Privacy Policy for Jezreel Student Software provided by Silver Surge (PTY) Ltd
Last Updated: May 21, 2025
1. Introduction Welcome to Jezreel Student Software (the “Service”), provided by Silver Surge (PTY) Ltd (“we,” “us,” or “our”). We are committed to protecting the privacy of personal information of the users of our software platform, including our website jezsoftware.co.za and the application portal AGENCY SPECIFIC (collectively, the “Platform”).
This Privacy Policy explains what personal information we collect, how we use and share it, how we protect it, and your rights regarding your personal information. This policy applies to student accommodation management agencies (“Agencies”) and students (“Students”) who use our Platform.
Silver Surge (PTY) Ltd is the responsible party for the processing of personal information as described in this Privacy Policy.
Contact Information: Silver Surge (PTY) Ltd
0646570876
Attention: Jp Silver
2. Information We Collect We collect personal information directly from our users. We do not track users across other websites or services.
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Information Collected from Students (via the application form on behalf of Agencies):
- Year Applying For
- First Name(s)
- Last Name
- Student Number
- ID / Passport Number (and copy of ID Document)
- Phone Number
- Whatsapp Number
- Residential Address (Home)
- Email Address (and confirmation)
- Student Email
- Course
- Gender
- Year of study
- Campus
- Applying For (Type of Accommodation)
- Room Preference
- Preferred Room
- Method of payment
- Cash Budget
- Name of Bursary (if applicable)
- Any Special Requirements or Needs
- Where did you hear about us?
- Copy of Student Card
- Parent / Guardian Full Name
- Parent / Guardian Phone Number
- Parent / Guardian Work Number
- Parent / Guardian Email
- Signature (digital or scanned)
- Acceptance of terms of agreement
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Information Collected from Agency Users:
- Account information (e.g., agency name, contact person details, email address, phone number) for creating and managing the agency’s application instance.
- Billing information for services rendered.
- Accommodation Information (Eg. Vat number, registration number, name, address, rooms)
- Company Information (As per requested for setup)
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System Logging (Audit Trails):
- For any database changes made within the Platform (e.g., when student information is submitted or updated by an agency), our system (using Envers) logs the user’s IP address, browser type, and device information associated with that specific change. This is for security, auditing, and maintaining data integrity, not for tracking individual user behavior across the platform or other sites.
3. How We Use Your Information We use the collected information for the following purposes:
- To Provide and Manage the Service:
- To enable Agencies to manage student accommodation applications and student details.
- To allow Students to submit their applications to their chosen Agencies.
- To process transactions related to student accommodation.
- To create and manage Agency accounts on our Platform.
- To Communicate with Users:
- To send important service-related notifications to Agencies and Students.
- To respond to inquiries and provide support.
- Service Improvement and Security:
- To maintain the security and integrity of our Platform, including through audit trails.
- To understand how our Platform is used to improve its functionality (e.g., analyzing the “Where did you hear about us?” feedback for marketing insights).
- Legal and Contractual Obligations:
- To fulfill our contractual obligations to Agencies.
- To comply with applicable legal requirements.
4. Legal Basis for Processing (primarily under POPIA) We process personal information based on the following legal grounds:
- Consent: Where you have provided your consent for a specific processing activity (e.g., submitting an application, providing optional information like “where did you hear about us?”).
- Contractual Necessity: To perform our contractual obligations to our Agency clients and to facilitate the application process for Students as initiated by them.
- Legitimate Interests: For purposes such as maintaining the security of our platform, system integrity via audit logs, and improving our services, provided these interests are not overridden by your rights and interests.
- Legal Obligation: To comply with our legal duties.
5. Data Sharing and Disclosure We are committed to maintaining the confidentiality and isolation of your data:
- Student Data: Personal information submitted by a Student through the application portal is only accessible to the specific Agency to which the Student has applied. Each Agency has its own isolated application instance, and student data is not shared with other Agencies or any other third parties by us unless required by law.
- Agency Data: Information related to an Agency is kept strictly isolated and is not shared with other Agencies or third parties by us, unless required by law or for the provision of services directly contracted by the Agency (e.g., payment processing, if applicable).
