Afrihost Home-Connect (Pty) Ltd

THE PROTECTION OF PERSONAL INFORMATION ACT CUSTOMER PRIVACY NOTICE

This Notice explains how we obtain, use and disclose your personal information, in accordance with the requirements of the Protection of Personal Information Act (“POPIA”).

At Afrihost Home-Connect we are committed to protecting your privacy and to ensure that your personal information is collected and used properly, lawfully and transparently.

1. 1. Responsible Party and Operators

   1. Afrihost Home-Connect will be the Party collecting and processing a Customer or user’s personal information and as such, is designated as the “Responsible Party” for purposes of this Privacy Policy.
   2. Afrihost Home-Connect may instruct third party “Operators” from time to time to undertake certain processing activities related to the Customer or user’s personal information.

2. 2. Definition of personal information

   1. According to the Act ‘‘personal information’’ means information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person. Further to the POPI Act, Afrihost Home-Connect also includes the following items as personal information:
      1. All addresses including residential, postal and email addresses.
      2. Change of name – for which we require copies of the marriage certificate or official change of name document issued by the state department.

3. 3. The information we collect

   1. We collect and process your personal information mainly to contact you for the purposes of understanding your requirements, registering your account, and delivering Services accordingly. For this purpose we will collect contact details including your name, date of birth, physical address, account and financial information, email address, contact number and organisation or company details. We further collect emails, messages, and notes and recordings of calls the Customer or user makes to Afrihost Home-Connect.
   2. We collect information directly from you where you provide us with your personal details. Where possible, we will inform you of the information you are required to provide to us and what information is optional.
   3. If the Customer or user does not agree to supply any personal information that is required for Afrihost Home-Connect to render its Services, certain consequences may flow from such a refusal, such as preventing Afrihost Home-Connect from concluding or performing any contract with the Customer or user, or preventing Afrihost Home-Connect from complying with one or more of its obligations in law. Certain laws require or authorise Afrihost Home-Connect to collect personal information, including RICA, FICA and directives issued under these laws.
   4. Website usage information may be collected using “cookies” which allows us to collect standard internet visitor usage information.

4. 4. Consent

   1. By using the Afrihost Home-Connect website, you hereby consent to our Privacy Policy and agree to its terms.

5. 5. How we use your information

   1. We will use your personal information only for the purposes for which it was collected and agreed with you. In addition, where necessary your information may be retained for legal or research purposes. For example:
      1. To gather contact information;
      2. To confirm and verify your identity or to verify that you are an authorised user for security purposes;
      3. To protect the legitimate interests of a Customer or user (unless the Customer or user has validly objected in writing to all or some of the processing activities on reasonable grounds);
      4. For the detection and prevention of fraud, crime, money laundering or other malpractice;
      5. For Afrihost Home-Connect to pursue its own legitimate interests or the legitimate interests of a third party who it is sharing the information with, unless the Customer or user has validly objected in writing to all or some of the processing activities on reasonable grounds;
      6. To conduct market or customer satisfaction research or for statistical analysis;
      7. To customise and display content to the Customer or user in a way that Afrihost Home- Connect feels may interest the Customer or user or be most beneficial to them;
      8. To send content including, but not limited to products, articles, listings and advertisement content to the Customer via email or other electronic media, where the user has consented to be contacted by Afrihost Home-Connect;
      9. To process personal information for direct marketing purposes;
      10. For audit and record keeping purposes;
      11. To enable the Customer or user to voluntarily participate in interactive features;
      12. To improve, personalise, and expand the Afrihost Home-Connect website, App or Portal;
      13. To notify the Customer or user about changes to the Afrihost Home-Connect website, App, Portal or Services;
      14. To understand and analyse how you use the Afrihost Home-Connect website, App or Portal;
      15. To develop new products, Services, features and functionalities; and/or
      16. In connection with legal proceedings.
   2. If Afrihost Home-Connect intends to process a Customer or user’s personal information for any other purpose not listed above, or which is not automatically permitted by law, it shall ensure that it obtains the Customer or user’s written consent to do so.

