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 responsibility
party 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 GagasiFM.
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.
·
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.
2.11. Any form of media (Images/Video/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 inappropriate content.
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 Radio
iGagasi 99.5 (PTY) LTD.
14.2. We are registered in South
Africa under registration number 1997/006698/07, and our registered
office is at U128 Cornubia Mall, Flanders & Tacoma Drive,
Blackburn Estate, MOUNT EDGECOMBE.
14.3. Our principal place of
business is at U128 Cornubia Mall, Flanders
& Tacoma Drive, Blackburn Estate, MOUNT EDGECOMBE.
14.4. You can contact us:
14.4.1.
via the app;
14.4.2.
by email, using info@gagasiworld.co.za;
14.4.3.
by post, to U128
Cornubia Mall, Flanders & Tacoma Drive, Blackburn Estate, MOUNT EDGECOMBE,
4319.
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