Information security on our website:  

1. Any information that you upload on our website will be stored on a secure server and be used for limited purposes such as future communications (which you are always entitled to un-subscribe to).  
2. The Company will not disclose, sell, rent, or disseminate your personal information to third parties without your consent unless the Company is compelled to do so by law. The Company may do so if you have granted consent thereto.  
3. While all reasonable efforts are taken to ensure that your personal information is protected as it travels over the internet, the Company cannot guarantee the absolute security of any information you exchange with us due to reasons beyond our control.  
4. The Company may use cookies and web beacons to facilitate improvement of our website. However, neither cookies nor web beacons collect personal information such as the user’s name or email address. You may reject cookies, as most browsers permit individuals to decline same.  

POPI Compliance:  Procurement of Personal Information 

Personal information collected by the Company and/or any of its representatives, will be collected directly from the data subject, unless:  

1. The information is contained or derived from a public record or has deliberately been made public by the data subject;  
2. The data subject or a competent person where the data subject is a child, has consented to the collection of the information from another source;  
3. Collection of the information from another source would not prejudice a legitimate interest of the data subject;  
4. Collection of the information from another source is necessary:  

To avoid prejudice to the maintenance of the law by any public body, including the prevention, detection, investigation, prosecution and punishment of offences;  

1. To comply with an obligation imposed by law or to enforce legislation concerning the collection of revenue;  
2. For the conduct of proceedings in any court or tribunal that have commenced or are reasonably contemplated;  
3. To maintain the legitimate interests of the Company or of a third party to whom the information is supplied;  
4. Compliance would prejudice a lawful purpose of the collection; or  
5. Compliance is not reasonably practicable in the circumstances of the particular case.   
6. Personal Information must be collected for a specific, explicitly defined and lawful purpose related to a function or activity of the Company.  
7. Steps will be taken to ensure that the data subject is aware of the purpose of the collection of the information.  
8. The Company will take reasonably practicable steps to ensure that the personal information is complete, accurate, not missing and updated where necessary, having regard to the purpose for which the personal information is collected and further processed.

Where personal information is collected from a data subject, the Company will take reasonable practicable steps to ensure that the data subject is aware of:   

1. The information being collected and where the information is not collected from the data subject, the source from which it is collected;  
2. The name and address of the Company;  
3. The purpose for which the information is being collected;  
4. Whether or not the supply of the information by the data subject is voluntary or mandatory;  
5. The consequences of failure to provide the information;  
6. Any particular law authorising or requiring the collection of the information;  
7. The fact that, where applicable, the Company intends to transfer the information to a third country or international organisation and the level of protection offered to the information by that third country or international organisations;  
8. Any further information such as the:  
9. Recipient or category of recipients of the information;  
10. Nature or category of the information;  
11. Existence of the right of access to and the right to rectify the information collected;  
12. Existence of the right to object to the processing of personal information; 

This is necessary, having regard to the specific circumstances in which the information is or is not to be processed, to enable processing in respect of the data subject to be reasonable.  

The steps that must be taken:  

1. If the information is collected directly from the data subject, before the information being collected, unless the data subject is already aware of the information;  
2. In any other case, before the information is collected or as soon as reasonably practicable after it has been collected.  

It will not be necessary for the Company to comply :  

1. The data subject or a competent person if the data subject is a child has provided consent for the non-compliance;  
2. Non-compliance would not prejudice the legitimate interests of the data subject;  

Non-compliance is necessary:  

1. To avoid prejudice to the maintenance of the law by any public body, including the prevention, detection, investigation, prosecution, and punishment of offenses;  
2. To comply with an obligation imposed by law or to enforce legislation concerning the collection of revenue;  
3. For the conduct of proceedings in any court or tribunal that have commenced or are reasonably contemplated; or  
4. In the interest of national security.  

Compliance would prejudice a lawful purpose of the collection;  
Compliance is not reasonably practicable in the circumstances of the particular case; or  
The information will:  

1. Not be used in a form in which the data subject may be identified; or  
2. Be used for historical, statistical, or research purposes.  

Processing of Personal Information  

Personal Information will only be processed lawfully and in a reasonable manner that does not infringe on the privacy of the data subject.  
Personal Information may only be processed if:  

1. given the purpose for which it was processed, it is adequate, relevant, and not excessive;  
2. the data subject or a competent person where the data subject is a child consents to the processing;  
3. processing is necessary to carry out actions for the conclusion or performance of a contract to which the data subject is a party;  
4. processing complies with an obligation imposed by law on the Company;  
5. processing protects a legitimate interest of the data subject; or  
6. processing is necessary for pursuing the legitimate interest of the Company or of a third party to whom the information is supplied.  

If the Company appoints or authorizes an operator to process any personal information on its behalf or for any reason, it will implement necessary agreements to ensure that the operator or anyone processing personal information on behalf of the Company or an operator, must:  

1. Process such information only with the knowledge or authorization of the Company; and  
2. Treat personal information which comes to his/her/its knowledge as confidential and must not disclose it, unless required by law or in the course of the proper performance of his/her/its duties.  
3. The Company must maintain the documentation of all processing operations under its responsibility. 

Further Processing of Personal Information  

The Company must ensure that the further processing of personal information is compatible with the purpose for which it was collected. 
To assess whether further processing is compatible with the purpose of collection, the Company will take into account of:  

1. The relationship between the purpose of the intended further processing and the purpose for which the information was collected;  
2. The nature of the information concerned;  
3. The consequences of the intended further processing for the data subject;  
4. How the information has been collected; and  
5. Any contractual rights and obligations between the parties.  

The further processing of personal information will not be incompatible with the purpose of collection if:  

1. The data subject or competent person where the data subject is a child, has consented to the further processing of the information;  
2. The information is available in or derived from a public record or has deliberately been made public by the data subject; 

Retention and Restriction of Records 

Records of personal information must not be retained any longer than necessary for achieving the purpose for which the information was collected or subsequently processed, unless:  

1. The retention of a record is required or authorized by law;  
2. The Company reasonably requires a record for lawful purposes related to its functions or activities;  
3. Retention of a record is required by a contract between the parties thereto; or  
4. The data subject or a competent person where the data subject is a child has consented to the retention of a record.  
5. Information collected or processed initially for the purpose of historical, statistical, or research value. 
6. The Company will destroy or delete a record of personal information or de-identify it as soon as reasonably practicably after The Company is no longer authorized to retain a record.  
7. The de-identifying or deletion of a record of personal information must be done in a manner that prevents its reconstruction in an intelligible/understandable form.   
8. If The Company uses a record of personal information of a data subject to decide on the data subject, it must:  
9. Retain the record for such period as may be required or prescribed by law or a code of conduct; or  
10. If there is no law or code of conduct prescribing a retention period, retain the record for a period that will afford the data subject a reasonable opportunity, taking all considerations relating to the use of the personal information into account, to request access to the record.  

The Company will restrict the processing of personal information if:  

1. Its accuracy is contested by the data subject, for a period enabling The Company to verify the accuracy of the information;  
2. The Company no longer needs the personal information for achieving the purpose for which it was collected or subsequently processed, but it has to be maintained for proof;  
3. The processing is unlawful, and the data subject opposed its destruction or deletion and requested the restriction of its use instead; or  
4. The data subject requests to transmit the personal data into another automated processing system. 

Personal information that has been restricted may only be processed for purposes of proof, with the data subject’s consent, or with the consent of a competent person where the data subject is a child, or for the protection of the rights of another natural or legal person or if such processing is in the public interest.  

 Where the information is restricted, The Company will inform the data subject before lifting the restriction.

Security Safeguards  
The Company will secure the integrity and confidentiality of personal information in its possession or under its control by taking appropriate, reasonable, technical, and organizational measures to prevent:   

1. Loss of, damage to, or unauthorized destruction of personal information; and  
2. Unlawful access to or processing of personal information.  

