Privacy Policy
OUR WEBSITE PRIVACY POLICY
We are committed to ensuring that your privacy is protected.
1. INTRODUCTION
- ALTECRETE is sensitive to the personal nature of the information you provide to us.
- This Privacy Policy (the “policy”) explains how we protect and use your Personal Information.
- By providing us with your Personal Information, you-
- agree to this Policy and authorise us to process such information as set out herein; and
- authorise ALTECRETE, its associates, our Service Providers and other third parties to process your Personal Information for the purposes stated in this Policy.
- We will not use your Personal Information for any other purpose than that set out in this Policy and will endeavour to protect your personal information that is in our possession from unauthorised alteration, loss, disclosure or access.
- Please note that we may review and update this Policy from time to time. The latest version of this Policy is available on our website as well as upon request.
- This Policy applies to all external parties with whom we interact, including but not limited to individual clients, representatives of client organisations, visitors to our offices, users of our website and other users of our professional services offered. Please refer to Annexure A for terms and definitions.
2. COLLECTION OF PERSONAL INFORMATION
- We may collect or obtain Personal Information about you:
- Directly from you;
- in the course of our relationship with you or your organisation;
- when you make your Personal Information public;
- 2.1.4 when you visit and/or interact with our Website or our various social media platforms;
- when you visit our offices;
- We may also receive personal information about you from third parties;
- In addition to the above, we may create Personal Information about you such as record of your communications and interactions with us, including but not limited to your order history or other engagements with us.
3. CATEGORIES OF PERSONAL INFORMATION WE MAY PROCESS
We may, in the ordinary course of business, process the following categories of Personal Information about you:
- Personal details: full name and copy of your Identity document;
- Demographic information: gender, date of birth, age, nationality, salutation, title and language preferences;
- Identifier information: identity number or banking details (in the event of a supplier or refund)
- Contact details: correspondence address, telephone numbers, email address, and postal as well as physical addresses
- Instruction details: details of individuals who may place orders or interact with us, Personal Information included in correspondence, documents or other materials that we process in the course of providing our services to you.
- Attendance records: details of meetings and other events organised by us that you attend
- Payment details: billing address; payment method; bank account number or card number (where applicable); invoice records; payment records; payment dates and amounts;
- Data relating to your visits to our website: your device type, operating system; browser type, browser settings; IP address; language settings; dates and times of connecting to a website and other technical communications information;
- Employer details: where you interact with us in your capacity as an employee of an organisation, the name, address, telephone number and email address of your employer to the extent that same is relevant for our business relationship;
- Content and advertising data: records of your interactions with our online advertising and content displayed on pages displayed to you, and any interaction you may have had with such content or advertising (included but not limited to mouse hover, mouse clicks and any forms you complete or submit).
4. SPECIAL PERSONAL INFORMATION AND INFORMATION RELATING TO CHILDREN
- Where we need to process your Special Personal Information, we will do so in the ordinary course and scope of our business relationship with you, and for a legitimate purpose in accordance with applicable law.
- We will not collect any personal information of children in the ordinary course of our business relationship with you as we cannot conduct business with persons under the age of 18 years of age. By using our services and/or purchasing our products, you confirm that you are over the age of 18.
5. PURPOSES OF PROCESSING AND LEGAL BASIS FOR PROCESSING
- We will process your Personal Information in the ordinary course and scope of our business of providing you with our services and products. We will primarily use your personal information only for the purpose for which it was originally or primary collected – e.g billing and/or delivery of products. We will only use or process your personal information for a secondary purpose if it constitutes a legitimate interest or is in order to protect a right.
- We may subject your Personal Information to processing during the course of various activities, including but not limited to:
- operating our business;
- analysis, evaluation, review and collation of information in order to fulfil our contracted obligations to our clients and client contracts, and provide professional advice, packages, services and recommendations (whether in electronic form or otherwise)
- compliance with applicable FICA regulations and fraud prevention;
- attending to the legitimate interests of Data Subjects;
- tracking Data Subject activity on the Company Website, various social media platforms and through direct interactions with us;
- transfer of information to our Service Providers and other third parties or
- marketing or recruitment purposes.
