In this policy, references to “Do” or “the Group” are to Livingstone Capital (Pty) Ltd (reg: 2015/257665/07) and its subsidiary and affiliates companies, including divisions, and business units. The Group consists of:

• The do life company (Pty) Ltd. (reg: 2020/547015/07)
• Isikolo Ventures (Pty) Ltd (reg: 2019/129155/07)
• Livingstone Venture Fund (Pty) Ltd (reg: 2016/070888/07)

The Group adheres to the highest standards of protecting your personal information when we process it by virtue of your use of our Products, Services, your use of our websites or any of its related blogs, websites, applications, or platforms (collectively, “the Digital Domains”), or by providing us with your personal information in any other way.
As such, we have created this specific and detailed Privacy Policy for you to read and appreciate exactly how we collect, process, and safeguard your personal information and respect your privacy (“Policy”).

Please note that the Group companies are private limited liability company duly registered and operating in accordance with the laws of South Africa. For more information regarding your personal information lawfully stored or used by the Group, please contact privacy@dolife.io who will gladly assist. Not all terms are necessarily defined in order or may be defined in our other agreements or policies. Please ensure that you read all the provisions below, and our other Group rules and policies which may apply from time to time and made available to you, to understand all of your, and our, rights and duties.

Purpose of this Privacy Policy
This Privacy Policy aims to give you information on how the Group collects and processes your personal data through any form of your engagement with Group companies such as your engagement with us when contacting, purchasing, contracting or corresponding with us, when using our Products, Services, accessing or using the Digital Domains, or providing us with your personal information in any other way (such as when participating in courses or surveys, participating in events, promotions, signing up for newsletters or sharing a testimonial).

This Privacy Policy complies with, and facilitates the obligations required from, the South African Protection of Personal Information Act, No. 4 of 2013 (“POPI”), as amended.

Users with citizenships from jurisdictions other than of South Africa, please note that Do Group complies with all South African data protection laws when processing your personal information pursuant to the Services as we are a South African entity operating in the South African market. Should foreign law be applicable in any regard to your use of the Services and/or the Website in any way, including how we may process your personal information, please contact the Group at privacy@dolife.io who will gladly engage you on its application and your rights.

It is important that you read this Privacy Policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

By virtue of the comprehensive and very unique products and services we provide to our clients & customers, we have to process limited special categories/sensitive of personal data as well as the data of minors (if a user is a minor). Users understand and expressly consent to this processing. All such special categories/sensitive data is protected/secured at better standards than conventional data.

Minors must only use the Digital Domains and Services using their parent’s devices and have their parent’s supervision and consent when doing so, where all minors’ parents/guardians will be liable for not only their child’s/ward’s use of the Services and Digital Domains but are also hereby providing their express consent to our processing of their child’s/ward’s personal data when using our Services and Website.

If customers use Group products, solutions, and services (including both assisted and unassisted interactions), or by accepting any agreement, contract, or document with the Group or by utilising any product or service offered by the Group, customers agree that in order to:

• conclude and fulfil contractual terms or obligations to a customer; ·
• comply with obligations imposed by law; or
• to protect or pursue customers’, the Group’s, or a third party’s legitimate interests, including offering solutions that best meet customers’ needs;
• customers’ personal information may be processed through centralised functions and systems across Group.

Responsible Party and Operator roles
Do is the “Responsible Party” and is responsible for your personal data in instances where we decide the processing operations concerning your personal data. Sometimes we also operate as a “Operator” of personal data on behalf of a third-party Responsible Party, where that Responsible Party’s privacy terms will apply, but we will draw your attention to them, when applicable. We have appointed an Information Officer (“IO”) at Do who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the IO using the details set out at the end of this policy.

Changes to the Privacy Policy and your Duty to Inform us of Changes
This Privacy Policy version was last updated on 01 January 2024 and historic versions are archived and can be obtained by contacting us. It is important that the personal data we hold about you is accurate and current. Please update your personal data yourself by send us an email on support@skills.dolife.io or contacting our experience centre at, or keep us informed (using email or telephone engagements) if your personal data changes during your relationship with us.

