October 2022 | Version 2.01
Summary and intent
We respect your privacy. Under European law, we need to and want to explain in simple and unambiguous terms how we work with your data.
Right to Access
This means you are allowed to know what personal information we have on you, how we use it and for what purpose.
Once you are logged in and go to your profile page, you will see what personal information we have on you. By personal information,u need to realise that it is all information that can uniquely identify you. Think of your name, email address etc. or combinations of data such as an address, date of birth and sex.
Right to transfer
You can ask us at any time to provide you with the information that we have to be able to send it to someone else. This policy helps you transition to other providers of our services. i.e. we will not make it difficult for you to leave our services and join someone else that provides the same services by withholding your data from them where it may apply.
Right to be forgotten.
You can request that we remove your personally identifiable data at any time. This means that we may keep data such as your month and year of birth for demographic analyses, the city you had as part of your address, and any other kind of information that does not allow for personally identifying you. This process is irreversible. Once you start this process, you will become completely anonymous to us. Any assessments or other types of information you have provided us will be rendered entirely anonymous and as such, we cannot reinstate your account once you have done so. As your email address is part of your user account and your username, when you ask to be forgotten, we will remove your account from our systems. Please be aware that we cannot ask our suppliers on your behalf to remove your data from their systems. We work with highly ethical suppliers whose terms and conditions you may have accepted separately from ours. We will provide you with the contact details and processes where necessary to assist you in achieving the right to be forgotten.
This policy’s purpose is to describe how we handle your personal information.
This policy applies to you if you are:
a visitor to our website or our application;
a customer who has ordered the goods or services that we provide.
This policy applies to you under certain circumstances.
Personal information includes:
certain information that we collect automatically when you visit our website or application;
certain information collected on registration (see below);
certain information collected on submission; and
optional information that you provide to us voluntarily (see below);
information that has been made anonymous so that it does not identify a specific person;
permanently de-identified information that does not relate or cannot be traced back to you specifically;
non-personal statistical information collected and compiled by us; and
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 information subject to protection under this policy).
Personal information includes information we collect (i) automatically when you visit our website, (ii) on registration, (iii) on submission, and (iv) from you voluntarily. It excludes (i) anonymous, (ii) de-identified, (iii) non-personal statistical, and (iv) public information.
Common examples of the types of personal information which we may collect and process include your:
identifying information – such as your name, date of birth, or identification number of any kind;
contact information – such as your phone number or email address;
address information – such as your physical or postal address; or
demographic information – such as your gender or marital status.
Sensitive personal information
Depending on the goods or services that you require, we may also collect sensitive personal information including your:
financial information – such as your bank account details;
sensitive demographic information – such as your race or ethnicity;
criminal information – such as information about your commission or alleged commission of any offence or about any related legal proceedings;
employment information – including your membership of a trade union; and
beliefs – including your political or religious beliefs.
Identity and orientation – to ensure we use the proper forms of address and log our diversity metrics
You must accept all the terms of this policy when you download our application and use our website. If you disagree with this policy, you may not use any of our services.
You may not order any of our goods or order, register for or use any of our services if you do not accept this policy.
You may not access our website and application or order our goods or services if you are younger than 18 years old or do not have the legal capacity to conclude legally binding contracts.
By accepting this policy, you are deemed to have read, understood, accepted, and agreed to be bound by all of its terms.
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 and the application, or by sending you an email 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 the website and the application. If you continue to use the them following notification of a change to the terms, the changed terms will apply to you and you will be deemed to have accepted those updated terms.
On registration and download
Once you register and download our application, you will no longer be anonymous to us as you will provide us with certain personal information which include your username and password.
This personal information will include:
your name and surname;
your email address;
your telephone number;
your postal address or street address; and
your username and password.
We will use this personal information to fulfil your account, provide additional services and information to you as we reasonably think appropriate, and for any other purposes set out in this policy.
We collect certain information from your web browser, including your Internet usage information when you visit our website.
We may place small text files called ‘cookies’ on your device when you visit our website. These files do not contain personal information, but they do contain a personal identifier allowing us to associate your personal information with a certain device. These files serve a number of useful purposes for you, including:
granting you access to age restricted content;
tailoring our website’s functionality to you personally by letting us remember your preferences;
improving how our website performs;
allowing third parties to provide services to our website; and
helping us deliver targeted advertising where appropriate in compliance with the applicable laws.
We collect certain information from cookies that we may send to your computer to try and give you a personalised experience.
Third party cookies
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 information. We merely use them to compile anonymous information about our website.
We collect certain information from web beacons on our website to compile anonymous information about our website.
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 and application or when you enter respond to surveys, order certain additional goods or services, or otherwise use the optional features and functionality of our website and application.
We collect certain optional information, that you provide when you upload or download content from our website or when you enter competitions, take advantage of promotions, respond to surveys or register and subscribe for certain additional services.
We may monitor and record any telephone calls that you make to us, unless you specifically request us not to.
