Privacy Policy

1. Welcome to our Privacy Policy (“Privacy Policy”).
2. We are committed to protecting your privacy. This Privacy Policy applies to all our brands and explains how we collect, use, disclose and protect your Personal Information and respect any rights you benefit from under the Protection of Personal Information Act No. 4 of 2013 (“POPIA”).
3. “Personal Information” means information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person, including, but not limited to:

• information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth of the person;
• information relating to the education or the medical, financial, criminal or employment history of the person;
• any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier or other particular assignment to the person;
• the biometric information of the person;
• the personal opinions, views or preferences of the person;
• correspondence sent by the person that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence;
• the views or opinions of another individual about the person; and
• the name of the person if it appears with other Personal Information relating to the person or if the disclosure of the name itself would reveal information about the person.

4. This policy applies to you if you are:

• a visitor to our website; or
• a customer who has ordered or requested the goods or services that

5. In our context, we shall process the following Personal Information:

• certain information that we collect automatically when you visit our website;
• certain information collected on registration (see below);
• certain information collected on submission; and
• optional information that you provide to us voluntarily (see below).

6. 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;
• banking/credit card information.

7. Personal Information excludes

• 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).

8. You should be aware of the fact that our website may contain hyperlinks to third-party websites, apps, etc. which are not controlled by us, and which are not covered by this Privacy Policy. We have no responsibility or liability for the content and activities of these third-party websites, apps, etc. As these third parties may collect your Personal Information, we suggest that you consult the privacy policies of these third parties to learn more about their use of your Personal Information.

1. Once you register on our website, you will no longer be anonymous to us. You will provide us with certain Personal Information when you register on our website.
2. This Personal Information will include:

• your name and surname;
• your email address;
• your telephone number;
• your postal address or street address, together with the details of your town/city, suburb, province and country/region of residence; and
• your username and password.

3. We will use this Personal Information to fulfill your account, and provide additional services and information to you as we reasonably think appropriate, and for any other purposes set out in this Privacy Policy.
4. When you order goods from us, you will be asked to provide us with additional information on a voluntary basis (goods or services information).
5. Cookies:

• We may place small text files called ‘cookies’ on your device when you register as a user of 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:
  • 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.
• Your internet browser generally accepts cookies automatically, but you can often change this setting to stop accepting them. You can also delete cookies manually. However, no longer accepting cookies or deleting them will prevent you from accessing certain aspects of our website where cookies are necessary. Many websites use cookies and you can find out more about them at www.allaboutcookies.org.

6. Third-party cookies

• Some of our business partners use their own cookies or widgets on our website. We have no access to or control over them. Information collected by any of those cookies or widgets is governed by the Privacy Policy of the company that created it, and not by us.

7. 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 Information. We merely use them to compile anonymous information about our website.

8. 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 otherwise use the optional features and functionality of our website.

9. Recording calls

• We may monitor and record any telephone calls that you make to us, unless you specifically request us not to.

10. Purpose for collection

• We may use or process any goods or 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:
  • goods or services purposes – such as collecting orders or requests for and providing our goods or 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;
  • monitor website usage metrics such as total number of visitors and pages accessed; and
  • track your entries, submissions, and status in any promotions or other activities in connection with your usage of the website.

11. 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.

1. We may use your Personal Information to fulfil our obligations to you.
2. We may send administrative messages and email updates to you about the website. In some cases, we may also send you primarily promotional messages. You can choose to opt out of promotional messages. We may send you one message asking you to opt-into promotional messages without you having opted-into promotional messages.
3. While you are logged into 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.
4. Disclosure

• 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);
  • an affiliate, in which case we will seek to require the affiliates to honour this Privacy Policy;
  • our goods or service providers under contract who help provide certain goods or services or help with parts of our business operations, including fraud prevention, bill collection, marketing, logistical issues, technology services (our contracts dictate that these goods or services providers only use your information in connection with the goods or services 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.

5. Regulators

• We may disclose your Personal Information as required by law or governmental audit.

6. Law enforcement

• 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.

7. No selling

• We will not sell Personal Information. No Personal Information will be disclosed to anyone except as provided in this Privacy Policy.

8. Marketing purposes

• We may disclose aggregate statistics (information about the customer population in general terms) about the Personal Information to advertisers or business partners.

9. Employees

• 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.

10. 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.

11. Security

• We take the security of Personal Information 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 authorize access to Personal Information only for those employees who require it to fulfil their job responsibilities. We implement disaster recovery procedures where appropriate.

12. 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 Privacy 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 online, 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.

13. Retention

• We will only retain your Personal Information for as long as it is necessary to fulfill 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.
• 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.

14. 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 processed 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 the processing of Personal Information may be less stringent.
• Notwithstanding the above, we confirm that we will comply with all POPIA requirements in this regard.