Privacy Policy

3. COLLECTION AND USAGE OF YOUR PERSONAL DATA
3.1 Types of Data Collected
a) Personally identifiable information

We may ask you to provide certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to, the following:

• Your names and surname
• Your email address
• Your phone number
• Your physical address (street address, city, province, postal code)

We will retain your information only for as long as necessary to fulfil the purposes for which it was collected, such as providing our services, addressing your requests, or meeting obligations to clients, contractors, and authorised third-party service providers (operators).

If you request to unsubscribe from all email communications, we will promptly remove your details from our active databases and archive your information. Please note that certain information may be retained to prevent fraud, resolve issues, assist with investigations, or comply with applicable legal and regulatory requirements.

b) Protection of Minors’ Personal Information
The Company is committed to protecting the personal information of minors. In terms of section 35 of the Act, the personal information of a minor may only be processed with the express consent of a competent person, such as a parent or legal guardian.
The Company may collect, use, process, and store the personal information of minors only when necessary and lawful, including but not limited to:

• Providing and administering services that directly relate to the minor;
• Fulfilling legal and regulatory obligations;
• Communicating with the parent or legal guardian regarding the minor;
• Maintaining records as required by law or business operations.

The Company shall not collect or process a minor’s personal information without prior written consent from the parent or legal guardian. Such consent may be withdrawn at any time, subject to legal or contractual obligations.

The Company implements appropriate technical and organisational security measures to protect minors’ personal information from unauthorized access, loss, destruction, or disclosure. Access to such information is strictly limited to authorized personnel who require it for legitimate purposes.

The Company will not share a minor’s personal information with third parties unless:

• Required by law, court order, or regulatory authority;
• Necessary to fulfil contractual obligations, with consent from the parent/legal guardian;
• Shared with service providers assisting in delivering services to the minor, subject to strict confidentiality agreements.

The parent or legal guardian has the right to:

• Access and review the minor’s personal information held by the Company;
• Request corrections or deletions of inaccurate or unnecessary information;
• Withdraw consent for processing the minor’s information, subject to legal requirements; and
• Lodge a complaint with the Information Regulator if they believe the minor’s privacy rights have been violated.

c) Emails and related communication
If you no longer wish to receive correspondence, emails, or other communications from us, you may opt out by contacting our Assistant Information Officer via email. Please clearly indicate your request to unsubscribe and/or specify your communication preferences in your message.
If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.

d) Usage Data
Usage Data is collected automatically when you use our service or contact us. This may include:

• Your device’s Internet Protocol (IP) address
• Browser type and version
• The time and date of your visit to our website
• Unique device identifiers
• Other diagnostic data

When you access our website or contact us using a mobile device, we may collect additional information, including:

• The type of mobile device you use
• Your mobile device’s IP address
• Your mobile operating system
• The type of mobile Internet browser you use
• Unique device identifiers and other diagnostic data

e) Tracking technologies and cookies
We use cookies and similar tracking technologies to track activity on our website and store certain information. These technologies help us improve and analyse our service. The technologies we use may include:

• Cookies or Browser Cookies: A cookie is a small file placed on your device. You can instruct your browser to refuse all cookies or indicate when a cookie is being sent. Please note that if
  you do not accept cookies, you may not be able to access some parts of our website. Unless you have adjusted your browser settings to refuse cookies, our service may use cookies.
• Flash Cookies: Certain features of our service may use local stored objects (or Flash Cookies) to collect and store information about your preferences or activity. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies.
• Web Beacons: Certain sections of our service and our emails may contain small electronic files known as Web Beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs). These allow us to count users who have visited specific pages or opened emails and to gather other related statistics (e.g., recording the popularity of a section or verifying system integrity).

Cookies can be Persistent or Session cookies. Persistent Cookies are cookies that remain on your device when you go offline whereas Session Cookies are deleted as soon as you close your web browser.
We use both Session and Persistent Cookies for the following purposes:

• to provide you with services available through our website and to enable you to use its features;
• to authenticate users and prevent fraudulent use of accounts; and
• to remember your preferences (e.g., login details or language settings) and provide a personalised experience

3.2 Use of Your Personal Information
We collect your Personal Information for the following reasons:

• to identify you;
• to contact you via email, telephone call, SMS, communication-based mobile applications, or other equivalent forms of electronic communication;
• to process your instructions or requests;
• to provide and maintain our services;
• to manage your account or our relationship;
• to ensure that the content of our website remains up-to-date, user-friendly, and comprehensive;
• operational, marketing, auditing, legal and record-keeping requirements;
• verifying your identity or the identity of your beneficial owner;
• for contractual-related matters (negotiations, enforcing performance, etc.);
• to provide you with news, and general information about our services;
• to evaluate or conduct a merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of our assets, whereby Personal Data held by us is among the assets transferred;
• for data analysis, identifying usage trends, to evaluate and improve our services;
• to manage your potential employment as an applicant or post-employment relationship with us;
• for the prevention and control of any disease;
• for assessing and dealing with complaints and requests;
• for detecting and preventing fraud and money laundering and/or in the interest of security and crime prevention; and
• to comply with Applicable Laws, including lawful requests for information received from local or foreign law enforcement, government and tax collection agencies.

