LAST UPDATED: 19 October 2018

GUIDE TO THIS PRIVACY POLICY

1. INTRODUCTION

2. WHAT INFORMATION DO WE COLLECT?

3. PROTECTION OF PERSONAL INFORMATION ACT 4 OF 2013

4. WHO DO WE COLLECT DATA FROM?

5. HOW LONG DO WE KEEP YOUR INFORMATION?

6. COOKIES AND THIRD PARTY TECHNOLOGIES

7. LINKS TO OTHER SITES

8. HOW WE USE YOUR INFORMATION

9. WHO DO WE DISCLOSE YOUR INFORMATION TO?

10. WILL WE EVER SELL YOUR PERSONAL DATA?

11. WHAT HAPPENS IF THE SOCIAL COLLECTIVE IS SOLD?

12. WHAT PERSONAL DATA CAN OUR STAFF SEE?

13. HOW DOES THE SOCIAL COLLECTIVE PROTECT MY INFORMATION?

14. YOUR RIGHTS

15. PROCESSING YOUR DATA OUTSIDE SOUTH AFRICA

16. USE OF THE PLATFORM BY CHILDREN

17. QUESTIONS OR CONCERNS ABOUT THIS POLICY

  1. INTRODUCTION
    1. This is the privacy policy of The Social Collective Proprietary Limited (Registration No. 2015/160496/07), a private company registered in the Republic of South Africa, with our registered office being at Unit 10, 17 Owl Street, Braamfontein Werf, Gauteng, 2094 ("we", "us", "our", “Social Collective”) (“Privacy Policy”).
    2. This Privacy Policy sets out the basis on which we collect, use, store, disclose and destroy information (“Process”) from users of our Platform and/or our mobile application (collectively, the “Platform”), as well as your rights to control the certain use of that information. By accessing, or otherwise using the Platform, you agree to our Processing of your information in accordance with this Privacy Policy.
    3. We will always aim to Process the minimum amount of personal data necessary to provide The Social Collective services (the “Services”) to you.
    4. if you have any general questions or comments about our data practices, or if you think our policy falls short of your expectations or that we are failing to abide by our policy, please contact us at hello@thesocialcollective.co
    5. By making use of the Platform, you agree to be bound by this Privacy Policy, and our Terms of Use, which can be found avo.thesocialcollective.co.co/terms.
  2. WHAT INFORMATION DO WE COLLECT?
    1. Information You Provide
      1. While using the Services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to, your email address, name, phone number, identity or passport number, location, race, gender, physical address, details of the categories and subcategories, interests, evaluation of experiences, details of responses to enquiries via online communication, any information you share on the Platform and/or any unsolicited information provided to the Platform that could have otherwise been lawfully collected and other information ("Personal Data"). When you submit Personal Data to us via the Platform, you retain ownership, but consent to us Processing same. This consent may be withdrawn at any time, save where we are required to continue to use such information in order to perform our contractual obligations to you, or where such information is needed for our legitimate business interests.
    2. Where there is a legal basis to do so
      1. We Process your Personal Data only where we have a lawful basis to do so. Accordingly, we will only Process your Personal Data where:
        1. you provide consent for us to do so (which consent can be freely withdrawn at any time by you);
        2. it is necessary for us to perform any contractual obligations to you;
        3. we have a legitimate interest in Processing the information in order for our Platform to function, and for our legitimate business purposes (for example, to communicate with you, to use data for analytics purposes, to combat fraud); or
        4. we are under a legal obligation to do so.
    3. Information Collected Automatically
      1. When you visit the Platform or receive correspondence from us, we may passively collect and store information from you, including, your IP address, what browser software and operating system you are using and your ISP carrier information. You can control the technologies we use by utilising the settings in your browser or third-party tools, however, refusing or deleting some cookies may make it impossible for us to provide the Services to you. 
    4. Location Information
      1. We may use and store information about your location, if you give us permission to do so. We use this information to provide features of our Services, to improve and to customize our Services. You can enable or disable location services when you use our Services at anytime through your device settings.
    5. Correspondence Information
      1. We may Process Personal Data when we receive correspondence from you via email, social media and phone calls. This includes your sender information, the content of the message and the metadata pertaining to the message. We use this information to communicate with you and to improve the Services.
    6. Non-personally identifiable information
      1. We may aggregate and analyse your 'de-identified' information (i.e. stripped of all uniquely identifiable attributes and that cannot subsequently be re-identified) with that of other customers and information received from other sources. We will do this to develop market insights, troubleshoot problems, detect and protect against error, fraud and other criminal activity, identify behaviour/usage patterns and improve our Services generally. We own the information once it has been de-identified, and we may publish or share any insights we discover through analysing your de-identified information.
  3. PROTECTION OF PERSONAL INFORMATION ACT 4 OF 2013

    This Privacy Policy adheres to the requirements of the Protection of Personal Information Act 2013.

