Privacy Policy

Introduction

We are committed to safeguarding the privacy of our website visitors and service users.

This policy applies where we act as a data controller concerning the personal data of our website visitors and service users; in other words, where we determine the purposes and means of processing that personal data.

By using our website and agreeing to this policy, you consent to our use of cookies by the terms of this policy.

In this policy, “we,” “us,” and “our” refer to Siyavaya Limited. For more information about us, see Section 11.

Credit

This document was created using a template from SEQ Legal (https://seqlegal.com).

How we use your data

In this Section 3, we have set out:

  • the general categories of personal data that we may process;
  • in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
  • the purposes for which we may process personal data; and
  • the legal bases of the processing.

 

We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type, version, operating system, referral source, length of visit, page views, and website navigation paths, as well as information about your timing, frequency, and pattern service use. The source of the usage data is Google Analytics. This usage data may be processed to analyse the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

We may process your data provided in the course of our services (“service data”). The service data may include your name, email address, telephone number, and company name.  The source of the service data is you or your employer. The service data may be processed to operate our website, provide our services, ensure the security of our website and services, maintaining back-ups of our databases, and communicate with you. The legal basis for this processing is our legitimate interests, namely the performance of a contract between you and us and taking steps, at your request, to enter into such a contract.

We may process information in any inquiry regarding goods and services (“inquiry data”). The inquiry data may be processed to offer, market, and sell relevant goods and services to you.  The legal basis for this processing is our legitimate interests.

We may process information relating to transactions, including purchases of goods and services, that you enter into with us and through our website (“transaction data”). The transaction data may include your contact details, card details, and transaction details. The transaction data may be processed to supply the purchased goods and services and keep proper records. The legal basis for this processing is the performance of a contract between you and us and taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

We may process the information you provide to us to subscribe to our email notifications and newsletters (“notification data”). The notification data may be processed to send relevant messages and newsletters. The legal basis for this processing is consent.

We may process information relating to any communication you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications using the website contact forms. The correspondence data may be processed to communicate with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

We may process any of your data identified in this policy where necessary for establishing, exercising, or defending legal claims, whether in court proceedings or 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, our legal rights, and the legal rights of others.

We may process any of your data identified in this policy where necessary for obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

In addition to the specific purposes for which we may process your data set out in this Section 3, we may also process any of your data where such processing is necessary for compliance with a legal obligation to which we are subject or to protect your vital interests or the vital interests of another natural person.

Please do not supply any other person’s data to us unless we prompt you to do so.

4. Providing your data to others

We may disclose your data 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.

We may disclose your data to our insurers and professional advisers insofar as reasonably necessary for obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise, or defense of legal claims, whether in court proceedings or an administrative or out-of-court procedure.

Financial transactions relating to our website and services may be handled by our payment services provider, Sage Pay. We will share transaction data with our payment services providers only to the extent necessary for processing your payments, refunding such fees, and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at  https://www.sage.com/en-za/legal/privacy-and-cookies/

In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your data where such disclosure is necessary for compliance with a legal obligation to which we are subject or to protect your vital interests of another natural person. We may also disclose your data where such disclosure is necessary for establishing, exercising, or defending legal claims, whether in court proceedings or an administrative or out-of-court procedure.

We use MailChimp as our email marketing platform. By submitting data through any form on this website, you acknowledge that the information you provide will be transferred to MailChimp for processing by their Privacy Policy and Terms.

This website uses Google Analytics to collect anonymous information, such as the number of visitors to the site and the most popular pages.

Retaining and deleting personal data

This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations regarding the retention and deletion of personal data.

Personal data we process for any purpose or purposes shall not be kept longer than is necessary for that purpose or those purposes.

We will retain your data as follows:

  • Usage data will be retained for a minimum period of 12 months following submission and an indefinite period following the request.
  • Service data will be retained for a minimum of 12 months following submission and an indefinite period following the request.
  • Enquiry data will be retained for 12 months following submission and an indefinite period following the request.
  • Transaction data will be retained for a minimum period of 12 months following submission and an indefinite period following the request.ng submission.
  • Notification data will be retained for as long as you remain subscribed to notifications.
  • Correspondence data will be retained for a minimum period of 12 months following submission and an indefinite period following the request.

 

5.4 In some cases, it is not possible for us to specify in advance the periods for which your data will be retained. In such cases, we will determine the period of retention based on the following criteria:

  • the period of retention of all personal data will be determined based on business needs.

 

Notwithstanding the other provisions of this Section 6, we may retain your data where such retention is necessary for compliance with a legal obligation to which we are subject or to protect your vital interests or the vital interests of another natural person.

Amendments

We may update this policy from time to time by publishing a new version on our website.

You should check this page occasionally to ensure you are happy with any changes to this policy.

Your rights

You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to the following:

  • the payment of a fee (currently fixed at GBP 10), and
  • the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

 

We may withhold personal information you request to the extent permitted by law.

You may instruct us at any time not to process your personal information for marketing purposes.

In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of using your data for marketing purposes.

About cookies

A cookie is a file containing an identifier (a string of letters and numbers) sent by a web server to a web browser and stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user. Still, personal information we store about you may be linked to the information stored in and obtained from cookies.

Cookies used by our service providers

Our service providers use cookies, which may be stored on your computer when you visit our website.

We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use using cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.

Google Analytics will store the following cookie data as detailed below:

Cookie NameExpiration TimeDescription
_gaTwo yearsUsed to distinguish users.
_gid24 hours_gid 24 hours Used to distinguish users.
_gat1 minuteThey are used to throttle request rates. If Google Analytics is deployed via Google Tag Manager, this cookie will be named _dc_gtm_.
AMP_TOKEN30 seconds to 1 yearIt contains a token that can be used to retrieve a Client ID from the AMP Client ID service. Other possible values indicate opt-out, inflight request, or an error retrieving a Client ID from the AMP Client ID service.
_gac_90 daysContains campaign-related information for the user. If you have linked your Google Analytics and AdWords accounts, AdWords website conversion tags will read this cookie unless you opt out.

Managing cookies

Most browsers allow you to refuse to accept and delete cookies. The methods for doing so vary from browser to browser and from version to version. You can, however, obtain up-to-date information about blocking and deleting cookies via these links:

 

Blocking all cookies will have a negative impact on the usability of many websites.

If you block cookies, you cannot use all the features on our website.