6. 6. Disclosure of information

   1. We may disclose your personal information to our service providers who are involved in the delivery of products or services to you. We have agreements in place to ensure that they comply with the privacy requirements as required by the Protection of Personal Information Act.
   2. We may also disclose your information:
      1. Where we have a duty or a right to disclose in terms of law or industry codes;
      2. Where we believe it is necessary to protect our rights.
   3. You consent to Afrihost Home-Connect sharing your personal information with the following operators:
      1. Partners or agents involved delivering the products and Services to the Customer or user.
      2. Partners or agents that conduct network performance, client satisfaction surveys and any other surveys related to the products or Services provided to the Customer or user.
      3. Law enforcement agencies, regulatory organisations, courts or other public authorities if Afrihost Home-Connect is mandated to do so or if authorised by law.
   4. Afrihost Home-Connect will release information if it’s reasonable for the purpose of protecting against fraud, defending its rights or property, or to protect the interests of its customers or users.
   5. If Afrihost Home-Connect is reorganised or sold to another organisation, it may transfer any personal information it holds about the Customer or user to that organisation.
   6. Afrihost Home-Connect may also share aggregated information about Customers or users of this website and their usage patterns. Such aggregated information will be de-identified and the Customer’s or user’s personal information will not be disclosed.

7. 7. Further processing

   1. Afrihost Home-Connect shall not process a Customer or user’s personal information for any purpose not previously specified except in the following circumstances:
      1. Where the Customer or user has consented to such further processing;
      2. Where the further processing is necessary for the exercise of any contractual rights or the fulfilment of any obligations between Afrihost Home-Connect and the Customer or user;
      3. Where further processing activities are linked to or compatible with the original purpose;
      4. Where the further processing is necessary for the prevention, detection, investigation, prosecution and punishment of an offence;
      5. Where the further processing is necessary to enforce any law;
      6. Where the further processing is necessary for the conduct of legal proceedings in any court or tribunal that has commenced or is reasonably contemplated;
      7. Where the further processing is necessary to prevent or mitigate a serious and imminent threat to the life or health of the Customer or user or another individual; and/or
      8. Where the further processing is necessary for historical, statistical or research purposes.
   2. Afrihost Home-Connect shall ensure that if it intends processing personal information for other purposes not previously specified, it shall notify the Customer or user of such further purposes and the possible consequences of the intended further processing for the Customer or user.
8. Call Recordings
   1. All our calls are recorded for quality and training purposes, these recordings remain the property of Afrihost Home-Connect.

9. 9. Information Security

   1. We are legally obliged to provide adequate protection for the personal information we hold and to stop unauthorized access and use of personal information. We will, on an on-going basis, continue to review our security controls and related processes to ensure that your personal information remains secure.
   2. Our security policies and procedures cover:
      1. Physical security;
      2. Computer and network security;
      3. Access to personal information;
      4. Secure communications;
      5. Security in contracting out activities or functions;
      6. Retention and disposal of information;
      7. Acceptable usage of personal information;
      8. Governance and regulatory issues;
      9. Monitoring access and usage of private information; and
      10. Investigating and reacting to security incidents.
   3. When we contract with 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.
   4. 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.
   5. If personal information about a Customer or user is inadvertently leaked or Afrihost Home- Connect’s security has been unlawfully breached by an unauthorised party, Afrihost Home- Connect shall immediately identify the relevant Customers and/or users who may be affected by the security breach, and shall contact them at their last known email address or contact details or by the quickest means possible. In this regard, Afrihost Home-Connect shall provide sufficient information to the Customer or user to allow him or her to take the necessary protective measures against the potential consequences of the compromise, or shall advise Customers and/or users of the steps to be taken by them and the possible consequences for them that may ensure from the breach.

10. 10. Log Files

    1. Afrihost Home-Connect follows a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this and a part of hosting services’ analytics. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analysing trends, administering the site, tracking users’ movement on the website, and gathering demographic information.

11. 11. Cookies and Web Beacons

    1. Like any other website, Afrihost Home-Connect uses ‘cookies’. These cookies are used to store information including visitors’ preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimize the users’ experience by customizing our web page content based on visitors’ browser type and/or other information.
    2. Afrihost Home-Connect may use cookies on its website to:
       1. distinguish one user from another on the website;
       2. remember the user’s last session when they return to the website;
       3. estimate the website’s audience size and usage patterns;
       4. store information about a user’s preferences, which allows Afrihost Home-Connect to customize the website and content according to the user’s individual preferences; and
       5. speed up functionalities on the website.
    3. The provisions of this clause are only applicable to cookies used by Afrihost Home-Connect. In some instances, third party service providers may use cookies. Afrihost Home-Connect cannot and does not control or access cookies used by third party service providers and takes no responsibility therefore.
    4. The user has the right and ability to either accept or decline the use of cookies on their computer’s web browser, whether they are logged in as a member, or simply casually visiting the website. However, declining the use of cookies may limit a user’s access to certain features on the website.
    5. For more general information on cookies, please read “What Are Cookies”.

12. 12. Google DoubleClick DART Cookie

    1. Google is a third-party vendor on our site. It also uses cookies, known as DART cookies, to serve ads to our site visitors based upon their visit to www.home-connect.co.za and other sites on the internet. However, visitors may choose to decline the use of DART cookies by visiting the Google ad and content network Privacy Policy at the following URL: – https://policies.google.com/technologies/ads

13. 13. Our Advertising Partners

    1. Some of advertisers on our site may use cookies and web beacons. Our advertising partners are listed below. Each of our advertising partners has their own Privacy Policy for their policies on user data. For easier access, we hyperlinked to their Privacy Policies below.
       1. Google https://policies.google.com/technologies/ads
       2. Facebook https://web.facebook.com/policies/ads/?_rdc=1&_rdr

14. 14. Advertising Partners Privacy Policies

    1. You may consult this list to find the Privacy Policy for each of the advertising partners of Afrihost Home-Connect.
    2. Third-party ad servers or ad networks uses technologies like cookies, JavaScript, or Web Beacons that are used in their respective advertisements and links that appear on Afrihost Home-Connect, which are sent directly to users’ browser. They automatically receive the Customer’s or user’s IP address when this occurs. These technologies are used to measure the effectiveness of their advertising campaigns and/or to personalize the advertising content that you see on websites that you visit.
    3. Note that Afrihost Home-Connect has no access to or control over these cookies that are used by third-party advertisers.

15. 15. Third Party Privacy Policies

    1. Afrihost Home-Connect’s Privacy Policy does not apply to other advertisers or websites. Thus, we advise you to consult the respective Privacy Policies of these third-party ad servers for more detailed information. It may include their practices and instructions about how to opt-out of certain options.
    2. You can choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers’ respective websites.

16. 16. Cross border transfers of personal information

    1. The Customer or user consents that personal information (including special personal information) may be transferred transborder, even to countries without data protection laws similar to those of South Africa, for storage purposes, or if it is in Afrihost Home-Connect’s legitimate interests or those of a third party to do so.

17. 17. CCPA Privacy Rights (Do Not Sell My Personal Information)

    1. Under the California Consumer Privacy Act (CCPA), among other rights, California consumers have the right to:
       1. Request that a business that collects a consumer’s personal data disclose the categories and specific pieces of personal data that a business has collected about consumers.
       2. Request that a business delete any personal data about the consumer that a business has collected.
       3. Request that a business that sells a consumer’s personal data, not sell the consumer’s personal data.
    2. If you make a request, we have 1 (one) month to respond to you. If you would like to exercise any of these rights, please contact us.

18. 18. GDPR Data Protection Rights

    1. We would like to make sure you are fully aware of all of your data protection rights where applicable. Every user is entitled to the following:
       1. The right to access – You have the right to request copies of your personal data. We may charge you a small fee for this service.
       2. The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.
       3. The right to erasure – You have the right to request that we erase your personal data, under certain conditions.
       4. The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
       5. The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.
       6. The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
    2. If you make a request, we have 1 (one) month to respond to you. If you would like to exercise any of these rights, please contact us.

