1. This Compliance Manual sets out the framework for our company’s compliance with the Protection of Personal Information Act (hereinafter POPIA). Where reference is made to the “processing” of personal information, this will include any activity in which the information is worked with, from the time that the information is collected, up to the time that the information is destroyed, regardless of whether the information is worked with manually or by automated systems.
2. This policy, together with the Angel Watch terms and conditions, applies to the relationship between you and Angel Watch and the service we provide from time to time. Unless otherwise stated, the defined terms in the Terms & Conditions will have the same meaning in this privacy policy and words defined in the POPIA will have those defined meanings in this privacy policy.
3. According to the Act ‘‘personal information’’ means information relating to an identifiable, living, natural person and, where it is applicable, an identifiable, existing juristic person. Addresses will include residential, postal and email addresses.
4. By becoming a member and using the Angel Watch App, you specifically consent to Angel Watch collecting and processing your personal information. You have to provide the required personal information in order to utilize the services provided by Angel Watch.
5. We collect information directly from you, where you provide us with your personal details. Where possible, we will inform you what information you are required to provide to us and what information is optional.
6. Website usage information may be collected using “cookies” which allows us to collect standard internet visitor usage information.
7. Angel Watch may process personal information from you in connection with:
7.1 the provision of any product or service that Angel Watch may provide now or in the future;
7.2 creation of a user profile on our App and verification of such profile;
7.3 information requests or complaints;
7.4 visits or browsing on the Angel Watch website or App;
7.5 visits or browsing any partner websites or Apps.
8. Angel Watch may collect the following types of personal information:
8.1 personal and business contact information, such as name, address, telephone number and email address;
8.2 financial information such as your debit/credit card number or other billing information;
8.3 identity number or passport number;
8.4 any information necessary in order to provide our service to you;
8.5 geo-location information such as your physical location;
8.6 any additional information relating to you that you provide to us directly through our website or App;
8.7 information you provide us through customer surveys.
9. We may also collect information about your computer or mobile device, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our webmasters. This information reveals nothing personal about you. It is statistical data about our users’ browsing actions and patterns which does not identify any individual and allows us to ensure that content from our website or App is presented in the most effective manner for you and for your device.
10. Personal information provided by you will only be used for the purpose it was provided, as well as for the purpose listed in this policy and in the terms and conditions.
11. In light of the nature of the service we offer, we may share your information with third-party service providers, including PayGate (Pty) Ltd who processes payments between you and ourselves, and you consent to such processing of your information in order for us to provide our service to you.
12. Credit card information is used only for payment processing and fraud prevention. Purchases made via credit card will be verified, authenticated and securely stored by PayGate (Pty) Ltd. This information is not used for any other purpose by us or our financial service providers and will not be kept longer than necessary for providing the service.
13. We may disclose your personal information to our service providers who are involved in the delivery of services to you.
14. We undertake to follow POPI at all relevant times and to process personal information lawfully and reasonably, so as not to infringe unnecessarily on the privacy of our clients.
15. We undertake to process information only for the purpose for which it is intended, to enable us to do our work, as agreed with our clients.
16. Whenever necessary, we shall obtain consent to process personal information.
17. We may also provide third parties with your personal information, provided you have agreed thereto, in order to provide you with marketing and promotional material. Personal information will not be provided to direct marketing companies or other such organizations without your permission.
18. Where we do not seek consent, the processing of our client’s personal information will be following a legal obligation placed upon us or to protect a legitimate interest that requires protection.
19. We shall stop processing personal information if the required consent is withdrawn, or if a legitimate objection is raised.
20. We shall collect personal information directly from the client whose information we require unless:
20.1 the information is of public record, or
20.2 the client has consented to the collection of their personal information from another source, or
20.3 the collection of the information from another source does not prejudice the client, or
20.4 the information to be collected is necessary for the maintenance of the law and order or national security, or
20.5 the information is being collected to comply with a legal obligation, including an obligation to SARS, or
20.6 the information collected is required for the conduct of proceedings in any court or tribunal, where these proceedings have commenced or are reasonably contemplated; or
20.7 the information is required to maintain our legitimate interests; or
20.8 where requesting consent would prejudice the purpose of the collection of the information; or
20.9 where requesting consent is not reasonably practical in the circumstances.
21. We shall advise our clients of the purpose of the collection of the personal information.
22. We shall retain records of the personal information we have collected for the minimum period as required by law unless the client has furnished their consent or instructed us to retain the records for a longer period.
23. We shall destroy or delete records of the personal information (so as to identify the client) as soon as is reasonably possible after the time period, for which we were entitled to hold the records, has expired.
24. We shall restrict the processing of personal information:
24.1 where the accuracy of the information is contested, for a period of sufficient to enable us to verify the accuracy of the information;
24.2 where the purpose for which the personal information was collected has been achieved and where the personal information is being retained only for the purposes of proof;
24.3 where the client requests that the personal information is not destroyed or deleted, but rather retained; or
24.4 where the client requests that the personal information be transmitted to another automated data processing system.
25. We make every effort to keep the personal information we hold updated, complete and accurate. It is your duty to provide Angel Watch with the most up to date personal information, and Angel Watch will then take reasonable steps to update your information as soon as possible.
26. We will require a copy of your ID document to confirm your identity before making changes to the personal information we may hold about you.
27. We would appreciate it if you would keep your personal information accurate.
28. 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.
29. Our security policies and procedures cover:
29.1 Physical security;
29.2 Computer and network security;
29.3 Access to personal information;
29.4 Secure communications;
29.5 Security in contracting out activities or functions;
29.6 Retention and disposal of information;
29.7 Acceptable usage of personal information;
29.8 Governance and regulatory issues;
29.9 Monitoring access and usage of private information;
29.10 Investigating and reacting to security incidents.
30. 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.
31. 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.
32. You have the right to request a copy of the personal information we hold about you in terms of the Promotion of Access to Information Act, 2000. To do this, simply contact us at the numbers/addresses as provided on our website 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.
33. Any such access request may be subject to a payment of a legally permissible fee.
34. You have the right to request that we rectify any personal information we hold on you; or request to have your personal information removed from our records, subject to any legal restrictions that may be applicable (it being understood that if we do so you will no longer be able to make use of our services).
35. You have the duty to inform us if you believe that someone is impersonating or otherwise unlawfully using your account.
36. Personal information may be processed even in the absence of consent if it protects your legitimate interest, is necessary for the proper performance of a public law duty by a public body or processing is necessary for pursuing the legitimate interests of Angel Watch or a third party to whom the information is supplied. You are entitled to object at any time to such processing, as prescribed and on reasonable grounds relating to your particular situation, unless legislation provides for such processing.
Full name: Tune Laubscher
Physical address: 3 Victoria Road – Bantry Bay - 8005
Website: www.angelwatch.co.za
Email address: info@angelwatch.co.za
Tel no: 064 821 6037
Registration number: 2017/365201/07
Country of incorporation: South Africa
You have a right to lodge a complaint with:
THE INFORMATION REGULATOR:Any queries or concerns about privacy on our App or website should be sent by email to info@angelwatch.co.za or customer care number: 064 821 6037