Protection of Personal Information Act
POLICY DOCUMENT
1
COLLECTION OF INFORMATION
1.1
As part of your interactions with Endor Technology (Pty) Ltd t/a aCoin (“aCoin”), aCoin collects various data from you, both by you providing it directly, and automatically from, amongst other things, browsing aCoin’s website. This Policy Document explains how aCoin collects your data and what it can and cannot do with such information.
1.2
Personal information
1.2.1
Personal information includes:
1.2.1.1
certain information that aCoin collects automatically when you visit our website;
1.2.1.2
certain information collected on registration (see below);
1.2.1.3
certain information collected on submission; and
1.2.1.4
optional information that you provide to aCoin voluntarily (see below);
but excludes:
1.2.1.5
information that has been made anonymous so that it does not identify a specific person;
1.2.1.6
permanently de-identified information that does not relate or cannot be traced back to you specifically;
1.2.1.7
non-personal statistical information collected and compiled by aCoin; and
1.2.1.8
information that you have provided voluntarily in an open, public environment or forum including any blog, chat room, community, classifieds, or discussion board (because the information has been disclosed in a public forum, it is no longer confidential and does not constitute personal information subject to protection under this policy).
1.2.2
Sensitive personal information
Depending on the services required, aCoin may also collect sensitive personal information including your:
1.2.2.1
financial information – such as your bank account details;
1.2.2.2
biometric information – such as images of your face or fingerprints; and
1.2.2.3
historical conduct – such as payment defaults and credit bureau listings.
1.3
From Browsers
aCoin automatically receives and records internet usage information on its server
logs from your browser, such as your Internet Protocol address (IP address),
browsing habits, click patterns, version of software installed, system type, screen
resolutions, colour capabilities, plug-ins, language settings, cookie preferences,
search engine keywords, JavaScript enablement, the content and pages that you
access on the website, and the dates and times that you visit the website, paths
taken, and time spent on sites and pages within the website (usage information).
Please note that other websites visited before entering aCoin’s website might place
personal information within your URL during a visit to it, and aCoin has no control
over such websites. Accordingly, a subsequent website that collects URL information
may log some personal information.
1.4
Cookies
1.4.1
aCoin may place small text files called ’cookies’ on your device when you visit its website. These files do not contain personal information, but they do contain a personal identifier allowing aCoin to associate your personal information with a certain device. These files serve a number of useful purposes for you, including:
1.4.1.1
granting you access to age restricted content;
1.4.1.2
tailoring aCoin website’s functionality to you personally by allowing your preferences to be remembered;
1.4.1.3
improving how aCoin’s website performs;
1.4.1.4
allowing third parties to provide services to aCoin’s website; and
1.4.1.5
helping aCoin deliver targeted advertising where appropriate in compliance with the applicable laws.
1.4.2
Your internet browser generally accepts cookies automatically, but you can often change this setting to stop accepting them. You can also delete cookies manually. However, no longer accepting cookies or deleting them will prevent you from accessing certain aspects of aCoin’s website where cookies are necessary.
1.5
Third Party Cookies
Some of aCoin’s business partners use their own cookies or widgets. aCoin has no
access to or control over them. Information collected by any of those cookies or
widgets is governed by the privacy policy of the company that created it, and not by
aCoin.
1.6
Optional Details
You may also provide additional information to aCoin on a voluntary basis (optional
information). This includes content or products that you decide to upload or download
from aCoin’s website or when you respond to surveys (if and/or when applicable),
order certain additional services, or otherwise use the optional features and
functionality of aCoin’s website.
1.7
Purpose of Collection
1.7.1
aCoin may use or process any services information, or optional information that you provide to it for the purposes that you indicated when you agreed to provide it to aCoin, including information provided to aCoin following the conclusion of a service level agreement in terms of which aCoin shall be rendering services to you/your company/organisation. Processing includes gathering your personal information, disclosing it, and combining it with other personal information. aCoin generally collects and processes your personal information for various purposes, including:
1.7.1.1
services purposes – such as requests for and providing our services;
1.7.1.2
marketing purposes – such as pursuing lawful related marketing activities;
1.7.1.3
business purposes – such as internal audit, accounting, business planning, and joint ventures, disposals of business, other proposed and actual transactions as well the selling of personal information to third-parties in order to enable offerings of related products and services; and
1.7.1.4
legal purposes – such as handling claims, complying with regulations, or pursuing good governance.
1.7.2
aCoin may use your usage information for the purposes described above and to:
1.7.2.1
remember your information so that you will not have to re-enter it during your visit or the next time you access aCoin’s website;
1.7.2.2
monitor website usage metrics such as total number of visitors and pages accessed; and
1.7.2.3
track your entries, submissions, and status in any promotions or other activities in connection with your usage of the website.
