Privacy Policy

South Africa

7. Subject Categories of Records

• 7.1. Personnel Records: “Personnel” refers to any person who works for or provides services to or on behalf of Company and receives, or is entitled to receive, remuneration and any other person who assists in carrying out or conducting the business of Company. It includes, without limitation, directors (executive and non-executive), all permanent, temporary and part-time staff, as well as contract workers.
• 7.2. Personal records provided by personnel include:
• 7.2.1. Records provided by a third party relating to Personnel;
• 7.2.2. Conditions of employment and other Personnel-related contractual and quasi-legal records, including job applications;
• 7.2.3. Internal evaluation records and other internal records;
• 7.2.4. Correspondence relating to, or emanating from, Personnel (internal and external to the organization); and
• 7.2.5. Training schedules and material;
• 7.2.6. Payment records (and beneficiary payments), including banking details.
• 7.3. Client Related Records: “Client” refers to any natural or juristic entity that receives services from Company.
• 7.4. Client related records include:
• 7.4.1. Records provided by a client to a third party acting for or on behalf of Company;
• 7.4.2. Records provided by a third party (for example, records from a reseller);
• 7.4.3. Records generated by or within Company relating to its clients;
• 7.4.4. Transactional records;
• 7.4.5. Correspondence with a client that is implicitly or explicitly of a private or confidential nature
• 7.4.6. Records pertaining to a client retrieved from “other sources”, such as any credit bureau or credit providers industry association.
• 7.5. Private Body Records which include but are not limited to records pertaining to Company’s own internal affairs:
• 7.5.1. Financial records;
• 7.5.2. Operational records;
• 7.5.3. Information technology;
• 7.5.4. Communication;
• 7.5.5. Administrative records, such as contracts and service level agreements;
• 7.5.6. Product records;
• 7.5.7. Statutory records;
• 7.5.8. Internal Policies and procedures; and
• 7.5.9. Human resources records.
• 7.6. Other Party Records:
• 7.6.1. Records held by Company pertaining to other parties, including without limitation, financial records, correspondence, contractual records, records provided by the other party (for example third party beneficiaries or employees of a client), and records third parties have provided about Company’s contractors / suppliers.
• 7.6.2. Company may possess records pertaining to other parties including, but not limited to, contractors, suppliers, and service providers and such other parties may possess records that can be said to belong to Company.

8. Processing details

• 8.1. In terms of POPIA, data must be processed for a specified purpose. The purpose for which data are processed by Company will depend on the nature of the data and the particular data subject. This purpose is ordinarily disclosed, explicitly or implicitly, at the time the data are collected.
• 8.2. Purpose of Processing
• 8.2.1. Personnel data
• 8.2.1.1. Company processes personnel data for business administration purposes.  For example, personnel data are processed for payroll purposes.  Personnel data are also processed to the extent required by legislation and regulation.  For example, Company discloses employees’ financial information to the Commissioner for the South African Revenue Service, in terms of the Income Tax Act 58 of 1962 and employee’s sensitive personal information in terms of the Employment Equity Act 55 of 1998.
• 8.2.2. Client related data
• 8.2.2.1. Company processes client related records as an integral party of its commercial services. For example Company processes client related records during the client application and onboarding processes and for provision of a service.
• 8.2.2.2. This list of processing purposes is non-exhaustive.

9. Third party data

• 9.1. Company processes third party records for business administration purposes.

10. Other party data

• 10.1. Company processes “other party” records for business administration purposes.  For example, Personnel data may be processed in order to effect payment to contractors and / or suppliers.
• 10.2. In performing these various tasks, Company may, amongst others, collect, collate, process, store and disclose personal information.

11. Categories of Data Subjects

• 11.1. Employees / Personnel of Company;
• 11.2. Clients of Company;
• 11.3. Any third party with whom Company conducts its business services;
• 11.4. Contractors of Company;
• 11.5. Suppliers of Company;
• 11.6. Service providers of Company.
• This list of categories of data subjects is non-exhaustive.

