Definitions
Our Privacy Policy is based on the prescripts of POPIA, which requires our documentation to be understandable to our data subjects. To ensure this, we have set out terminology used herein for Your ease of reference. In this Policy, we use, inter alia, the following terms:
“We” and “Us” shall mean:
Entilini Operations (RF) (Pty) Lp
Registration Number: 2003/002559/07
of Chapmans Peak Toll Plaza, Chapmans Peak Drive,
Hout Bay, 7406.
‘’POPIA’’ shall mean:
Protection of Personal Information Act 4 of 2013
‘’You’’ and “Your” shall mean:
the person to whom personal information relates
‘’Personal’’ Information shall mean:
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, 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 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.
“Data subject” shall mean:
the person to whom personal information relates and includes any identifiable, living, natural person, and an identifiable, existing juristic person.
“Processing” shall mean:
any operation or set of operations which is performed on personal information or on sets of personal information, whether or not by automated 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.
“Automated Decision Making” shall mean:
any form of automated processing of personal information consisting of the use of personal information to evaluate certain personal aspects relating to a data subject, in particular to analyse or predict aspects concerning that data subject’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
“Responsible Party” shall mean:
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.
“Operator” shall mean:
a person, natural or juristic, which processes personal information for a responsible party in terms of a contract or mandate, without coming under the direct authority of that party.
“Consent” shall mean”:
Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal information relating to him or her.
Purpose
We are committed to respecting concerns regarding privacy and will process all personal information in alignment with the prescripts of POPIA and any further prevailing privacy legislation.
All personal information furnished collected and processed by Us regardless of form or medium shall be processed in accordance with the provisions set out hereunder.
Collecting Personal Information
We endeavour to collect and process information, which has been collected directly from data subjects.
Generally, the processing of Your personal information is necessary for purposes set out below and we will therefore only request information that is relevant and necessary for such processing. Where possible, we will inform You what information You are required to provide to us and what information is optional. Failure to provide this personal information could prevent or cause a delay in the fulfillment of these obligations.
You agree to provide accurate and complete personal information. Should You fail to provide accurate Personal Information, we may refuse to process Your request for goods/services.
We collect and process the following information:
| Data Subject | Types of Information Collected |
|---|---|
| Clients | Name and surname, email, phone number and addresses. |
| Suppliers/Sub-contactors | Name, company registration number, VAT registration number, contact details, addresses, employee names, identity numbers and bank details. |
| Visitors to Website | Name, contact details, email address, location data and information collected via cookies. |
*This policy excludes personal information collected from employees, which shall be subject to a separate agreement.
Legal basis for the processing
We, and service providers we engage, process data subjects’ personal information exclusively for the following purposes:
Consent
We will process Your personal information where You have expressly consented to the processing thereof. For example:
- Newsletters, in the form of specific consent received from you; or
- if You contact Us using our contact form.
To Comply with Contractual Obligations
We will carry out administrative activities which includes but is not limited to liaising with data subjects (telephonically or via email) for invoicing, collecting payments and delivery of services or for any other purposes related to the our contractual obligations to the data subject.
To Comply with Legal Obligations
Personal information is also collected and processed in order to comply with any legal obligation imposed on Us, which includes but is not limited to our duty to monitor and provide notification.
In Pursuit of our legitimate interests or that of any third parties
We may process Your data where necessary to pursue our legitimate interests or the legitimate interests of third parties. This includes but is not limited to:
- Enforcement of legal claims and defence in legal disputes;
- Prevention and investigation of criminal acts;
- Preservation of IT security and IT operations.
When we contract third parties, we impose appropriate security, privacy and confidentiality obligations on them to ensure that Personal Information that we remain responsible for, is kept secure.
We will ensure that anyone to whom we pass Your Personal Information agrees to treat Your information with the same level of protection as we are obliged to.
Retention of Records
The criteria used to determine the period of storage of personal information is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfilment of the contract or the initiation of a contract.
Newsletters
If you wish to opt-out from receiving newsletters from Us, please email ____________ at __________________.
Collection of Non-Personal Information
We may automatically collect non-Personal Information about You such as the type of internet browsers You use or the website from which You linked to our website. We may also aggregate details which You have submitted to the site (for example, the products or services You are interested in). You cannot be identified from this information and it is only used to assist Us in providing an effective service on this web site. We may from time to time supply third parties with this non-personal or aggregated data for uses in connection with our website.
Collection of Information by “Cookies”
You are aware that information and data is automatically collected through the standard operation of the Internet servers and through the use of "cookies." "Cookies" are small text files a Website can use to recognise repeat users, facilitate the user's ongoing access to and use of the Website and allow a Website to track usage behaviour and compile aggregate data that will allow content improvements and targeted advertising. Cookies are not programs that come onto Your system and damage files. Generally, cookies work by assigning a unique number to You that has no meaning outside the assigning site. If You do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows You to deny or accept the cookie feature; however, You should note that cookies may be necessary to provide You with certain features (e.g., customized delivery of information) available on our Websites.