  4. WHO DO WE COLLECT DATA FROM?
    1. We collect Personal Data from the following:
      1. natural and juristic persons who have signed up for the Services;
      2. people who send enquiries or requests to our contact email address;
      3. end users of the Services; and
      4. integrated software services.
  5. HOW LONG DO WE KEEP YOUR INFORMATION?

    We will keep your information for as long as you are an active user of the Services. We delete your information when you terminate your use of the Services but will retain some Personal Data for so long as we are obliged to in order to fulfil our legal obligations. Such information will always be maintained under the same security and privacy controls that are in place for other users of the Services. Note that we may keep de-identified information indefinitely.

  6. COOKIES AND THIRD PARTY TECHNOLOGIES
    1. “Cookies” are small files stored on your computer during your use of the Platform and which contain data about your use of the Platform. We may use session Cookies (which expire when you close your browser) or persistent Cookies (which stay on your computer until you delete them) to understand more about your activity on the Platform or on other Platforms, including for:
      1. authenticating users;
      2. remembering preferences and settings;
      3. determining the popularity of Platform content;
      4. delivering and measuring the effectiveness of advertising campaigns;
      5. analysing site traffic and trends; and/or
      6. operating our content management system.
    2. We also use Cookies and other technologies to collect information about your visit to the Platform, such as the date and time of your visit, the information you searched to find the Platform, or your activity on the Platform.
    3. You may adjust your browser or operating system settings to limit or to decline or delete Cookies, but this may affect your use of certain areas of the Platform. Check the settings menu of your browser or operating system to learn how to change your tracking settings or Cookie preferences. On your mobile device, you can adjust your privacy and advertising settings to limit your tracking for advertising or control whether you receive more relevant advertising.
  7. LINKS TO OTHER SITES

    The Services may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third-party's site. We strongly advise you to review the privacy policy of every site you visit. We have no control over, and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

  8. HOW WE USE YOUR INFORMATION
    1. We may use your information to:
      1. provide the Services;
      2. report on your use of the Services to various stakeholders, including, but not limited to, your employer;
      3. personalise your use of the Platform;
      4. develop new services  or to conduct analysis of Services;
      5. review usage and operation of the Platform;
      6. contact you for:
        1. marketing (although you will always be able to opt out of receiving such marketing correspondence);
        2. responding to your queries;
        3. other legitimate business purposes;
        4. verifying your identity; and/or
        5. any other reason, with your express permission.
    2. We may also use your non-personally identifiable information in an anonymous manner to analyse the use of the Platform in general, and to:
      1. improve the Services;
      2. compile statistical and other information related to the performance, operation and use of the Services and of any equipment, machinery or other assets managed using the Services;  
      3. measure monitoring and evaluation specifics and reports in aggregated form for security and operations management, to create statistical analyses, and for research and development purposes.
  9. WHO DO WE DISCLOSE YOUR INFORMATION TO?
    1. Organisations
      1. We may share your contact details with organisations, related to your indication of interest (by applying to a “opportunity”, or other available options), subscribing to an organisation to make a donation, to end communications, related interested and automated communication based on your requests and actions taken on the Services.
    2. Service Providers
      1. We may share your information with our authorised administrative service providers (“Service Providers”) to assess performance and statistical data to improve operations, to provide us with business, professional, or technical support, for instance, to host and run our servers, send emails, manage support requests, to provide feedback, updating of records on your contact details, process complaints, facilitate updates regarding business developments and opportunities, provide marketing material, and enrich information. They process your Personal Data strictly in accordance with our instructions and only for the purpose for which such Personal Data has been disclosed to them. They will always be under obligation to protect your Personal Data on terms that provide the same or equivalent protection as set out in this Privacy Policy and will not use or disclose your data for any other purpose.
    3. Partners and/or affiliates
      1. We may share your information with selected partners and/or affiliates we believe may have offers of interest to you. If you do not want us to disclose your information to Service Providers for their direct marketing or any other purpose, you may opt out of such disclosure by contacting us at hello@thesocialcollective.co.
    4. Legal obligations
      1. We may access or share your information in any manner necessary in order to comply with any law, regulation legal process or governmental request. We may also access and/or disclose your information if it is necessary for an investigation relating to public safety, or as otherwise required by law.
    5. Security
      1. We may disclose your information to protect the security of the Platform, our servers, network systems, and databases. We may also disclose your information as necessary where there has been a violation of any legal document or contract related to the Platform, or the rights of any third party.
    6. Fraud
      1. We may access and disclose your information in order to combat fraud.
    7. Non-personally identifiable or anonymised data
      1. We may also share non-personally identifiable, aggregate or anonymous information with third parties for their marketing or analytics uses.
  10. WILL WE EVER SELL YOUR PERSONAL DATA?