- Service Providers: We may use third-party service providers for specific functions, such as hosting. Our server is located in Johannesburg and maintained by Xneelo. These providers are contractually bound to protect your information and use it only for the services we have engaged them for.
- Legal Requirements: We may disclose personal information if required to do so by law or in the good faith belief that such action is necessary to comply with a legal obligation, protect and defend our rights or property, or in urgent circumstances to protect the personal safety of users or the public.
6. Data Retention
- Personal information is kept indefinitely to allow Agencies to manage ongoing student relationships and for historical record-keeping.
- Agency Deletion Request: If an Agency requests the deletion of their account, their entire application instance and associated database will be permanently removed from our active systems. Audit trail data related to the agency’s activity might be retained for legal and compliance purposes where necessary.
- Student Deletion Request: A Student can request the deletion of their personal data via the Agency they applied to, or directly from us. Upon such a request, the student’s personal data will be permanently removed from the active application instance. However, information contained within our audit trails (Envers logs of database changes) may be retained for legal and compliance purposes, as these are essential for system integrity and historical accountability. Reconstructing a student’s full data from audit trails alone is not a standard operational procedure.
7. Data Security We implement reasonable technical and organizational measures to protect the personal information we collect and store. These include:
- Isolated application instances for each Agency, using Spring Boot and Spring Security frameworks.
- Envers logging for database changes, which includes IP address, browser type, and device for auditing purposes.
- Hosting our servers in a secure data center in Johannesburg, maintained by Xneelo and managed by Silver Surge.
- Restricting access to personal information to authorized personnel only.
While we strive to protect your personal information, no method of transmission over the Internet or electronic storage is 100% secure, we do however follow best practices and global standards.
8. Your Rights (under POPIA) As a data subject in South Africa, you have certain rights regarding your personal information. These include:
- Right of Access: You have the right to request access to the personal information we hold about you.
- Right to Rectification: You have the right to request the correction of inaccurate or incomplete personal information.
- Right to Erasure (Deletion): You have the right to request the deletion of your personal information, subject to legal and contractual retention requirements (as detailed in Section 6).
- Right to Object to Processing: You have the right to object to the processing of your personal information under certain circumstances.
- Right to Restrict Processing: You have the right to request the restriction of processing of your personal information under certain circumstances.
- Right to Withdraw Consent: Where processing is based on consent, you have the right to withdraw your consent at any time.
- Right to Data Portability: You may have the right to receive your personal information in a structured, commonly used, and machine-readable format.
- Right to Lodge a Complaint: You have the right to lodge a complaint with the Information Regulator of South Africa if you believe your data protection rights have been infringed.
To exercise any of these rights, please contact us using the details provided in Section 1. Students may also contact the relevant Agency through which they submitted their information. We will respond to your request in accordance with applicable data protection laws.
9. Cookies We use cookies on our Platform (Agency Specific URL) solely for the purpose of persisting data that you have entered into forms during your session. This is for your convenience, so you do not have to re-enter information if you navigate away and return. We do not use cookies for tracking users across different websites or for advertising purposes. You can typically manage cookies through your browser settings.
10. International Data Transfers All personal information we collect is stored on servers located in Johannesburg, South Africa. We do not routinely transfer personal data outside of South Africa. If an Agency user accesses the platform from outside South Africa, their data will be processed from that location to our South African servers.
11. Children’s Privacy Our Platform is designed for use by student accommodation management agencies and adult students. It is not directed towards children under the age of 18, and we do not knowingly collect personal information from children under 18. If we become aware that we have inadvertently collected personal information from a child under 18, we will take steps to delete such information.
12. Changes to This Privacy Policy We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. If we make material changes, we will provide notification on our web portal (AGENCY SPECIFIC). We encourage you to review this Privacy Policy periodically. The “Last Updated” date at the top of this policy indicates when it was last revised.
13. Contact Us If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:
Silver Surge (PTY) Ltd
70 Olivier Street Potchefstroom, South Africa
0646570876
Attention: Jp Silver