WTTX Communication

PRIVACY POLICY

DEFINITIONS
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.

INTRODUCTION
1. This Policy regulates the Processing of Personal Information/Personal Data by WTTX and sets forth the requirements with which WTTX undertakes to comply when Processing Personal Information/Personal Data pursuant to undertaking its operations and fulfilling its contractual obligations in respect of Data Subjects and Third Parties in general.
2. WTTX places a high premium on the privacy of every person or organisation with whom it interacts or engages with and therefore acknowledges the need to ensure that Personal Information/Personal Data is handled with a reasonable standard of care as may be expected from it. WTTX is therefore committed to ensuring that it complies with the requirements of POPIA, and also with the terms of the GDPR to the extent that the GDPR applies.
3. When a Data Subject or Third Party engages with WTTX , whether it be physically or via any digital, electronic interface such as WTTX’s Website, the Data Subject or Third Party acknowledges that they trust WTTX to Process their Personal Information/Personal Data, including the Personal Information/Personal Data of their dependents, beneficiaries, customers, members, or employees as the case may be, which further entrenches the importance of WTTX ’s compliance with Applicable Laws in regards to the Processing of Personal Information/Personal Data.
4. All Data Subjects and Third Parties have the right to object to the processing of their Personal Information/Personal Data. The acceptance of the Terms and Conditions to which this Policy relates is required by the Data Subject to enable the proper use of WTTX ’s Website and/or Services.

PURPOSE AND APPLICATION
1. The purpose of this Policy are not only to inform Data Subjects of what Personal Information/Personal Data of theirs WTTX may Process, where WTTX may have collected such Personal Information/Personal Data from (if not directly from them as the Data Subject), how WTTX Processes their Personal Information/Personal Data, but also to establish a standard by which WTTX and its employees, representatives and operators shall comply in as far as the Processing of Personal Information/Personal Data is concerned.
2. WTTX, in its capacity as a Responsible Party and/or Operator and/or Controller, as the case may be, shall strive to observe and comply with its obligations under POPIA when it Processes Personal Information/Personal Data from or in respect of any Data Subject.

THE PROVIDER’S LICENCES, AFFILIATIONS AND OFFERINGS
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.

PERSONAL INFORMATION/PERSONAL DATA FOR DIRECT MARKETING PURPOSES
1. WTTX acknowledges that it may only use Personal Information/Personal Data to contact Data Subjects for purposes of direct marketing where WTTX has complied with the provisions of POPIA and when it is generally permissible to do so in terms of Applicable Laws.
2. In the event that WTTX may lawfully direct market to a Data Subject in terms of section 69 of POPIA, WTTX will ensure that a reasonable opportunity is given to such Data Subjects to object (opt-out) to the use of their Personal Information/Personal Data for WTTX ‘s marketing purposes when collecting the Personal Information/Personal Data and on the occasion of each communication to the Customer for purposes of direct marketing.

STORAGE AND RETENTION OF PERSONAL INFORMATION/PERSONAL DATA
1. WTTX will retain Personal Information/Data it has Processed, in an electronic or hardcopy file format, with a Third-Party service provider appointed for this purpose (the provisions of clause 9 below will apply in this regard).
2. Personal Information/Personal Data will only be retained by WTTX for as long as necessary to fulfil the legitimate purposes for which that Personal Information/Personal Data was collected in the first place and/or as permitted or required in terms of Applicable Law.
3. It is specifically recorded that any Data Subject has the right to object to the Processing of their Personal Information and WTTX shall retain and store the Data Subject’s Personal Information/Personal Data for the purposes of dealing with such an objection or enquiry as soon and as swiftly as possible.

FAILURE TO PROVIDE PERSONAL INFORMATION
1. Where WTTX is required to collect Personal Information/Personal Data from a Data Subject by law or in order to fulfil a legitimate business purpose of WTTX and the Data Subject fails to provide such Personal Information/Personal Data, WTTX may, on notice to the Data Subject, decline to render services without any liability to the Data Subject.

