- Cortac (Pty) Ltd and its associated Companies / subsidiaries / portfolios / subgroup(s) (as fully described in our Section 51 Manual and for ease of reference herein referred to as “Cortac”) are committed to data protection and the right to privacy. This policy sets out the basis on which Personal Information collected from a Data Subject or that a Data Subject provides is processed.
- As a responsible party under the Protection of Personal Information Act, 2013 and the Regulations thereto (the “Act”), we shall use our best endeavours to ensure that Personal Information is processed as required by the Act.
- For purposes of this policy: –
- Act refers to the Protection of Personal Information Act, 2013 and the Regulations promulgated thereto.
- Data Subject has the meaning ascribed thereto in section 1 of the Act.
- Our Website means cortac.co.za and/or Cortac’s associated social media pages and/or mobile Application/(s).
- Personal Information has the meaning ascribed thereto in section 1 of the Act;
- Process has the meaning ascribed thereto in section 1 of POPIA.
- Services means collection of online content provided for information purposes on our Website.
- ‘users’ or ‘you’ or ‘your’, as required by the context, means all visitors to our Website, including members of the public or legal entities accessing the Website for information purposes; members of the public or legal entities submitting advertisements, comments, files, images, videos, sounds, business listings and/or information, service and information requests and/or any other material or data (‘Content’); web search engines; and data and/or information aggregators.
- ‘we’ or ‘us’ or ‘our, as required by the context, means Cortac.
- This policy should be read together with our “Website terms and conditions” and our “Section 51 Manual”, which are both available on our Website.
- By using our Website and/or our Services and communicating electronically with us, you consent to the processing, including the transfer of your Personal Information, as set out in this policy.
We are continually improving our methods of communication and adding new functionality and features to our Website. Due to these ongoing changes, changes in the law and the changing nature of technology, our data protection practices will change from time to time. If and when our privacy protection practices change, we will update this policy, to describe such new practices and you are encouraged to check regularly for such updates and/or revisions.
- We endeavour to keep our Website secure at all times. We do however advise you that we cannot guarantee the security of any information provided to us or by us through our Website, email, internet or social media channels. We cannot be held responsible for any loss or unauthorised use or interception of information transmitted via the internet which is beyond our control.
- Information we collect
2.1 We process Personal Information relating to both natural and juristic persons in the operation of our Website, in carrying out our business and organisational functions, and to provide our services.
2.2 You may provide Personal Information to us either directly or indirectly, by requesting information in respect of our products and services, or by entering into a service agreement with us, or by placing an order or making a purchase from us, whether in writing, through our Website, over the telephone, or any other means.
2.2 When you visit our Website we may collect certain information that is not Personal Information, which information when viewed independently from other identifying criteria, does not identify you personally (for example your Internet Protocol (‘IP’) address, operating system, browser type, and Internet service provider).
2.3 When you use our Website or our Services, we may collect Personal Information (any information of a personal nature by which you can be identified as an individual, such as your name, postal address, physical address, e-mail address, telephone number, postal code, fax number, gender, identity number, date of birth and company name) that you provide to us. In particular, we may collect and process the following information about you:
- information that you provide by filling in forms on our Website, subscribing to our newsletter, submitting a job application, taking part in a competition or survey, and requesting products and/or services;
- information submitted when you report a problem with our Website or our Services;
- information that constitutes records of correspondence between us;
- details of your visits to our Website (including traffic data, location data, weblog(s) and other communication data such as social media tracking pixels that allow platforms such as Facebook and Twitter to interact with our Website, and your activity thereon); and
- public Personal Information collected when monitoring other websites, for example to monitor digital conversations on public platforms to understand what people are saying about us, and/or our particular service industry in general.
- Your information may be combined from various sources.
- The Personal Information we process in the ordinary course of business include, but is not limited to: –
- information that is adequate, necessary, and relevant to enable us to effectively render a service or assist you in any manner required; such as your name, identity number, business registration number, employees or director’s Personal information, and contact information;
- electronic communications transmitted to us;
- information submitted to us in response to an employment advertisement; and
- The Personal information we process in the operation of our business, include but is not limited to: –
- customer information required to engage our Services and/or to make purchases from us;
- information required in compliance with domestic and foreign legal & regulatory requirements;
- the screening of visitors to our business premises through CCTV footage;
- the screening of visitors to our business premises in terms of COVID19 protocols;
- conducting searches for dangerous weapons; and
- completing an attendance register for security purposes to ensure that only authorised persons enter our business premises.
- Cookies & IP addresses
3.1 We may collect information about your computer (including your IP address, operating system and browser type) for system administration purposes. This information is statistical data about your browsing actions and patterns only.
3.4 Cookies enable us and/or our service provider to: –
3.4.1 estimate the size and usage pattern of our Website’s audience;
3.4.2 store information about your preferences, which allows us to customise our Website to your individual interests;
3.4.3 speed up your searches; and
3.4.4 recognise you when you return to our Website.
- Storage of data
4.1 We undertake to protect the Personal Information we process and we will use technology to help us do this.
4.2 The transmission of information via the Internet is however not completely secure, and we cannot guarantee the security of the information you transmit through our Website. Transmission of your information to our Website is entirely at your own risk. Once we have received your information, we will use appropriate procedures and security features to prevent unauthorised access.
