Privacy Policy
Latest Update: 19 June 2021
1. Introduction
The document below details our privacy policy. We are HUMPHREY AND ASSOCIATES CC. (Registration number: 1998/064198/23) and this is our plan of action when it comes to protecting your privacy. We have the utmost respect for your privacy and take the protection of your personal information very seriously. This policy describes the way that we collect, store, use, and protect information that can be associated with you or another specific natural or juristic person and can be used to identify you or that person.
2. Audience
This policy applies to you if you are:
- a customer who has ordered or requested the goods or services that we provide
- a supplier that we order or request goods or services from
3. Personal Information
Personal information includes:
- applicable information collected on registration/on boarding
- optional information that you provide to us voluntarily
but excludes:
- information that has been made anonymous so that it does not disclose personal information of any sort
- information that you have provided voluntarily in an open, public environment or forum
- non-personal statistical information collected and compiled by us; and
- permanently de-identified information that cannot be traced back to you specifically
4. Common Examples
Common examples of the types of personal information which we may collect, and process include your:
- address information – such as your physical or postal address; or
- contact information – such as your phone number or email address;
- demographic information – such as your gender or marital status.
- identifying information – such as your name, date of birth, or identification number of any kind
- company information – such as registration numbers, director details, billing information etc.
5. Sensitive Personal Information
Depending on the goods or services that you require, we may also collect sensitive personal information including your:
- beliefs – including your political or religious beliefs
- criminal information – such as information about your commission/alleged commission of any offences/ legalities
- employment information – including your membership of a trade union
- financial information – such as your bank account details
- sensitive demographic information – such as your race or ethnicity
- sexual information – such as information about your sex life or sexual orientation
6. Acceptance
6.1.1 You must accept all the terms of this policy when you order our goods or request our services. If you do not agree with anything in this policy, then you may not order our goods or request our services.
7. Legal Capacity
7.1 You may not access our website or order our goods or request our services if you are younger than 18 years old or do not have legal capacity to conclude legally binding contracts.
8. Deemed Acceptance
8.1 By accepting this policy, you are deemed to have read, understood, accepted, and agreed to be bound by all of its terms.
9. Your Obligations
9.2 We accept no responsibility for information you have obtained from a data subject/third party that you have shared with us and did not get consent to do so.
10. Changes
10.1 We may change the terms of this policy at any time by updating this web page. We will notify you of any changes by placing a notice in a prominent place on the website, updating the date on this policy document or by sending you an email detailing the changes that we have made and indicating the date that they were last updated. If you do not agree with the changes, then you must stop using the website and our goods or services. If you continue to use the website or our goods or services following notification of a change to the terms, the changed terms will apply to you, and you will be deemed to have accepted these updated terms.
11. Collection of Data
11.1.1 Once you on board with us as a new client you will no longer be anonymous to us. You will provide us with certain personal information when you register for our services. This personal information will include:
- your name and surname;
- your email address;
- your telephone number;
- your company name, company registration number, and VAT number;
- your postal address or street address; and
- applicable usernames and passwords needed for us to assist you
11.1.2 We will use this personal information to fulfill your account, provide additional services and information to you as we reasonably think appropriate, and for any other purposes set out in this policy.
12. Optional Details
12.1 You may also provide additional information to us on a voluntary basis (optional information). This includes content or products that you decide to upload or download from our website or when you enter competitions, take advantage of promotions, respond to surveys, order certain additional goods or services, or otherwise use the optional features and functionality of our website and/or services.
13. Purpose of Collection
13.2 Processing includes gathering your personal information, disclosing it, and combining it with other personal information. We generally collect and process your personal information for various purposes, including:
13.3 goods or services purposes – such as collecting orders or requests for and providing our goods or services; marketing purposes – such as pursuing lawful related marketing activities; business purposes – such as internal audit, accounting, business planning, and joint ventures, disposals of business, or other proposed and actual transactions; and legal purposes – such as handling claims, complying with regulations, or pursuing good governance. We may use your usage information for the purposes described above and to: remember your information so that you will not have to re-enter it during your visit or the next time you access the website; monitor website usage metrics such as total number of visitors and pages accessed; and track your entries, submissions, and status in any promotions or other activities in connection with your usage of the website.
