Privacy Policy

PRIVACY POLICY (“POLICY”) OF UNITEC AFRICA (PTY) LTD

REGISTRATION NUMBER 2015/218096/07

(“UNITEC AFRICA”, “US”, “WE”, “OUR”)

(VERSION 1.O – EFFECTIVE AS AT DATE OF PUBLICATION)

1. INTRODUCTION
   • This policy applies to all users (“User”, “You”, “Your”) of this website, which provides an overview of our offerings and other related information.
   • The purpose of this policy is to set out the conditions under which we use and process personal information for purposes of compliance with the Protection of Personal Information Act No. 4 of 2013 (“POPIA”) of the Republic of South Africa.
   • We are strongly committed to protecting the rights to privacy and protection of personal information of our user base. In order for us to provide you with information occasionally, we need to process personal information which you voluntarily provide to us.
   • This policy must be read in conjunction with all of our other policies which may be published on our website or obtained from us upon request.
   • We reserve the right to amend this policy at any time and without prior notice to anyone. In such instances, the latest version of the policy in question shall apply.
   • We specifically draw your attention to the contents hereof, as it is important that you understand it may:
     • Limit our risk or that of a third party;
     • Create risk or liability for you as the user;
     • Compel the user to indemnify and hold us or a third party entirely harmless; and/or
     • Serve as an acknowledgment of the user of a fact.

2. DEFINITIONS
   • In this policy, unless the context clearly dictates a contrary intention, the following words and expressions bear the meanings ascribed to them:
     • “Client” means anyone engaging with us with the intention of procuring any of our services, or anyone we have engaged for the purpose of rendering any of our services to;
     • “Data Subject” means the person to whom the personal information relates;
     • “Enquiry” means reaching out to us via our website or the information provided thereon;
     • “Information Regulator” means the statutory body created under the provisions of POPIA, empowered to monitor and enforce compliance therewith;
     • “Information Retention Policy” means our internal policy dictating the rules applicable to retaining of any information in any form, and related matters;
     • “Personal Information” has the meaning ascribed to it under POPIA;
     • “Process” means any operation or activity or any set of operations, whether or not by automatic means, concerning personal information, including— (a) the collection, receipt, recording, organisation, collation, storage, updating, modification, retrieval, alteration, or use; (b) dissemination by means of transmission, distribution or making available in any other form; or (c) merging, linking, restriction, degradation, erasure or destruction of information and “Processing” has the corresponding meaning;
     • “Responsible Party” means a public or private body or any other person which, alone or in conjunction with others, determines the purpose of and means for processing personal information;
     • “Services” means our electronic website which provides information regarding our offerings, provides a user portal, and any related information;
     • “Unitec Group” refers to the business structure including Unitec Africa (Pty) Ltd, its parent entity, affiliates, and/or subsidiaries in all jurisdictions;
     • “User” means anyone who accesses our website for any reason, but more specifically with the aim of procuring any of our services and/or related information.

3. COLLECTION OF INFORMATION
   • For the purpose of providing the user with information about our service offerings, we process personal information in the manner prescribed by POPIA contained in this policy.
   • We process information in a manner that is non-excessive, purpose specific, reasonable, adequate, and relevant. We process information for the purposes of engaging with you following a submitted enquiry and related matters.
   • The information we collect from you as an individual may include:
     • Your name and surname;
     • Your e-mail address;
     • Your cell phone number;
     • Any landline number;
     • Your physical address;
     • Online identifiers;
     • Date of Birth;
     • Identification number.
   • The information we collect from you as an entity may include:
     • Registered name of entity;
     • Registration number of entity;
     • Registered, postal and operating address;
     • Personal information of shareholders and/or directors;
     • Principle industry of operation;
     • Contact telephone number;
     • Email address;
     • Alternative contact information.
   • Other information that may be collected from you may include:
     • Log-on information;
     • Which pages you visit;
     • The duration for which you visit the page;
     • The content you view;
     • Information about the equipment you use to access our website;
     • Your location, wi-fi network, and cell towers;
     • Other information about you which may be supplied by third parties.
   • We collect this information from you as the data subject directly and only for a specified purpose.
   • We do not necessarily collect all of this information. The information that we do however collect is dependent on various factors, including the nature of your enquiry. The above listed is therefore non-exhaustive.
4. PURPOSE OF COLLECTION OF INFORMATION
   • The purpose of collecting and processing your personal information is to:
     • Identify you as a prospective Client;
     • Verify that the information provided is true and accurate;
     • Contact you regarding an enquiry you may have submitted;
     • Provide you with more information about our service offerings and related matters;
     • Communicate with you regarding our website and any challenges you may be experiencing;
     • Notify you of any changes to our website, its policies, rules, notices and/or service offerings;
     • Send you marketing- or other informational material, unless you have opted out of receiving it;
     • Comply with any regulatory or financial obligations; and/or
     • Obtain feedback from you so that we may continue developing and upgrading our website and related matters.

5. YOUR RIGHTS
   • As the user you have the following rights:
     • To access, view and/or amend your personal- and any other information held by us;
     • To request a record of your information we hold, subject to payment of the prescribed fee;
     • To request that your personal information be corrected, amended, and/or deleted by sending an e-mail to hello@unitecafrica.co.za detailing the request;
     • To receive communication from us regarding any request hereunder in a timeous and sufficient manner;
     • To be informed of any suspected or actual unauthorized access to your personal information;
     • To receive reasonable proof of compliance with this policy from us; and/or
     • To lodge a complaint and/or query with the Information Regulator (more information can be found in this regard in clause 14 of this Policy).

