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Kunjani AS (“Kunjani”) is concerned about privacy issues and wants you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we collect through websites operated by us from which you are accessing this Privacy Policy (the “Websites”), through the software applications made available by us for use on or through computers and mobile devices (the “Apps”), and through HTML-formatted email messages that we send that link to this Privacy Policy (collectively, including the Websites and Apps, the “Services”). By providing Personal Information to us, you agree to the terms and conditions of this Privacy Policy.


Last Updated: 01 February 2021


Kunjani Privacy Policy

Kunjani provides a game-based learning tool that can be played through most web browsers (at )  via video conference and face to face. A Kunjani game (referred to as a “Board”) consists of players participating in various activities, questions, tasks and more presented on the screen of the user who hosts the particular game or, on the screens of the participants in the particular game itself.

1. Personal Information Act (POPI) and the General Data Protection Regulation (GDPR)

2. What is Kunjani?

Kunjani is committed to protecting the privacy of our users, in accordance with the Protection of Personal Information Act (POPI) and the General Data Protection Regulation (GDPR). For this reason:


  • We never share identifiable user data with third parties.

  • We are explicit about what data we are collecting and what we intend to use it for. We only collect data that is necessary to provide an excellent educational service.

  • We always require consent from your institution to process data related to your users.

  • We only hold user data for the period that a user is legitimately registered to use our service.

  • We only use that data to make sure that your users are getting the most out of the platform.

  • We do not market to users under 18 years of age with the intention to sell.

3. Define Personal Information

Personal Information” is information that identifies an individual or relates to an identifiable person, including:



Email address (required)

Company or organization (of work-related users)

Financial information (required when signing up for Kunjani “the Paid Subscriptions”)

School or university (of students and teachers)

Chosen username and password for Kunjani account (required)


We need to collect and process Personal Information marked as ‘required’ in order to provide the requested Services to you, or because we are legally required to do so. If you do not provide the information that we request, we may not be able to provide the requested Services.


If you submit any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

4. Personal Information we collect

We and our service providers collect Personal Information from account holders in a variety of ways, including:


  • Through the Services: We collect Personal Information through the Services, e.g., when you create an account, attend an event, register your credit/debit card information and other financial data that we/our payment processors need to provide the Services, or populate your profile.


  • Offline: We collect Personal Information from you offline, such as when you contact customer service.

  • From Other Sources: We may receive your Personal Information from other sources, such as Google or Microsoft (if you choose to register using your Google or Microsoft account), public databases, joint marketing partners and other third parties.

5. How We Collect Personal Information 

We do not collect any Personal Information from a person who merely plays or participates in a Kunjani game. In order to be able to create and host a Kunjani game and session, however, a user (“account holder”) must create an account at As described in more detail below, we may collect, use and disclose Personal Information from account holders.

6. How We Use Personal Information 

We and our service providers use Personal Information for our legitimate business purposes, including the following:


  • Providing the functionality of the Services and fulfilling your requests.

    • To provide the Services’ functionality to you, such as arranging access to your account.

    • To respond to your inquiries and fulfill your requests, such as to send you newsletters.

    • To complete your transactions.

    • To send administrative information to you, such as information regarding the Services and changes to our terms, conditions and policies.


We engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.


  • Providing you with marketing material that we believe may be of interest to you.

    • This may include recommended games based on your general location and your use of the Services, subject to your consent if required by applicable law.


We engage in this activity with your consent or where we have a legitimate interest.


  • Analysis of Personal Information for business reporting and providing personalized services.

    • To personalize your experience on the Services by presenting products and offers tailored to you.


We provide personalized services either with your consent or because we have a legitimate interest.


  • Allowing you to participate in Kunjani’s Marketplace in creating games or selling games.

    • We may offer you the opportunity to participate in the Kunjani Marketplace. This activity has additional rules, which could contain additional information about how we use and disclose your Personal Information.


We engage in these activities to manage our contractual relationship with you.


  • Anonymizing and/or aggregating Personal Information.

    • We may anonymize and/or aggregate Personal Information so that it will no longer be considered Personal Information. We do so to generate other information for our use, which we may use and disclose for any purpose.


  • Accomplishing our business purposes.

    • For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.


We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.

7. How Personal Information May Be Disclosed

The Personal Information of account holders may be disclosed:


  • To our third-party service providers who provide services such as website hosting, data analysis, information technology, and related infrastructure provision, customer service, email delivery, auditing, payment processing, and other services.