Third-Party Links on Website or otherwise
The Digital Domains may include links to third-party websites, third-party service providers, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites/technology or applications and are not responsible for their privacy statements or terms. When you leave our Digital Domains, or engage with such third parties, we encourage you to read the distinct privacy policy of every third-party you engage with. 

Personal data, or personally identifiable information, means any information about an individual, both natural and juristic entities (i.e. people and companies), from which that entity can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer (“process”) different kinds of personal data about you which we have grouped together as follows:

• Identity Data including first name, maiden name, age, last name, country of residence, username or similar identifier, title, address, disability, date of birth and gender, pictures, videos, voice, what you are interested in studying and/or why you would like to study or the information about your company such as company registration details, company address and name;
• Contact Data including email address, physical/registered/business addresses, social media contact details and telephone numbers;
• Employment Data including name of employer (current and past), addresses, contract person, industry of your employer as well as positions you may hold with the current and past employers.
• Financial Data including bank account details, third-party payment provider information, credit records at registered credit bureaus, we do not store any credit card information processed through our payment portals (for details of their privacy policy please visit the related site);
• Social Media Data including all information accessible on your publicly available profile such as images, photos, photo tags, likes, followers, comments, posts and stories;
• Educational Data including your current studies and your attended learning institutions, course selections, course results, course completion, course assignments, disciplinary records, awards and course reviews;
• Transaction Data including details about payments to and from you, contracts, contractual terms, contract fees, signups, subscriptions, invoices, statements and other details of products and services you have obtained from us, or provide to us;
• Technical Data including internet protocol address/es, your login data, browser type and version, time zone setting and location, cookies, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Digital Domains;
• Profile Data including your Website/Profile username and password, preferences, feedback, opinion, ratings and reviews, and survey responses;
• Usage Data including information about how you use our company, website, surveys, events, products, data and Services; and
• Marketing and Communications Data including your preferences in receiving notices and marketing from us and our third parties and your communication preferences, references about you.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Digital Domain feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy. Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services or allow you to provide us with your services). In this case, we may have to cancel Digital Domain-access or Services you have with us, but we will notify you if this is the case at the time.

We use different methods to collect data from and about you, including through:
Direct interactions: You may give us your Identity, Contact, Technical, Social Media, Usage, Transaction, Profile, Educational, Marketing & Communications and Financial Data by filling in various Do forms on Digital Domains, Purchasing Products or Services, Subscribing, completing application forms, Providing services in terms of agreements with the Group or by corresponding with us by phone, email, post or otherwise. This includes personal data you provide when you:

• use our Services;
• use our Websites, Apps or Tools;
• contract with us (as a client, service provider or otherwise);
• consult with us;
• transact with us;
• complete forms, surveys and competitions;
• sign-up for rewards, newsletters or promotional content;
• interact with us via webinar or social platform group, such as a Meta™
• provide any services to us as a service provider or independent contractor on contract with us;
• request information to be sent to you;
• attend any Do Group event whether online (such as online calls, instructional videos or webinars) or in person; or
• give us feedback and surveys.

Automated technologies or interactions: As you interact with our Digital Domains, we may automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:

• Technical Data and Usage Data from the following parties:
• Analytics providers Google Analytics, Google Tag Manager, WordPress, Facebook based in the United States of America;
• Social networks Meta, Instagram, Facebook and LinkedIn based in the United States of America;
• Survey data providers used by the Group mostly based in United States of America;
• Marketing platforms Facebook Business Manager, Google, other marketing platforms or software based in the United States of America, and elsewhere in the world;
• Employers working with one of the Group companies;
• Data and communication packages provided by CellC, MTN, Hero Vodacom based in Johannesburg;
• Contact, Financial and Transaction Data from providers of technical, financial and/or payment services being;

List of banks in South Africa:

• ABSA Bank Limited
• African Bank Limited
• Bidvest Bank Limited
• Capitec Bank Limited
• Discovery Bank Limited
• FirstRand Bank Limited
• Grindrod Bank Limited
• Investec Bank Limited
• Nedbank Limited
• Sasfin Bank Limited
• The Standard Bank of South Africa Limited
• Tyme Bank Limited
• UBANK Limited
• Bank Zero Mutual Bank
• Finbond Mutual Bank
• GBS Mutual Bank

