Thrive by Five Website Privacy Policy

Last updated: 1 April 2022

This is the website privacy policy (“Privacy Policy”) for the Thrive by Five Index (“Thrive by Five”, “we”, “us” or “our”), an early childhood development campaign in South Africa.

This Privacy Policy describes how we collect, use and disclose your information when you access and use our website. The purpose of our Privacy Policy is to give you knowledge of how we process information about you. We are highly focused on processing any personal data with care, trust and respect.

Contact Details

This website is operated and owned by:
The Thrive by Five Index
Cape Town
South Africa
Email Address:

Contact Details Are
Name Sonja Giese
Contact No. 082 870 7345
Email Address:


In this Privacy Policy, the following words mean:

“Account” means a unique account created for you to access our Services or parts of our Services.

“Cookies” are small files stored on your Device during your use of the Website and which contain data about your use of the Services. We may use session Cookies (which expire when you close your browser) or persistent Cookies (which stay on your Device until you delete them).

“Data Protection Laws” means POPI and, where applicable, the GDPR, which includes the retained EU law version of GDPR as it forms part of the law of the United Kingdom, and any other applicable data protection legislation and/or regulation.

“Device” means any device that can access the Services such as a computer, a cellphone or a digital tablet.

“GDPR” means the General Data Protection Regulation (EU 2016/679).

“Personal Information” means any information relating to a data subject who can be identified, directly or indirectly, by reference to an identifier such as a name, 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 data subject, and includes “Personal Data” as the term is defined in GDPR.

“POPI” means the Protection of Personal Information Act, 2013.

“Services” means the services provided by Thrive by Five Index from time to time, including the provision of access to the Website and Google Form Application Portals.

“Service Provider” means any natural or legal person who processes Personal Information on behalf of Thrive by Five Index. It refers to third-party companies or individuals employed by Thrive by Five Index to facilitate the Services, to provide the Service on behalf of Thrive by Five Index, to perform services related to the Services or to assist Thrive by Five Index in analysing how the Services are used.

“Usage Data” refers to data collected automatically, either generated by the use of the Services or from the Service infrastructure itself (for example, the duration of a page visit).

“Website” refers to the website owned and operated by Thrive by Five Index, accessible from https:/

Our Services

By using our Services, you agree to us processing your Personal Information in accordance with this Privacy Policy and applicable Data Protection Laws.

Collecting and Using Your Personal Data

In using our Services, we may ask you to provide us with certain Personal Information that can be used to contact or identify you. The Personal Information we collect may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Usage Data

Usage Data and Cookies

We use Cookies and other technologies to collect information about your visit to the Website and access to the Services, such as the date and time of your visit, the information you searched to find the Website, or your activity on the Website.

You may adjust your browser or operating system settings to limit or to decline or delete Cookies, but this may affect your use of certain areas of the Website or the Services. Check the settings menu of your browser or operating system to learn how to change your tracking settings or Cookie preferences.

From time to time, we may collect Usage Data automatically when you use the Services.

The Usage Data we collect may include information such as your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Services through a mobile Device, we may collect certain information automatically, including, but not limited to, the type of mobile Device You use, your mobile Device unique ID, the IP address of your mobile Device, Your mobile operating system, the type of mobile Internet browser you use, unique Device identifiers and other diagnostic data.

We may also collect information that your browser sends whenever you visit our Website or when you access the Services from a mobile device.

Use of Your Personal Data

We process your personal information only where we have a lawful basis to do so, for example, for the following purposes:

  • To provide and maintain our Services, including to monitor the usage of our Services.
  • To contact you by email, telephone calls, SMS, or other methods of electronic communication.
  • To provide you with news, special offers and general information about other services and events which we offer that are similar to those that you have already enquired about (unless you have opted not to receive such information).
  • To attend to and manage your requests to us.

We may use your information for other purposes where we have a legitimate reason, such as to verify your identity, for data analysis purposes, to respond to your queries, identify usage trends, determine the effectiveness of our promotional campaigns and, to evaluate and improve our Services, products, services, marketing and your experience and otherwise for our legitimate business purposes or where you have consented to the processing.

Retention of Your Personal Data Thrive by Five Index will retain Your Personal Data only for as long as is necessary to provide the Services to you. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with Data Protection Laws and other applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.


We maintain appropriate procedures to safeguard and secure your Personal Information and to prevent unauthorised access of your Personal Information. However, the accuracy, safety, and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to your Account or to certain parts of the Website, you are responsible for keeping this password confidential. We are not responsible for any unauthorised access to or acquisition of your Account or to your information.

Transfer of Your Personal Data

Your information, including Personal Information, is processed at Thrive by Five Index’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of the country in which you are located or where it was collected.

Thrive by Five Index will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Information will be processed in a country unless there are adequate controls in place including the security of your Personal Information.

Disclosure of Your Personal Data


We may share your information with our donors and/or funders and/or Service Providers for statistical reasons, to analyse participation in relation to the Services. The information we provide in this regard will not be personally identifiable information, unless we have a legitimate basis to disclose your Personal Information.

Business Transactions

If Thrive by Five Index is involved in a merger or acquisition, your Personal Information may be transferred to the merging or acquiring entity. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, we may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Service Providers

We may share your information with our Service Providers to render the Services, and/or otherwise for our internal administration purposes, including to provide us with business, professional, or technical support. These persons will only be provided with access to your Personal Information to the extent necessary.

Other legal requirements

We may disclose your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend our rights and/or our property
  • Prevent or investigate possible wrongdoing in connection with the Services
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability
  • Secure your Personal Information

While we try our best to protect your Personal Information, transmission via date over the Internet is never completely secure and we accordingly cannot guarantee its absolute security.

Links to Other Websites

Our Service may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.


No person under the age of 18 may submit any Personal Information to us or use the Services without their legal guardian’s consent and supervision.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. The most up-to-date version of the Privacy Policy will always be available on our Website.

It is your responsibility to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective from the time they are posted on the Website.

You have certain rights in respect of your Personal Information, including:

  • The right to be notified that your Personal Information is being collected by us or has been accessed or acquired by an unauthorised person.
  • The right to access the Personal Information that we hold about you.
  • The right to rectify/correct/update inaccurate Personal Information and to update incomplete Personal Information.
  • The right to request that we correct, destroy or erase any of your Personal Information.
  • The right to object to or restrict us processing your Personal Information.
  • The right to request the transfer of your Personal Information to you or to a third party.
  • The right not to be subject, under certain circumstances, to automated-decision-making processes.
  • The right to object at any time to the processing of your Personal Information for direct marketing purposes.
  • The right to lodge a complaint with the relevant regulatory body which, for the purposes of POPI, is the Information Regulator. The Information Regulator can be contacted by email: or
  • The right to institute civil proceedings in relation to your Personal Information.

You will not generally have to pay a fee to access your Personal Information(or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

If you would like to exercise any of your rights in respect of your Personal Information or have any queries or complaints on how we have handled your Personal Information, please contact us via our information officer so we can investigate the matter.