ALL CUSTOMERS WHO HAVE SUBSCRIBED TO THE SERVICES WE OFFER and ALL VISITORS TO OUR WEBSITE
Effective: November 2020
1. DEFINITIONS AND INTERPRETATION
1.1 In this Policy:
(a) “Device” means any computer used to access the Services and/or the Website, including a desktop, laptop, mobile phone, tablet, or any other electronic device;
(b) “Personal Information” has the meaning assigned thereto in POPI;
(c) “POPI” means the Protection of Personal Information Act, No 4 of 2013, and the regulations published thereunder (as amended);
(e) “Coligo”, “we” or “us” means Coligo Group, registration number 2020/670963/07;
(f) “Services” means any and all services we offer, including software-based communication, logging and visitor management systems, call centre, call recording, custom development, hosted PBX, IP PBX, and voice]; and
(g) “Website” means the Coligo website found a https://www.Coligo.co.za/.
1.2 Headings are for convenience and reference only and shall not be used in the interpretation of this Policy.
1.3 Words importing any gender include the other genders, the singular includes the plural (and vice versa) and natural persons include artificial or juristic persons (corporate and unincorporated) (and vice versa).
1.4 The rule of construction that if general words or terms are used in association with specific words or terms which are a species of a particular genus or class, the meaning of the general words or terms shall be restricted to that same class (ie the eiusdem generis rule) shall not apply, and whenever the word “including” is used followed by specific examples, such examples shall not be interpreted so as to limit the meaning of any word or term to the same genus or class as the examples given.
2.1 Coligo provides Services to its customers and operates the Website. As such, this Policy applies to all customers who subscribe to our Services and all visitors to our Website.
2.2 We respect your privacy, subscribe to the principles set out in POPI, and are committed to taking the necessary steps and implementing the necessary procedures to ensure that your Personal Information is protected.
2.3 As such, the purpose of this Policy is to inform you of the way we may collect, store and use your Personal Information, and protect same.
We have taken appropriate, reasonable technical and organisational measures to prevent loss of, damage to or unauthorised destruction of Personal Information, and unlawful access to or processing of Personal.
2.4 Information, but we nonetheless caution that no method of electronic storage or transmission over the internet can be said to be 100% secure. As such, while we will take all reasonable steps to protect your Personal Information, we cannot guarantee its absolute security.
3. ACCEPTANCE OF POLICY
3.1 You must read this Policy before subscribing to our Services or browsing our Website.
3.2 Should you not accept and agree to the terms of this Policy, you may not use our Services and/or our Website, and must immediately cease using same, as your continued use of our Services and/or Website will be deemed to indicate that you have read, accepted and agreed to the terms of this Policy.
4. CHANGES TO POLICY
4.1 We may amend and/or replace this Policy from time to time.
4.2 We will notify you of any amendments to, or replacement of, this Policy by email or by placing a prominent notice on our Website prior to any such amendments or replacement becoming effective, and we will update the “effective date” at the top of this Policy accordingly.
4.3 By continuing to use the Services and/or the Website after having been notified of amendments to, or replacement of, this Policy, and after the new “effective date”, you will be deemed to have read, accepted and agreed to the revised terms of this Policy or the new Policy, as the case may be.
5.1 Subject to the terms of this Policy, we will obtain your consent to collect Personal Information:
(a) in accordance with POPI; and
(b) at the time you provide us with any registration information for purposes of our Services and/or the Website.
5.2 By using the Services and/or the Website, you consent to the collection, transfer, processing, storage, disclosure and other uses described in this Policy on the terms and conditions set out herein.
6. HOW WE COLLECT AND STORE INFORMATION
INFORMATION PROVIDED BY YOU
6.1 When you register to use any Service, or on our Website, you may be required to provide us with certain Personal Information, including your name and surname, company name, company registration number, VAT number, company statistics, contact details (including physical, postal, and email addresses), and a unique username and password.
6.2 We store your Personal Information using certain third-party CRM programs, including Agile CRM.
6.4 We may use a combination of “persistent cookies” and “session cookies”: “persistent cookies” are used to save your unique username and password for future use of our Services or visits to our Website, whereas “session cookies” may be used to enable certain features of the Service and/or Website, to better understand how you interact with the Service and/or the Website, and to monitor usage and web traffic routing on the Service and/or the Website.
6.5 Permanent cookies remain on your Device after you close your browser (but can be removed manually), whereas session cookies disappear after you close your browser.
6.6 You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting cookies from the websites you visit. However, if you do not accept cookies, you may not be able to use all aspects of the Service and/or the Website.
6.7 We may collect information on how the Service and/or Website is accessed and used (“Usage Data”). Usage Data may include information such as your Device’s Internet Protocol address (IP address), browser type, browser version, web pages you visited before you accessed the Service and/or the Website, the pages of our Website that you visit, the date and time of your visit to our Website, the time spent on the different pages of our Website, and other interactions with the Service.
6.8 We may use third-party service providers such as Google Analytics to analyse and monitor the use of our Website. We also use Agile CRM, Freshdesk ticketing and other service provider that may collect analytics data.
6.9 Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to monitor and track the use of our Website. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.
6.11 For more information on Google’s privacy practices, please visit the Google Privacy and Terms web page: https://policies.google.com/privacy?hl=en.
7. HOW WE USE PERSONAL INFORMATION
7.1 In the course of using our Services and/or Website, we may collect Personal Information that can be used to contact or identify you.
