This Policy complies with the European Union’s General Data Protection Regulation (“GDPR”) and South Africa’s Protection of Personal Information Act No. 4 of 2013 (“POPI”).
This Policy applies to you if you are:-
2.1. a visitor to our website; or
2.2. a customer who has ordered, registered for or uses the services that we provide.
3. PERSONAL DATA
3.1. Personal Data includes:-
3.1.1. certain information that we collect automatically when you visit our website;
3.1.2. certain information collected on registration (see below);
3.1.3. certain information collected on submission; and
3.1.4. optional information that you provide to us voluntarily (see below);
3.1.5. information that has been made anonymous so that it does not identify a specific person;
3.1.6. permanently de-identified information that does not relate or cannot be traced back to you specifically;
3.1.8. information that you have provided voluntarily in an open, public environment or forum, including any blog, chat room, community, classifieds or discussion board (because the information has been disclosed in a public forum, it is no longer confidential and does not constitute personal data subject to protection under this policy).
3.2. Common examples of the types of Personal Data we may collect and process include your:-
3.2.1. identifying information – such as your name, date of birth, or identification number of any kind;
3.2.2. contact information – such as your phone number or email address; and
3.2.3. address information – such as your physical and/or postal address;
3.2.4. demographic information – such as your gender or marital status.
3.3. Depending on the services that you require, we may also collect sensitive Personal Data, including your:-
3.3.1.financial information – such as your bank account details;
3.3.2. sensitive demographic information – such as your race or ethnicity; and
3.3.3. employment information – including your job title and the industry you work in.
4. ACCEPTANCE OF THIS POLICY
4.1. You must accept all the terms of this Policy when you register for or use our website or any of our services. If you do not agree with anything in this Policy, then you may not register for or use our website or any of our services. Furthermore, you may not register for or use our website or any of our services if you do not accept this Policy.
4.2. You may not access our website or order our services if you are younger than 18 (eighteen) years of age or do not have legal capacity to conclude legally binding contracts.
4.3. By accepting this Policy, you are deemed to have read, understood, accepted, and agreed to be bound by all of its terms.
5. YOUR OBLIGATIONS
You may only send us your own Personal Data or the information of another data subject, where you have their permission to do so. Our website may give you the option to post information in a way that is publicly accessible and may be collected by others (such as via comments on articles). You are responsible for any Personal Data that you post in this way.
We may change the terms of this Policy at any time by updating this web page. We will notify you of any changes by placing a notice, in a prominent place, on the website, or by sending you an e-mail detailing the changes that we have made and indicating the date that they were last updated. If you do not agree with the changes, then you must stop using our website and our services. If you continue to use our website and/or our services following notification of a change to this Policy, the changed Policy will apply to you and you will be deemed to have accepted the updated Policy.
7. COLLECTION OF DATA
7.1. Once you register on our website, you will no longer be anonymous to us. You will provide us with certain Personal Data. This Personal Data will include:-
7.1.1. your name and surname;
7.1.2. your email address; and
7.1.3. your username and password.
7.2. We will use this Personal Data to complete your account, provide additional services and information to you, as we reasonably think appropriate, and for any other purposes set out in this Policy.
7.3. On Order
When you order any services from us, you may be asked to provide us with additional information, on a voluntary basis (services information). This information may include:-
7.3.1. your identity number;
7.3.2. your postal address or street address;
7.3.3. your telephone number.
7.4. From Browser
Please note that other websites you visited before entering our website may place Personal Data within your URL during a visit to it and we have no control over such websites. Accordingly, a subsequent website that collects URL information may log some Personal Data, without our knowledge or consent, and we are not liable for their use of such Personal Data.
9. WEB BEACONS
Our website may contain electronic image requests (called a single-pixel GIF or web beacon request) that allow us to count page views and to access cookies. Any electronic image viewed as part of a web page (including an ad banner) can act as a web beacon. Our web beacons do not collect, gather, monitor or share any of your Personal Data. We merely use them to compile anonymous information about our website.
10. OPTIONAL DETAILS
You may also provide additional information to us, on a voluntary basis (optional information). This includes content or products that you decide to upload or download from our website, or when you enter competitions, take advantage of promotions,respond to surveys, order certain additional goods or services, or otherwise use the optional features and functionality of our website.
11. RECORDING CALLS
We may monitor and record any telephone calls that you make to us, unless you specifically request us not to.
12. PURPOSE FOR COLLECTION OF DATA
12.1. We may use or process any services information or optional information that you provide to us, for the purposes that you indicated when you agreed to provide it to us. Processing includes gathering your Personal Data, disclosing it and combining it with other Personal Data. We generally collect and process your Personal Data for various purposes, including, but not limited to:-
12.1.1. services purposes – such as providing our services;
12.1.2. marketing purposes – such as pursuing lawful, marketing-related activities, including business intelligence (including website activity and market research);
12.1.3. business purposes – such as internal audit, accounting, business planning and joint ventures, disposals of business, or other proposed and actual transactions; and
12.1.4. legal purposes – such as handling claims, complying with regulations or pursuing good governance.
