Privacy Policy

PACK App

Effective Date: June 2026

This privacy policy (“Privacy Policy”) applies to how we process your Personal Information when you use the website available at https://knowledgetranslation.co.za (“Website”) and the PACK clinical guide application available at https://digital-platforms.knowledgetranslation.co.za (the “App”), whether you access the App through a web browser or install and use it on your device, and whether you use it online or offline.

All the provisions of this Privacy Policy are important, but please pay special attention to the parts that are in bold writing or in a box. Boxed explanations are aids to understanding only and are not provisions themselves.

1. What the PACK App collects – in short

To keep this guide useful, the App records a few things about how it is used. In plain terms:

• the country and province/region you enter when you first set up the App;
• a code that our App assigns to your device so we can count unique devices and understand overall usage (this is a code we generate – it is not your name, and we do not collect your hardware or device identifiers);
• which pages you open and how long you spend on them.

We use this information to keep the guide accurate, fix problems, improve the App, target our training, produce grouped maps of how the guide is used, and send you updates such as changes to clinical guidelines or relevant health alerts. Our reports use grouped, de-identified figures, and are not used to identify any individual.

2. Introduction and scope

2.1 The Website and the App are managed by Knowledge Translation Foundation NPC (the “KTF”), registration number 2024/333268/08, a non-profit company registered in accordance with the company laws of the Republic of South Africa. Any reference to “we”, “our” or “us” shall mean the KTF, who is the responsible party for the processing described in this Privacy Policy.

2.2 We are committed to protecting and respecting your privacy and to processing your Personal Information lawfully, reasonably and in a manner that is minimally necessary for the purposes set out below.

2.3 This Privacy Policy does not apply to the processing of Personal Information by third parties by means of their own websites, products or services, such as sites linked to from the Website or the App. Such processing may be subject to the privacy policies of those third parties.

3. Your consent and our lawful basis for processing

3.1 “Processing” means collecting, receiving, recording, organising, storing, updating, retrieving, using, sharing or otherwise handling your Personal Information.

3.2 We process your Personal Information on the following bases:

3.2.1 to provide the App and the Services you request – for example, delivering the guide to your region and sending you essential updates to the Content – which is necessary to perform our agreement with you and is in our and your legitimate interest;

3.2.2 to understand and improve how the App is used, and to support efforts to strengthen primary care, which we do on the basis of our legitimate interest, using de-identified and grouped information as far as reasonably possible; and

3.2.3 with your consent, where we rely on consent (for example, for optional communications that are not essential to the Service). Where we rely on your consent, you may withdraw it at any time by the same means you gave it, without affecting the lawfulness of processing before withdrawal.

3.3 If you do not agree with this Privacy Policy, or are concerned about any aspect of how we process your Personal Information, please do not continue to use the Website or the App.

4. What is Personal Information?

4.1 “Personal Information” means information relating to an identifiable, living natural person. In relation to the App, the Personal Information we process is limited to:

4.1.1 the country and province/region you enter when you first set up the App;

4.1.2 an application-assigned device code that we generate and store to count unique devices and measure usage over time. Because this code persists on your device, it is treated as Personal Information even though it does not contain your name;

4.1.3 usage information - which pages you open, how long you spend on them, and the order in which you view them.

4.2 We do not collect your name, contact details (unless you choose to give them to us, for example by emailing us), patient information, or your hardware or device identifiers. Where we report on usage, we do so using grouped, de-identified figures that cannot reasonably be linked back to you.

4.3 If you contact us (for example, by email), we may keep a record of that correspondence, which may include your email address and any information you provide.

5. How we collect your Personal Information

5.1 We collect your Personal Information in two ways:

5.1.1 actively from you – for example, the country and province/region you enter at registration, and any information you give us when you contact us; and

5.1.2 automatically from your device when you use the App – for example, the application-assigned device code and usage information described in clause 4..

5.2 The App may store some of this information on your device (including when you use the App offline) and upload it to us when your device next connects to the internet.

6. How we use your Personal Information

6.1 We use the information we collect to:

6.1.1 provide, maintain and improve the Website and the App and keep the Content accurate and up to date;

6.1.2 understand how the guide is used so that we can target and improve our training for specific conditions and produce grouped maps of usage across regions to support primary care;

6.1.3 diagnose and fix technical problems and respond to user queries;

6.1.4 detect, prevent and deal with fraud, security issues, and misuse of the Website or the App;

6.1.5 send you service communications, such as updates to clinical guidelines and relevant health alerts (for example, disease-outbreak notifications); and

6.1.6 compile grouped, de-identified statistics about how the Website and the App are used, in order to develop, provide and improve them and to support efforts to strengthen primary care. This information is grouped and cannot reasonably be linked back to identify you.