12. Recipients To Whom Personal Information Will Be Supplied

• 12.1. Depending on the nature of the data, Company may supply information or records to the following categories of recipients:
• 12.1.1. Statutory oversight bodies, regulators or judicial commissions of enquiry making a request for data (i.e. the Information Regulator in terms of POPIA);
• 12.1.2. Any court, administrative or judicial forum, arbitration, statutory commission, or ombudsman making a request for data or discovery in terms of the applicable rules (i.e. the Competition Commission in terms of the Competition Act 89 of 1998);
• 12.1.3. South African Revenue Services, or another similar authority;
• 12.1.4. A contracted third party who requires this information to provide services;
• 12.1.5. Third parties with whom Company has a contractual relationship for the retention of data (for example, a third party hosting services);
• 12.1.6. Research/ academic institutions;
• 12.1.7. Auditing and accounting bodies (internal and external);
• 12.1.8. Anyone making a successful application for access in terms of PAIA.

13. Planned Transborder Flows Of Personal Information

• 13.1. Company may transfer personal information to a third party who is in a foreign country in order to administer certain services, but may only do so subject to the provisions of POPIA.  Thus internal cross-border transfers, as well as external cross-border transfers of information are envisaged, subject to the provisions of POPIA.

14. Security Measures

• 14.1. Company takes extensive information security measures to ensure the confidentiality, integrity and availability of personal information in Company’s possession.  Company takes appropriate technical and organizational measures designed to ensure that personal data remain confidential and secure against unauthorized or unlawful processing and against accidental loss, destruction or damage.

15. Grounds for Refusal of Access to Records

• 15.1. Company may refuse a request for information on the following basis:
• 15.1.1. Mandatory protection of the privacy of a third party who is a natural person, which would involve the unreasonable disclosure of personal information of that natural person;
• 15.1.2. Mandatory protection of the commercial information of a third party, if the record contains:
• 15.1.2.1. Trade secrets of that third party;
• 15.1.2.2. Financial, commercial, scientific or technical information which disclosure could likely cause harm to the financial or commercial interests of that third party; and
• 15.1.2.3. Information disclosed in confidence by a third party to Company, if the disclosure could put that third party at a disadvantage in negotiations or commercial competition.
• 15.1.3. Mandatory protection of confidential information of third parties if it is protected in terms of any agreement or legislation;
• 15.1.4. Mandatory protection of the safety of individuals and the protection of property;
• 15.1.5. Mandatory protection of records which would be regarded as privileged in legal proceedings;
• 15.1.6. The commercial activities of Company, which may include:
• 15.1.6.1. Trade secrets of Company;
• 15.1.6.2. Financial, which, if disclosed, could put Company at a disadvantage in negotiations or commercial competition;
• 15.1.6.3. A computer program which is owned by Company and which is protected by copyright.
• 15.1.7. Requests for information that are clearly frivolous or vexatious, or which involve an unreasonable diversion of resources shall be refused.

16. Access procedure

• 16.1. A requester is any person making a request for access to a record of, or held by, Company. The requester is entitled to request access to information, including information pertaining to third parties, but Company is not obliged to grant such access. Apart from the fact that access to a record can be refused based on the grounds set out in paragraph 15 above, in order to successfully access information the requester must fulfil the prerequisite requirements for access in terms of PAIA, including the payment of a request and access fee.

17. Access Request Procedure

• 17.1. A requester requiring access to information held by Company must complete the prescribed Access Request Form, available here: https://www.justice.gov.za/forms/paia/J752_paia_Form%20C.pdf, submit it to the Information Officer at the physical address or electronic mail address recorded in paragraph 3.5 and pay a request fee (and a deposit, if applicable).
• 17.2. In order to facilitate a timely response to requests for access, all requesters should take note of the following when completing the Access Request Form:
• 17.2.1. The Access Request Form must be comprehensively completed.
• 17.2.2. Proof of identity is required to authenticate the identity of the requester.  Therefore, in addition to the access request form, requesters will be required to supply a copy of their identification document.
• 17.2.3. Every applicable question must be answered. If a question does not apply “N/A” should be stated in response to that question. If there is nothing to disclose in reply to a particular question “Nil” should be stated in response to that question.
• 17.2.4. The Access Request Form must be completed with enough particularity to enable the Information Officer to identify:
• 17.2.4.1. The record(s) requested;
• 17.2.4.2. The identity number of the requester;
• 17.2.4.3. The form of access required if the request is granted;
• 17.2.4.4. The postal address or fax number of the requester.
• 17.3. The requester must also state that he or she requires the information in order to exercise or protect a right, and clearly state the nature of the right to be exercised or protected. In addition, the requester must clearly specify why the record is necessary to exercise or protect such a right.
• 17.4. If a request is made on behalf of another person, then the requester must submit proof of the capacity in which the requester is making the request to the reasonable satisfaction of the Information Officer.
• 17.5. If an individual is unable to complete the prescribed form because of illiteracy or disability, such a person may make the request orally.
• 17.6. The requester will be informed in writing whether access has been granted or denied. If, in addition, the requester requires the reasons for the decision in any other manner, he must state the manner and the particulars so required.

18. Payment Of Fees

• 18.1. Payment details can be obtained from the Information Officer and can be made either via a direct deposit, by bank guaranteed cheque or by postal order. Proof of payment must be supplied when the Access Request Form is submitted.
• 18.2. The prescribed fee is set out below in Annexure 1.
• 18.3. Note that the requester may lodge a complaint to the Information Regulator or an application with a court against the tender or payment of the request fee.
• 18.4. If the search for, and the preparation of, the record for disclosure would, in the opinion of the Information Officer, require more than 6 hours, the requester may be required to pay as a deposit one third of the access fee (the fee which will be payable if the request is granted).
• 18.5. Note that the requester may lodge a complaint to the Information Regulator or an application with a court against the tender or payment of the deposit.
• 18.6. If a deposit has been paid in respect of a request for access which is subsequently refused, then the Information Officer must refund the deposit to the requester.
• 18.7. The requester must pay the prescribed fee before any processing, or any further processing, can take place.

19. Third Party Notification

• 19.1. Company must take all reasonable steps to inform a third party to whom or which a requested record relates if the disclosure of that records would –
• 19.1.1. involve the disclosure of personal information about that third party;
• 19.1.2. involve the disclosure of trade secrets of that third party; financial, commercial, scientific or technical information (other than trade secrets) of that third party, the disclosure of which would be likely to cause harm to the commercial or financial interests of that third party; or information supplied in confidence by a third party, the disclosure of which could reasonably be expected to put that third party at a disadvantage in contractual or other negotiations; or to prejudice that third party in commercial competition;
• 19.1.3. constitute an action for breach of a duty of confidence owed to a third party in terms of an agreement; or
• 19.1.4. involve the disclosure of information about research being, or to be, carried out by or on behalf of a third party, the disclosure of which would be likely to expose the third party, a person that is or will be carrying out the research on behalf of the third party, or the subject matter of the research, to serious disadvantage.
• 19.2. Company will inform the third party as soon as reasonably possible, but in any event, within 21 days after that request is received.
• 19.3. Within 21 days of being informed of the request, the third party may-
• 19.3.1. make written or oral representations to the Information Officer why the request for access should be refused; or
• 19.3.2. give written consent for the disclosure of the record to the requester.
• 19.4. Company will notify the third party of the outcome of the request.  If the request is granted, adequate reasons for granting the request will be given.
• 19.5. The third party may lodge a complaint to the Information Regulator or an application with a court against the decision within 30 days after notice is given, after which the requester will be given access to the record after the expiry of the 30 day period.

20. Notification of Decision

• 20.1. The Information Officer will, within 30 days of receipt of the request, decide whether to grant or decline the request and give notice with reasons (if required) to that effect.
• 20.2. The 30 day period, within which Company has to decide whether to grant or refuse the request, may be extended for a further period of not more than 30 days if the information cannot reasonably be obtained within the original 30 day period. For example, the time period may be extended if the request is for a large amount of information, or the request requires Company to search for information held at another office of Company.
• 20.3. The Information Officer will notify the requester in writing should an extension be required.  The requester may lodge a complaint to the Information Regulator or an application with a court against the extension.

