30 June 2021 | Version 2.0
CUSTOMER INFORMATION MANUAL IN TERMS OF REGULATION 4(A) OF THE PROTECTION OF PERSONAL INFORMATION ACT 4 OF 2013
We are Cactus Cade (Pty) Ltd (Registration number 2018/374638/07) and this is our plan of action when it comes to protecting your privacy. We respect your privacy and take the protection of personal information very seriously, and strive to be in full compliance of the POPI Act.
The purpose of this policy/manual is to describe the way that we collect, store, use, and protect information that can be associated with you or another specific natural or juristic person and can be used to identify you or that person (personal information).
This policy applies to you, if you are:
- a visitor to our website; or
- a customer who has ordered or requested the goods or services that we provide online.
Personal information includes:
- certain information that we collect automatically when you visit our website;
- certain information collected on registration (see below);
- certain information collected on submission; and
- optional information that you provide to us voluntarily (see below);
- information that has been made anonymous so that it does not identify a specific person;
- permanently de-identified information that does not relate or cannot be traced back to you specifically;
- non-personal statistical information collected and compiled by us; and
- 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).
Common examples of the types of personal information which we may collect and process include your:
- identifying information – such as your name, date of birth, or identification number of any kind;
- contact information – such as your phone number or email address;
- address information – such as your physical or postal address; or
- financial information – such as your bank account details.
You must accept all the terms of this policy when you order our goods or request our services. If you do not agree with anything in this policy, then you may not order our goods or request our services.
You may not access our website or order our goods or request our services if you are younger than 18 years old or do not have legal capacity to conclude legally binding contracts.
By accepting this policy, you are deemed to have read, understood, accepted, and agreed to be bound by all of its terms.
You may only send us your own personal information or the information of another data subject where you have their permission to do so.
We may change the terms of this policy at any time by updating this web page. We will notify you of any changes by placing a notice in a prominent place on the website or by sending you an email detailing the changes that we have made and indicating the date that they were last updated.
If you do not agree with the changes, then you must stop using the website and our goods or services.
If you continue to use the website or our goods or services following notification of a change to the terms, the changed terms will apply to you and you will be deemed to have accepted those updated terms.
Once you register on our website, you will no longer be anonymous to us. You will provide us with certain personal information when you register on our website.
This personal information will include:
- your name and surname;
- your email address;
- your telephone number;
- your postal address or street address; and
- your username and password.
We will use this personal information to fulfil your account, provide additional services and information to you as we reasonably think appropriate, and for any other purposes set out in this policy.
On order or request
When you order our goods, or request our services from us, you will be asked to provide us with additional information on a voluntary basis (goods or services 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.
We may place small text files called ‘cookies’ on your device when you visit our website. 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 files serve a number of useful purposes for you, including:
- granting you access to age restricted content;
- tailoring our website’s functionality to you personally by letting us remember your preferences;
- improving how our website performs;
- allowing third parties to provide services to our website; and
- helping us deliver targeted advertising where appropriate in compliance with the applicable laws.
Third party cookies
Our website may contain electronic image requests (called a single-pixel gif or web beacon request) 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.
You may also provide additional information to us on a voluntary basis (optional information). 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.
We may monitor and record any telephone calls that you make to us, unless you specifically request us not to.
Purpose for collection
We may use or process any goods or services information, or optional information that you provide to us for the purposes that you indicated when you agreed to provide it to us. Processing includes gathering your personal information, disclosing it, and combining it with other personal information.
We generally collect and process your personal information for various purposes, including:
- goods or services purposes – such as collecting orders or requests for and providing our goods or services;
- marketing purposes – such as pursuing lawful related marketing activities;
- business purposes – such as internal audit, accounting, business planning, and joint ventures, disposals of business, or other proposed and actual transactions; and
- legal purposes – such as handling claims, complying with regulations, or pursuing good 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 the website;
- 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 the website.
Consent to collection
We will obtain your consent to collect personal information:
- in accordance with applicable law;
- when you provide us with any registration information or optional information.
We may use your personal information to fulfil our obligations to you.
Messages and updates
We may send administrative messages and email updates to you about the website. In some cases, we may also send you primarily promotional messages. You can choose to opt-out of promotional messages.
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);
- 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).
We may disclose your personal information as required by law or governmental audit.
We may disclose personal information 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.
We will not sell personal information.
We may disclose aggregate statistics (information about the customer population in general terms) about the personal information to advertisers or business partners.
We may need to disclose personal information to our employees that require the personal information to do their jobs. These include our responsible management, human resources, accounting, audit, compliance, information technology, or other personnel.
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.
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.
We are legally obliged to provide adequate protection for the personal information we hold and to stop unauthorized access and use of personal information. We will, on an on-going basis, continue to review our security controls and related processes to ensure that your personal information remains secure.
Our security policies and procedures cover:
- Physical security;
- Computer and network security;
- Access to personal information;
- Secure communications;
- Security in contracting out activities or functions;
- Retention and disposal of information;
- Acceptable usage of personal information; Governance and regulatory issues;
- Monitoring access and usage of private information;
- Investigating and reacting to security incidents.
When we contract with third parties, we impose appropriate security, privacy and confidentiality obligations on them to ensure that personal information that we remain responsible for, is kept secure. We will ensure that anyone to whom we pass your personal information agrees to treat your information with the same level of protection as we are obliged to.
Accurate and 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 accessing your account online, emailing us, 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.
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.
Transfer to another country
We will not transfer any personal information across a country border without your prior written consent.
Updating or removing
Access to information
You have the right to request a copy of the personal information we hold about you. To do this,simply contact us at the numbers/addresses as provided below and specify what information you require. We will need a copy of your ID document to confirm your identity before providing details of your personal information.
Correction of your information
You have the right to ask us to update, correct or delete your personal information. We will require a copy of your ID document to confirm your identity before making changes to personal information we may hold about you. We would appreciate it if you would keep your personal information accurate.
We are not responsible for, give no warranties, nor make any representations in respect of the privacy policies or practices of linked or any third-party websites.