We may share your Personal Information in the following situations:

• With service providers: To monitor and analyse the use of our service.
• With Affiliates: Including our parent company, subsidiaries, joint venture partners, or other companies under common control. These affiliates are required to honour this Privacy Policy.
• With business partners: To offer you certain services or respond to your queries.
  
  

We will not use your Personal Information for any purpose other than those disclosed to you, unless you provide us with express written permission to do so, or we are permitted or required to do so by law.

We may disclose your Personal Information without your consent if it is required by law or a court order, if disclosure is in the public interest, if it is in the Company’s legitimate interests, or if you have provided implied consent.

3.3 Retention of Your Personal Data

We will retain your Personal Information only for as long as necessary to fulfil the purposes outlined in this Privacy Policy. This includes retaining your data to comply with legal obligations, resolve disputes, and enforce our legal agreements and policies.

Usage Data is generally retained for shorter periods, except when it is used to strengthen security, improve functionality, or comply with legal obligations requiring longer retention.

3.4 Transfer of your Personal Information

Your information, including Personal Information, may be processed at our operating offices or other locations where the parties involved in processing are located. This means your information may be transferred to and maintained on computers located outside your province, country, or jurisdiction, where data protection laws may differ.

Your consent to this Privacy Policy, followed by your submission of such information, constitutes your agreement to this transfer.

We will take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy. We will not transfer your Personal Information to an organisation or country unless adequate controls, including data security measures, are in place.

4. DISCLOSURE OF YOUR PERSONAL DATA

If we are involved in a merger, acquisition or sale of our assets, your Personal Information may be transferred. We will provide notice before your Personal Information is transferred and becomes subject to a different Privacy Policy.

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

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

• Comply with a legal obligation;
• Protect and defend the rights or property of the Company;
• Prevent or investigate possible wrongdoing in connection with the service;
• Protect the personal safety of users of the service or the public; and
• Protect against legal liability.

5. SECURITY OF YOUR PERSONAL DATA

The security of your Personal Information is a top priority for us. It is, however, important to note that no method of transmission over the Internet or electronic storage is entirely safe. While we employ commercially acceptable measures and industry-standard practices to safeguard your Personal Information, we cannot guarantee its absolute security. Despite our best efforts, unauthorised access, hacking, or other security breaches may occur, and we encourage you to take steps to protect your personal information as well.

5.1 Data Protection Impact Assessments

To ensure compliance with regulatory obligations and to proactively manage risks, we conduct annual Data Protection Impact Assessments (DPIAs). These assessments help us identify potential risks associated with the processing of Personal Information and evaluate their impact.
Based on the findings, we develop and implement mitigating measures to address these risks effectively. This ongoing process allows us to maintain a robust data protection framework and continuously improve our practices to safeguard your information.

5.2 Data Breaches

In the unfortunate event of a data breach, we have established clear and comprehensive procedures to respond promptly and effectively. Our response plan includes the following:

• Immediate Containment: Taking swift action to contain the breach and prevent further unauthorised access or damage to your Personal Information.
• Assessment and Investigation: Conducting a thorough investigation to determine the cause, scope, and impact of the breach that has occurred.
• Notification: Reporting the breach to the relevant regulatory authorities as required by law and notifying the affected Data Subjects as soon as practically possible.
• Remediation: Implementing corrective measures to address vulnerabilities and prevent similar incidents in the future.

We are committed to ensuring that all affected parties are informed and supported throughout the process. If you have any concerns about the security of your Personal Information or would like more information about our data protection practices, please contact our Assistant Information Officer.

6. INFORMATION RECORDS CLASSIFICATION

To ensure compliance with POPIA, the Company categorises its records into specific groups. This classification system enables management to effectively manage the availability and accessibility of documents, both internally and externally, in alignment with our data protection framework.

For any questions or further details regarding the classification of data records, please reach out to the Information Officer.

7. 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 that 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.

8. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time. We will notify you of any changes by uploading the new Privacy Policy onto the website.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on the Company’s website.

The contents of this document should only be used for and by the Company and may not be distributed unlawfully. Older versions are not deemed official. Only the latest version is acceptable.

9. COMPLAINTS
Should you believe that we have utilised your personal information contrary to Applicable Laws, you undertake to first attempt to resolve any concerns with us directly. The following contact details can be used to contact us: