PoPI POLICY

PROTECTION OF PERSONAL INFORMATION STATEMENT
(“POPI Statement”)

1. INTRODUCTION
We care about privacy issues and want you to be familiar with how we collect, disclose, and otherwise use (“Process”) information about you. This Protection of Personal Information (POPI) statement forms part of the Teamwork Computer CC (“TWC”) terms and conditions. It seeks to explain how TWC may collect, share and use your Personal Information (PI). If you do not agree with any term/s of this POPI statement, you must cease your access of our website immediately.

2. COLLECTION
We may collect PI directly from you, and where lawful and reasonable, we may collect PI about you from third parties and publicly available sources.
We may collect your PI through our website, social media pages we control (“Social Media Pages”), and software applications we make available for use on or through computers and mobile devices (“Apps”), and through any of our offline activities, such as when you provide your PI on the phone or in person (“Offline Activities”) (collectively, including the website, Apps, Social Media Pages, and Offline Activities, the “Services”)
WHAT INFORMATION IS COLLECTED AND HOW IT IS COLLECTED?

2.1. We may collect “Personal Information” (information that identifies you or relates to you as an identifiable person) about you such as your:

• Name
• Postal address (including billing, shipping and service delivery address)
• E-mail address
• Credit and debit card numbers and details
• Financial information in certain circumstances
• Social media account information
• Driver’s license, Identity Document, or Passport
• Geolocation information
• Communication, product, service or other preferences
• Your opinions, comments, suggestions, inquiries and other communications you provide to us
• Demographic information
• Audio/visual recordings such as when you call or attend on our offices
• Internet Click Activity on our website
• Internet Protocol (“IP”) address or Device ID
• Subscriber Account details, including username, password and transaction information.

2.2. We may collect information from you when you interact with us such as when you:

• Register for, subscribe to, use, or make a payment for a product or service
• Contact us with a query or request
• Use our Services
• Provide feedback or participate in a survey
• “Like”, “Follow” or otherwise connect with or post on our Social Media pages
• Provide goods or services to us (Eg. As a vendor or contractor)

2.3. Other information we may collect about you:
• We may receive your PI from other sources, such as public databases, joint marketing partners, data firms, social media platforms, from people with whom you are friends or otherwise connected on social media platforms, as well as other third parties.
• We may collect certain data when you submit a support request, including information about your hardware, software and other information related to your support requirement. We will use this support data to resolve your support incidents / queries and for training and product development purposes.
• Location data may be collected, but only with consent. We will only share his information with our mapping provider for the purpose of mapping customer locations.
• When you use or access our Services from a device, we may collect information such as your unique device ID and your location, date and time of usage. If you download and use an App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number, as well as any other Personal Information specified by the App in its terms or notices.
• We use Google Analytics to help us get a better understanding of how visitors use this Website and to facilitate interest-based advertising associated with your Google Account and other devices you use. The information generated by the Google Analytics cookie about your use of this Website is transmitted to and stored by Google. If you do not want your activity on this Website to be tracked by Google Analytics, you may opt out of this means of data collection.
• We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use our Services and other websites, apps or online services, based on information relating to your access and use of our Services and other websites, apps and services on any of your devices, as well as information received from third parties. To do so, these companies may place or recognize a unique cookie on your browser (including through the use of pixel tags). They may also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. If you would like more information about this practice, and to learn how to opt out please do contact us and we will assist.
• In addition to any Personal Information or other information you choose to provide to us or that we otherwise collect about you as described in this POPI Statement on the Services, we and our third-party service providers may use a variety of technologies, now and hereafter devised, that automatically collect certain website usage information whenever you visit or interact with the Services. This information may include browser type, operating system, the page served, the time, the source of the request, the preceding page view, and other similar information. We may use this usage information for a variety of purposes, including to enhance or otherwise improve the Services. In addition, we may also collect your IP address or some other unique identifier for the particular device you use to access the Internet, as applicable. When analyzed, usage information helps us determine how our Services are used, such as what types of visitors arrive at the Services, what type of content is most popular, what type of content you may find most relevant and what type of visitors are interested in particular kinds of content and advertising. We may associate your website usage information with the Personal Information you provide, but we will treat the combined information as Personal Information.

We use information in a variety of ways, including to analyze site traffic, understand customer needs and trends, and to improve our services.
WEBSITE LINKS
Some pages of our websites contain external links. You are advised to verify the privacy practices of such other websites as TWC is not responsible for the manner of use or misuse of information made available by you at such other websites.

3. USE AND MANAGEMENT

HOW WE USE YOUR INFORMATION AND WHY

3.1. We may Process Personal Information in connection with any of the following:

3.1.1. Our business transactions with you, including, but not limited to:
• Entering into or performing a contract with you
• Responding to your inquiries and fulfilling your requests
• Sending administrative information to you, for example, information regarding the Services or relating to a service or product we provide
• Completing and fulfilling any purchases or requests for services, which may include sharing our payment data with the banks and other third party financial institutions to process your payment transactions, or for fraud prevention

3.1.2. For our legitimate business interest, including but not limited to:
• Personalizing your experience on the Services by presenting products and offers tailored to you.
• Facilitating social sharing functionalities of your social media account/s.
• Carrying out data analysis, audits, fraud monitoring and prevention, internal quality assurance, developing new products, enhancing, improving or modifying our Services, identifying usage trends, auditing use and functionality of our Services, helping enforce compliance with our Terms of Use, helping protect our Services, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
• Subject to your marketing preferences (which may include consent to marketing under applicable law), sending you newsletters or marketing communications we believe may interest you, for our own products and services, and on behalf of third parties / service providers, contractors and agents acting on behalf of TWC, in accordance with applicable law.
• Publishing your company name as a listed customer on our website, advertisements and promotional materials.