List of Payment Solution situated in South Africa

• Payfast
• Payflex
• Layup
• Paystack
• Float

We will only use your personal data when the law allows us to and for legitimate reasons, which you hereby expressly understand and consent to. Most commonly, we will use your personal data in the following circumstances:

• where we have your express consent to do so;
• where we directly market our products and services to you. with express consent of customer
• where we need to consult with you or perform on the Services contract, we are about to enter into or have entered into with you;
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and/or
• where we need to comply with a legal or regulatory obligation.
• We do, from time to time, process personal data about Individuals in an automated way to evaluate certain personal aspects about such Individual, including to enable us to analyse and make predictions about their interests and how they are likely to interact with our business and which of our services may be of interest to them. This is commonly referred to as profiling and it is our way of providing Individuals with a more bespoke customer experience based on how we think the Individual will engage with us. We may choose to send a particular marketing communication to an Individual based on our calculation of which of our services may be of most interest to them. The Group may use a customer’s personal information to make an automated decision as allowed by the law. An example of automated decision making is the approval or declining an application or purchase. Customers have the right to query any such decisions made, and the Group will provide reasons for the decisions as far as reasonably possible.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate, and which exact External Third Parties your personal data is handed to for same reasons.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

• We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. To manifest your rights attached to any marketing sent to you as an existing customer, please use the in-built prompts provided on those communications, or contact us.
• You will receive marketing communications from us if you are a contracted data subject of ours already (or become one by accepting this Policy) have requested information from us, use our Services, have participated in any Do service or event, or if you provided us with your details when registering for a promotion or event and, in each case, you have not opted-out of receiving that marketing.
• e use various marketing software solution to legitimately pursue the Group’s interest, these software solutions are changed often and sometime irregularly. These solutions follow strict GDPR protocols and adhere to strict data security protocols.

Third-Party Marketing

• Whilst we may use your personal data within our Do Group, we will get your express opt-in consent before we share your personal data publicly with any entity outside the Do Group of organisations for public purposes.

Opting-Out

• You can ask us or authorised third parties to stop sending you marketing messages at any time by contacting us or the relevant third party at any time and requesting us to cease or change your marketing preferences.
• Where you opt-out of receiving these marketing messages, this opt-out will not apply to other personal data of yours which we process for another lawful basis.

Change of Purpose

• We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
• If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
• Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

• We may have to share your personal data with the parties set out below for the purposes set out in the table above.
• Internal Third Parties as set out in the Glossary;
• External Third Parties as set out in the Glossary;
• Specific third parties listed in the table above; and/or
• Third parties to whom we may choose to sell, transfer, or merge parts of our organisation or our assets. Alternatively, we may seek to acquire other organisations or merge with them. If a change happens to our organisation, then the new owners may use your personal data in the same way as set out in this Privacy Policy.
• We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions and standards.

Express Cookies provision

• The Digital Domains, including Websites may make use of “cookies” to automatically collect information and data through the standard operation of the Internet servers. “Cookies” are small text files a website can use (and which we may use) to recognise repeat users, facilitate the user’s on-going access to and use of a website and allow a website to track usage behaviour and compile aggregate data that will allow the Website operator to improve the functionality of the Website and its content, and to display more focused advertising to a user by way of third party tools.
• The type of information collected by cookies is not used to personally identify you. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to deny or accept the cookie feature. Please note that cookies may be necessary to provide you with certain features available on our Website, and thus if you disable the cookies on your browser you may not be able to use those features, and your access to our Website will therefore be limited. If you do not disable “cookies”, you are deemed to consent to our use of any personal information collected using those cookies, subject to the provisions of this Policy and our other policies or terms.

• We share your personal data within the Do Group and affiliates, and this may involve transferring and processing your data outside of South Africa.
• Whenever we transfer your personal data out of either territory, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• We will always have a contract concluded between the parties speaking specifically to data protection and the duties of each party related thereto; and
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the Information Regulator’s Office of South Africa; and/or
• Where we use certain service providers, we may use specific contracts/clauses approved by the Information Regulator’s Office which give personal data the same protection it has in South Africa.
• Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of South Africa.

