Privacy Policy

This User Privacy Policy outlines our commitment to protecting and upholding the integrity
of the personal information which you, the user, elect to provide to us.
This policy outlines the when, how and why we collect your personal information and
describes the manner in which we store, use and protect your personal information, as
informed by the Protection of Personal Information Act 4 of 2013 (“POPIA”).

OUR GENERAL WAIVER

We hereby make no warranties or representations regarding any aspect of this website or any
associated websites (the/our “websites”) including, but not limited to:

  • Its operation;
  • Its content;
  • The accuracy of the information provided; or
  • The goods and/or services advertised or referred to on any of our websites.

APPLICATION TO USERS

This policy applies to you if you:

  • Visit any of our websites; or
  • Have previously made use of goods and/or services through any of our websites.

ACCEPTANCE OF THIS POLICY

To procure and make use of our goods and/or services, you must accept the terms of this
privacy policy. Otherwise, you will not be able to access our products and/or services.

USER WARRANTIES

By accessing our websites and procuring or goods and/or services, you warrant that you are at
least 18 years of age or otherwise have the legal capacity to enter into binding agreements.
You warrant that, upon acceptance of this policy, you have read, understood, accepted and
agreed to be bound by the terms of this policy.

You further warrant that the personal information you provide to us is given voluntarily or,
where such information relates to another person, such information is given with that
person’s consent.

WHAT DO WE MEAN BY PERSONAL INFORMATION?

Personal Information (“PI”) refers to any information which helps us identify you as an
individual.
PI includes the following:

  • Certain information we collect automatically when you access our websites;
  • Certain information that you submit to us when you request information or otherwise
    contact us; and
  • Any other information which you may voluntarily provide to us but which is not
    strictly necessary.

PI excludes the following:

  • Information collected/submitted/provided anonymously is a manner that does not
    identify you specifically;
  • Information that has been de-identified and no longer relates to or otherwise cannot be
    traced back to you;
  • Non-personal statistical information collected and compiled by us for record-keeping
    purposes;
  • Information that you have made public elsewhere in an open forum such as on a blog
    post, online discussion group or any other public social media platform

Examples of information we collect:

  • Identifying information: your name, date of birth or any sort of identification
    number
  • Contact information: cellphone number or email address
  • Address information: physical or postal address
  • Financial information: your banking details

WHAT IS SPECIAL PERSONAL INFORMATION?

Special Personal Information (“SPI”) includes all information relating to your religious or
philosophical beliefs, race or ethnic origin, trade union membership, political persuasion,
health or sex life, biometric information or criminal behaviour.
We will not collect or process your SPI unless:

  • You voluntarily provide it to us;
  • The processing thereof is necessary to establish, exercise or defend any right or
    obligation we have in law;
  • The processing thereof is necessary for historical, statistical or research purposes
    where doing so serves a public interest; or
  • You have deliberately made the information available on an open, public forum.

CHANGES TO THIS POLICY

We reserve the right to amend this policy from time to time upon notice to all users, either by
way of email or prominent display thereof on our websites or other digital platforms.
Each update will reflect the date on which such update was last made.
Where you do not agree with any updates made, you must stop using our websites and our
goods/services.
If you continue using our websites, we will deem your actions as acceptance of any updated
policy and the terms thereof will automatically apply to you.

COLLECTION OF INFORMATION

When you access our website, we automatically receive and record Internet usage
information on our 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 our website might place personal
information within your URL during a visit to it, and we have no control over such websites.
Accordingly, a subsequent website that collects URL information may log some personal
information.

When you request information or otherwise contact us you will be requested to provide us
certain additional information.

WHY DO WE USE PERSONAL INFORMATION AND FOR HOW LONG?

We generally collect and process your personal information for various purposes, including:

  • Collecting information relating to access and procure of our goods and/or services;
  • Lawful marketing related activities, such as identifying our target audience and
  • creating ad campaigns;
  • Other business-related activities such as internal audits, business planning, joint ventures and other proposed or actual transactions’
  • Otherwise complying with our legal obligations or in the pursuit of good legal
    governance.
  • We may use your usage information for the purposes described above and to:
  • Remember your information so that you will not have to re-enter it during your visit
    or the next time you access our websites;
    Monitor website usage metrics such as total number of visitors and pages accessed;
    and
  • Track your entries, submissions, and status in any promotions or other activities in
    connection with your usage of our websites.

Importantly, we will only collect your information for a transparent, defined purpose and
only where you have given us your consent to do.

We will only retain your personal information for as long as it is necessary to fulfil the
purposes explicitly set out in this policy, unless:

  • Retention of the record is required or authorised by law; or
  • You have consented to the retention of the record.

During the period of retention, we will continue to abide by our non disclosure obligations
and will not share or sell your personal information.
We may retain your personal information in physical or electronic records at our discretion.

STANDARD COOKIES

Cookies are small text files stored in the user’s browser. These files do not contain personal
information, but they do contain a personal identifier allowing us to associate your personal
information with a certain device.
These allow us overall to better manage our websites and to facilitate improvements thereto.

Cookies further allow us to:

  • tailor our website’s functionality to you as an individual by remembering your
    preferences;
  • allow third parties to provide services to our website;
  • deliver targeted advertising where appropriate in compliance with the applicable laws.

You can choose to have your computer warn you each time a cookie is being sent, or you can
choose to turn off all cookies in your browser. You do this through your browser settings.
However, no longer accepting cookies or deleting them will prevent you from accessing
certain aspects of our website where cookies are necessary.

THIRD-PARTY COOKIES/LINKS

Some of our business partners use their own cookies or widgets on our website. We have 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 us.

WEB BEACONS

Our website may contain electronic image requests that allow us to count page views and to
access cookies.

