1. Whenever any Data Subject engages with WTTX, whether it be physically or electronically, or through the use of its Services or Products, facilities or Website WTTX will in effect be Processing the Data Subject’s Personal Information/Personal Data.

    2. It may be from time to time that WTTX has collected a Data Subject’s Personal Information/Personal Data from other sources and in such instances WTTX will inform the Data Subject by virtue of any privacy notices it deploys from time to time. In the event that a Data Subject has shared their Personal Information/Personal Data with any third parties, WTTX will not be responsible for any loss suffered by the Data Subject, their dependents, beneficiaries, customers, representatives, agents or employees (as the case may be).

    3. When a Data Subject provides WTTX with the Personal Information of any other Third Party, WTTX will process the Personal Information/Personal Data of such Third Party in line with this Policy, as well as any terms and conditions or privacy notices to which this Policy relates.

    4. WTTX will primarily Process Personal Information/Personal Data in order to facilitate and enhance the delivery of Products and/or Services to its Customers, manage and administer its business, foster a legally compliant workplace environment, as well as safeguard the Personal Information/Personal Data relating to any Data Subjects which it in fact holds. In such an instance, the Data Subject providing WTTX with such Personal Information/Personal Data may also be required to confirm that they are a Competent Person and that they have authority to give the requisite consent to enable WTTX to process such Personal Information/Personal Data.

    5. WTTX undertakes to process any Personal Information/Personal Data in a manner which promotes the constitutional right to privacy, retains accountability and Data Subject participation.

    6. Prior to recording the purpose(s) for which WTTX may, or will, process the Personal Information/Personal Data of Data Subjects, WTTX hereby records the types of Personal Information/Personal Data of Data Subjects it may process from time to time:
      • personal information submitted by the User in any form or otherwise filled in by the User on the Website
      • IP address;
      • Information specifically and voluntarily entered by the User pursuant to using the Website, Products or Services;
      • Information required to identify a mobile or other electronic device used by the User, including the device ID and location; and
      • Information related to the User’s interactions in relation to the Products and Services.

    7. In supplementation of the above and any information privacy notices provided to any Data Subjects from time to time pursuant to any engagement with them, WTTX may process Personal Information/Personal Data for the following purposes:
      • verifying the identity of the Data Subject;
      • entering into and concluding an agreement with the Data Subject (where applicable);
      • sharing such information with third parties who require same in respect of services to be procured by or potentially procured by the User and/or processing payments on behalf of the Data Subject;
      • sharing such information with partners and third-party service providers for record keeping and statistical purposes and so as to enable them to enter into communications with the User in relation to their activities;
      • transmitting and receiving necessary correspondence to the Data Subject in relation to the services offered on the Website;
      • processing payments, refunds and the like in respect of any subscriptions or other monetary transfers made by the Data Subject or Products delivered and Services rendered to him / her by us or our partners, contractors or third-party service providers;
      • transmitting marketing material to the Data Subject in respect of products or services sold by us or our partners, contractors or third-party service providers;
      • performing website analytics, such as impression reporting, demographic reporting and interest reporting to improve our services;
      • maintaining and improve the Website, Services and Products and tailoring the Data Subject’s user experience;
      • employing security safeguards in relation to the Data Subject’s use of the Website; and
      • exercising any legal right or obligation accruing to us or our partners, contractors or third-party service providers.

    8. When collecting Personal Information/Personal Data from a Data Subject, WTTX shall comply with the notification requirements as set out in Section 18 of POPIA.

    9. WTTX will collect and Process Personal Information/Personal Data in compliance with the conditions as set out in POPIA to ensure that it protects the Data Subject’s privacy.

    10. WTTX will not Process the Personal Information/Personal Data of a Data Subject for any purpose other than for the purposes set forth in this Policy or in any other privacy notices which may be provided to Data Subjects from time to time, unless WTTX is permitted or required to do so in terms of Applicable Laws or otherwise by law.

    11. WTTX may from time-to-time Process Personal Information/Personal Data by making use of automated means (without deploying any human intervention in the decision-making process) to make decisions about the Data Subject or their application. In this instance it is specifically recorded that the Data Subject may object to or query the outcomes of such a decision.