“Privacy Policy”

RESPO TECHNOLOGY PROPRIETARY LIMITED T/A RESPO (REGISTRATION NUMBER: 2018/359585/07)

(“RESPO”, “Us”, “We” “Our”)

IMPORTANT – PLEASE READ THESE TERMS CAREFULLY WHEN USING OR ACCESSING OUR WEBSITE AND/OR SOFTWARE-AS-A-SERVICE OFFERING (“RESPO SERVICES”).

 (Version 1.0 – Effective as of 11/11/2019)

1. INTRODUCTION
   • We respect your privacy and take the protection of personal information very seriously. The purpose of this policy is to describe the way we collect, store, use, and protect information that can be associated with a specific natural or juristic person and can be used to identify that person.
   • Please read this policy carefully before accessing any RESPO Services.
2. EFFECTIVE DATE
   • You agree that this policy will apply and be effective when you access or use our website and or any RESPO Services found at RESPO.CO.ZA
3. BROWSER TERMS AND COMMERCIAL TERMS
   • There are other terms that are applicable to your use of our Website and RESPO Services. Browser Terms can be found at https://respo.co.za/browserterms/ on our Website. Commercial Terms become applicable when you purchase and access products and services through our Website and Mobile Application found at https://respo.co.za/commercialterms/
4. ACCEPTANCE AND CONSENT
   • You accept all the terms in this policy when you use our Website or Mobile Application and/or access RESPO Services and consent to us collecting the personal information as referred to in this policy.
5. AMENDMENTS TO THIS POLICY
   • We may amend and/or amplify the terms of this policy from time to time in line with any changes that the law or our internal business operations require, without prior notice. It is your responsibility to consider the policy each time you use our website or access any RESPO Service. If you do not agree with any terms of this policy, you must stop using our website and or RESPO Services immediately.
6. PRIVACY LAWS AND PROTECTING YOUR PERSONAL INFORMATION
   • We will take the necessary steps to protect your privacy when you use our website, including compliance with the Protection of Personal Information Act, 4 of 2013 (“POPI”), General Data Protection Regulations (GDPR) and all reasonable steps to be in compliance with the privacy laws of users outside of the EU and South Africa.
   • we have listed your rights that you have under data protection laws.
     • the right to access – you can ask for copies of your personal data;
     • the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
     • the right to erasure – you can ask us to erase your personal data;
     • the right to restrict processing – you can ask use to restrict the processing of your personal data;
     • the right to object to processing – you can object to the processing of your personal data;
     • the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
     • the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
     • the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
   • These rights are subject to certain limitations and exceptions.
   • General Data Protection Regulation (GDPR) – You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
7.  WHAT IS PERSONAL INFORMATION?
   • If we refer to “personal information” or “information” in this policy, we mean personal information as defined in POPI. It includes, for example, your full name, surname, email address, identity number, contact details, and location.
8. INFORMATION COLLECTION
   • We collect information about you when you use our website, access and use RESPO Services and communicate with us. We may also collect information about you from third parties.
   • Our service is not directed to children under sixteen and does not knowingly collect personally identifiable information from children under the age of sixteen. If you are under the age of sixteen, you must ask your parent or guardian for permission to use this website. If we learn that we have collected personal information of a child under sixteen, we will take the appropriate steps to delete such information from our files as soon as possible. If you learn that a child has provided us with personal information in violation of this policy, you can alert us at support@respo.co.za
9. USE OF COOKIES
   • We sometimes use “cookies”. “Cookies” are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive.
   • They enable us to improve interactivity with the web site. The purpose of “cookies” is to enhance your future visits to our Website. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use all of our RESPO Services. Cookies enable us to improve our service to you, estimate our audience size and usage patterns, store information about your preferences and recognise when you return to our website. In some instances, we collect and store information about your location. We convert your IP address or mobile GPS data into a rough geo-location.
   • Please note that third parties who advertise on our website may also use cookies, but we do not have access to, or control over them, and therefore cannot take responsibility for them.
   • We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website.
10. USE OF YOUR INFORMATION
    • We use your information to provide our website and services to you and generally for purposes of our relationship.
    • We will not sell personal information, unless such information has been appropriately anonymised ensuring all identifying fields have been securely masked and encrypted. No personalised individual data will be disclosed to anyone except as provided in this privacy policy.
11. INFORMATION THAT WE STORE AND USE
    • We generally store and use the following information:
      • your first name(s);
      • surname;
      • address;
      • phone numbers;
      • email address;
      • IP address;
      • cookie information;
      • location information;
      • demographic information;
      • including your age and gender;
      • information regarding emergency;
      • health information submitted via the RESPO Application; and
      • next of kin and beneficiary details
      • and any other information which we reasonably need to perform our obligations in terms of the agreement with you when you purchase or use our services.

12. PURPOSES FOR PROCESSING INFORMATION
    • We will only process adequate and relevant information to:
      • Perform in terms of our agreement;
      • Operate and manage your account;
      • Monitor and analyse our business;
      • Carry out market research, business and statistical analysis; and
      • Comply with our regulatory or other obligations.

13. SHARING OF PERSONAL INFORMATION
    • We will keep your personal information confidential and only share it with others in terms of this policy, if you consent to it, or if the law requires from us to share it.
    • We have trusted relationships with carefully selected third parties who perform services for us. All these service providers have a contract with us in terms whereof they have a legal obligation to secure your personal information and to use it only in a way that we permit. In general, we may share your information with our affiliates, third party service providers, payment gateways, regulatory and governmental authorities or tax authorities (if they request us to do so), and any other third party if the law requires from us to share it.
    • Our website may connect to various social media sites or apps, including Facebook, Twitter, LinkedIn, Instagram and Google+. If you want to use our website for social media integration, including to create user profiles and login functionality, we will share your information with the relevant social media sites or apps.
    • We may transmit or transfer personal information outside South Africa to a foreign country.
    • Across the EU, we will endeavour to ensure compliance with the General Data Protection Regulation (GDPR) and should you believe we are in contravention of the GDPR, you may contact our privacy officer at info@respo.co.za and we will ensure we revert within 48 hours of your correspondence.
14. RETENTION OF INFORMATION
    • We will aim to keep the personal information we collect as accurate, complete and up to date as is necessary for the purposes in this policy. From time to time we will request you to update your personal information on the website.
    • We will only retain your personal information for as long as it is necessary to fulfil the purposes explicitly set out in this policy, unless retention of the record is required or authorised by law; or you have consented to the retention of the record.
15. CONCERNS AND SECURITY BREACH
    • We will report any security breach to the Information Regulator in South Africa, and the GDPR regulatory body (if applicable) and to the individuals or companies involved. If you want to report any concerns about our privacy practices or if you suspect any breach regarding your information, kindly notify us by sending an email info@respo.co.za