14. Consent to Collection
14.1 We will obtain your consent to collect personal information: in accordance with applicable law; when you provide us with any registration information or optional information.
15. Use
15.1.1 We may use your personal information to fulfill our obligations to you.
16. Messages and Updates
16.1 We may send administrative messages and email updates to you about the website. In some cases, we may also send you primarily promotional messages. You can choose to opt-out of promotional messages.
17. Disclosure
17.1.1 We may share your personal information with: other divisions or companies within the group of companies to which we belong so as to provide joint content and services like registration, for transactions and customer support, to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about our products, services, and communications (they will only use this information to send you marketing communications if you have requested their goods or services); an affiliate, in which case we will seek to require the affiliates to honour this privacy policy; our goods or services providers under contract who help provide certain goods or services or help with parts of our business operations, including fraud prevention, bill collection, marketing, technology services (our contracts dictate that these goods or services providers only use your information in connection with the goods or services they supply or services they perform for us and not for their own benefit); credit bureaus to report account information, as permitted by law; banking partners as required by credit card association rules for inclusion on their list of terminated merchants (in the event that you utilise the services to receive payments and you meet their criteria); and other third parties who provide us with relevant services where appropriate.
18. Regulators
18.1 We may disclose your personal information as required by law or for the purposes of a governmental audit.
19. Law Enforcement
19.1 We may disclose personal information if required: by a subpoena or court order; to comply with any law; to protect the safety of any individual or the general public; and to prevent violation of our customer relationship terms.
20. No Selling
20.1 We will not sell personal information. No personal information will be disclosed to anyone except as provided in this privacy policy.
21. Employees
21.1 We may need to disclose personal information to our employees that require the personal information to do their jobs. These include our responsible management, human resources, accounting, audit, compliance, information technology, or other personnel.
22. Change of Ownership
22.1 If we undergo a change in ownership, or a merger with, acquisition by, or sale of assets to, another entity, we may assign our rights to the personal information we process to a successor, purchaser, or separate entity. We will disclose the transfer on the website. If you are concerned about your personal information migrating to a new owner, you may request us to delete your personal information.
23. Security
23.1 We take the security of personal information very seriously and always do our best to comply with applicable data protection laws. Our hosting company will host our website in a secure server environment that uses a firewall and other advanced security measures to prevent interference or access from outside intruders. We authorize access to personal information only for those employees who require it to fulfil their job responsibilities. We implement disaster recovery procedures where appropriate.
24. Accurate and Up to Date
24.1 We will try to keep the personal information we collect as accurate, complete, and up to date as is necessary for the purposes defined in this policy. From time to time, we may request you to update your personal information. You are able to review or update any personal information that we hold by emailing us or phoning us. Please note that in order to better protect you and safeguard your personal information, we take steps to verify your identity before granting you access to your account or making any corrections to your personal information.
25. Retention
25.1 We will only retain your personal information for as long as it is necessary to fulfill 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. During the period of retention, we will continue to abide by our non-disclosure obligations and will not share or sell your personal information. We may retain your personal information in physical or electronic records at our discretion.
26. Updating or Removing
26.1 You may choose to correct or update the personal information you have submitted to us, by contacting us by phone or email.
27. Limitation
27.1 We are not responsible for, give no warranties, nor make any representations in respect of the privacy policies or practices of linked or any third-party websites, suppliers, ISPs etc.
28. Enquiries
28.1 If you have any questions or concerns arising from this privacy policy or the way in which we handle personal information, please contact us by sending an email to informationofficer@humanda.co.za.
© 2021 Humphrey and Associates CC. All rights reserved. | Privacy Policy