21. Remedies Available for Refusals for a Request for Information

• 21.1. All complaints, by a requester or a third party, can be made to the Information Regulator or a court, in the manner prescribed below.
• 21.2. The requester or third party, as the case may be, may submit a complaint in writing to the Information Regulator, within 180 days of the decision, alleging that the decision was not in compliance with the provisions of PAIA.
• 21.3. The Information Regulator will investigate the complaint and reach a decision – which may include a decision to investigate, to take no further action or to refer the complaint to the Enforcement Committee established in terms of POPIA.  The Information Regulator may serve an enforcement notice confirming, amending or setting aside the impugned decision, which must be accompanied by reasons.
• 21.4. An application to court maybe brought in the ordinary course.  For purposes of PAIA, any reference to an application to court includes an application to a Magistrates’ Court.

ANNEXURE 1: PRESCRIBED FEES

• 1.1. The fee for a copy of the manual as contemplated in regulation 9(2)(c) is R1,10 for every photocopy of an A4-size page or part thereof.
• 1.2. The fees for reproduction referred to in regulation 11(1) are as follows:
• 1.2.1. For every photocopy of an A4-sized page or part thereof: R1,10
• 1.2.2. For every printed copy of an A4-sized page or part thereof held on a computer or in electronic or machine-readable form: R0,75
• 1.2.3. For a copy in a computer-readable form on:
• 1.2.3.1. stiffy disc R7,50
• 1.2.3.2. compact disc R70,00
• 1.2.3.3. For visual images:
• 1.2.3.3.1. a transcription of visual images, for an A4-size page or part thereof  40,00
• 1.2.3.3.2. For a copy of visual images R60,00
• 1.2.3.4. For an audio record:
• 1.2.3.4.1. For a transcription of an audio record, for an A4-size page or part thereof R20,00
• 1.2.3.4.2. For a copy on an audio record R30,00
• 1.3. The request fee payable by a requester, other than a personal requester, referred to in regulation 11(2) is R50,00.
• 1.4. The access fees payable by a requester referred to in regulation 11(3) are as follows:
• 1.4.1. Fees are:
• 1.4.1.1. For every photocopy of an A4-size page or part thereof R1,10
• 1.4.1.2. For every printed copy of an A4-size page or part thereof held on a computer or in electronic or machine-readable form R0,75
• 1.4.1.3. For a copy in a computer-readable form on:
• 1.4.1.3.1. stiffy disc R7,50
• 1.4.1.3.2. compact disc R70,00
• 1.4.1.4. For a transcription of visual images:
• 1.4.1.4.1. for an A4-sized page or part thereof R40,00
• 1.4.1.4.2. For a copy of visual images R60,00
• 1.4.1.5. For a transcription of an audio record:
• 1.4.1.5.1. For an A4-size page or part thereof R20,00
• 1.4.1.5.2. For a copy of an audio record R30,00
• 1.4.1.6. To search for and prepare the record for disclosure, R30,00 for each hour or part of an hour reasonably required for such search and preparation.
• 1.4.2. For purposes of section 54(2) of the Act, the following applies:
• 1.4.2.1.1. Six hours as the hours to be exceeded before a deposit is payable; and
• 1.4.2.1.2. one third of the access fee is payable as a deposit by the requester.
• 1.4.3. The actual postage is payable when a copy of a record must be posted to a requester.
• 1.5. Deposits
• 1.5.1. Where Company receives a request for access to information held on a person other than the requester himself/herself and the Information Officer upon receipt of the request is of the opinion that the preparation of the required record of disclosure will take more than 6 hours, a deposit is payable to the requester. The amount of the deposit is equal to 1/3 of the amount of the applicable access fee.
• Please note: In terms of Regulation 8, Value Added Tax (VAT) must be added to all fees prescribed in terms of the Regulations. Therefore, the fees reflected above are VAT inclusive.

