1.
Introduction
1.1.
We are committed to safeguarding the privacy
of the users of our App/s.
1.2.
This policy applies where we are acting as a
data controller with respect to the personal information of such persons; in
other words, where we determine the purposes and means of the processing of
that personal information.
1.3. In this
policy, "we", "us" and "our" refer to Izwi loMzansi Radio
Station Association NPC. For more information about us, see Section 14.
2.
The personal information that we collect
2.1.
In this Section 2 we have set out the general
categories of personal information that we process.
2.2.
We may process information enabling us to get
in touch with you ("contact information"). The contact
information may include your name, email address and telephone number. The
source of the contact information is you.
2.3.
We may process your App/s user account
information ("account information"). The account information
may include your account identifier, name, email address, account creation and
modification dates, App/s settings and marketing preferences. The primary
source of the account information is you, although some elements of the account
information may be generated by our App/s.
2.4.
We may process your information included in
your personal profile on our App/s ("profile information").
The profile information may include your name, address, telephone number, email
address, profile pictures, gender, date of birth, location, employment details,
income, languages, relationship status, interests and hobbies, educational
details. The source of the profile information is you.
2.5.
We may process your personal information that
are provided in the course of the use of our services and generated by our
services in the course of such use ("service information").
The source of the service information is you and/or our services.
2.6.
We may process information contained in or
relating to any communication that you send to us or that we send to you
("communication information"). The communication information
may include the communication content and metadata associated with the
communication. Our App/s and will generate the metadata associated with
communications made using the contact options.
2.7.
We may process information about your use of
our App/s, and services ("usage information"). The usage
information may include your IP address, geographical location, browser type
and version, operating system, referral source, length of visit, page views and
App/s navigation paths, as well as information about the timing, frequency and
pattern of your service use. The source of the usage information is our
analytics tracking system.
2.8. Automatically Collected Information - Location. We collect and use precise location information from your device with your permission when you choose to use location-related features, like when you decide to share your location. There are certain settings relating to location-related information which you can find in your device settings or the in-app settings, such as location sharing. Even if you do not use our location-related features, we use IP addresses and other information like phone number area codes to estimate your general location (e.g., city and country). We also use your location information for diagnostics and troubleshooting purposes.
2.9. Please do not supply any other person's personal information to us, unless we prompt you to do so.
2.10. The following user information is collected and stored securely in our systems for as long as you are a member.
· First Name and Surname: This is stored
and referenced to enable personalized communication between ourselves and you
as the user. Provision is made for a username which is editable by you, that is
used in the Messages section of the app as your profile identification.
· Email: This is stored and referenced to enable a
backup means of communication between ourselves and you as the user. It is also
a security measure for ensuring recovery of an account if your cellular number
changes or is lost.
· Address: This is stored and referenced to ensure that
you are a valid member of the app community and are reachable via respective
security companies in the event of a reported matter.
· Phone Number: This is stored and
referenced as the primary means of registering and logging in to the app. This
is the main method of identification and security via OTP delivery and is
required.
· Gender: This field is stored and referenced to allow
personalized communication or offers and is an optional field.
· Profile image: The option to upload a
profile image is available should you elect to. This image will display with
your username on conversation channels.
3. Purposes of processing and legal bases
3.1.
In this Section 3, we have set out the
purposes for which we may process personal information and the legal bases of
the processing.
3.2.
Operations - We may process your
personal information for the purposes of operating our App/s and providing our
services. The legal basis for this processing is our legitimate interests,
namely the proper administration of our App/s, services and business.
3.3.
Publications - We
may process account information, profile information and/or service information
for the purposes of publishing such information on our App/s and elsewhere
through our services in accordance with your express instructions. The legal
basis for this processing is our legitimate interests, namely the publication
of content in the ordinary course of our operations.
3.4.
Relationships and communications - We
may process contact information, account information and/or communication
information for the purposes of managing our relationships, communicating with
you (excluding communicating for the purposes of direct marketing) by push
notification, email, SMS, post, fax and/or telephone, providing support
services and complaint handling. The legal basis for this processing is our
legitimate interests, namely communications with our App and service users, the
maintenance of relationships, and the proper administration of our App/s
services and business.
3.5.
Personalisation - We
may process account information, service information and/or usage information
for the purposes of personalising the content and
advertisements that you see on our App/s and through our services to ensure
that you only see material that is relevant to you. The legal basis for this
processing is our legitimate interests, namely offering the best possible
experience for our App/s users and service users.
3.6.
Direct marketing - We
may process contact information, account information and profile information
for the purposes of creating, targeting and sending direct marketing
communications by email, SMS, post and/or fax and making contact by telephone
for marketing-related purposes. The legal basis for this processing is our
legitimate interests, namely promoting our business and communicating marketing
messages and offers to our App/s users and service users.
3.7.
Research and analysis - We
may process usage information and/or service information for the purposes of
researching and analysing the use of our App/s and
services, as well as researching and analysing other
interactions with our business. The legal basis for this processing is our
legitimate interests, namely monitoring, supporting, improving and securing our
App/s, services and business generally.
3.8.
Record keeping - We
may process your personal information for the purposes of creating and
maintaining our databases, back-up copies of our databases and our business
records generally. The legal basis for this processing is our legitimate
interests, namely ensuring that we have access to all the information we need
to properly and efficiently run our business in accordance with this policy.
3.9.
Security - We may process your
personal information for the purposes of security and the prevention of fraud
and other criminal activity. The legal basis of this processing is our
legitimate interests, namely the protection of our App/s, services and
business, and the protection of others.
3.10.
Insurance and risk management - We
may process your personal information where necessary for the purposes of
obtaining or maintaining insurance coverage, managing risks and/or obtaining
professional advice. The legal basis for this processing is our legitimate
interests, namely the proper protection of our business against risks.
3.11.
Legal claims - We
may process your personal information where necessary for the establishment,
exercise or defence of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure. The legal basis
for this processing is our legitimate interests, namely the protection and
assertion of our legal rights, your legal rights and the legal rights of
others.
3.12.
Legal compliance and vital interests - We
may also process your personal information where such processing is necessary
for compliance with a legal obligation to which we are subject or in order to
protect your vital interests or the vital interests of another natural person.
4.
Providing your personal information to others
4.1.
We may disclose your personal information to
any member of our group of companies (this means our subsidiaries, our ultimate
holding company and all its subsidiaries) insofar as reasonably necessary for
the purposes, and on the legal bases, set out in this policy.
4.2.
We may disclose your personal information to
our insurers and/or professional advisers insofar as reasonably necessary for
the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining
professional advice.
4.3.
We may disclose personal information to our
suppliers or subcontractors identified below insofar as reasonably necessary.
We only share information with them that is required for the services offered.
4.4.
In addition to the specific disclosures of
personal information set out in this Section 4, we may disclose your personal
information where such disclosure is necessary for compliance with a legal
obligation to which we are subject, or in order to protect your vital interests
or the vital interests of another natural person. We may also disclose your
personal information where such disclosure is necessary for the establishment,
exercise, or defence of legal claims, whether in
court proceedings or in an administrative or out-of-court procedure.
5.
International transfers of your personal
information
5.1.
In this Section 5, we provide information
about the circumstances in which your personal data may be transferred to
countries outside of South Africa.
5.2.
We and/or our other group companies have
offices and/or facilities in South Africa. Transfers to each of these countries
will be protected by appropriate safeguards.
5.3.
The hosting facilities for our App/s are
situated in South Africa, Netherlands, Ireland, United States. Transfers to
each of these countries will be protected by appropriate safeguards.
5.4.
You acknowledge that personal information
that you submit for publication through our App/s may be
available, via the internet, around the world. We cannot prevent the use (or
misuse) of such personal information by others.
6.
Retaining and deleting personal information
6.1.
This Section 6 sets out our data retention
policies and procedures, which are designed to help ensure that we comply with
our legal obligations in relation to the retention and deletion of personal
information.
6.2.
Personal information that we process for any
purpose or purposes shall not be kept for longer than is necessary for that
purpose or those purposes.
6.3.
We will retain your personal information as follows
for a minimum period of 90 days following the date of deletion of the profile
by you, and for a maximum period of 180 days following that date.
6.4.
Notwithstanding the other provisions of this
Section 6, we may retain your personal information where such retention is
necessary for compliance with a legal obligation to which we are subject, or in
order to protect your vital interests or the vital interests of another natural
person.
7.
Your rights
7.1.
In this Section 7, we have listed the rights
that you have under data protection law.
7.2.
Your principal rights under data protection
law are:
7.2.1.
the right to access - you
can ask for copies of your personal information;
7.2.2.
the right to request
correction, deletion or destruction of your personal information;
7.2.3.
the right to object when
the processing is justified by legitimate interests of data subject or of the
responsible party or when the processing is for direct marketing purposes;
7.2.4.
the right to not have personal information
processed for the purpose of direct marketing by means of
unsolicited electronic communications;
7.2.5.
the right to not be subject, under
certain circumstances, to a decision which results in legal circumstances based
solely on the basis of the automated processing;
7.2.6.
the right to complain to the Regulator - you
can complain about our processing of your personal information; and
7.3.
You may exercise any of your rights in
relation to your personal information by written notice to us, using the
contact details set out below.
8.
Third-party websites
8.1.
Our App/s includes hyperlinks to, and details
of, third-party websites.
8.2.
In general, we have no control over, and are
not responsible for, the privacy policies and practices of third parties.
9.
Personal data of children
9.1.
Our App/s and services are targeted at
persons over the age of 18.
9.2.
If we have reason to believe that we hold
personal information of a person under that age in our databases, we will
delete that personal information.
10.
Updating information
10.1.
Please let us know if the personal
information that we hold about you needs to be corrected or updated.
11.
Sub processors
11.1.
We use a select number of trusted external
service providers for certain technical data processing and/or service
offerings. These service providers are carefully selected and meet high data
protection and security standards. We only share information with them that is
required for the services offered.
11.2. We use
the following sub processors to process the information collected by us:
|
Sub
Processor |
Data
Location |
Service |
|
immedia Studio |
Netherlands,
Ireland, United States Worldwide |
Infrastructure
for servers and databases and logs. Data analytics platform for data
engineering, data science, machine learning, and analytics Secure
CDN (Content Delivery Network) to store and deliver JavaScript files. |
12.
Third-party services we use
12.1. When
you use our App/s, we use the following third-party services which may collect
personal information:
|
Third Party (Recipient) |
Purpose of processing |
Lawful basis |
Data location and security |
Personal data collected |
Privacy policy |
|
To collect and analyse
information about how you interact with our websites, apps, hosted services
(analytics) |
Legitimate interest |
Frankfurt, Germany |
Anonymised IP address, Pages visited, browser and
device used, mouse movements, anonymised key
strokes, and more. |
||
|
SendGrid (by Twilio) |
Transactional and marketing emails |
Legitimate interest |
United States |
Mobile numbers and email address |
|
|
Clickatell |
Two-way SMS messaging |
Legitimate interest |
United States, South Africa |
Mobile numbers |
|
|
Google Console App Store Firebase |
Mobile application analytics, databases,
messaging and crash reporting |
Legitimate interest |
United States |
Device ID, Device Manufacturer, Device
Operating System, Device Information, Country associated to Device, App
versions and app update date etc. , App Crashes information, Device Operator |
|
|
Visual Studio App Center |
Building, testing, releasing, and
monitoring mobile and desktop apps |
Legitimate interest |
United States |
|
|
|
Apple (AppStoreConnect) |
MobileApp Analytics on iOS devices |
Legitimate interest |
United States |
Account information, Device information,
contact information, transaction information, fraud prevention information,
usage data, location information. |
13.
Amendments
13.1.
We may update this policy from time to time
by publishing a new version on our website.
13.2.
You should check this page occasionally to
ensure you are happy with any changes to this policy.
13.3. We may
notify you of significant changes to this policy by notice within the App.
14.
Our details
14.1. This
App is owned and operated by Izwi loMzansi Radio Station Assciation
NPC.
14.2. We are
registered in South Africa under registration number Reg.no 2000/02 1775/08,
and our registered office is at 65 Masabalala Yengwa Avenue, Suite no.21 Main Concurse,
Durban 4000.
14.3. Our
principal place of business is at 65 Masabalala Yengwa Avenue, Suite no.21 Main Concourse, Durban 4000.
14.4. You can
contact us:
14.4.1. via the app;
14.4.2. by email, using stationmanager@izwi98fm.co.za;
14.4.3. by post, to P.O Box 4667 Durban 4000.
15.
Complaints
You may report to the Information Regulator if you are unhappy with how
we have used your Information. Their contact details are as follows:
Address:
The Information Regulator (South Africa)
33 Hoofd Street
Forum III, 3rd Floor Braampark
P.O Box 31533
Braamfontein, Johannesburg, 2017
Email: complaints.IR@justice.gov.za