1. In this Policy (as defined below), unless the context requires otherwise, the following capitalised terms shall have the meanings given to them:

    2. Active Processing” means instances where WTTX has directly been provided with the Personal Information/Personal Data of Data Subjects, such as when Data Subjects submit an enquiry in respect of our Services or Products, or when Data Subjects provide Personal Information/Personal Data to WTTX pursuant to any interaction with WTTX (through its website or otherwise);

    3. Inactive Processing” means instances where WTTX has not actively been provided with the Personal Information/Personal Data of Data Subjects, such as when WTTX deploys Passive Processing Means to collect information from Data Subjects. These Passive Processing Means allow WTTX to Process certain kinds of Non-personally Identifiable Information which cannot be linked to Data Subjects;

    4. Anonymisation” means the Processing of Personal Information/Personal Data in such a manner that the Personal Information/Personal Data can no longer be attributed to Data Subjects without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the Personal Information/Personal Data are not attributed to Data Subjects;

    5. Applicable Laws” means any laws applicable to Personal Data and Personal Information and includes any statute, regulation, notice, policy, directive, ruling or subordinate legislation; the common law; any binding court order, judgement or ruling; any applicable industry code, policy or standard enforceable by law; or any applicable direction, policy or order that is given by any regulator, competent authority or organ of state or statutory industry body;

    6. Controller” means WTTX, in circumstances where it Processes Personal Data;

    7. Consent” means any voluntary, specific and informed expression of will in terms of which permission is given for the Processing of Personal Information;

    8. Cookies” means small text files that store Non-personally Identifiable Information/Data about Data Subjects, either temporarily in connection with a Data Subjects Internet Protocol (IP) address (known as a temporary or session cookie, and deleted once a Data Subject closes their browser window) or more permanently on the hard drive of a Data Subject’s device (known as a permanent or persistent cookie). WTTX ’s Website(s) may from time-to-time use session cookies so that Data Subject’s do not have to fill in the same information from page to page within our Website(s);

    9. Customer(s)” means any natural person(s), or juristic person(s), who have conducted business with WTTX in terms of which such Customer procures the Products or Services provided by WTTX or interacts with WTTX through the WTTX or its Website(s);

    10. Data Subject” means WTTX ’s Customer(s) or any Third Party in respect of whom WTTX Processes Personal Information/Personal Data.

    11. Data Processing Infrastructure” means any and all systems, networks, servers, workstations, laptops, mobile devices, web applications, mobile applications, cloud storages, websites owned, controlled or operated by WTTX;

    12. Embedded Scripts” means, programming code that is designed to collect information about a Data Subject’s interactions with the relevant Website(s) or Mobile Application(s). It is temporarily downloaded onto a Data Subject’s device from our web server or a Third-Party Operator. This program is active only while a Data Subject is connected to the relevant Website(s) or Mobile Application(s) and is deleted or deactivated thereafter;

    13. Electronic Means” means, in relation to the Processing of any Personal Information/Personal Data, the use of any Website(s), Mobile Application(s), electronic mail (email), text, voice, sound or image messages by WTTX;

    14. Non-Electronic Means” means, in relation to the Processing of any Personal Information/Personal Data, the use of traditional means of Processing, such as hard copy documents, traditional filing systems deployed for the storage and retention of Personal Information/Personal Data and face-to-face personal engagements with Data Subjects;

    15. Mobile Application(s)” means any multi-device software application, whether in web-based format or device-native format, to which this Privacy Policy relates and through which Customer(s) and Third Parties gain access to WTTX ’s Products and/or Services;

    16. Mobile Device Identifier” means device information if you access our Website(s) or Mobile Application(s) through mobile devices. Certain features of the relevant Website(s) or Mobile Application(s) may require collection of mobile phone numbers and we may associate that phone number with the mobile device identifiers. Additionally, some mobile phone service providers operate systems that pinpoint the physical location of devices that use their service. Depending on the provider, WTTX and/or our Third-Party Operators may receive this information. If WTTX associates any such passively collected information with the Personal Information/Personal Data of Data Subjects, we will treat the combined information as Personal Information/Personal Data as contemplated in this Policy;

    17. Non-personally Identifiable Information/Data” means any information/data which cannot be linked to Data Subjects, such as an internet domain name, the type of web browser used by a Data Subject, the type of operating system relied on by a Data Subject, the date and time of a Data Subject’s visit to our Website(s) and Mobile Application(s), the specific pages a Data Subject may have visited, and the address of the website which a Data Subjects may have visited prior to entering or gaining access to WTTX ’s Website(s) or Mobile Application(s);

    18. Operator” means a person or entity who Processes Personal Information/Data for a Responsible Party;

    19. Passive Processing Means” means the use of technologies to facilitate the Inactive Processing of Personal Information/Personal Data, namely the use of Cookies, Web Beacons, Embedded Scripts and/or Mobile Device Identifiers;

    20. Personal Data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, which in the context of WTTX shall comprise of the types of Personal Data recorded in this Policy below;

    21. Personal Information” shall have the same meaning as is given in section 1 of POPIA but shall in the context of WTTX comprise of the types of Personal Information recorded in this Policy below;

    22. Policy” means this Data Protection and Privacy Policy;

    23. POPIA” means the Protection of Personal Information Act, No 4 of 2013;

    24. Processing” means any operation or activity or any set of operations, whether or not by automatic means, concerning Personal Information/Personal Data, including:
      • the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use;
      • dissemination by means of transmission, distribution or making available in any other form by electronic communications or other means; or
      • merging, linking, blocking, degradation, erasure or destruction. For the purposes of this definition, “Process” has a corresponding meaning.
    25. Products” means the any products procured by Customers of WTTX through the Website(s) and/or other interaction with WTTX;

    26. Regulator” means the Information Regulator established in terms of POPIA;

    27. Responsible Party” means in the context of this Policy, WTTX;

    28. Services” means the various services provided by WTTX to its Customer(s), the particulars of which services are clearly set forth on WTTX ’s Website from time to time;

    29. Special Personal Information/Data” means Personal Information/Personal Data concerning, amongst other aspects contemplated in terms of section 26 Part B of POPIA, a Data Subject’s, religious beliefs, race or ethnic origin, trade union membership, political persuasion, health or sex life, biometric data, or criminal behaviour;

    30. Third-Party” means any affiliate of the WTTX (if applicable), Customer(s), Data Subject(s), employees, independent contractor, agent, consultant or user of WTTX ’s Products, Services, Website or any other digital application interface;

    31. Unique Identifier” means any identifier that is assigned to a Data Subject and is used by the Responsible Party for the purposes of the operations of that Responsible Party and that uniquely identifies that data subject in relation to the Responsible Party;

    32. Website” means the website owned and operated by WTTX sourced at https://www.wttx.co.za/; and

    33. Web Beacons” means small graphic images called web beacons, also known as “Internet tags” or “clear gifs,”, which Web Beacons may be deployed in WTTX ’s Website(s) pages and e-mail messages. Web beacons may be invisible to Data Subjects, but any electronic image inserted into a web page or e-mail can act as a Web Beacon. WTTX may use web beacons or similar technologies for a number of purposes, including, without limitation, to count the number of visitors to our Websites, Mobile Application(s), to monitor how users navigate the Website(s) or Mobile Application(s), to count how many e-mails that we have sent were actually opened or to count how many particular articles or links were actually viewed by Data Subjects in certain circumstances.