SOUTH AFRICA PRIVACY POLICY

1. Introduction

• 1.1 COMPANY collects, uses and, in some circumstances, shares the personal information of Users in and through this website and during the provision of services to you.
• 1.2 COMPANY respects the rights of Users whose personal information is collected and used by it, including their right to protection against the unlawful collection, retention, sharing and use of such personal information.
• 1.3 The purpose of this Privacy Policy is to provide Users with information about the information processing activities of  COMPANY and the manner in which their rights are protected.
• 1.4 This Privacy Policy shall serve as a blanket notification to Users about  COMPANY’s processing activities which will remain valid for as long as one has an active account with or is using the services of COMPANY, including the browsing of this website. Users will not be notified separately on each occasion that  COMPANY processes the same personal information in the same way over the period.
• 1.5 COMPANY may amend the provisions of this Privacy Policy to comply with any changes in the law, and/or pursuant to any changes to its information processing activities or privacy practices. Such amendments will be published on the website and will become operable from the date of such publication.
• 1.6 This privacy policy, and the interpretation and enforcement thereof, will be governed by the laws of the Republic of South Africa.
• 1.7 The provisions of this Privacy Policy is, as far as possible, be incorporated into any agreement between  COMPANY and Users.

2. Definitions and interpretation

• 2.1 In this Privacy Policy, the following words bear the following meanings:
• 2.1.1 ‘’consent’’ means any voluntary, specific and informed expression of will in terms of which permission is given by or on behalf of a User for the processing of their personal information;
• 2.1.2 ‘‘direct marketing’’ means to approach a data subject, either in person or by mail or electronic communication, for the direct or indirect purpose of promoting or offering to supply any goods or services to the data subject;
• 2.1.3 ‘’information officer’’ means the head of COMPANY from time to time.
• 2.1.4 ‘‘operator’’ means an outside third party who processes personal information for or on behalf of  COMPANY in terms of a contract or mandate;
• 2.1.5 ‘’personal information’’ means any information linked to a User or information that can identify a User, including but not limited to:
• 2.1.5.1 information relating to a User’s gender, nationality, ethnic or social origin age, language;
• 2.1.5.2 a User’s e-mail address, physical address, telephone number, location information or online identifier;
• 2.1.5.3 a User’s financial information including banking details and invoice information;
• 2.1.5.4 a User’s personal opinions, views or preferences;
• 2.1.5.5 correspondence sent by a User which is of a private or confidential nature;
• 2.1.5.6 the User’s special personal information, including without limitation information about a User’s health; and
• 2.1.5.7 the User’s name if it appears with other personal information relating to that User, or if the disclosure of their name on its own would reveal further personal information about that User;
• 2.1.6 ‘’POPIA’’ means the Protection of Personal Information Act of 2013, including any regulations or codes of conduct promulgated under it;
• 2.1.7 ‘’PAIA’’ means the Promotion of Access to Information Act 2 of 2000;
• 2.1.8 ‘’process or processing’’ means, in relation to personal information, any operation or activity or any set of operations, whether or not by automatic means, including:
• 2.1.8.1 the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use of that information;
• 2.1.8.2 dissemination by means of transmission, distribution or making available in any other form; or
• 2.1.8.3 merging, linking, as well as restriction, degradation, erasure or destruction of that information;
• 2.1.9 “special personal information” means the religious or philosophical beliefs, race or ethnic origin, trade union membership, political persuasion, health, sex life or any biometric information of a User; and may include criminal behaviour of a User to the extent such data relates to the alleged commission of the User of an offence or any proceedings in respect of any offence allegedly committed by a User or the disposal of such proceedings
• 2.1.10 “services” means the products and services provided to any User by COMPANY;
• 2.1.11 ‘’User’’ means a visitor or user of this website, or any of the content or services associated with this website or the services offered by the Company; and
• 2.1.12 ‘’the website’’ means the website or any part thereof which is accessible from www.wassermanrugby.wpengine.com.

2.2 Any reference in this Privacy Policy to:

• 2.2.1 the singular includes the plural and vice versa;
• 2.2.2 any one gender includes the other genders, as the case may be;
• 2.2.3 an act, regulation or other law is to the version of that law in force at the effective date of this Policy and includes any amendment or re-enactment made to that law after the effective date of this Policy.

2.3 When calculating any number of days for the purposes of this Policy, the first day must be excluded and the last day of the relevant interval included, unless the last day is not a business day, then the last day will be the next succeeding business day.

2.4 The word “include” means “include without limitation”. Use of the word ‘’include’’ or ‘’in particular’’ is for illustration or emphasis only and where followed by specific examples must not be interpreted as limiting the meaning of the general wording preceding it.