  • To identify you to anyone with whom you share a Kunjani link or other messages.

8. Other Uses and Disclosures

We also use and disclose Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:


  • To comply with applicable law and regulations.

    • This can include laws outside your country of residence.

  • To cooperate with public and government authorities.

    • To respond to a request or to provide the information we believe is important.

    • These can include authorities outside your country of residence.

  • To cooperate with law enforcement.

    • For example, when we respond to law enforcement requests and orders or provide information we believe is important.


  • For other legal reasons.

    • To enforce our terms and conditions.

    • To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.


  • In connection with a sale or business transaction.

    • We have a legitimate interest in using, disclosing, or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.

9. Other Information 

Other Information We Collect

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:


  • Browser and device information

  • App usage data

  • Information collected through cookies, pixel tags and other technologies

  • Demographic information and other information provided by you

  • Aggregated information

  • If we are required to treat Other Information as Personal Information under applicable law, then we may use it for the purposes for which we use and disclose Personal Information as detailed in this Policy.

We and our third-party service providers collect Other Information in a variety of ways, including:


  • Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.


  • Using cookies: Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other anonymous traffic data. We and our service providers use the information only to support the internal operations of the Services, such as for security purposes, to facilitate navigation, to display information more effectively, to personalize your experience while using the Services and to recognize your computer in order to assist your use of the Services. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them.


  • If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You may also wish to refer to If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services. For example, we may not be able to recognize your computer, and you may need to log in every time you visit.


  • Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Services to, among other things, track the actions of users of the Services (including adult account holders that may receive emails from us), measure the success of marketing campaigns and compile statistics about usage of the Services and response rates.


  • Analytics: We use third parties, including Google Analytics, which use cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. You can learn about Google’s practices by going to, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at


  • IP Address: Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for the purposes of providing support for the internal operations of the Services, such as calculating usage levels, diagnosing server problems, and administering the Services. We may also derive your approximate, general, location from your IP address.


  • From you: Information such as communications preference may be collected from  account holders when they voluntarily provide it.


  • By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the Services.

10. How we Collect Other Information 

We use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

11. How We Use and Disclose Other Information 

12. Third Party Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.


In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Twitter, WhatsApp, Apple, Google, Microsoft, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to these or other organizations

Our Kunjani App in Microsoft Teams is enabled by Microsoft Bot Framework. The Microsoft Bot Framework is a set of web-services that enable intelligent services and connections using conversation channels you authorize. As a service provider, Microsoft will transmit content you provide to our bot/service in order to enable the service. For more information about Microsoft privacy policies please see their privacy statement here: In addition, your interactions with this bot/service are also subject to the conversational channel’s applicable terms of use, privacy and data collection policies. To report abuse when using a bot that uses the Microsoft Bot Framework to Microsoft, please visit the Microsoft Bot Framework website at and use the “Report Abuse” link in the menu to contact Microsoft.

13. Kunjani App in Microsoft Teams

14. Security 

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contacting Us” section below.

15. Choices and Access

Your choices regarding our use and disclosure of your Personal Information

We give account holders choices regarding our use and disclosure of their Personal Information for marketing purposes. You may opt-out from receiving marketing-related emails from us on a going-forward basis by clicking the unsubscribe link in any such email. 


We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.


How you can access, change or suppress your Personal Information

If you are an account holder and you would like to request to review, correct, update, suppress or delete Personal Information, restrict the processing of your Personal Information, object to the processing of your Personal Information, or if you would like to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below. We will respond to your request consistent with applicable law.


In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. You may also delete your account by “Contacting us” see section below. You may also delete, when logged into the Services, any content or information that you have posted to the Services in the form of Kunjani games that you have created. Please note that your actions cannot ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted or re purposed by another account holder.


Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.

We keep your Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include (i) the length of time we have an ongoing relationship with you and provide our Services to you; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations).

16. Retention Period

We ask that you not send us, and you do not disclose, any sensitive Personal Information (e.g., personal identification numbers, social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.

17. Sensitive Information 

We may change this Privacy Policy. The “LAST UPDATED” legend at the top of this page indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services.

19. Contacting Us

If you have any questions about this Privacy Policy, please contact us +27 81 767 3600

8 Binnekring Rd, 

Dalsig Stellenbosch 

South Africa 



Because email communications are not always secure, please do not include sensitive information in your emails to us.

18. Updates to this Privacy Policy 

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