: processing is required to comply with applicable law (e.g. tax and financial record-keeping requirements).
• Legitimate interest: processing is necessary for our legitimate interests in running our business, provided these interests are not overridden by your rights.
• Consent: where we process your information for marketing purposes or other uses not covered by the above, we will seek your consent. You may withdraw consent at any time by contacting us.

7. Sharing Your Information

We do not sell your personal information. We may share it in the following limited circumstances:

• McKaynine franchise network: we share relevant information with McKaynine (Pty) Ltd for franchise administration, quality assurance and system support purposes. McKaynine (Pty) Ltd is bound by its own POPIA obligations.
• Service providers: we use third-party service providers (including our platform hosting provider and payment processors) who process personal information on our behalf and are contractually required to protect it.
• Legal authorities: we may disclose personal information to comply with a court order, subpoena or other legal obligation, or to protect the rights, property or safety of any person.
• Business transfers: in the event of a sale or transfer of our business, personal information may be transferred as part of that transaction, subject to equivalent privacy protections.

We will not share your information for any purpose other than those described above without your prior consent.

8. Retention of Personal Information

We retain your personal information for as long as it is necessary to fulfil the purposes described in this Policy, or as required by law. Our standard retention periods are:

• Enrolment and training records: 5 years from the end of your last enrolment.
• Financial and payment records: 5 years, as required by South African tax legislation and the Companies Act.
• Marketing consent records: until you withdraw consent or request deletion.
• Health and safety records (vet clearance): for the duration of your enrolment plus 1 year.

After these periods, your personal information will be securely deleted or anonymised.

9. Security Safeguards

We implement reasonable technical and organisational security measures to protect your personal information against loss, theft, unauthorised access, disclosure or destruction. These include:

• Encrypted data transmission (HTTPS)
• Access controls restricting who can view your information
• Regular security reviews of our platform

While we take reasonable precautions, no transmission of information over the internet can be guaranteed to be completely secure. You acknowledge and accept this inherent risk.

In the event of a security breach affecting your personal information, we will notify you and the Information Regulator as required by POPIA.

10. Your Rights as a Data Subject

Under POPIA, you have the following rights in relation to your personal information:

• Right of access (PAIA): you may request confirmation of whether we hold personal information about you, and a copy of that information.
• Right to correction: you may request that we correct inaccurate, incomplete or outdated information.
• Right to deletion: you may request deletion of your personal information, subject to our legal retention obligations.
• Right to object: you may object to the processing of your personal information in certain circumstances, including for direct marketing.
• Right to withdraw consent: where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact our Information Officer at honeydew@mckaynine.co.za . We will respond within a reasonable time and in accordance with POPIA.

11. Direct Marketing

We may send you information about our upcoming classes, events or services. You may opt out of marketing communications at any time by:

• Clicking "unsubscribe" in any marketing email; or
• Contacting us directly at honeydew@mckaynine.co.za .

Opting out of marketing will not affect service-related communications, such as class reminders and enrolment confirmations.

12. Cookies and Tracking

Our platform uses session cookies that are necessary for the operation of the website (for example, to keep you logged in). These cookies do not store personal information beyond what is needed for the session.

We do not use third-party tracking or advertising cookies. You can configure your browser to refuse or delete cookies, but this may affect the functionality of the platform.

13. Cross-Border Transfers

We primarily store and process your personal information in South Africa. Where any information is transferred outside the Republic (for example, to cloud hosting infrastructure), we ensure that the recipient country offers an adequate level of protection consistent with POPIA, or that appropriate safeguards are in place.

14. Children's Information

Our services are directed at adults. We do not knowingly collect personal information from persons under 18 years of age without the consent of a parent or guardian. If a minor is the registered handler, a parent or guardian must enrol on their behalf and accepts full responsibility under our Terms and Conditions.

15. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. Material changes will be communicated to you via the platform or by email. The date at the top of this page reflects when the Policy was last updated. Continued use of our services after notification of changes constitutes acceptance.

16. How to Contact Us

Information Regulator of South Africa

You have the right to lodge a complaint with the Information Regulator if you believe we have not handled your personal information in accordance with POPIA: