Privacy policy
1. Introduction
1.1. We are committed to safeguarding the privacy of our mobile application/s
users.
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 Waterberg Stereo. For more information about us, see
Section 14.
2. The personal data 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 mobile application/s user account information
("account information"). The account information may
include your account identifier, [name, email address], account creation
and modification dates, mobile application/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 mobile
application/s.
2.4. We may process your information included in your personal profile
on our mobile application/s ("profile information"). The
profile information may include [your name, address, telephone number,
email address]profile pictures,[gender, date of birth,
relationship status, interests and hobbies, educational details and employment
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 mobile application/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 mobile application/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 mobile
application/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. Please do not supply any other person's personal information to us, unless we prompt you to do so.
2.9. 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.
�
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.
2.10. Any form of media (Images/Videos/Audio/Files) shared on the
application/website are shared at your own discretion and made public where in
the context to do so, such as public conversation channels. We reserve the
right to remove any content deemed as inappropriate.
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 mobile application/s and
providing our services. The legal basis for this processing is our legitimate
interests, namely the proper administration of our mobile application/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 mobile application/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 mobile application and
service users, the maintenance of relationships, and the proper administration
of our mobile application/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 mobile application/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
mobile application/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 mobile application/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 mobile application/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 mobile application/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 mobile application/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. The hosting facilities for our mobile application/s are situated
in South Africa, Netherlands, Ireland, United States.Transfers
to each of these countries will be protected by appropriate safeguards.
5.3. You acknowledge that personal information that you submit forpublication through our mobile application/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 mobile application/sincludes 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 mobile application/s and services aretargeted
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 mobile application/s, we use the following third-party services which may
collect personal information:
|
Recipient |
Purpose of processing |
Lawful basis |
Data location and security |
Personal data collected by the third party |
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 with a pop up
screen to accept the policy.
14. Our details
14.1. This mobile
application is owned and operated by Bushveld t/a.
14.2. We are
registered in South Africa under registration number 2006/028610/08, and
our registered office is at Shop No. 3, Corner of Van der Bijl and Judith
Street, Thabazimbi, Limpopo.
14.3. Our principal
place of business is at Shop No. 3, Corner of Van der Bijl and Judith
Street, Thabazimbi, Limpopo
14.4. You can
contact us:
14.4.1. by post, to Shop No. 3, Corner of Van der Bijl and Judith Street,
Thabazimbi, Limpopo
14.4.2. by email, using kobus@waterbergstereo.co.za
15. You can also
complain to the Information Regulator if you are unhappy with how we have used
your Information. Their contact details are as follows:
The
Information Regulator (South Africa)
33 Hoofd Street
Forum III, 3rd
Floor Braampark
P.O Box 31533
Braamfontein,
Johannesburg, 2017
Complaints
email: complaints.IR@justice.gov.za