- We may process your Personal Information for relationship management and marketing purposes in relation to our services (including but not limited to processing that is necessary for the development and improvement of our services), for account management, and for marketing activities in order to establish, maintain and/or improve our relationship with you and with our Service Providers. We may also analyse your Personal Information for statistical purposes.
- We may process your Personal Information for internal management and management reporting purposes including but not limited to conducting internal audits / investigations, implementing internal business controls, providing central processing facilities, for insurance purposes and for management reporting analysis.
- We may process your Personal Information for safety and security, as well as verification purposes.
6. DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES
- We may disclose your Personal Information to our Associates and Service Providers, for legitimate business purposes, in accordance with applicable law and subject to applicable professional and regulatory requirements regarding confidentiality. In addition we may disclose your Personal Information –
- if required by law;
- to legal and regulatory authorities, upon request, or for the purposes or reporting any actual or suspected breach of applicable law or regulations;
- to third party Operators (including but not limited to: data processors such as providers of data hosting services) located anywhere in the world, subject to paragraph 6.2 below.
- where it is necessary for the purposes of, or in connection with actual or threatened legal proceedings or establishment, exercise or defense of legal rights;
- to any relevant party for the purposes of the prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including but not limited to safeguarding against and the prevention of threats to public security.
- to any relevant third party acquirer(s), in the event that we sell or transfer all or any portion of our business or assets (including but not limited to, in the event of reorganization, dissolution or liquidation) and
- to any relevant third party provider where our website uses third party advertising, plugins or content.
- if we engage a third party Operator to process any of your Personal Information, we recognise that nay Operator who is in a foreign country must be subject to a law, binding corporate rules or binding agreements which provide an adequate level of protection similar to POPIA. We will review our relationships with Operators we engage with and to the extent required by any applicable law, we will ensure and/or require that such Operations be contractually bound to –
- only process such Personal Information in accordance with our prior written instructions and
- use appropriate measures to protect the confidentiality and security of such Personal Information.
7. INTERNATIONAL TRANSFER OF PERSONAL INFORMATION
- We may transfer your Personal Information to recipients outside of the Republic of South Africa.
- Subject to paragraph 6.2 above, the Personal Information will only be transferred outside of the Republic of South Africa provided that the country to which the data is transferred has adopted a law that provides for an adequate level of protection substantially similar to POPIA, or where no such legislation exist, contractual undertakings by the Operator / third party to protect the personal information in line with the provisions of POPIA and our obligations to you. We will at all times ensure that the transfer of data or information is necessary in order to provide the services and products that is required by our clients.
8. DATA SECURITY
- We implement responsible and appropriate technical and organisational security measures to protect your Personal Information that is in our possession against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or unauthorised access in accordance with applicable laws.
- Where there are reasonable grounds to believe that your Personal Information that is in our possession have been subject to any unauthorised breach, we will notify the Information Regulator and you in accordance with the guidelines and/or requirements issued by the Information Regulator unless we are advised by the Information Regulator and/or other public body responsible for detection, prevention or investigation of offences that such notification will impede a criminal investigation in which event you will be notified as soon as we are permitted to do so.
- The Internet is a open system, and therefore transmission of information via the internet is not completely secure. We have implemented all reasonable measures to protect your Personal Information that is in our possession but cannot guarantee the security of any information transmitted using the internet and as a consequence cannot be held liable for any loss of privacy that occurs as a result of such data transmission.
9. DATA ACCURACY
You have the obligation to ensure that all Personal Information that are provided to us are accurate, complete and up to date. Should any of your Personal Information change, it remains your responsibility to ensure that we are notified of any such change and to provide us with the updated Personal Information. We will endeavour to ensure that your Personal Information are kept relevant and up to date to the best of our ability and knowledge.
10. DATA MINIMISATION
ALTECRETE will restrict it’s processing of Personal Information to data which is sufficient for the fulfilment of the primary purpose or legitimate interest or for the period required to comply with an applicable legal requirement, whichever is longer.
11. DATA MINIMISATION
ALTECRETE shall only retain and store Personal Information for the period for which the data is required to serve its primary purpose or a legitimate interest or for the period required to comply with an applicable legal requirement whichever is longer. ALTECRETE undertakes to act upon such instruction from a Data Subject in respect of destruction of Personal Information in accordance with applicable laws.