4.2 When you have chosen or been given a password which enables you to access certain parts of our Website (if applicable), you are responsible for keeping that password confidential. Please do not share your password with anyone.
- Third Parties
5.1 Our Website may occasionally contain links to Third Party Websites. If you click on links to Third Party Websites, you leave our Website. We are not responsible for the content of Third Party Websites or for the security of your Personal Information when you use them.
- We may share your Personal Information with the following third parties:
- our agents and suppliers, including those who provide us with technology services such as data analytics, hosting and technical support;
- our professional advisors, auditors and business partners;
- Regulators, Governments and Law enforcement authorities; and
- other third parties in connection with re-organising all or any part of our business.
- Use of Personal Information
6.1 We may use the information (including Personal Information) we hold about you in the following ways:
6.1.1 to ensure that content from our Website is presented in the most effective manner for you and for your computer;
- in aggregate and de-identified form, for internal business purposes such as generating statistics and developing our strategic and marketing plans;
- to provide you with information, products or services that you request from us or which we feel may interest you, when you have consented to be contacted for such purposes (including online / webcast events; press releases; job postings; financial results and marketing communications about our products and/or services);
6.1.4 to allow you to participate in interactive features of our Website when you choose to do so;
- to carry out any contracts entered into between us;
- to comply with applicable laws, regulations and guidance notes;
- to comply with demands or requests made by Regulators, Governments, Courts and Law enforcement Authorities;
6.1.6 to respond to any queries you make; and
6.1.7 to notify you about important notices and updates to our terms, standard operating procedures (SOPs), policies, security alerts and administrative messages in respect of our Website and/or our Services.
6.2 We may use information provided by you to:-
6.2.1 enforce our rights in respect of agreements entered into with you;
6.2.2 monitor user activity and more effectively manage traffic on our Website;
6.2.3 provide customer services;
6.2.4 create and manage user accounts; and
6.2.5 to assist you with technical difficulties.
6.3 We may block certain users from using our Website.
- Retention of personal information
7.1 Personal Information will be retained for the period as required by law, and where we need to do so in connection with legal action or an investigation in which it is involved.
- Otherwise, we retain Personal Information only for as long as reasonably necessary to provide you with access to the Services you requested, or to allow us to respond to your request.
- Protecting Personal Information
8.1 We recognise that protecting your privacy is important to you. For this reason, we are committed to protecting the Personal Information you provide to us and we shall implement and maintain adequate data protection measures to accomplish this.
8.2 It is also important that you take all necessary and appropriate steps to protect your Personal Information yourself (for example by ensuring that all your login details, including passwords and access codes across your various devices and Websites accessed, are kept secure).
8.3 You may utilise our Website as an anonymous user, however, should the Personal Information you submit through our Website be protected by a unique user ID and customer password, you should not disclose your password information to anyone, and always remember to log off when you are using a shared computer. You are responsible for maintaining the confidentiality of your username and password and all uses of your account, whether or not you have authorised such use.
8.4 We have taken security precautions to safeguard your Personal Information. However, as with most electronic transactions, no method is 100% safe. While we strive to use commercially acceptable means to protect the Personal Information you provide, we cannot guarantee its security.
- Your rights in respect of Personal Information
9.1 You may access, remove, review, and/or make changes to Personal Information that you provide us with, which includes the right to: –
9.1.1 opt out of e-mail communications from us, including our notifications to you;
9.1.2 request the correction and/or deletion of your Personal information;
9.1.3 request the restriction of the processing of your Personal information, or object to that processing;
9.1.4 where applicable, withdraw your consent to the processing of your Personal information (where we are processing your Personal information based on consent);
9.1.5 withdraw your consent to receive marketing messages; and
9.1.6 request the receipt and/or the transfer of your Personal information provided to us, to another organisation, in a machine- readable form.
9.2 We will not change your preferences without your consent.
10.1 On rare occasions, we may be required to disclose your Personal Information because of legal or regulatory requirements. In such instances, we reserve the right to disclose your Personal Information as required in order to comply with our legal obligations, including complying with court orders and/or warrants and/or subpoenas and/or service of process requirements and/or discovery requests.
10.2 We may also disclose information about our users to law enforcement officers or others, in the good faith belief that such disclosure is reasonably necessary to enforce our Website terms and conditions and/or this Policy and/or respond to legal claims that any content violates the rights of third parties and/or to protect our Intellectual Property rights and/or our personal safety or the personal safety of our users or the general public.
10.3 By submitting Personal Information to us you indemnify and hold us harmless from any loss, damages or injury that you may incur as a result of any unintentional disclosures of your Personal Information to unauthorised persons or the provision of incorrect or incomplete personal information to us.
10.4 We will notify you of any transaction in which substantially all of our assets are sold to or merged into another company, including assets which contain your Personal Information. The acquiring company will have access to your Personal Information without your consent.
- Notification of changes
We reserve the right to change this policy from time to time in our sole discretion, and will notify you of material changes to this policy by publishing such changes on our Website.
- How to contact us