Privacy Policy

Introduction

Shadowmatch has two client types: Direct and Business-to-business. Shadowmatch Direct provides services to individuals by capturing information from the individual who voluntarily makes use of the Shadowmatch Services. Shadowmatch Business-to-business provides the Shadowmatch services to businesses. The business, as a Shadowmatch client, then invites/requests individuals to provide information via the Shadowmatch System to the requesting entity.

Shadowmatch Direct

With individuals as clients, Shadowmatch only requests information necessary to identify the reports generated by the system and to enable the system to email reports to the individual on request by the individual. Nobody is ever granted access to this data other than the individual who gets password protected access to his/her information and Shadowmatch System programmers and engineers who will only access data if requested by the relevant individual or to fix a system bug.

Shadowmatch direct sells reports to individuals online. Payments are processed by PayPal and PayFast (limited to South Africa and Namibia). Their security protection and privacy policy frameworks protects the client if and when online payments are made.

Shadowmatch Business-to-business

Shadowmatch is used by businesses, different institutions and government departments in different countries around the world. The business/institution will sign-up to use the system. An internal employee will be trained to use the system and this external (to Shadowmatch) Shadowmatch administrator will then be granted access to a Shadowmatch file allocated to that business/institution. This external administrator accesses the data on the Shadowmatch System by entering their unique login details. The system has security intelligence to prevent creating duplicate login details per user. The client then invites individuals to capture their information on the Shadowmatch System and the client has access to the captured data. The client has the authority to export that data for purposes defined by the client. The client is responsible to keep the data of the individual secure and to protect the secrecy of their access to the Shadowmatch System.

General

The Shadowmatch Team is committed to respecting your privacy. We recognize that when you choose to provide us with information about yourself, you trust us to act in a responsible manner and to protect and safely manage any Personal Information hosted on the Shadowmatch System.

‘Personal data’ (also referred to as ‘Personal Information’) means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to any personal identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. All information submitted by an individual via the Shadowmatch System can be regarded as ‘personal data’.

IMPORTANT NOTE: By accessing and using any Shadowmatch/Skillsgrid website, you acknowledge and agree to abide and be bound by this privacy policy (this “Privacy Policy”), and you expressly consent to collection, use, and disclosure of your Personal Information, in accordance with the terms and conditions of this Privacy Policy. This Privacy Policy is incorporated into and subject to the Terms and Conditions for any website.

Because Personal Information originates from countries around the world, Shadowmatch agrees to comply with regulations governing such in a reasonable way without the obligation to publish a Privacy Policy for each country. With respect to such Personal Information on the Shadowmatch System, it is our aim to put such protective measures in place that it will comply with all best practices and thus be compliant to any country.

Definitions

“You” and “Your” refers jointly and severally to the individual accessing this site.
“Affiliates” refers to present or future companies that, directly or indirectly, through one or more intermediaries, control, are controlled by, or are under common control with Shadowmatch.
“Shadowmatch Team” refers to employees of Shadowmatch working on the system as programmer, software engineers, research, customer support and training personnel. Included in this is a network of accredited independent Shadowmatch consultants and resellers.
“Services” refers to the services provided by Shadowmatch in connection with the data, software algorithms and reports generated by Shadowmatch. It also refers to training material and content created and presented by Shadowmatch. In addition to this, ‘services’ also refers to research papers and publications released by the Shadowmatch Team.
“User Content” refers to any data, text, links, media, or other content that You submit to Shadowmatch via a Website.
“Website” refers to the website www.Shadowmatch.com and all other related sub-domains such as Shadowmatch.co.za, Shadowmatch.net, Shadowmatch.biz and others not mentioned but owned by the owners of Shadowmatch.
“Visitors” refers to individuals who visit a Website.

From time to time, some of the Shadowmatch/Skillsgrid websites may utilize “cookies” and other tracking technologies. When you visit any website, Shadowmatch may place one or more “cookies” on your computer. A “cookie” is a small text file that may be used, for example, to collect information about website activity. Some cookies and other technologies may serve to recall Personal Information previously indicated by a website visitor. Shadowmatch does not use cookies to track your website behavior. Shadowmatch uses cookies for all or any of the following purposes:

Identify you when you access, visit, or log-in to any Shadowmatch/Skillsgrid website. This enables you to re-visit any of our websites without having to re-enter information upon each visit.
Detecting when your browser receives files for download on the Shadowmatch/Skillsgrid website.
Analyzing and improving website security.