1.8
Consent to Collection
1.8.1
aCoin will obtain your consent to collect personal information:
1.8.1.1
in accordance with applicable law;
1.8.1.2
when you provide aCoin with any registration information or optional information voluntarily.
1.8.2
To the extent that you object to aCoin processing your personal information, you can request that aCoin no longer process your personal information by completing Form 1 of the regulations relating to the Protection of Personal Information Act 4 of 2013 (as amended) and submitting your form to aCoin via email, alternatively by accessing your account online (if applicable), emailing aCoin or notifying aCoin of your objection.
2
USE
aCoin may use your personal information to fulfil aCoin’s obligations and to provide
services to you.
3
DISCLOSURE
3.1
Sharing
aCoin may share your personal information with:
3.1.1
other divisions or companies within the group of companies to which aCoin belongs 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 its policies, and to guide decisions about its products, services, and communications (such divisions or companies will only use this information to send you marketing communications if you have requested their services);
3.1.2
an affiliate, in which case aCoin will seek to require the affiliates to honour this privacy policy, and which affiliates will include entities which provide products and services relating to the services which aCoin provides;
3.1.3
aCoin service providers under contract who help provide certain services or help with parts of aCoin’s business operations, including fraud prevention, bill collection, marketing, technology services (aCoin’s contracts dictate that these service providers only use your information in connection with the services they supply or services they perform for aCoin and not for their own benefit);
3.1.4
credit bureaus to report account information, as permitted by law;
3.1.5
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
3.1.6
other third parties who provide aCoin with relevant services where appropriate.
3.2
Regulators
aCoin may disclose your personal information as required by law or governmental
audit.
3.3
Law enforcement
aCoin may disclose personal information if required:
3.3.1
by a subpoena or court order;
3.3.2
to comply with any law;
3.3.3
to protect the safety of any individual or the general public; and
3.3.4
to prevent violation of our customer relationship terms.
3.4
No selling
aCoin will not sell personal information for purposes other than those related to the
services which aCoin provides. No personal information will be disclosed to any
person, save for any third-party with whom aCoin contracts for the purposes of
providing products and/or services related to the services provided by aCoin, as
contemplated in this policy. aCoin will only disclose personal information collected by
aCoin during the ordinary course of its business and any third-party will provide
similar products and services in the ordinary course of its business, which products
and services are closely related.
3.5
Marketing purposes
aCoin may disclose aggregate statistics (information about the customer population
in general terms) about the personal information to advertisers or business partners.
3.6
Employees
aCoin will need to disclose personal information to its employees that require the
personal information to do their jobs. These may include aCoin’s responsible
management, human resources, accounting, audit, compliance, information
technology, or other personnel.
3.7
Change of ownership
If aCoin undergoes a change in ownership, or a merger with, acquisition by, or sale
of assets to, another entity, aCoin may assign its rights to the personal information it
processes to a successor, purchaser, or separate entity. aCoin will disclose the
transfer on its website. If you are concerned about your personal information
migrating to a new owner, you may request aCoin to delete your personal information.
4
SECURITY
4.1
Protocols
aCoin adheres to strict security protocols in respect of data protection laws. aCoin’s
website and servers are hosted in a secure server environment that uses a firewall in
addition to other advanced security measures aimed to prevent any interference or
access from unwarranted outside third parties.
4.2
Access
Access to any personal information is only authorised for employees who require
such information in order to fulfil their employment responsibilities.
5
ACCURACY OF INFORMATION
5.1
aCoin aims to ensure that all personal information collected is accurate, complete and up to date as is necessary for the purposes defined in this policy. In order to maintain accurate information, aCoin may request that you update your information on our website.
5.2
Updating Information
You are able to review and update any personal information that may be held by
aCoin by accessing your account online (if applicable), emailing aCoin, alternatively
by completing Form 2 of the regulations relating to the Protection of Personal
Information Act 4 of 2013 (as amended) and submitting the completed form to aCoin
via email. The identity of any person wishing to update any information is required to
be verified prior to the granting of any access to the respective person’s account or
making any changes to any personal information.
6
RETENTION OF INFORMATION
6.1
Period of Retention
aCoin will retain personal information for as long as it deems it necessary to do so in
order to perform services in the ordinary course of its business, and for as long as
retention of the record is required or authorised by law.
6.2
Obligations
During the period of retention, aCoin will continue to abide by all its obligations
stipulated in this policy.
6.3
aCoin reserves the right to retain information in physical or electronic records at its discretion.
7
TRANSFER OF INFORMATION
aCoin undertakes not to transfer any personal information across any country border
without prior written consent.
8
LIMITATION
8.1
Liability
aCoin is not responsible for, gives no warranties and makes no representations
whatsoever in respect of any privacy policy and/or practice belonging to linked or
third-party websites.
9
ENQUIRIES
If you have any questions or concerns arising from this privacy policy or the way in which
we handle personal information, please contact us.
Last updated: 13.01.2022