INFORMATION PROCESSING POLICY
We are committed to protecting your privacy. We recognise our obligation to respect and protect the confidentiality of your personal information. For this reason we have developed this policy to govern the processing of your information. Please read and consider this document carefully since it sets out our intended use of such information. We require your consent to the terms contained in this policy before we permit you to participate in our services. When registering for our services (whether as an account holder or as designated participant) you will be required confirm that you are at least 18 years old or have obtained your parent’s or guardian’s consent to use our services, and agree that we may collect, hold, process, use and disclose your personal information on the basis described in this policy.
Who we are
When we refer to “we”, “us” or “our” herein we are referring to Cellfind (Pty) Ltd (Registration Number 2003/020255/07) and the affiliated entities within our company group. Our principal place of business is at 142 16th Road, Midrand, South Africa but we recommend you contact us via telephone at (0)11 848 8200 or electronic mail at legal@cellfind.co.za.
How we collect information
We may collect information about you as follows:
(a) From you, including when you register for participation in our services, submit requests or instructions or otherwise make use of our services;
(b) From your mobile cellular service provider, including through its location from time to time of your registered mobile cellular handset for the purposes of our services in which you have elected to participate;
(c) From public registers, credit bureaus, money laundering, fraud prevention and law enforcement agencies;
(d) From people and entities employed by us to provide services for us, which may include debt collection services, communications services and data hosting, processing and management services;
(e) From persons employed by you to provide services to you, including your mobile cellular service provider; and
(f) From such other persons as you may consent to or which may be legally entitled to provide us with information about you.
We may also make enquiries with anyone for the purposes of verifying the accuracy of information already given to us.
Information we may hold
We may record and hold the following types of information about you:
(a) Information submitted by you, including your name, mobile cellular number, other contact details and identity number;
(b) Information collected and generated by us or your mobile cellular service provider in response to requests and instructions pertaining to your participation in our services, including your geographic location and movements established from time to time as part of the services;
(c) All other information pertaining to your participation in our services and the related services rendered by your mobile cellular service provider, including relevant payment records;
(d) Details of your service preferences, and other demographic and lifestyle information;
(e) Details of all communications between us;
We may hold your personal information for at least 5 years calculated from the date of collection, or for as long as you subscribe to any of our services and 5 years thereafter, as the case may be, subject thereto that in either case we shall not hold your personal information for a period which exceeds the maximum period permitted by applicable law.
Why we need your information
We collect and will process your information for the following purposes:
(a) To determine whether you qualify and register you for our services and for making related decisions;
(b) To effectively render our services and to exercise our rights and comply with our obligations in respect thereof, including by processing and recording service requests, managing service accounts, delivering our services to you and to such other users as you may have consented to, communicating with you regarding our services and collecting payments you may owe;
(c) To ensure that the information we receive and hold about you is accurate, complete and up to date;
(d) To prevent, investigate and prosecute fraud, money laundering, terrorism, abuse of our services and other unlawful activities;
(e) To comply with legal and regulatory requirements, for audit purposes and legal proceedings;
(f) To conduct market research and business analysis, understand your preferences, learn more about the products and services that you are interested in and improve the products and services we offer to you;
(g) To inform and provide you with the opportunity to make use of products, services and benefits that we offer and that we believe may be of interest to you to the extent that we are lawfully permitted to do so; and
(h) For such other purposes as you may consent to or as may otherwise be lawfully permitted, including for the purposes of protecting our and/or your legitimate interests and/or that of our business partners.
Please note that we will not contact you telephonically for unsolicited marketing purposes or send unsolicited marketing communications to you by mail, facsimile, SMS or electronic mail if you have objected to receiving such communications by way of a public register recognised for such purposes by law or by notifying us of your objection in the prescribed manner. We will provide you with reasonable opportunities to object to receiving marketing communications in the manner prescribed by law, including upon your application to subscribe to our services and on each occasion when we send you such communications.
Sharing your information
Keeping your personal information secure is one of our most important responsibilities. We cannot disclose your information unless legally permitted thereto. Save as set out below, we will not transfer your personal information to a third party without your consent unless legally obliged thereto. You agree that we may transfer your information to the following people and organisations in pursuit of the processing purposes set out in this policy:
(a) To the entities in our company group, including to the directors, employees, contractors, agents, auditors, legal and other professional advisors of such entities;
(b) To other participants in our services consented to by you;
(c) To your mobile cellular service provider;
(d) To any person that supports or authorises your participation in a service we provide insofar as it pertains to your registration for and participation in such service, including your bank or legal guardian where appropriate;
(e) To governmental, judicial, regulatory and law enforcement bodies and agencies, including the South African Police Service;
(f) To persons employed by us to provide services on our behalf that adhere to principles similar to ours regarding the treatment of your information, including data hosting, processing and management services;
(g) To any person to whom we cede, delegate, transfer or assign any of our rights or obligations pertaining to the services provided by us or contracts concluded by us;
(h) To any person that acts as your executor of your estate, curator or in a similar capacity;
(i) To such other persons as may be permitted by applicable law or that you may consent to, including persons and entities who may request such information to evaluate your creditworthiness.
Please note that our sharing of your information may also involve the transfer thereof to third parties outside South Africa. In the event of such transfer, we will require that such third party also subscribes to protecting your information on terms similar to the terms of this policy.
Security
We will strive at all times to ensure that your records will always be protected against unauthorised or accidental access, processing or loss. We maintain this commitment to data security by implementing appropriate reasonable technical and organisational measures to safeguard and secure your information, including by using appropriate cryptographic techniques and access control mechanisms. If we use a third party to host, manage or process your data on our behalf we will require that such third party also commit to implementing appropriate reasonable technical and organisational measures to safeguard and secure your information. If we are not prevented by a law enforcement or regulatory agency, we will notify you as soon as practicably possible in writing and at your registered postal or email address if we believe that unauthorised access to your information may have occurred, providing you with such information as you may reasonably require to implement protective measures.
Web Sites
When you visit our site we may collect certain information about your usage preferences and history. Such information will be stored in a cookie on your computer's hard drive by your web browser. Cookies are intended to assist and improve your use of our web sites. Most browsers accept cookies automatically, but usually you can alter the settings of your browser to prevent automatic acceptance. If you choose not to receive cookies, you may not be able to use all of the features of our site.
Every time you connect to our web sites we store web server logs which show your IP address (the unique number which your machine uses when it is connected to the Internet); what you looked at; whether the page request was successful or not, and which browser you used to view the pages. The use of this data is strictly for statistical and personalisation purposes only. This helps us understand which areas of the site are of particular interest and also which pages are not being requested. It also tells us how many hits and page requests we get.
Your rights regarding your information
Provided that you give us suitable and adequate proof of your identity, you have a right to know which records we hold about you. This can be done by submitting a written request to us. We will not be obliged to provide you with information to the extent that we are prohibited or permitted thereto by applicable law.
You also have the right to require us to correct or erase any records we hold about you that we are no longer permitted to retain, is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or has been unlawfully obtained. This can be done by submitting a written request to us to do so. We will notify you of the steps taken as a result of your request.
Please contact us at via electronic mail at legal@cellfind.co.za if you want to submit any request to us hereunder.
Objections and Opting Out
Please email us at legal@cellfind.co.za if you want to object to our collection, processing, recording, protection, use or sharing of your information. We may furthermore, if you are a participant in our services, from time to time provide you with the option to discontinue your participation in data processing activities. Please note that we may require a reasonable period to comply with your objection or decision to opt out and can only do so if permitted thereto by law and such compliance does not unreasonably prejudice our legitimate interests or that of a third party.