Please note, you may set most browsers to notify you if and when you receive a cookie, or you may choose to block cookies through the settings associated with your browser. But, please note that if you choose to erase or block cookies, you will need to re-enter your original information (e.g. email, password or general contact info) to gain access to certain parts of the websites.

Shadowmatch may also use tracking technologies that record information such as Internet domain and host names; Internet protocol (IP) addresses; browser software and operating system types; clickstream patterns; and dates and times that any website is accessed by visitors. Shadowmatch may also analyze information that does not contain Personal Information (or contains Personal Information in anonymous or aggregated form) for trends and statistics, such as through the use of Google Analytics or other similar analytics services.

Collection, Use and Purpose Limitations of Your Information

When and where Shadowmatch collects Personal Information, such information will only be used in accordance with the purposes outlined within the functional capabilities of Shadowmatch and to provide the client with the reports and data either under their control or requested by the client. Unless expressly noted otherwise in the purpose statement or below, or elsewhere in this Privacy Policy, Shadowmatch does not intend to transfer Personal Information without your consent to third parties.

Automatic Collection of Information

Any website automatically gathers your IP address when you use any portion of any website. It also may collect the name and URL of the website. Shadowmatch may use this type of non-personal information on a cumulative basis to better understand difficulties and bugs in the system if and when clients can’t get what they want to access reports generated by Shadowmatch.

Voluntarily-Provided Information

When you participate in, access or sign up to receive any of the Shadowmatch services, activities or online content, such as email publications, blogs, newsletters, competitions, live chats, message boards, vote or create an account using Shadowmatch online registration system, Shadowmatch may receive Personal Information about you. This may consist of contact information but may also include other Personal Information. Shadowmatch will use your Personal Information for a number of purposes which include, responding to your requests for information, blogs or newsletters, adding your details to the Shadowmatch list of persons who receive blog updates or other publications, and providing these to you on a regular or as-requested basis.

Shadowmatch will also compile data based on responses received from visitors in order to allow Shadowmatch to analyze the experience of visitors so that improvements can be made to the services that Shadowmatch currently offer and to allow Shadowmatch to predict future products or services that Shadowmatch may consider offering. This information may also be used by Shadowmatch for its business purposes. If you do decide to provide information through any website or to otherwise contact Shadowmatch, then it is implied that you consent to receiving a response from Shadowmatch to your email address or via other contact information that you provided to Shadowmatch. Note that requesting information using any website does not give you a right to receive a response. Other than as particularly described in this Privacy Policy, any requests for information will be responded to entirely at the discretion of Shadowmatch, and there is no obligation on the part of Shadowmatch to respond to such requests or to provide any responsive information.

Any individual can request their information to be deleted by sending and email to this effect to [email protected]. On request, all data of the data subject will be deleted, all Shadowmatch reports will be deleted and the personal portal of the individual will also be deleted. The individual will no longer have access to any of the system functionalities, reports or development and coaching programs. Shadowmatch will not be able to restore any data related to such a data subject.

Data is kept on the system until the data subject requests data to be deleted. The reason for this is that data subjects use their Shadowmatch personal portals for personal development, relationship management and general personal value such as work application and self-insight. If the data subject requests personal data to be deleted, access to all these functions is deleted. Shadowmatch doesn’t monitor how often and how intense individuals uses their personal portals. It must be explained that Shadowmatch doesn’t use the data of individuals. It hosts the data for use by the individual and entities authorized by the individual. Answers to the questions of the Shadowmatch worksheet cannot be accessed by anybody and it is not shared with anybody. On completion of the worksheet the data subject (the individual involved) can’t access the way they have answered the questions either.

Hosting Services

Shadowmatch may use certain third party hosting service providers (“Hosting Service Providers”) to provide you with access to materials or services through the websites. Some Hosting Service Providers may require you to create an account and provide Personal Information to access certain materials and services. You should review the privacy policy of each such Hosting Service Provider to ensure you are comfortable with their privacy practices before providing any Personal Information. Please note that our Hosting Service Providers may use, store or otherwise process your Personal Information in jurisdictions other than the jurisdiction in which you reside. Shadowmatch has no control over and disclaims all liability for a Hosting Service Provider’s failure to comply with its own privacy policies with respect to Personal Information you provide directly to such Hosting Service Provider.

Forum Posts

Shadowmatch may also receive information from visitors via any blogs, forums, or comments pages that are maintained on any website for public comment by Visitors. Note that if you provide any Personal Information via any page of the websites maintained for public comment, your information will be publicly available and is subject to public disclosure. If you provide such Personal Information, you acknowledge that Shadowmatch is not liable for any public access to such information.