12.2. We may use your usage information for the purposes described above and to:-
12.2.1. remember your information so that you will not have to re-enter it during your visit or the next time you access our website;
12.2.2. monitor website usage metrics, such as total number of visitors and pages accessed; and
12.2.3. track your entries, submissions and status in any promotions or other activities in connection with your usage of our website.
13. CONSENT TO COLLECTION OF DATA
We will obtain your consent to collect Personal Data:-
13.1. in accordance with applicable law;
13.2. when you provide us with any registration information or optional information.
14. USE OF DATA
14.1. Our obligations
We may use your Personal Data to fulfil our obligations to you. This could include delivering newspapers to you, allowing you to access exclusive content on our website, billing you for our services, or improving our offerings.
14.2. Messages and updates
We may send administrative messages and e-mail updates to you about our website. We may wish to provide you with information about new goods or services in which we think you may be interested. This means that, in some cases, we may also send you primarily promotional messages. We will not send you promotional messages unless you have chosen to opt in to receive them. You can choose to opt out of receiving promotional messages.
14.3. Targeted content
While you are logged into our website, we may display targeted adverts and other relevant information, based on your Personal Data. In a completely automated process, computers process the Personal Data and match it to adverts or related information. We never share Personal Data with any advertiser, unless you specifically provide us with your consent to do so.
Advertisers receive a record of the total number of impressions and clicks for each advert. They do not receive any Personal Data. If you click on an advert, we may send a referring URL to the advertiser’s website, identifying that a customer is visiting from the website. We do not send Personal Data to advertisers with the referring URL. Once you are on the advertiser’s website, however, the advertiser is able to collect your Personal Data. We are not responsible for any Personal Data collected and/or used by any advertisers.
15. DISCLOSURE OF DATA 15.1. Sharing
We may share your Personal Data with:-
15.1.1. other divisions or companies within the group of companies to which we belong, to provide joint content and services, like registration for transactions and customer support, to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about our products, services, and communications (they will only use this information to send you marketing communications if you have requested their goods or services);
15.1.2. an affiliate, in which case we will seek to require the affiliates to honour this Policy;
15.1.3. our goods suppliers or service providers under contract who help supply certain goods or help with parts of our business operations, including fraud prevention, bill collection, marketing, technology services (our contracts dictate that these goods suppliers or service providers only use your information in connection with the goods they supply to us or services they perform for us, and not for their own benefit);
15.1.4. credit bureaus, to report account information, as permitted by law;
15.1.5. banking partners, as required by credit card association rules for inclusion on their list of terminated merchants (in the event that you utilise the services to receive payments and you meet their criteria);
15.1.6. social media platforms, when you use tools or functionality on our website provided by those platforms (such as recommend or share buttons); and
15.1.7. other third parties who provide us with relevant services, where appropriate.
We may disclose your Personal Data, as required by law or governmental audit. 17. LAW ENFORCEMENT
We may disclose Personal Data if required:-
17.1. by a Subpoena or Court Order;
17.2. to comply with any law;
17.3. to protect the safety of any individual or the general public; and
17.4. to prevent violation of our customer relationship terms.
18. NO SELLING
We will not sell Personal Data. No Personal Data will be disclosed to anyone, except as provided for in this Policy.
19. NO LINKED WEBSITES
We do not share Personal Data with any websites linked to our website, unless they are a party with whom we are allowed to share Personal Data, as provided for in this Policy. Please check these websites’ own privacy policies before sharing your Personal Data with them. We are not responsible for any Personal Data collected and/ or used by these websites.
20. MARKETING PURPOSES
We may disclose aggregate statistics (information about the customer population in general terms) about the Personal Data to advertisers or business partners, for marketing purposes.
We may need to disclose Personal Data to our employees that require the Personal Data to do their jobs. These employees include, but are not limited to, our responsible management, human resources, accounting, audit, compliance, information technology, or other personnel. Any of our employees or personnel that handle your Personal Data will have signed non-disclosure and confidentiality agreements.
22. CHANGE OF OWNERSHIP
If we undergo a change in ownership, or a merger with, acquisition by, or sale of assets to, another entity, we may assign our rights to the Personal Data that we possess to a successor, purchaser or separate entity. We will disclose such transfer on our website. If you are concerned about your Personal Data migrating to a new owner, you may request us to delete your Personal Data.
We take the security of Personal Data very seriously and always do our best to comply with applicable data protection laws. Our hosting company will host our website in a secure server environment that uses a firewall and other advanced security measures to prevent interference or access from outside intruders. We authorise access to Personal Data only for those employees who require it to fulfil their job responsibilities. We implement disaster recovery procedures where appropriate. We do not, however, accept liability for any Personal Data being obtained by a third party, notwithstanding the aforesaid security measures being in place.