Any electronic image viewed as part of a web page (including an ad banner) can act as a web
beacon.

We use this information collected off our site and share it with our advertising platforms to
carry out marketing initiatives.

All the information that we share is encrypted and we make sure that our third-party service
providers comply with relevant data protection laws.

We may provide this information including identifiers that allow our advertising platforms to
deliver targeted online advertising on social media and websites.

OPTIONAL DETAILS

You may also provide additional information to us on a voluntary basis.

This includes content or products that you decide to upload or download from our website or
when you enter competitions, take advantage of promotions, respond to surveys, order certain
additional goods or services, or otherwise use the optional features and functionality of our
website.

Importantly, in the process of any of the above, you may provide us with SPI which we will
treat will the highest level of confidentiality.

USE OF YOUR PERSONAL INFORMATION

We may use your personal information for the purpose for which you have provided it and to
fulfil our obligations to you.
We may send administrative messages and email updates to you about the website as well as
primarily promotional messages.

DISCLOSURE OF YOUR PERSONAL INFORMATION

We may share your personal information with:

  • other divisions or companies within the group of companies to which we belong 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 our
    policies, and to guide decisions about our products, services, and communications
    (they will only use this information to send you marketing communications if you
    have requested their goods or services);
  • an affiliate, in which case we will seek to require the affiliates to honour this privacy
    policy;
  • our goods or services providers under contract who help provide certain goods or
    services or help with parts of our business operations, including fraud prevention, bill
    collection, marketing, or technology services (our contracts dictate that these goods or
    services providers only use your information in connection with the goods or services
    they supply or services they perform for us and not for their own benefit);
  • credit bureaus to report account information, as permitted by law;
  • 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);
  • our third party suppliers who provide us with their goods; and
  • other third parties who provide us with relevant services where appropriate (for
    example our couriers).

Where necessary, we insist on concluding agreements to ensure that our suppliers, affiliates
and other third parties to who we supply your personal information process such information
according to the same standards of care and confidentiality that we observe in all our dealings
with information processing.
We may disclose your personal information as required by law or governmental audits to
certain governmental bodies or agencies.
We may disclose personal information to law enforcement agencies if required:

  • by a subpoena or court order;
  • to comply with any law;
  • to protect the safety of any individual or the general public; and
  • to prevent violation of our customer relationship terms.

Your personal information may be disclosed to our employees during the course and scope of
their employment for them to fulfil their duties. Each employee has undertaken a duty of
confidentiality as written into their employment contract.

NO SELLING

We will not sell, trade or otherwise disseminate your personal information and no personal
information will be disclosed to anyone except as provided in this privacy policy.

CHANGE OF OWNERSHIP

If we undergo a change in ownership, or a merger with, acquisition by, or sale of assets to,
another entity, we may assign our rights to the personal information we process to a
successor, purchaser, or separate entity. We will disclose the transfer on the website.
If you are concerned about your personal information migrating to a new owner, you may
request us to delete your personal information.

UNAVAILABILITY OF ANY OF OUR WEBSITES

You acknowledge and accept that any of our websites may become unavailable from time to
time due to various circumstances, including:

  • technical failure or problems with any of our websites;
  • technical failure or problems with third party information technology systems;
  • unavailability of telecommunication or electricity services; or
  • other circumstances beyond our control, in which case there shall be no claim
    whatsoever that may be brought against us.

INTELLECTUAL PROPERTY RIGHTS

  • The full contents of our websites are copyright-protected.
  • All intellectual property associated with any of our websites and our brand as a whole,
    including but not limited to content, trademarks, domain names, design elements,
    software, databases, text, graphics and hyperlinks remain our sole property remain our
    sole and exclusive property.
  • Any unlawful or unauthorised use, modification, alteration or distribution thereof will
    be considered an offence and punishable by law.

SECURITY MEASURES

We take the security of personal information very seriously and always do our best to
comply with applicable data protection laws.
Our hosting company will host our website in a secure server environment that uses a firewall
and other advanced security measures to prevent interference or access from outside
intruders.
We authorize access to personal information only for those employees who require it to fulfil
their job responsibilities.
We implement disaster recovery procedures where appropriate.

ACCURACY OF INFORMATION AND KEEPING OF INFORMATION UP TO DATE

We will try to keep the personal information we collect as accurate, complete and up to date
as is necessary for the purposes defined in this policy.
From time to time we may request you to update your personal information on the website.
You are able to review or update any personal information that we hold on you by emailing
or phoning us.
Please note that in order to better protect you and safeguard your personal information, we
take steps to verify your identity before granting you access to your account or making any
corrections to your personal information.

TRANSBORDER TRANSFERS OF INFORMATION

We may not transfer your personal information to a third party in a foreign country, unless:

  • You have consents to this or specifically requested it; or
  • such third party is subject to a law, binding corporate rules or a binding agreement
    which protects the personal information in a manner similar to POPIA, and such third
    party is governed by similar rules which prohibit the onward transfer of the personal
    information to a third party in another country; or
  • the transfer of the personal information is required for the performance of the contrac
    between you and ourselves; or
  • the transfer is necessary for the conclusion or performance of a contract for the benefit
    of the client/data subject entered into between ourselves and the third party; or
  • the transfer of the personal information is for the benefit of the client and it is not
    reasonably possible to obtain their consent and that if it were possible the client would
    be likely to give such consent.

CONTACT US

InnuScience SA Pty Ltd is a member of the Bothongo Group of Companies.

If you have any concerns or queries regarding this policy or our implementation of any of the
sections of POPIA, or would otherwise like to amend or withdraw your consent, please
contact us on the information below:

www.bothongogroup.co.za
16 Macbeth Road Fourways, South Africa
Johannesburg, Gauteng 2125
South Africa
info@bothongo.com
+27 11 467-7870