2.5 A requirement that any Policy, request, demand or other communication made in terms of this Privacy Policy must be in writing will be met if it is in the form of a data message as defined in the Electronic Communications and Transactions Act, No. 25 of 2002, and is accessible in a manner usable for subsequent reference, provided that this policy may not be amended as such.

3. Responsible Party

• 3.1 COMPANY will be the party who will be collecting and processing a User’s personal information and as such is designated as the ‘’responsible party’’ for the purposes of this Policy.
• 3.2 COMPANY‘s contact details are as follows:
• 3.2.1 Email address: @esportif.com
• 3.2.2 Website address: www.wassermanrugby.wpengine.com
• 3.3 COMPANY may instruct third party operators from time to time to undertake certain processing activities relating to the User’s personal information.

4. What Personal Information Is Collected

• 4.1 COMPANY may collect the following personal information from the User:
• 4.1.1 Initials, first name, surname;
• 4.1.2 Date of birth;
• 4.1.3 Email address;
• 4.1.4 Age and language preference;
• 4.1.5 Gender and other physical identifiers such as height and weight;
• 4.1.6 Health and fitness information;
• 4.1.7 Sporting experience and information including details about previous teams, team members, coaches, advisors or clubs;
• 4.1.8 Online identifiers such as social media handles;
• 4.1.9 Financial information;
• 4.1.10 Cellphone number;
• 4.1.11 Physical address;
• 4.1.12 Employment details;
• 4.1.13 Family details;
• 4.1.14 Company registration and VAT  number; and
• 4.1.15 Identity or passport number, valid visa and other travel information and nationality.
• 4.2 The supply of personal information by the User to  COMPANY is voluntary and not mandatory. However, if the User refuses to supply any personal information, certain consequences may naturally flow from such a refusal, such as preventing  COMPANY from concluding or performing any contract with the User, or preventing  COMPANY from complying with one or more of its obligations in law.
• 4.3 There is no applicable law which directly requires or authorises COMPANY to collect a User’s personal information.

5. Purpose/s For Collection And Processing Of Personal Information

• 5.1 COMPANY shall only collect a User’s personal information for a specific, explicitly defined and lawful purpose relating to a function or activity of  COMPANY‘s business.
• 5.2 Such purposes may include the following:
• 5.2.1 to enter into a contract with a User;
• 5.2.2 to perform any obligations under a contract with a User;
• 5.2.3 to comply with a legal obligation;
• 5.2.4 to protect a legitimate interest of a User (unless the User has specifically objected in writing to all or some of the processing activities on reasonable grounds);
• 5.2.5 to pursue its own legitimate interests or the legitimate interests of a third party who it is sharing the information with (unless the User has specifically objected in writing to all or some of the processing activities on reasonable grounds);
• 5.2.6 to process personal information for direct marketing purposes (only if the User has opted in to receiving any direct marketing material);
• 5.2.7 to customise and display content to the User in a way that  COMPANY feels may interest the User or be most beneficial to them;
• 5.2.8 to send content including, but not limited to products, articles, listings and advertisement content to the User via email or other electronic media, where the User has consented to be contacted by  COMPANY with such content;
• 5.2.9 to enable the User to voluntarily participate in interactive features;
• 5.2.10 to notify the User about changes to the website or services.
• 5.3 If  COMPANY intends to process a User’s personal information for any other purpose not listed in clause 5.2 or which is otherwise not automatically permitted by law, it shall ensure that it obtains the User’s written consent to do so.
• 5.4 COMPANY will not sell a User’s personal information to any third party without the prior written consent of the User., such consent may be included in a contract you sign with the COMPANY.