24. ACCURATE AND UP TO DATE
We will try to keep the Personal Data that we collect as accurate, complete and up to date as is necessary for the purposes defined in this Policy. From time to time, we may request you to update your Personal Data on our website. You are able to review or update any Personal Data that we hold on you, by accessing your account online, e- mailing us or phoning us.
Please note that, in order to better protect you and safeguard your Personal Data, we take steps to verify your identity before granting you access to your account or making any corrections to your Personal Data. Throughout your interaction with us, you retain the right to rectify your Personal Data that is incorrect or inaccurate. This does not apply if we process your Personal Data in our capacity as an operator or processor on behalf of a responsible party or data controller.
25. RETENTION OF DATA
25.1. We will only retain your Personal Data for as long as it is necessary to fulfil the purposes explicitly set out in this Policy, unless:-
25.1.1. retention of the Personal Data is required or authorised by law; or
25.1.2. you have consented to the retention of your Personal Data.
25.2. Without derogating from the generality of paragraph 25.1 above, we may, in particular, store the following types of Personal Data, for the following durations:-
25.2.1. account and subscription data – 5 years after the most recent transaction;
25.2.2. business intelligence – 36 months;
25.2.3. comments on articles – the lifetime of the article;
25.2.4. site features and preferences – the lifetime of your account;
25.2.5. customer service communications – 7 years.
25.3. During the period of retention, we will continue to abide by our non-disclosure obligations and will not share or sell your Personal Data, save as provided for in this Policy.
25.4. We may retain your Personal Data in physical or electronic records, at our discretion.
26. TRANSFER TO ANOTHER COUNTRY
We may transmit or transfer Personal Data outside the country in which it was collected to a foreign country and process it in that country. Personal Data may be stored on servers located outside the country in which it was collected, in a foreign country whose laws protecting Personal Data may not be as stringent as the laws in the country in which it was collected. You consent, by accessing our website and/or making use of our services, to us processing your Personal Data in a foreign country whose laws regarding processing of Personal Data may be less stringent.
27. UPDATING OR REMOVING
27.1. You may choose to correct or update the Personal Data you have submitted to us, by clicking the relevant menu in any of the pages on our website, or contacting us by phone or e-mail.
27.2. You are entitled to a right to be forgotten. We will delete any Personal Data that you don’t want us to have. If you do this, we will remove your Personal Data from our system, but we may still retain certain Personal Data, as required or allowed by law, including:-
27.2.1. where we can show legitimate grounds for processing your Personal Data, that override your request; or
27.2.2. where we process your Personal Data in order to establish, exercise or defend legal claims.
27.3. You understand that if we delete your Personal Data from our system, we may be unable to continue providing some or all of our services to you.
27.4. If you are a data subject of one of our customers (who is the data controller), then you must submit your request to the relevant data controller, who will then delete your Personal Data.
28. RESTRICTION OF PROCESSING
You may request that we restrict the use of your Personal Data. When we restrict the use of your Personal Data, we still have the right to store it but not use it. You can ask that we do this verbally or in writing (which writing may be in an electronic form), via the forums described in this Policy. We will respond to the request within 30 (thirty) days.
29. DATA PORTABILITY
If you should wish to transfer your Personal Data from us to another data controller, we will facilitate this transfer. We will pass on all of your Personal Data to the relevant data controller. If you are a data subject of one of our customers (who is the data controller), then you must submit your request for your Personal Data to be transferred to the relevant data controller, who will then export your personal data as a Microsoft Excel or CSV file.
30. DATA BREACHES
We will notify our customers of any confirmed data breaches. It is our customers’ responsibility to notify relevant supervisory authorities and any affected data subjects of such data breach.
We are not responsible for, give no warranties, nor make any representations in respect of the privacy policies or practices of any linked, associated or third-party websites.
If you wish to update or remove your Personal Data, restrict how we process it, or opt in or out of receiving newsletters or other promotional content, please contact us:-
- Telephone: 087 057 3966
- E-mail: firstname.lastname@example.org
Registered users can also edit their name and surname on our website itself or change their e-mail newsletter preferences. Once you've signed in, hover the mouse over your name displayed at the top of the website and click the “Profile” label that appears (on your mobile phone, click on the menu bar at the top right to find the “Profile” option) to find your personal information and newsletter preferences.
If you have any questions or concerns arising from this Policy or the way in which we handle Personal Data, please contact our data protection officer via one of the following methods:-
- Telephone: 087 057 3966
- E-mail: email@example.com
If you have any complaints about the way we handle your Personal Data, please contact our data protection officer as described above, so that we can resolve it. You may choose, however, to approach a supervisory authority instead, including, the data protection authority in your jurisdiction or the South African Information Regulator.