    No, however, this is subject to clause 11. We collect and use your Personal Data only to provide the Services to you and as set out in this Privacy Policy. However, we can market and sell any de-identified data and information, without limitation.

  11. WHAT HAPPENS IF THE SOCIAL COLLECTIVE IS SOLD?

    If we become involved in any merger, consolidation, or sale of our assets, your Personal Data may be sold as part of such transaction.

  12. WHAT PERSONAL DATA CAN OUR STAFF SEE?

    Our staff are bound by comprehensive confidentiality obligations and are given access only to information they are required to see in order for them to fulfil their responsibilities. In all cases we provide access to the minimum amount of information. Given their role, our customer support team has access to the most amount of Personal Data to enable them to answer your support questions. In addition to service usage information, our internal systems provide them with secure access to other Personal Data such as your name and email address.

  13. HOW DOES THE SOCIAL COLLECTIVE PROTECT MY INFORMATION?
    1. We are committed to protecting your information. We maintain appropriate procedures to safeguard and secure your information and to prevent unauthorised access of your information. The accuracy, safety, and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Platform, you are responsible for keeping this password confidential. Even though we do our best to protect your information, the transmission of information via the internet is not completely secure, and we cannot guarantee our security measures. We are not responsible for any unauthorised access to or acquisition of your information.
    2. To ensure that your Personal Data is Processed correctly and with a suitable level of privacy, we endeavor to ensure that Personal Data is:
      1. Processed in a manner that is lawful, fair and transparent;
      2. collected only for specified, explicit and legitimate purposes (and not further Processed in a manner that is incompatible with those purposes);
      3. adequate, relevant and is limited to what is necessary in relation to the purposes for which it is Processed;
      4. accurate and kept up to date, and inaccurate or incomplete Personal Data will be rectified, erased or further Processing suspended;
      5. not kept for longer than necessary for the purposes for which the data is collected or for which it is to be further Processed; and
      6. Processed in a manner that ensures appropriate security of the Personal Data.
  14. YOUR RIGHTS
    1. You have the following rights:
      1. right of access – to request a copy of the information that we hold about you. Access to this information may be subject to an administrative fee if the request is unfounded, excessive or repetitive;
      2. right of rectification – to correct data that we hold about you that is inaccurate or incomplete. Failure to provide updated information may make it difficult or impossible for you to access certain Services. You will need to ensure your Personal Data is accurate and up-to-date;
      3. right to be forgotten – to ask for the data we hold about you to be erased from our records, in certain circumstances. Erasure will be subject to an administrative fee if your request is manifestly unfounded, excessive or repetitive;
      4. right to restriction of processing – to restrict processing of your information in certain circumstances;
      5. right of portability – to have the data we hold about you transferred to another organization;
      6. right to object – to object to certain types of processing such as direct marketing and to object to the automated processing or profiling;
      7. right to judicial review – you have the right to complain to a relevant authority regarding the use of your Personal Data by us;
      8. right to withdraw consent – you have the right to withdraw your consent to us Processing your Personal Data, by emailing us at  hello@thesocialcollective.co.
    2. If you wish to remove or change personally identifiable information from our Platform or other databases, you may do so by contacting us at hello@thesocialcollective.co. To better safeguard your information, we may require that you verify that you are in fact the owner of such Personal Data. Once the changes are made we will notify you by email at your nominated email address.
  15. PROCESSING YOUR DATA OUTSIDE SOUTH AFRICA

    The Platform may be hosted in the Republic of South Africa. Data obtained within South Africa may be Processed outside South Africa and data obtained in any other country may be Processed within or outside that country. We shall ensure that our host providers are subject to laws, or policies, which uphold principles for the reasonable processing of information substantially similar to the data protection laws in South Africa and the European Union to ensure adequate protection of any such data.

  16. USE OF THE PLATFORM BY CHILDREN

    You must be 13 years or older to use the Platform and must have the consent of your parent or legal guardian if you are under the age of 18. If we become aware that we have Processed Personal Data from someone under the age of 18 without verification of parental consent, we will take steps to remove that information from our servers as soon as possible.

  17. QUESTIONS OR CONCERNS ABOUT THIS POLICY

    If you have any questions or comments about this Privacy Policy, please email us at hello@thesocialcollective.co.