7.2 Personal Information may be used:
(a) to provide and improve our Services and/or the Website;
(b) to administer your use of our Services and/or the Website;
(c) to better understand your interests and needs;
(d) to personalise and improve your experience; and
(e) to provide or offer software updates and product announcements.
7.3 Should you not wish to receive communications from us, you may unsubscribe at any time by following the instructions provided in the relevant communications, or by contacting us in any manner contemplated in paragraph 14 below.
7.4 Analytics data, such as that referred to above (see Analytics Data), may similarly be used for the above purposes, and to analyse and monitor use of our Website, and to increase the Website’s functionality and/or user-friendliness.
8. DISCLOSURE AND SHARING OF INFORMATION
8.1 We may disclose your Personal Information if we are required to do so:
(a) in terms of any applicable law, including POPI;
(b) by a court of competent jurisdiction;
(c) by a governmental or regulatory authority or body;
(d) in order to protect the safety and security of any person or the general public; and
(e) to defend or protect our property and/or rights.
8.2 We may share your Personal Information with our holding companies and/or subsidiaries.
8.3 We may use certain trusted third-party companies and individuals to help us provide, analyse, and improve our Services and/or Website (including data storage, maintenance services, database management, web analytics, payment processing, and improvement of features). These third parties may have access to your Personal Information only to perform these tasks on our behalf, and are obligated not to disclose, share or use your Personal Information for any other purpose.
DISTRIBUTORS, SUPPLIERS AND VENDORS
8.4 In instances where we on-sell, re-sell or sub-license licences, products and/or software which we procure from third-party distributors, suppliers and vendors, we may be required to share certain of your Personal Information with such distributors, suppliers and vendors.
8.5 We may disclose your Personal Information to those of our employees that require same to do their jobs.
ACQUISITION, MERGER OR SALE
8.6 If we are the subject of an acquisition or a merger, or if we sell our assets or business to another entity, we may assign our rights to your Personal Information to the relevant purchaser or successor. We will disclose the transfer on the website.
8.7 If you are concerned about your Personal Information migrating to a new owner, you may request us to delete or destroy your Personal Information.
DE-IDENTIFIED OR NON-PERSONAL INFORMATION
8.8 We may disclose de-identified (as contemplated in POPI), non-personal or non-private information.
PROHIBITION ON SALE OF PERSONAL INFORMATION
8.9 We will not sell any Personal Information to any person and will only disclose and/or share same as provided in this Policy.
9. CORRECTION, DESTRUCTION OR DELETION OF PERSONAL INFORMATION
9.1 You may request the correction, destruction or deletion of your Personal Information in accordance with section 24 of POPI.
9.2 We will action your request as soon as reasonably practicable and will notify you of the action taken as a result of your request, as required by section 24(4) of POPI.
10. UPDATE OF PERSONAL INFORMATION
10.1 We may from time to time ask you to update your Personal Information stored by us so that we can ensure that such information is accurate, complete and up-to-date.
10.2 In order to protect you and safeguard your Personal Information, we will take reasonable steps to verify your identity before making any corrections to your Personal Information.
11. SECURITY OF PERSONAL INFORMATION
11.1 We protect your Personal Information using secure socket layer technology and firewalls.
11.2 We authorise access to your Personal Information only for those employees, service providers and suppliers who require it to fulfil their job responsibilities or obligations to us.
11.3 We follow generally accepted standards to protect the information submitted to us, both during transmission and upon receipt. We nonetheless caution that no method of electronic storage or transmission over the internet can be said to be 100% secure. As such, while we will take all reasonable steps to protect your Personal Information, we cannot guarantee its absolute security.
11.4 If you have any questions about the security of our Services and/or Website, please do not hesitate to contact us in any manner contemplated in paragraph 14 below.
12. RETENTION OF PERSONAL INFORMATION
12.1 We will only retain your Personal Information for as long as your account (whether for our Services or our Website) is active or if necessary, to fulfill the purposes mentioned in paragraph 7.2, unless:
(a) you have consented to us retaining your Personal Information for a longer period; or
(b) we are required, whether by law or a governmental or regulatory authority or body to retain same; or
(c) we are required to retain same in order to enforce our agreements and/or resolve any disputes.
12.2 You may request the destruction or deletion of your Personal Information in accordance with section 24 of POPI, and we will action your request as soon as reasonably practicable and notify you of the action taken as a result of your request, as required by section 24(4) of POPI.
13. TRANSFER OF PERSONAL INFORMATION
13.1 We will not transfer any of your Personal Information across the border of South Africa otherwise than in compliance with section 72 of POPI.
13.2 If you are located outside South Africa and choose to provide Personal Information to us, please note that we will transfer such Personal Information to South Africa and will process same there.
14.1 This Policy is subject to, and shall be construed and interpreted in accordance with, POPI.
14.2 To the extent that any of our Services or our Website contain links to other services or sites that are not operated by us, we caution that we have no control over, and assume no liability or responsibility for the content, privacy policies or practices of any such third-party services or sites.
15. CONTACT US
15.1 If you have any questions or concerns arising from this policy or the way in which we handle Personal Information, please do not hesitate to contact us.
15.2 You may contact us:
(a) by email to firstname.lastname@example.org;
(b) by telephone at 011 700 3800; or
(c) by visiting this page on our Website: www.coligo.co.za