6. Collection Directly From User

• 6.1 COMPANY shall, as far as possible, always collect personal information about a User directly from the User, except in the following circumstances:
• 6.1.1 Where personal information is collected from a public record, or from another source if the information has already been made public by the User for example from social media platforms;
• 6.1.2 where the User has given their written consent to  COMPANY to collect their information from another source;
• 6.1.3 where the collection of a User’s personal information from another source will not prejudice any of the User’s legitimate interests;
• 6.1.4 where the collection of personal information from another source is necessary to maintain  COMPANY’s legitimate interests or those of any third party it intends sharing the information with;
• 6.1.5 where the collection of personal information directly from the User would prejudice the purpose for the collection;
• 6.1.6 where the collection of personal information directly from the User is not reasonably practicable in the circumstances.
• 6.2 If  COMPANY collects personal information from a source other than the User, it shall record in writing the details of that source, including the full names and contact details of that source where applicable.
• 6.3 Personal information may be collected from or supplied by the User in any of the following ways:
• 6.3.1 when subscribing to a service;
• 6.3.2 when requesting further services or information from  COMPANY;
• 6.3.3 when entering into an agreement with the COMPANY;
• 6.3.4 when contacting  COMPANY to report a problem with the website or the services or for any other reason;
• 6.3.5 when completing any forms on the website.
• 6.4 The User may visit the website without providing any personal information. However, the website’s servers may still collect technical information regarding the use of the website, which is aggregated for analytical purposes, technical maintenance and for improving the content offered on the website. Such information may include details of the User’s visit, information about the User’s computer, including IP (Internet Protocol) address, operating system and browser type, the User’s location, and usage information. An individual User will not be identified from or by this information and  COMPANY is entitled to copy, distribute or otherwise use such information without limitation.

7. Cookies

• 7.1 “Cookies” are small text files transferred by a webserver to a User’s hard drive and thereafter stored on their computer.  The types of information a Cookie collects includes a User’s username, the date and time of their visits to the website, their browsing history and preferences.
• 7.2 COMPANY may use Cookies on this website to:
• 7.2.1 distinguish one User from another on the website;
• 7.2.2 remember the User’s last session when they return to the website;
• 7.2.3 estimate the website’s audience size and usage patterns;
• 7.2.4 store information about the User’s preferences, which allows  COMPANY to customize the website and content according to the Users individual preferences; and
• 7.2.5 speed up searches on the website.
• 7.3 The provisions of this clause are only applicable to Cookies used by  COMPANY. In some instances, third-party service providers may use Cookies on the website.  COMPANY cannot and does not control or access Cookies used by third party service providers and takes no responsibility therefor.
• 7.4 The User has the right and ability to either accept or decline the use of Cookies on their computer’s web browser, whether they are logged in as a member, or simply casually visiting the website. However, declining the use of Cookies may limit a User’s access to certain features on the website.

8. General Conditions For Processing Personal Information

• 8.1 COMPANY shall comply with all laws, contracts or regulations when it processes a User’s personal information.
• 8.2 COMPANY shall not act unreasonably when processing a User’s personal information. This means that it will collect and process a User’s personal information in a way that the User can reasonably expect and in a way that is fair.
• 8.3 COMPANY shall respect the User’s right to privacy at all times. If there is another way in which it can achieve the same goal without posing any risk of harm to the privacy rights of the User, then it will choose that option.
• 8.4 Similarly, if  COMPANY needs to process personal information but there are less privacy-invasive methods of collecting, using and sharing that information, then it will use those methods.
• 8.5 COMPANY shall ensure that the personal information that is collected and processed is and remains relevant to the identified purpose/s for such processing, and that such information is and remains adequate, but not excessive, for achieving the identified purpose/s.
• 8.6 If there are any alternative ways to achieve the identified purpose/s without processing personal information,  COMPANY shall not process that personal information.
• 8.7 COMPANY shall ensure that the processing activities it chooses to apply are proportionate to achieving the identified purpose/s and that no less privacy invasive measures are available to achieve the same purpose/s.
• 8.8 COMPANY shall ensure that, regardless of the stated purpose/s for processing personal information, the rights and interests of Users will not be unnecessarily prejudiced or infringed, unless it cannot be avoided, and then in such cases, it shall ensure that its own rights and/or interests justify such prejudice or infringement taking place.
• 8.9 COMPANY shall be entitled to store the personal information of Users indefinitely unless the User objects thereto. In the event a User objects to the indefinite storage, once  COMPANY has achieved the purpose for the collection of the User’s personal information, it will destroy or delete such information, unless the User has directed otherwise in writing, or  COMPANY is required by law to retain the information for a longer period of time.
• 8.10 If  COMPANY no longer needs to process personal information to achieve the purpose originally specified, it will stop using that information.