6. YOUR OBLIGATIONS
   • It is your obligation to ensure that the information you have provided remains relevant, accurate, true and updated. You may do so in accordance with clause 1.3.
   • You warrant and represent that the information you provide to us is true, accurate, and does not misrepresent or falsely state any affiliation with anyone or anything.
   • We may request documentation from you at any time to verify the veracity of any information you have provided us with. You must co-operate with such request in a timeous manner failing which we reserve the right to regard the request as closed.
   • Persons under the age of 18 (eighteen), must obtain their legal guardian’s permission to use our website. Permission from the legal guardian must be obtained before any personal information is submitted to us. If the permission has not been obtained, you may not use our website any further and must cease to do so immediately. We retain the right to verify the veracity of information disclosed to us, including the information of a legal guardian.
7. OUR OBLIGATIONS
   • We will only use your information for the intended purpose. If we wish to use your information for more than one purpose, we will obtain your prior consent.
   • In all instances, we will only retain your personal information for as long as is required to fulfil the purpose it was collected for, or for any other lawful reason. Where we have obtained your consent to use your information for more than one purpose, we will only retain the information for as long as is required to fulfil the additional purpose.
   • We will not sell your personal information to anyone for any reason, except where you have expressly agreed thereto.
   • We will provide you with access to information upon your request in accordance with this policy.
8. ACCESS TO YOUR INFORMATION
   • To enable us to provide our website and related information to you, we may grant access to your personal information to:
     • Employees of the wider Unitec Group;
     • Persons or institutions where we are legally obliged to do so;
     • Third party suppliers;
     • Other entities if applicable.
   • By continuing your use of our website, you specifically grant consent for us to do so. If you disagree with this, you must discontinue use of our website immediately.
   • In all instances, the persons specified in this clause who might gain access to your personal information are under duties of confidentiality which are relevant, adequate and proportionate.
9. SECURING OF INFORMATION
   • We take the securing of information very seriously. To ensure that confidentiality of your personal information is maintained, we take reasonable, appropriate and proportionate technical and organizational measures as best we can to prevent damage, loss, destruction or unauthorized access thereof.
   • If we transfer your personal information outside of the borders of South Africa for any reason including data storage, we conduct prior verification that the security measures in the relevant jurisdiction is adequate and similarly effective to those we implement in South Africa.
   • We regularly monitor, assess, evaluate, and amend all of our control measures as appropriate to ensure that our processes and policies remain effective.
   • Our policies and procedures include, amongst others, the following:
     • Access control;
     • Secure data storage, including where outsourced to third party service providers;
     • Information breach reporting and remediation;
     • Written non-disclosure agreements with all our stakeholders including staff, third party service providers, and all clients whether within the borders of South Africa or not.

10. USER TRACKING AND COOKIES
    • We make use of various technological tools to enhance our website on an ongoing basis, including the use of cookies and/or user tracking.
    • Cookies are broadly described as small text files containing information which are stored on a user’s computer and which hold a small amount of the user’s data.
    • We use cookies to:
      • Improve the user’s experience of our website;
      • Deliver a personalised user experience including information that may be of interest to you;
      • Provide advertising that may be of interest to you.
    • By continuing use of our website, you consent to our use of cookies.
11. RETENTION OF RECORDS
    • We retain your information on a secure database for only as long as is necessary in order to achieve the purpose for which it was collected. In other words, we only retain your information for as long as:
      • We are required to do so for lawful purposes;
      • Our internal policies require us to do so, including instances where you have requested us to stop processing your information;
      • It is required to allow us to provide our website and its related service offerings to you; and/or
      • It is necessary for us to fulfil our obligations to you.
    • By using our website, you consent to abide by the principles of our Information Retention Policy.
12. OPTING OUT OF RECEIVING DIRECT MARKETING
    • You have the right to opt out of receiving marketing communication from us. A request of this nature means that you no longer wish to receive marketing or related materials from us, regardless of the manner in which it is communicated.
    • You may “opt out” by sending an email to us at hello@unitecafrica.co.za detailing your request.
    • Where applicable, we will engage with you as appropriate to confirm that you will no longer receive any marketing material from us.
13. THE SENDING OF PERSONAL INFORMATION OUTSIDE OF THE BORDERS OF SOUTH AFRICA
    • We may send your information outside of the borders of South Africa occasionally. We may do so for various purposes, and in accordance with our business model to enable procurement of third party services, amongst other reasons.
    • Additionally, we may from time to time transfer personal information outside of the borders of South Africa for purposes of data storage and backup.
    • If we transfer any information in the manner mentioned above, we do so in accordance with the requirements for lawful processing as set out in POPIA.
    • By continuing use of our website, you agree to us transferring your personal information outside of the borders of South Africa in accordance with this policy.
14. THE INFORMATION REGULATOR
    • Under the provisions of POPIA, any data subject may lodge a query or complaint with the Information Regulator.
    • You may approach the Information Regulator at any time regarding queries or to obtain information, by following this link to its website: Contact Us | Information Regulator SA (justice.gov.za).