• Cloud hosted applications are accessed via secure logins and Digital Domains are SSL enabled. Strong password complexity is enforced and we are notified by email should there be any unauthorized sign in attempts. Should this happen we immediately block the account and inform the user account owner.
• We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed by using data encryption wherever possible as well as securing our applications and data storage environment behind a firewall.
• Work from home users connect to our network though a secure portal to allow secure access to internal systems.
• Granular file access is granted to staff within the company and certain restrictions apply based on user roles. Latest security patches are applied on systems, firewall equipment as well as user equipment. The use of flash drives and external storage drives are prohibited so data cannot be copied to these devices. This is achieved by applying machine group policies however these policies do not apply to Senior Management and Executive staff. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a legitimate need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
• We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

• We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements (including financial/tax reporting and record-keeping laws).
• To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, any other South African applicable law requiring us to retain the data and whether we can achieve those purposes through other means, and the applicable legal requirements.
• Details of retention periods for different aspects of your personal data are available from us by contacting us.
• In some circumstances you can ask us to delete your data; see below for further information.
• In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you

Lawful Basis

• Legitimate Interest means the interest of our Group in conducting and managing our organisation to enable us to give you the best service and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
• Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
• Express consent means the confirmed express consent you have provided to our processing of your personal data by actively accepting this Privacy Policy.

Third Parties

• Internal Third Parties means other entities or parties in the Do Group acting as joint controllers or processors and who are based in South Africa and provide IT and system administration services and undertake reporting.

External Third Parties means:

• Authorised third-party service providers under contract with Do who need your personal information in order to contact and transact with you pursuant to your use of the Services;
• Specific third parties who have been identified in the table above;
• Service providers acting as processors based in South Africa who provide IT and system administration services;
• South African or other national governments and/or their respective authorities pursuant to our adherence with anti-corruption and crime-fighting legislation; and/or
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers based in South Africa who provide consultancy, banking, legal, insurance and accounting services as required.

Your legal rights
You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no valid reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be communicated to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

1. if you want us to establish the data’s accuracy;
2. where our use of the data is unlawful but you do not want us to erase it;
3. where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
4. you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform on a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain Website access or Services to you. We will advise you if this is the case at the time you withdraw your consent. Please take note that regardless of your right to withdraw consent under POPI, other South African legislation applies and may require that we continue to process your data in order to comply with anti-corruption, educational reporting, child-protection, crime-fighting and/or other national legislation, which you expressly understand and agree to.

Our full details are:

• Full name of legal entity: Livingstone Capital (Pty) Ltd.
• Name of IO: Theo Kriek
• Email address: privacy@dolife.io
• Postal address: 18 Ajax Crescent, Cambridge East London, 5217
• Telephone number: 083 3095987

Please read this cookie policy (“cookie policy”, "policy") carefully before using any of out website (“website”, "service") operated by the ‘do group’ ("us", 'we", "our").

What are cookies?

Cookies are simple text files that are stored on your computer or mobile device by a website’s server. Each cookie is unique to your web browser. It will contain some anonymous information such as a unique identifier, website’s domain name, and some digits and numbers.

What types of cookies do we use?

Necessary cookies

Necessary cookies allow us to offer you the best possible experience when accessing and navigating through our website and using its features. For example, these cookies let us recognize that you have created an account and have logged into that account.

Functionality cookies

Functionality cookies let us operate the site in accordance with the choices you make. For example, we will recognize your username and remember how you customized the site during future visits.

Analytical cookies

These cookies enable us and third-party services to collect aggregated data for statistical purposes on how our visitors use the website. These cookies do not contain personal information such as names and email addresses and are used to help us improve your user experience of the website.

How to delete cookies?

If you want to restrict or block the cookies that are set by our website, you can do so through your browser setting. Alternatively, you can visit www.internetcookies.com, which contains comprehensive information on how to do this on a wide variety of browsers and devices. You will find general information about cookies and details on how to delete cookies from your device.

Contacting us

If you have any questions about this policy or our use of cookies, please contact us.