 The Company will take reasonable measures to: 

1. Identify all reasonably foreseeable internal and external risks to personal information in its possession or under its control;  
2. Establish and maintain appropriate safeguards against the risks identified;  
3. Regularly verify that the safeguards are effectively implemented; and  
4. Ensure that the safeguards are continually updated in response to new risks or deficiencies in previously implemented safeguards. 

The Company will have due regard to generally accepted information security practices and procedures which may apply to it generally or be required in terms of specific industry or professional rules and regulations. 

The Company will, in terms of a written contract between The Company and the operator, ensure that he operator which processes personal information for The Company, establishes and maintain the security measures as referred to herein.  

 The operator will inform The Company immediately where there are reasonable grounds to believe that the personal information of a data subject has been accessed or acquired by any unauthorized person.

Security Compromises  
Where there are reasonable grounds to believe that the personal information of a data subject has been accessed or acquired by any unauthorized person, The Company will notify:  

 The Information Regulator; and  the data subject unless the identity of such data subject cannot be established.  

The notification of a breach will be made as soon as reasonably possible after the discovery of the compromise, taking into account the legitimate needs of law enforcement or any measures reasonably necessary to determine the scope of the compromise and to restore the integrity of The Company’s information system.  

The Company will only delay notification of the data subject if a public body responsible for the prevention, detection, or investigation of offenses or the Regulator determines that notification will impede a criminal investigation by the public body concerned.  

The notification to a data subject will be in writing and communicated to the data subject in at least one of the following ways: 

1. Posted to the data subject’s last known physical or postal address; or  
2. Sent by e-mail to the data subject’s last known e-mail address; or  
3. Placed in a prominent position on the website of The Company; or  
4. Published in the news media. 

The notification will provide sufficient information to allow the data subject to take protective measures against the potential consequences of the compromise, including: 

 A description of the possible consequences of the security compromise.  
A description of the measures that The Company intends to take or has taken to address the security compromise;  

A recommendation concerning the measures to be taken by the data subject to mitigate the possible adverse effects of the security compromise; and  If known to The Company, the identity of the unauthorized person who may have accessed or acquired the personal information.

Rights of the Data Subject  

1. The data subject or competent person where the data subject is a child, may withdraw his, her or its consent to procure and process his, her or its personal information, at any time, providing the lawfulness of the processing of the personal information before such withdrawal or the processing of personal information is not affected. 
2. A data subject may object, at any time, to the processing of personal information in writing, on reasonable grounds relating to his/hers or its particular situation, unless legislation provides for such processing; or  
3. For purposes of direct marketing other than direct marketing using unsolicited electronic communications.  
4. A data subject, having provided adequate proof of identity, has the right to:  
5. Request the Company to confirm, free of charge, whether or not the Company holds personal information about the data subject; and  
6. Request from The Company a record or a description of the personal information about the data subject held by The Company, including information about the identity of all third parties, or categories of third parties, who have, or have had, access to the information: 

Within a reasonable time; 

1. At a prescribed fee as determined by the Information Officer;  
2. In a reasonable manner and format; and  
3. In a generally understandable form.  
4. A data subject may, in the prescribed manner, request The Company to:  
5. Correct or delete personal information about the data subject in its possession or under its control that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or obtained unlawfully; or  
6. Destroy or delete a record of personal information about the data subject that The Company is no longer authorized to retain.  
7. Upon receipt of a request referred to above, The Company will, as soon as reasonably practicable:  
8. Correct the information;  
9. Destroy or delete the information;  
10. Provide the data subject, to his, her or its satisfaction, with credible evidence in support of the information; or 

Where an agreement cannot be reached between The Company and the data subject, and if the data subject so requests, take such steps as are reasonable in the circumstances, to attach to the information in such a manner that it will always be read with the information, an indication that a correction of the information has been requested but not been made. 

The Company will inform the data subject, who requested as set out above, of the action as a result of the request. 

Request for Disclosure  

The Company will respond promptly when the data subjects request notification of the purpose of use, disclosure, correction, addition or deletion of details, and suspension of use or elimination relating to personal information held by the Company.