PRIVACY POLICY
Effective: November 9, 2021
Table of Contents
1. INTRODUCTION
1.1 BrightBroom (Pty) Ltd ("BB, we, us, our") is sensitive to the personal nature of the information you provide to us.
1.2 This privacy policy ("this Policy") explains how we protect and use your Personal Information.
1.3 By providing us with your Personal Information, you –
1.3.1 Agree to this Policy and authorise us to process such information as set out herein; and
1.3.2 Authorise us, our Service Providers and other third parties to Process your Personal Information for the purposes stated in this Policy.
1.4 We will not use your Personal Information for any other purpose than that set out in this Policy and will endeavour to protect your Personal Information that is in our possession from unauthorised alteration, loss, disclosure or access.
1.5 Please note that we may review and update this Policy from time to time. The latest version of this Policy is available on request, alternatively may be downloaded from our Website.
1.6 This Policy applies to all external parties with whom we interact, including but not limited to individual clients / tenants, representatives of client organisations, visitors to our offices, and other users of our services ("you"). Defined terms used in this Policy are explained in Annexure A.
2. COLLECTION OF PERSONAL INFORMATION
3. CATEGORIES OF PERSONAL INFORMATION
4. SENSITIVE PERSONAL INFORMATION
5. PURPOSES OF PROCESSING AND BASES FOR PROCESSING
6. DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES
7. INTERNATIONAL TRANSFER OF PERSONAL INFORMATION
8. DATA SECURITY
9. DATA ACCURACY
10. DATA MINIMISATION
11. DATA RETENTION
12. YOUR LEGAL RIGHTS
14. ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
15. DIRECT MARKETING
16. CONTACT DETAILS
ANNEXURE A - DEFINITIONS
1. "Associates" means the shareholders, the directors, employees and consultants of BB.
2. "Cookie" means a small file that is placed on your device when you visit a website. In this Policy, a reference to a "Cookie" includes analogous technologies such as web beacons and clear Graphic Interchange Format files ("GIFs").
3. "Operator" means any person or entity that Processes Personal Information on behalf of the Responsible Party.
4. "Personal Information" means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
5. "POPIA" means the Protection of Personal Information Act 4 of 2013.
6. "Process", "Processing" or "Processed" means anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
7. "Responsible Party" means the entity that decides how and why Personal Information is Processed.
8. "Sensitive Personal Information" means Personal Information about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that may be deemed to be sensitive under applicable law.
9. "Service Provider" – third party providers of various services whom we engage, including, but not limited to, providers of information technology, communication, file storage, data storage, copying, printing, accounting or auditing services, attorneys, debt collectors, counsel, experts, investigators, translators, taxation consultants, our insurers and professional advisors.
10. "Website" means any website operated, or maintained, by us or on our behalf.
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