Tracking of Signals
We honor do not track signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.
Behavioural Tracing
We do not allow third party behavioral tracking.
Links to Other Websites
We do not include or offer third party products or services on our website.
Google's advertising requirements can be summed up by Google's Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en
We use Google AdSense Advertising on our website.
Google, as a third party vendor, uses cookies to serve ads on our site. Google's use of the DART cookie enables it to serve ads to our users based on their visit to our site and other sites on the Internet. Users may opt out of the use of the DART cookie by visiting the Google ad and content network privacy policy.
We have implemented the following:
- Remarketing with Google AdSense
- Demographics and Interests Reporting
- DoubleClick Platform Integration
We along with third-party vendors, such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions, and other ad service functions as they relate to our website.
Opting out: Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising initiative opt out page or permanently using the Google Analytics Opt Out Browser add on.
Security Safeguards:
We:
- will treat Your personal information as strictly confidential;
- have taken appropriate technical and organisational measures to ensure that Your personal information is kept secure and is protected against unauthorised or unlawful processing, accidental loss, destruction or damage, alteration, disclosure or access. We have implemented security measures to ensure that our internal procedures meet our security policy standards. Accordingly we strive to protect the quality and integrity of Your information;
- will promptly notify You if we become aware of any unauthorised use, disclosure or processing of Your personal information;
- will provide You with reasonable evidence of our compliance with our obligations under this policy on reasonable request; and
- will not retain Your personal information longer than the period for which it was originally required, unless we are required by law to do so, or You consent to Us retaining such information for a longer period.
Protection of visitor information?
Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.
We use regular Malware Scanning.
Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.
We implement a variety of security measures when a user places an order enters, submits, or accesses their information to maintain the safety of your personal information.
All transactions are processed through a gateway provider and are not stored or processed on our servers.
ALTHOUGH WE TAKE THE AFOREMENTIONED PRECAUTIONS IN PROTECTING YOUR PERSONAL INFORMATION, WE SHALL HOWEVER NOT BE LIABLE FOR ANY LOSS OR DAMAGE, HOWSOEVER ARISING, SUFFERED AS A RESULT OF THE DISCLOSURE OF SUCH INFORMATION IF OUTSIDE OUR REASONABLE CONTROL.
Minors
We do not process the information of minor children.
Transfer of Your Personal Data
Your information, including personal information, may be processed at our operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
Some of the personal information that is collected automatically is collected by third parties whose technology we use to provide website functionality and acquire website analytics information.
Our Services may offer social sharing features and other integrated tools (such as the LinkedIn “Like” button), which let You share actions You take on our Services with other media, and vice versa. The use of such features enables the sharing of information with Your friends or the public, depending on the settings You establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.
We will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Notice and we will endeavour to ensure that no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.
Your submission of your information represents Your agreement to that transfer.
Your Rights
Right of Access
Each data subject has the right to obtain from Us confirmation as to whether personal information concerning him/her is being processed by it as well as a record of said personal information. Should the data subject require copies of any/all of the records held, a request must be submitted in the format and manner as prescribed detailed in our PAIA Manual, available upon written request.
Right to rectification
Each data subject has the right to obtain from Us, without undue delay, the rectification of inaccurate personal information concerning him/her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal information completed, including by means of providing a supplementary statement.
Right to erasure
A data subject, may at any time, request the deletion or destruction of its personal information held by Us. We, however reserve the right to refuse such request in light of any other laws, regulations and/or contractual obligations restricting Us from complying with the data subject’s request.
Right to object
Each data subject has the right to object, on grounds, to the processing of his/her personal information. We will refrain from processing the personal information in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.
In order to comply with any request received, we may require proof of identity.
Existence of automated decision-making
As a Responsible Party, we do not use automatic decision-making or profiling.
Promotion of Access to Information Act
In compliance with the provisions of the Promotion of Access to Information 2 of 2000 (PAIA), all requests for access to information must comply with the prescribed procedure set out in our PAIA manual, available upon written request or via our website www.chapmanspeakdrive.co.za.
Contact Us
All enquiries, requests, concerns or complaints relating to the processing of personal information must be directed to Mark Jacobs at This email address is being protected from spambots. You need JavaScript enabled to view it..
If You are not satisfied with our response to Your query, You may approach the following regulatory body for further assistance:
THE INFORMATION REGULATOR (SOUTH AFRICA) SITUATE AT: JD HOUSE, 27 STIEMENS STREET, BRAAMFONTEIN, JOHANNESBURG, 2001.
COMPLAINTS:
- This email address is being protected from spambots. You need JavaScript enabled to view it.
- This email address is being protected from spambots. You need JavaScript enabled to view it.
GENERAL QUERIES: This email address is being protected from spambots. You need JavaScript enabled to view it.
