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 Muslim
Broadcasting Corporation t/a The Voice of the Cape. 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.
2.11 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 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:Â
|
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 Muslim Broadcasting Corporation t/a The Voice of the
Cape.
14.2. We are
registered in South Africa under registration number, and our registered office
is at 2 Queens Park Ave, Salt River, Cape Town, South Africa.
14.3. Our
principal place of business is at 2 Queens Park Ave, Salt River, Cape Town,
South Africa.
14.4. You can contact
us:
14.4.1.
via the app;
14.4.2.
by email, using rustumg@vocfm.co.za;
14.4.3.
by post, to  2 Queens Park Ave, Salt River, Cape Town,
South Africa
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