Choice, Security, Access and Accuracy of Your Information

Choice

You may choose whether or not to provide certain Personal Information to Shadowmatch. If you choose not to provide the Personal Information Shadowmatch requests, you can still visit some of the Shadowmatch/Skillsgrid websites, but you may be unable to access certain options, offers, and services. If you decide to have a relationship with Shadowmatch, such as a contractual or other business relationship or partnership, Shadowmatch will contact you in connection with that relationship as per your request.

Security

Wherever your Personal Information may be held within Shadowmatch or on its behalf, Shadowmatch intends to take reasonable and appropriate steps to protect the Personal Information that you share with us from unauthorized access or disclosure. Shadowmatch trains its employees on the Privacy Policy guidelines and makes this Privacy Policy available in the public domain. In addition, Shadowmatch and its business partners enter into confidentiality agreements which require that care and precautions be taken to prevent loss, misuse, or disclosure of your Personal Information. Shadowmatch also processes Personal Information only in ways compatible with the purpose for which it was collected or subsequently authorized by you. To the extent necessary for such purposes, Shadowmatch takes reasonable steps to make sure that Personal Information is accurate, complete, current, and otherwise reliable with regard to its intended use. Notwithstanding the foregoing, although Shadowmatch takes reasonable measures to protect your Personal Information, unfortunately the transmission of data through the Internet cannot be guaranteed to be 100% secure. Neither Shadowmatch, nor its Affiliates, nor any of their respective employees, officers or agents or the provider of the internet services on behalf of Shadowmatch or the creator of any website (nor any other person involving the management or establishment of any website or otherwise involved in respect of any website) can give any representation or warranty as to the absolute security of the data transmitted using any website and cannot give any guarantee that such data will not be compromised by hackers or people with ill intent.

Specific data about a data subject (individual) might be required by a business using the Shadowmatch system for specific purposes. This may be data related to recruitment, student information for learning institutions and so on. This data is requested by Shadowmatch but not to be used for the specific purpose of generating Shadowmatch reports. Such information is gathered on behalf of a third party business/institution and it is for their use and access. Data subjects are herewith informed that such data is not under the control of Shadowmatch but under the control of the third party business that requested Shadowmatch to gather and host the data for them.

Access and Data Integrity

The Shadowmatch goal is to provide a means of contacting the Shadowmatch Team should you need to update or correct Personal Information. If for any reason those means are unavailable or inaccessible, you may send updates and corrections about your Personal Information to [email protected] and, if such Personal Information is within Shadowmatch possession, Shadowmatch will make reasonable efforts to incorporate the changes in your Personal Information as soon as practicable. The Shadowmatch Team may also send you guidelines on how to self-update your personal information.

Shadowmatch will not disclose or sell your Personal Data to third parties, except when one or more of the following conditions are true:

To provide products or services that you have requested from Shadowmatch;
Where an authorized third party has a “need to know” such information in accordance with this Policy and law;
Shadowmatch has your permission to make the disclosure;
The disclosure is required by a lawful request by public authorities;
The disclosure is reasonably related to a Transfer (see “Transfer or Information” section below);
The information in question is publicly available;
The information is seen by third parties who provide web services or professional services to Shadowmatch (including Payment Processors such as PayPal);
The information is used to investigate and correct technical problems and malfunctions in any website or the computer systems that support any Shadowmatch/Skillsgrid website;
The information is necessary to investigate, prevent or take action with regard to a violation of any website or in respect of the Terms and Conditions or to verify or enforce compliance with the policies (including but not limited to the Privacy Policy) governing any website;
The disclosure is reasonably necessary for the establishment or defense of legal claims, or to investigate, prevent or take action regarding illegal activities, suspected fraud, or situations involving potential threats to the physical safety of any person; or
The disclosure is to another Shadowmatch entity, Affiliate or to persons or entities providing services on behalf of Shadowmatch (each a “transferee” Eg Skillsgrid a Shadowmatch subsidiary), consistent with the purpose for which the information was obtained, if the transferee, with respect to the information in question:

is subject to law providing an adequate level of privacy protection; or
has agreed in writing (emails are regarded as writing) to provide an adequate level of privacy protection.

Personal Data may be available to third parties as noted in the preceding list. Shadowmatch values data privacy and will request that such third parties use Personal Information only for the purposes disclosed in this Privacy Policy.

