1. Introduction a. We are committed to safeguarding the privacy of our Website visitors and users (“user/s” – including listers and visitors). In this policy we explain how we will treat your personal information. b. By using our Website and agreeing to its Terms & Conditions, you understand and consent to our processing of your personal information and cookies in accordance with the provisions below. c. Please ensure that you read all the provisions below, and our Terms & Conditions to understand your, and our, rights and duties.
2. Collecting personal information a. Strictly for the purposes of providing the services and use of the Website to users and for our legitimate business purposes, we may collect, store and use the following kinds of personal information which a user might be required to disclose to us when using the Website, or creating a listing. (“personal information”): i. information about your computer and about your visits to and use of this Website (including, but not limited to, your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and Website navigation paths); ii. information that you provide to us when registering with our Website (including, but not limited to, information about the user that is personally identifiable like the user’s name, photographs, address, age, gender, e-mail address, phone number(s) and other unique information such as user IDs and passwords, banking/accounting information, product and service preferences and contact preferences that are not otherwise publicly available); iii. information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters; iv. information that you provide to us when using the services on our Website, or that is generated in the course of the use of those services (including the timing, frequency and pattern of service use); v. information contained in or relating to any communications that you send to us or send through our Website; and vi. any other personal information that you voluntarily choose to send to us.
3. Using your personal information a. We will only process your personal information strictly for the purposes of providing the services and use of the Website, and for our legitimate business purposes, as specified in this policy or on the relevant pages of the Website. b. We may use your personal information to: i. administer our Website and business; ii. personalise our Website for you; iii. enable your use of the services available on our Website; iv. supply to you services purchased through our Website; v. send statements, invoices and payment reminders to you, and collect payments from you; vi. send you non-marketing commercial communications; vii. send you email notifications that you have specifically requested; viii. send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter, in same communications); ix. send you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you, by post or, where you have specifically agreed to this, by email, SMS or similar technology (you can inform us at any time if you no longer require marketing communications, in same communications or by contacting email@example.com x. provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information); xi. deal with enquiries and complaints made by or about you relating to our Website; xii. keep our Website secure and prevent fraud; and xiii. verify compliance with the terms and conditions governing the use of our Website, and adherence to any applicable laws or lawful authorities’ instructions. c. If you submit personal information for publication on our Website, we will publish and otherwise use that information in accordance with the rights you grant to us.
4. Disclosing personal information a. We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy. b. We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy. c. We may disclose your personal information: i. to the extent that we are required to do so by law; ii. in connection with any ongoing or prospective legal proceedings; iii. in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk); iv. to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and v. to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information. d. Except as provided in this policy, we will not provide your personal information to third parties. e. Should we disclose your personal information to a third party, we will ensure that their standards for processing your personal information are equal to, or better, than those used by us.
5. International data transfers a. Information that we collect may be stored and processed in, and transferred between, any of the countries in which we operate in order to enable us to use the information in accordance with this policy. b. We ensure that all foreign processing laws applicable to the processing of your personal information in a foreign country, are applied properly as and when necessary, by our authorised/delegated third party.
6. Retaining personal information a. Personal information that we process for any purpose(s) shall not be kept for longer than is necessary for that purpose, or those purposes. b. Notwithstanding the other provisions of this Section 6, we will retain documents (including electronic documents) containing personal data for the protection and furtherance of the Website’s and our legitimate business needs, as well as: i. to the extent that we are required to do so by law or in compliance with lawful instructions provided to us by a legitimate authority; ii. if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and iii. in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of crime prevention and reducing credit risk).
7. Security of your personal information a. We will take all reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. b. We will store all the personal information you provide on our secure (password- and firewall protected) servers. c. You acknowledge that the transmission of information over the internet is inherently insecure by its nature, and, beyond implementing the reasonable precautions discussed, we cannot guarantee the security of data sent over the internet. d. You are responsible for keeping the information and password you use for accessing our Website confidential.
8. Amendments a. We may update this policy, or our Terms & Conditions, from time to time by publishing a new version on our Website. b. It is your responsibility to periodically check for any changes, and read and understand this policy and the Website’s Terms & Conditions to ensure you are always compliant with them. To this end, we are not responsible for ensuring that you are aware of any applicable changes.
9. Your rights a. You may instruct us to provide you with any personal information we hold about you, where the provision of such information will be subject to the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your South African ID book plus an original copy of a utility bill showing your current address). b. We may withhold personal information that you request, but only to the extent permitted by law. c. You may instruct us at any time not to process your personal information for particular marketing purposes. To this end, please contact firstname.lastname@example.org for further information on this right. Further, you understand that the deletion of certain personal information of yours might result in the Website or services and features related thereto, not functioning properly or at all. d. Notwithstanding the protections afforded herein, should you desire to be excluded from any marketing or correspondence from us, you may do so by utilising the “opt-out” feature provided in same correspondence or marketing, or by contacting us directly at email@example.com.
11. Updating and Correctness of Information a. Please let us know if the personal information that we hold about you needs to be corrected or updated. We are under no obligation to ensure the correctness of the information you provide us, nor to follow-up with you regarding any required amendments or notices sent to you in this regard. b. You warrant that the personal information disclosed to us or the Website is directly from you as the user on the Website or in connection to a listing, and all such personal information is lawfully yours to provide. You may choose to provide additional personal information to us, in which event you agree to provide accurate and current information, and, generally, not to impersonate or misrepresent any person or entity or falsely state or otherwise misrepresent your affiliation with anyone or anything.
13. Our details a. This Website is owned and operated by Route39 Digital Media (Pty) Ltd. Please visit our website for more information about us. b. You can contact us by using our Website contact form.
Updated: 11 July 2019