SECURING PERSONAL INFORMATION/PERSONAL DATA
1. WTTX will always implement appropriate, reasonable, physical, organisational, contractual and technological security measures to secure the integrity and confidentiality of Personal Information/Personal Data, including measures to protect against the loss or theft, unauthorised access, disclosure, copying, use or modification of Personal Information/Personal Data in compliance with Applicable Laws.
2. In further compliance with Applicable Laws, WTTX will take steps to notify the relevant Regulator(s) and/or any affected Data Subjects in the event of a security breach and will provide such notification as soon as reasonably possible after becoming aware of any such breach.
3. Notwithstanding any other provisions of this Policy, it should be acknowledged that the transmission of Personal Information/Personal Data, whether it be physically in person, via the internet or any other digital data transferring technology, is not completely secure. Whilst WTTX has taken all appropriate, reasonable measures to secure the integrity and confidentiality of the Personal Information/Personal Data its Processes, in order to guard against the loss of, damage to or unauthorized destruction of Personal Information/Personal Data and unlawful access to or processing of Personal Information/Personal Data, WTTX in no way guarantees that its security system(s) are 100% secure or error-free. Therefore, WTTX does not guarantee the security or accuracy of the information (whether it be Personal Information/Personal Data or not) which it collects from any Data Subject.
4. Any transmission of Personal Information/Personal Data will be solely at the own risk of a Data Subject. Once WTTX has received the Personal Information/Personal Data, it will deploy and use strict procedures and security features to try to prevent unauthorised access to it. As indicated above, WTTX reiterates that it restricts access to Personal Information/Personal Data to Third Parties who have a legitimate operational reason for having access to such Personal Information/Personal Data. WTTX also maintains electronic and procedural safeguards that comply with the Applicable Laws to protect your Personal Information from any unauthorized access.
5. WTTX shall not be held responsible and by accepting any terms and conditions to which this Policy relates, any Data Subject agrees to indemnify and hold WTTX harmless for any security breaches which may potentially expose the Personal Information/Personal Data in WTTX ’s possession to unauthorized access and or the unlawful processing of such Personal Information/Personal Data by any Third-Party.

PROVISION OF PERSONAL INFORMATION/PERSONAL DATA TO THIRD PARTIES
1. WTTX may disclose Personal Information/Personal Data to Third-Party service providers and any WTTX affiliates where necessary and to achieve the purpose(s) for which the Personal Information/Personal Data was originally collected and processed. WTTX will enter into written agreements with such Third-Party service providers and WTTX affiliates, to ensure that they comply with Applicable Laws pursuant to the Processing of Personal Information/Personal Data provided to it by WTTX from time to time.

TRANSFER OF PERSONAL INFORMATION/PERSONAL DATA OUTSIDE OF SOUTH AFRICA
1. WTTX may, under certain circumstances, transfer Personal Information/Personal Data to a jurisdiction outside of the Republic of South Africa in order to achieve the purpose(s) for which the Personal Information/Data was collected and processed, including for Processing and storage by Third-Party service providers.
2. If it is required, WTTX will obtain the Data Subject’s consent to transfer the Personal Information/Personal Data to such foreign jurisdiction.
3. The Data Subject should also take note that, where the Personal Information/Personal Data is transferred to a foreign jurisdiction, the Processing of Personal Information/Personal Data in the foreign jurisdiction may be subject to the laws of that foreign jurisdiction.

ACCESS TO PERSONAL INFORMATION/PERSONAL DATA
1. A Data Subject has the right to a copy of the Personal Information/Personal Data which is held by WTTX (subject to a few limited exemptions as provided for under Applicable Law).
2. The Data Subject must make a written request (which can be by email) to the Information Officer designated by WTTX from time to time and whose contact details can be sourced in WTTX ’s PAIA Manual.
3. WTTX will provide the Data Subject with any such Personal Information/Personal Data to the extent required by Applicable Law and subject to and in accordance with the provisions of WTTX ’s PAIA Manual.
4. The Data Subject can challenge the accuracy or completeness of his/her/its Personal Information/Personal Data in WTTX ’s records at any time in accordance with the process set out in WTTX ’s PAIA Manual.

KEEPING PERSONAL INFORMATION/PERSONAL DATA ACCURATE
1. WTTX will take reasonable steps to ensure that Personal Information/Personal Data that it Processes is kept updated where reasonably possible. For this purpose, WTTX shall provide Data Subjects with the opportunity to update their information at appropriate times.
2. WTTX may not always expressly request the Data Subject to verify and update his/her/its Personal Information/Personal Data and expects that the Data Subject will notify WTTX from time to time in writing:
  - of any updates or amendments required in respect of his/her/its Personal Information/Personal Data;
  - where the Data Subject requires WTTX to delete his/her/its Personal Information/Personal Data; or
  - where the Data Subject wishes to restrict the Processing of his/her/its Personal Information/Personal Data.

COSTS TO ACCESS PERSONAL INFORMATION/PERSONAL DATA
1. In the event that a cost is applicable, the prescribed fees to be paid for copies of the Data Subject’s Personal Information/Personal Data are listed in WTTX ’s PAIA Manual.
2. WTTX reserves the right to make amendments to this Policy from time to time.

COMPLAINTS TO THE INFORMATION REGULATOR
1. If any Data Subject or Third Party is of the view or belief that WTTX has Processed their Personal Information/Personal Data in a manner or for a purpose which is contrary to the provisions of this Policy, the Data Subject is requested to first attempt to resolve the matter directly with WTTX , failing which the Data Subject or Third Party shall have the right to lodge a complaint with the Information Regulator, under the provisions of POPIA.
2. The current contact particulars of the Information Regulator are:
  The Information Regulator (South Africa)
  Website: https://www.justice.gov.za/inforeg/index.html
  JD House 27 Stiemens Street Braamfontein Johannesburg, 2001
  PO Box 31533
  Braamfontein, Johannesburg, 2107

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