12. YOUR LEGAL RIGHTS IN RESPECT OF ACCESSING OF YOUR PERSONAL INFORMATION
- In terms of POPIA as well as several other laws, YOU have the right to access your Personal Information and to request us to rectify, erase and/or restrict of the use thereof. You also have the right to object to the further and/or continued processing of your Personal Information that has been made available to us and to withdraw the consent to us to process your Personal Information.
- If you would like to access, amend, erase, restrict or withdraw your consent to use any of your Personal Information, please contact the Information Officer by emailing tracy@altecrete.com
- The Information Officer will provide you with the relevant forms to complete. Once the completed form have been received, the Information Officer will make every effort to verify the identity of the Data Subject and the validity of the request prior to handling any Personal Information. All requests will be processed and considered on an individual basis and within a reasonable time.
13. COOKIES AND SIMILAR TECHNOLOGIES
We may process your Personal Information by our use of Cookies and similar technologies but only for the necessary functioning of our Website. When you visit ALTECRETE‘s website, we may place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable laws.
14. DIRECT MARKETING
- We may process your Personal Information for the purpose of providing you with information regarding services or products that may be of interest to you. You may withdraw your consent to direct marketing at any time.
- If you are currently receiving marketing information from us and would prefer to not receive any further marketing information in future, or if you are not receiving any marketing information and would like to receive such information, please send us an email to tracy@altecrete.com with your request.
15. COMPLAINTS, FEEDBACK AND INCIDENTS OR DATA BREACHES
- You may direct any feedback, complaints, data breach notifications, incident notifications and any requests to access, amend, erase or restrict the use of your Personal Information to the Information Officer: The Information Officer, Tracy Borejszo, tracy@altecrete.com, 010 001 5155
- When there is a complaint, incident or data breach identified, it should be brought under the attention of our Information Officer immediately. We will investigate the complaint, data breach or incident as a matter of priority, take the appropriate actions and provide feedback in respect of our findings and what actions have been taken in respect thereof.
- Should you have any complaints in regards to the manner in which we are processing your Personal Information, or regarding our compliance with any request made by you in respect of your Personal Information or our compliance with any of the provisions and regulations of POPIA and/or any other applicable law, you are entitled to lodge a complaint with the Information Regulator. https://www.justice.gov.za/inforeg/portal.html, complaints.IR@justice.gov.za, Inforeg@justice.gov.za, JD House, 27 Stiemans Street, Braamfontein, Johannesburg, 2001.
ANNEXURE A: TERMS AND DEFINITIONS
- ASSOCIATES: means ALTECRETE’s shareholders, subsidiaries and the directors, employees and consultants.
- COOKIE: means a small file that is placed on your device when you visit a website. In this Policy, a reference to a “cookie” includes analogous technologies such as web beacons and clear Graphic Interchange Format Files (GIF’s)
- OPERATOR: means any person or entity that processes Personal Information on behalf of the Responsible Party
- PERSONAL INFORMATION: means information that is about any individual and/or legal entity, or from which any individual and/or legal entity is directly or indirectly identifiable, in particular by reference to an identifier such as a name, identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of such an individual or legal entity.
- POPIA: means the Protection of Personal Information Act, 4 of 2013 and includes all the regulations issued in respect thereof.
- PROCESS: includes “processing” or “processed” means anything that is done with any Personal Information, whether or not byautomated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- RESPONSIBLE PARTY: means the entity that decides what, how and why Personal Information is processed.
- SPECIAL PERSONAL INFORMATION: SPECIAL PERSONAL INFORMATION: Means Personal Information about race or ethnicity, political affiliation or opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual orientation or preferences, any actual or alleged criminal offenses as defined in terms of POPIA.
- SERVICE PROVIDER: third party providers of various services whom we engage, including but not limited to providers of information technology, communication, file storage, data storage, copying, printing, accounting or auditing services, human resource consultation services, translators, taxation consultants as well as our insurers and professional advisors.
- WEBSITE: means any website operated, or maintained by us or on our behalf.