19. 19. Children’s Information

    1. Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.
    2. Afrihost Home-Connect does not knowingly collect any Personal Identifiable Information from children under the age of 13 (thirteen). If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.

20. 20. Your Rights: Access to information

    1. Customers or users have the right to request a copy of the personal information that Afrihost Home-Connect holds about them. To do this, simply contact Afrihost Home-Connect at the numbers/addresses as provided on our website and please specify what information you require. We will need a copy of your ID document to confirm your identity before providing details of your personal information.
    2. Please note that any such access request may be subject to a payment of a legally allowable fee.

21. 21. Correction of your information

    1. Afrihost Home-Connect shall take reasonably practicable steps to ensure that the personal information kept by it about Customers and users is complete, accurate, not misleading and is updated when necessary.
    2. Customers or users have the right to ask Afrihost Home-Connect to update, correct or delete their personal information. We will require a copy of your ID document to confirm the Customer’s or user’s identity before making changes to the relevant personal information we may hold. We would appreciate it if you would keep your personal information accurate.
    3. Afrihost Home-Connect reserves its right to only adhere to a request from a Customer or user in terms of clause 21.2 above, if the correction or updating of that information will result in the personal information being correct and accurate.

22. 22. Lodging an objection

    1. The Customer or user may, on reasonable grounds, object to the processing of their personal information at any time after that processing has started.
    2. If a Customer or user wishes to object to the processing of their personal information, they should contact Afrihost Home-Connect’s information officer in writing and provide reasons for doing so.
    3. The Customer or user acknowledges that clause 3.3 shall apply in the event of a Customer or user lodging an objection in terms of this clause 22.

23. 23. Retention of information

    1. The Customer or user consents that Afrihost may keep record of his/her personal information for an indefinite period of time, unless the Customer or user objects. In such cases, Afrihost Home-Connect will only keep such records if it is lawfully entitled or obliged to do so.

24. 24. Returning, destroying or deleting personal information

    1. Where Afrihost Home-Connect is no longer authorised to retain a record of any personal information, it shall either:
       1. Ensure that the information is permanently destroyed or deleted as soon as reasonably practicable; or
       2. Return the information to the Customer or user or transfer it to a third party, if requested by the Customer or user in writing to do so.

25. 25. Choice of law

    1. This privacy policy shall be governed and interpreted in accordance with the laws of the Republic of South Africa.

26. 26. Amendment of this privacy policy

    1. Afrihost Home-Connect reserves the right to change, update, add, remove, and/or amend any of the provisions of this Privacy Policy from time to time. Such changes, updates, additions, removals or amendments will become effective from the date of their publication on this website.
    2. It is the Customer or user’s obligation to periodically check the provisions of this Privacy Policy for any such changes, updates, additions, removals or amendments.
    3. The Customer’s or user’s continued use of this website following any changes, updates, additions, removals or amendments to this Privacy Policy will be considered as the Customer’s or user’s acceptance to abide by and be bound by this Privacy Policy, as amended.

27. 27. How to contact us

    1. If you have any queries about this notice; you need further information about our privacy practices; wish to withdraw consent; exercise preferences or access or correct your personal information, please contact us at the numbers/addresses listed on our website.
    2. At Afrihost Home-Connect, accessible from https://www.home-connect.co.za, one of our main priorities is the privacy of our visitors. This Privacy Policy document contains types of information that is collected and recorded by Afrihost Home-Connect and how we use it.
    3. If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us.
    4. This Privacy Policy applies only to our online activities and is valid for visitors to our website with regards to the information that they shared and/or collect in Afrihost Home-Connect. This policy is not applicable to any information collected offline or via channels other than this website.
    5. Customers or users shall have the right to lodge a complaint with the Information Regulator (https://inforegulator.org.za/) should there be a breach of this Privacy Policy.