We have updated this policy to comply with the European Union’s General Data Protection Regulation (GDPR) and South Africa’s Protection of Personal Information Act (Popia).
This policy applies to you if you are:
• a visitor to our website; or
• a customer who has ordered, registered for or uses the services that we provide.
Personal data includes:
• certain information that we collect automatically when you visit our website;
• certain information collected on registration (where this facility is available – 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 data subject to protection under this policy).
Common examples of the types of personal data 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 data
Depending on the services that you require, we may also collect sensitive personal data, including your:
• financial information – such as your bank account details;
• sensitive demographic information – such as your race or ethnicity; and
• employment information – including your job title and the industry you work in.
Acceptance of this policy
You must accept all the terms of this policy when you register for, or use the website or any of our services. If you do not agree with anything in this policy, then you may not register for or use the website or any of our services. You may not register for or use the website or any of our services if you do not accept this policy.
You may not access our website or order our services if you are younger than 18 years old or do not have 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.
You may only send us your own personal data or the information of another data subject where you have their permission to do so. Our website may give you the option to post information in a way that is publicly accessible and may be collected by others (such as via comments on articles). You are responsible for any personal data that you post in this way.
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, 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 our services. If you continue to use the website or our services 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.
Collection of data
Once you register on our website, you will no longer be anonymous to us. You will provide us with certain personal data.
This personal data will include:
• your name and surname;
• your email address; and
• your username and password.
We will use this personal data 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.
When you order any services from us, you may be asked to provide us with additional information on a voluntary basis (services information). This information may include:
• your ID number;
• your postal address or street address; and
• your telephone number.
Please note that other websites you visited before entering our website might place personal data within your URL during a visit to it, and we have no control over such websites. Accordingly, a subsequent website that collects URL information may log some personal data.
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 data. We merely use them 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 or when you enter competitions, take advantage of promotions, respond to surveys, order certain additional goods or services, or otherwise use the optional features and functionality of our website.
We may monitor and record any telephone calls that you make to us, unless you specifically request us not to.
Purpose for collection of data
We may use or process any 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 data, disclosing it, and combining it with other personal data. We generally collect and process your personal data for various purposes, including:
• services purposes – such as providing our services;
• marketing purposes – such as pursuing lawful related marketing activities, including business intelligence (including website activity and market research);
• 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.
Consent to collection of data
We will obtain your consent to collect personal data:
• in accordance with applicable law;
• when you provide us with any registration information or optional information.
Use of data
We may use your personal data to fulfil our obligations to you. This could include delivering newspapers to you, allowing you to access exclusive content on our website, billing you for our services, or improving our offerings.
Messages and updates
We may send administrative messages and email updates to you about the website. We may wish to provide you with information about new goods or services in which we think you may be interested. This means that in some cases, we may also send you primarily promotional messages. We will not send you promotional messages unless you have chosen to opt in to receive them. You can choose to opt out of receiving promotional messages.
While you are logged into the website, we may display targeted adverts and other relevant information based on your personal data. In a completely automated process, computers process the personal data and match it to adverts or related information. We never share personal data 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 data. 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 data to advertisers with the referring URL. Once you are on the advertiser’s website, however, the advertiser is able to collect your personal data.
Disclosure of data
We may share your personal data with:
• other divisions or companies within the group of companies to which we belong 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 to us 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);
• social media platforms when you use tools or functionality on our website provided by those platforms (such as “recommend” or “share” buttons); and
• other third parties who provide us with relevant services where appropriate.
We may disclose your personal data as required by law or governmental audit.
We may disclose personal data 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.
No linked websites
We do not share personal data with any websites linked to on our site, unless they are a party with whom we are allowed to share personal data, as indicated in this policy. Please check these websites’ own privacy policies before sharing your personal data with them.
We may disclose aggregate statistics (information about the customer population in general terms) about the personal data to advertisers or business partners.
We may need to disclose personal data to our employees that require the personal data to do their jobs. These include our responsible management, human resources, accounting, audit, compliance, information technology, or other personnel. Any of our employees or personnel that handle your personal data will have signed non-disclosure and confidentiality agreements.
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 data we process to a successor, purchaser or separate entity. We will disclose the transfer on the website. If you are concerned about your personal data migrating to a new owner, you may request us to delete your personal data.
We take the security of personal data 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 authorise access to personal data only for those employees who require it to fulfil their job responsibilities. We implement disaster recover procedures where appropriate.
Accurate and up to date
We will try to keep the personal data 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 data on the website. You are able to review or update any personal data 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 data, we take steps to verify your identity before granting you access to your account or making any corrections to your personal data. Throughout your interaction with us you retain the right to rectify personal data that is incorrect or inaccurate. This does not apply if we process your personal data in our capacity as an operator or processor on behalf of a responsible party or data controller.
Retention of data
We will only retain your personal data 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.
Without limiting the above, we may store the following types of personal data for the following durations:
• account and subscription data – 5 years after the most recent transaction;
• business intelligence – 36 months;
• comments on articles – the lifetime of the article;
• site features and preferences – the lifetime of your account;
• customer service communications – 7 years.