Purpose for collection
We may use or process any goods information, 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 information, disclosing it, and combining it with other personal information. We generally collect and process your personal information for various purposes, including:
services purposes – such as providing our services;
marketing purposes – such as pursuing lawful related marketing activities;
business purposes – such as internal audit, accounting, business planning, and joint ventures, disposals of business, or other proposed and actual transactions; and
legal purposes – such as handling claims, complying with regulations, or pursuing good governance.
We may use your usage information for the purposes described above and to:
remember your information so that you will not have to re-enter it during your visit or the next time you access the website or the application;
monitor website usage metrics such as total number of visitors and pages accessed; and
track your entries, submissions, and other activities in connection with your usage of the website and the application
We may use any of your personal information that you provide to us for the purposes that you indicated when you agreed to provide it to us.
Consent to collection
We will obtain your consent to collect personal information:
in accordance with applicable law;
when you provide us with any registration information or optional information.
We will get your consent to collect your personal information in accordance with applicable law when you provide us with it.
We may use your personal information to fulfil our obligations to you.
Messages and updates
We may send administrative messages and email updates to you about the website and the application. In some cases, we may also send you primarily promotional messages. You can choose to opt-out of promotional messages.
We may use your information to send you administrative messages and email updates to you regarding the website and for marketing purposes where lawful.
While using the website, we may display targeted adverts and other relevant information based on your personal information. In a completely automated process, computers process the personal information and match it to adverts or related information. We never share personal information 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 information. 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 information to advertisers with the referring URL. Once you are on the advertiser’s website however, the advertiser is able to collect your personal information.
We may use your information for targeted content in certain, specified instances.
We may share your personal information with:
other divisions or companies within the group of companies to which we belong so as 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);
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 or services they perform for us and not for their own benefit);
credit bureaus to report account information, as permitted by law;
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); and
other third parties who provide us with relevant services where appropriate.
We may share your personal information with third parties for the purposes of fulfilling our obligations to you among other purposes.
We may disclose your personal information as required by law or governmental audit.
We may disclose personal information if required:
by a subpoena or court order;
to comply with any law;
to protect the safety of any individual or the general public; and
to prevent violation of our customer relationship terms.
We may disclose personal information to third parties if required for legal reasons.
We may disclose aggregate statistics (information about the customer population in general terms) about the personal information to advertisers or business partners.
We may need to disclose personal information to our employees that require the personal information to do their jobs. These include our responsible management, human resources, accounting, audit, compliance, information technology, or other personnel.
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 information we process to a successor, purchaser, or separate entity. We will disclose the transfer on the website. If you are concerned about your personal information migrating to a new owner, you may request us to delete your personal information.
We take the security of personal information very seriously and always do our best to comply with applicable data protection laws. Our website is hosted in a secure server environment that uses a firewall and other advanced security measures to prevent interference or access from outside intruders. We authorize access to personal information only for those employees who require it to fulfil their job responsibilities. We implement disaster recover procedures where appropriate.
Our website is hosted on a secure server and uses security measures to prevent interference by intruders.
Accurate and up to date
We will try to keep the personal information 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 information on the website. You are able to review or update any personal information that we hold on you by accessing your account, emailing us, or phoning us. Please note that in order to better protect you and safeguard your personal information, we take steps to verify your identity before granting you access to your account or making any corrections to your personal information.
Please keep your personal information accurate and up to date by accessing your account, emailing us, by phoning us.
We will only retain your personal information for as long as it is necessary to fulfil the purposes explicitly set out in this policy, unless:
retention of the record is required or authorised by law; or
you have consented to the retention of the record.
The retention is necessary for your future use and enjoyment of our website and application
During the period of retention, we will continue to abide by our non-disclosure obligations and will not share or sell your personal information.
We may retain your personal information in physical or electronic records at our discretion.
We will only retain your personal information for as long as is necessary.
Transfer to another country
We may transmit or transfer personal information outside of the country in which it was collected to a foreign country and process it in that country. Personal information may be stored on servers located outside the country in which it was collected in a foreign country whose laws protecting personal information may not be as stringent as the laws in the country in which it was collected. You consent to us processing your personal information in a foreign country whose laws regarding processing of personal information may be less stringent.
We may transfer your personal information outside the country in which it was collected to a foreign country.
Updating or removing
You may choose to correct or update the personal information you have submitted to us. This includes us being allowed to remove the pictures you upload or you removing them at your own discretion.
You may choose to update or remove the personal information you have submitted to us.
We are not responsible for, give no warranties, nor make any representations in respect of the privacy policies or practices of linked or any third party websites. While we try to ensure the safety of the information you provide us, we are also not responsible for any harm ensuing as a result of you disclosing information without you having taken reasonable care to safeguard that information. When you take reasonable care to safe guard your information, it includes ensuring that you do not:
disclose financial information that can be used to defraud or cause you other types of harm
disclose other sensitive information that can be used to discriminate against or harm you,
Unless prompted by us, in line with this agreement. You, therefore, disclose your information on our website and application at your own risk.