Permitted transfers of information, either to third parties or within Shadowmatch, include the transfer of data from one jurisdiction to another. Because privacy laws vary from one jurisdiction to another, Personal Data may be transferred to a jurisdiction where the laws provide less or different protection than the jurisdiction in which the information originated.

Contact lists and information are properly considered assets of Shadowmatch. Accordingly, if Shadowmatch merges with another entity or if Shadowmatch sells its assets to another entity (collectively referred to as a “Transfer”), Shadowmatch contact lists and information, which may include Personal Information you have provided, would be included among the assets that would be transferred and Shadowmatch would request that the entity treat your information in accordance with this Privacy Policy. This same provision is applicable for each Affiliate of Shadowmatch.

Any client, affiliate, any other entity or individual using the Shadowmatch System, uses the system with a full understanding of this Privacy Policy, will comply with the conditions of use as outlined in this Privacy Policy and will treat Personal Data hosted on the Shadowmatch and Skillsgrid System in compliance with this Privacy Policy. Using the Shadowmatch and Skillsgrid System serves as a non disclosure agreement of compliance.

Ownership and Storage of Information

Shadowmatch and its licensors own the code, databases, and all rights to all Shadowmatch/Skillsgrid websites and any feedback you provide; provided that, as between you and Shadowmatch, subject to the terms of this Privacy Policy, you retain all rights to the Personal Information you provide to Shadowmatch through any website. If you incorporate into feedback any User Content, you hereby grant Shadowmatch a worldwide, non-exclusive, royalty-free, sublicenseable and transferable license to use, reproduce, distribute, prepare derivative works of, and display the User Content when operating any Shadowmatch/Skillsgrid website and for Shadowmatch/Skillsgrid internal business purposes.
Shadowmatch may indefinitely store Personal Information that you provide to Shadowmatch or any of its Affiliates through any website or it may destroy such information in accordance with any policy or directive of Shadowmatch or any of its Affiliates for destruction of data or as required by law. For so long as Shadowmatch stores such information, Shadowmatch will comply with the Privacy Shield Principles with respect to such information in accordance with this Privacy Policy.

Privacy Policies of Third-Party Websites

Any website may contain or reference links to non-Shadowmatch/non-Skillsgrid websites. Shadowmatch is not responsible for the content of any third-party website or any link contained in a third-party website. The inclusion of a link within any website does not imply any endorsement by or any affiliation with Shadowmatch. Access to any third-party website is at your own risk, and you should be aware that third-party websites may contain privacy policies that have terms that are different from that of this Privacy Policy.
In connection with your use of any website, you may be made aware of services, products, articles, offers, and promotions provided by third parties, and not by us. If you decide to use these third-party services, you are responsible for reviewing and understanding the privacy policies governing those services. You agree that the third party, and not Shadowmatch, is responsible for all data privacy obligations related to the Personal Information you provide to such third party and you expressly relieve Shadowmatch and its Affiliates from any and all liability arising from or related to such Personal Information.

Change Management of Privacy Policy

Shadowmatch may amend this Privacy Policy from time to time by posting a revised policy on this website, or a similar website that replaces this website. If Shadowmatch amends the Privacy Policy, the new policy will apply to Personal Information previously collected only insofar as the rights of the individual affected are not reduced. Regularly reviewing this page is the best method to ensure you are always aware of the information Shadowmatch collects, how it is used and under what circumstances.

Children’s Personal Information Policy

Shadowmatch does not knowingly solicit any Personal Information from children under the age of 13. If we are aware that Shadowmatch has collected Personal Information from a child under 13 years old in a manner that is inconsistent with the Children’s Online Privacy Protection of the country from where such data originates, then Shadowmatch will delete this information as soon as practicable.

Contact Information, Recourse and Enforcement

For disputes regarding Shadowmatch collection or use of your Personal Information/Data or for more information, or questions or comments concerning the Privacy Policy, please contact the Shadowmatch Global Compliance officer at:

Shadowmatch
PO Box 204
Groenkloof
Pretoria
South Africa
[email protected]

You may also stop email messages and other promotional mailings by contacting Shadowmatch at the above address or email.

Our goal is to resolve all disputes through our internal processes. If you have a complaint regarding our collection, use, disclosure or retention of Personal Information, we will take appropriate steps to address any adverse effects, to promote future compliance and to prevent repetition of the mistake.

This Privacy Policy serves as the Shadowmatch Global Privacy Policy with GDPR regulations as the primary guiding policy but not the only guiding policy.