6.2 We will obtain your consent before using your Personal Information for any materially different purpose. Any optional or promotional communications (that is, communications other than service communications) will be sent only where you have separately opted in, and every such message will allow you to opt out.

7. Sharing your Personal Information

7.1 We do not sell your Personal Information. We will not share it other than as set out in this Privacy Policy, as permitted by law, or with your permission.

7.2 We may share your Personal Information:

7.2.1 with our employees, service providers and operators who need it to provide services to or for us, such as hosting and technical support. We put written agreements in place requiring them to keep your Personal Information confidential and secure and to process it only on our instructions;

7.2.2 to enforce our Terms of Use or any other contract between you and us;

7.2.3 to protect our rights, property or safety, or those of our users or any third party; and

7.2.4 to a regulator, court or other authority where we are required to do so by law or legal process.

7.3 We may compile grouped, de-identified statistics for research and reporting purposes, provided these cannot reasonably be linked back to identify you.

8. Where your Personal Information is stored

8.1 Your Personal Information is stored on servers located in South Africa (Microsoft Azure, South Africa region), and on your device where the App stores information for offline use.

8.2 We do not routinely transfer your Personal Information outside South Africa. If, in future, we host or process your Personal Information in another country - for example, if the App is offered in other countries – we will update this Privacy Policy and ensure there is a lawful basis for any such transfer under section 72 of the Protection of Personal Information Act 4 of 2013 (“POPIA”), including, where required, ensuring that your Personal Information is adequately protected in that country.

8.3 Where we use an operator (such as our hosting provider) to process Personal Information on our behalf, we enter into a written agreement requiring them to secure the integrity and confidentiality of that information by taking appropriate, reasonable technical and organisational measures.

9. Security

9.1 We take appropriate, reasonable technical and organisational measures to secure the integrity and confidentiality of Personal Information and to prevent its loss, damage, or unauthorised access or use, including measures to protect information stored on your device.

9.2 Even with these measures, no processing of information is completely secure. As far as the law allows, and subject to POPIA, we will not be liable for any loss or damage arising from unauthorised access, disclosure, misuse, loss, alteration or destruction of Personal Information that occurs despite our taking such reasonable measures.

10. How long we keep your Personal Information

10.1 We keep Personal Information for as long as you continue to use the App, or for as long as reasonably necessary for the purposes set out in this Privacy Policy, or until you ask us to delete it, unless we are required or permitted by law to keep it for longer.

11. Your rights

11.1 Subject to POPIA and other applicable law, you have the right to:

11.1.1 ask what Personal Information we hold about you;

11.1.2 ask us to correct or update your Personal Information;

11.1.3 ask us to delete your Personal Information where it is no longer required for the purposes for which it was collected, subject to clause 10;

11.1.4 object to the processing of your Personal Information in certain circumstances; and

11.1.5 refuse the processing of your Personal Information for direct marketing purposes.

11.2 The App does not collect your name or contact details, we cannot link usage information to a specific person, and we are not required to collect further information in order to do so. You can remove the information stored on your device at any time by clearing the App's data or uninstalling it. If you ask us to delete information we hold, we will do so where you can give us enough detail to identify it. We keep usage information only for as long as necessary and in grouped, de-identified form for reporting

12. Changes to this Privacy Policy

12.1 We may update this Privacy Policy from time to time. If we do, we will post the revised policy with the date on which it was last updated, and, if the changes are material, take reasonable steps to bring them to your attention. If you continue to use the Website or the App after changes are displayed, you will be deemed to have accepted them.

13. POPIA, the Consumer Protection Act and other laws

13.1 It is not intended that any provision of this Privacy Policy contravene POPIA, the Consumer Protection Act 68 of 2008 or any other applicable law. All provisions must be treated as qualified, to the extent necessary, to ensure compliance with those laws. No provision limits or excludes any liability, warranty or obligation to the extent the law does not allow it to be limited or excluded.

14. How to contact us

14.1 If you have questions about this Privacy Policy, or wish to exercise any of your rights, please contact us at privacy@knowledgetranslation.co.za

14.2 You also have the right to lodge a complaint with the Information Regulator (South Africa) at POPIAComplaints@inforegulator.org.za or via https://inforegulator.org.za, for any alleged contravention of POPIA.