During the period of retention, we will continue to abide by our non-disclosure obligations and will not share or sell your personal data.
We may retain your personal data in physical or electronic records at our discretion.
Transfer to another country
We may transmit or transfer personal data outside the country in which it was collected to a foreign country and process it in that country. Personal data may be stored on servers located outside the country in which it was collected in a foreign country whose laws protecting personal data may not be as stringent as the laws in the country in which it was collected. You consent to us processing your personal data in a foreign country whose laws regarding processing of personal data may be less stringent.
Updating or removing
You may choose to correct or update the personal data you have submitted to us, by clicking the relevant menu in any of the pages on our website or contacting us by phone or email (please also see additional information under Enquiries).
You are entitled to a right to be forgotten. We will delete any personal data that you don’t want us to have. If you do this, we will remove your personal data from our system, but we may still retain certain personal data as required or allowed by law, including:
• where we can show legitimate grounds for processing your personal data that override your request; or
• where we process your personal data in order to establish, exercise or defend legal claims.
You understand that if we delete your data from our system, we may be unable to continue providing some or all of our services to you.
If you are a data subject of one of our customers (who is the data controller), then you must submit your request to the relevant data controller who will then delete your personal data.
Restriction of processing
You may request that we restrict the use of your personal data. When we restrict your personal data we still have the right to store it but not use it. You can ask that we do this verbally or in writing (which writing may be in an electronic form) via the forums described in this policy. We will respond to the request within 30 days.
If you should wish to transfer your data from us to another data controller, we will facilitate this transfer. We will pass on all of our personal data to the data controller.
If you are a data subject of one of our customers (who is the data controller), then you must submit your request for your personal data to the relevant data controller, who will then export your personal data as a Microsoft Excel or CSV file.
We will notify our customers of any confirmed data breaches that has occurred. It is our customers’ responsibility to notify relevant supervisory authorities and any affected data subjects of the data breach.
We are not responsible for, give no warranties, nor make any representations in respect of the privacy policies or practices of any linked or third-party websites.
If you want to update or remove your personal data, restrict how we process it, or opt in or out of receiving newsletters or other promotional content, please contact us:
• Telephone: 0860 52 52 00
• Email: firstname.lastname@example.org
Registered users can also edit their name and surname on the website itself or change their email newsletter preferences. Once you’ve signed in, hover the mouse over your name displayed at the top of the website and click the “Profile” label that appears (on your mobile phone, click on the menu bar at the top right to find the “Profile” option) to find your personal information and newsletter preferences.
• Telephone: +27 11 280 3000
• Email: email@example.com
• Post: Data Protection Office, PO Box 1746, Saxonwold, Johannesburg, 2132
If you have any complaints about the way we handle your personal data, please contact our data protection officer as described above, so that we can resolve it. You may choose, however, to approach a supervisory authority instead, including:
• the data protection authority in your jurisdiction, where you are covered by the EU GDPR; or
• the South African Information Regulator.
You can find out who your data protection authority, commissioner or regulator is by visiting this website.
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How we make our website work for you
What are cookies?
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• granting you access to restricted content;
• tailoring our website’s functionality to you personally by letting us remember your preferences, location or device type;
• 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.
The cookies we use
We use different types of cookies on our website. Some of these cookies are placed by us, while others are placed by our third-party plug-ins, suppliers or advertisers. These cookies may be deleted from your device at different times, such as at the end of your browsing session (when you leave the website) or after a pre-set amount of time, or they may persist on your device until you delete them.
You can see the main types of cookies we use in the following list. These cookies expire automatically at different times, depending on when they were last used by our website, or when you manually delete them:
Cookie name: Google Analytics
Cookie type: Analytics
Cookie function: Tracks and reports on website traffic and visitor behaviour
Cookie name: Narratiive
Cookie type: Analytics
Cookie function: Tracks and reports on website traffic and visitor behaviour
Cookie name: Chartbeat
Cookie type: Analytics
Cookie function: Tracks and reports on website traffic and visitor behaviour
Cookie name: Behavioural advertising/marketing cookies (various)
Cookie type: Advertising
Cookie function: Behavioural advertising cookies are used to provide you with advertising that is tailored to your interests when you visit websites on and off our network. Behavioural advertising cookies analyse information about your interests and your browsing history, and provide you with advertisements on and off our network that matches these interests
Cookie name: Social media (various)
Cookie type: Social media
Cookie function: Facebook, Twitter and other social media platforms use a cookie to track your behaviour on our website for advertising purposes and to enable some functionality such as sharing to social media platforms
Your internet browser generally accepts cookies automatically, but you can often change this setting to stop accepting them. You can also delete cookies manually. You can read how to do this here.
Deleting or no longer accepting cookies may prevent you from accessing certain aspects of our website where cookies are necessary, or cause the website to forget your preferences. Deleting cookies may not prevent you from seeing advertisements on our website, but such advertising may be less relevant to you.