3.1.3. In accordance with any consent you have provided
• You have the right to decline to provide your consent and, if consent is provided, to withdraw it at any time.

3.1.4. As necessary or appropriate for legal reasons, including but not limited to:
• As required by law;
• To comply to lawful process;
• Responding to requests from public and government authorities, including those outside your country of residence;
• Enforcing our terms and conditions in connection with the Services and the service we provide;
• Protecting our operations or those of any third parties / service providers, contractors and agents acting on behalf of TWC;
• Protecting our rights, privacy, safety or property or those of any third parties / service providers, contractors and agents acting on behalf of TWC;
• Allowing us to pursue available remedies or limit damages we or those of any third parties / service providers, contractors and agents acting on behalf of TWC.

4. PROCESSING
The processing of your information will align to the Protection of Personal Information Act, 4 of 2013 (“the POPI Act”). TWC will only process your personal information, where it is lawful to do so. We will not process your PI for a purpose which is incompatible with the purpose for which it was collected unless you have agreed to an alternative purpose or TWC is permitted in terms of national legislation of general application dealing primarily with the protection of personal information. In instances where you have the right to object to the processing of your personal information, such requests must be submitted to us in writing.

5. DISCLOSURE
We may disclose your information as follows:
• TWC will only disclose your personal information if you have agreed that we may disclose your personal information, where we have a duty or a right to disclose in terms of legislation or industry codes, as well as where we believe it is necessary to protect our rights.
• We may disclose your personal information within our group of companies, or those of any third parties / service providers, contractors and agents acting on behalf of TWC for the purposes described in this Statement, unless prohibited by law or by specific contractual agreement.
• We may disclose your personal information to a third party (eg. A prospective buyer or insolvency practitioner) in connection with any change in control of any part of our business or the business of any company within the group of companies, including, without limitation, merger, consolidation, divestiture, spin-off, purchase of all or a substantial portion of our assets, dissolution, liquidation, administration, receivership or other form of insolvency.
• We may disclose your Personal Information to law enforcement authorities, government or public agencies or officials, regulators, and/or to any other person or entity having appropriate legal authority or justification for receipt of your information, if required or permitted to do so by law or legal process, to respond to claims, or to protect our rights, interests, privacy, property or safety, and/or that of any third parties / service providers, contractors and agents acting on behalf of TWC.

6. THIRD PARTIES
TWC will share your Personal Information with its third parties, i.e. service providers, affiliates and other trusted businesses or persons, only for the purpose of processing your Personal Information in compliance with this Statement.
Prior to sharing your PI with a third party, TWC will conduct a due diligence to identify any possible risks posed by inadequate controls.
All third parties who process PI will do so under a written contractual arrangement which will include obligations on the third party in terms of the POPI Act.
TWC will not share your information with any third party that does not comply with the terms of our POPI Policy.

7. SECURITY SAFEGUARDS
We are legally obliged to provide adequate protection for the personal information we hold and to prevent unauthorised access and use of your personal information. We will take all the reasonably necessary technical and organisational measures to protect your personal information and continue to review our security controls and related processes to ensure that your personal information is secure.
Access to your personal information is restricted to employees, third parties / service providers, contractors and agents acting on behalf of TWC, who need to know such information in connection with our products and services, and for the purpose of processing your Personal Information in compliance with this Statement.

8. RETENTION
TWC will only keep your personal information for:
• as long as necessary for the purposes for which it is processed;
• as long as we have an ongoing relationship with you;
• as long as needed to provide services to you; and/or
• as long as necessary to comply with legal and contractual obligations.

9. MARKETING
We may use your personal information to market our products and services to you. When we do, we will do so in person, by post, telephone, or electronic channels such as SMS, e-mail and fax.
If you are not our customer, or in any other instances where the law requires, we will only market to you by electronic communications with your consent.
In all cases, you can revoke your consent to marketing communications to you at any time.

10. ACCESS TO YOUR PERSONAL INFORMATION
TWC recognises your rights to access all the personal information that we may hold about you and our responsibility to enable you to access this information. To this end, you may request access through our Personal Information Officer in writing at POPI@twcgroup.co.za.

11. CORRECTION OF YOUR PERSONAL INFORMATION
• You accept the responsibility for providing us with accurate Personal Information and for keeping Personal Information that you provide to us up to date, and undertake to inform us of any changes to Personal Information. If you believe that the Personal Information we hold about you is inaccurate or incomplete, please contact us and we will use all reasonable efforts to correct the information.
• You have the right to request us to update, correct or delete your personal information. You may do so in writing by contacting us at the numbers / addresses provided below.
• If, on receipt of a request from you to correct or delete your Personal Information, we do not believe the Personal Information we hold about you to be incorrect, we will retain your Personal Information in its original form but we will take reasonable steps at your request to add a statement to the Personal Information stating that you believe the information is inaccurate, incomplete or out of date.
• We will take all reasonable steps to confirm your identity before making changes to personal information we may hold about you.

12. WITHDRAWAL OF CONSENT
If the processing of your Personal Information is based on consent, you may withdraw consent granted at any time. We will delete your Personal Information within a reasonable time after you withdraw your consent, but we may not be able to continue providing the services to you thereafter. Please note that the withdrawal of your consent does not affect our right to continue to collect, use and disclose your Personal Information where such collection, use and disclosure without consent is permitted or required under the applicable laws.

13. CHANGES TO THIS STATEMENT
Please note that we may amend this Statement from time to time. Please check this website periodically to inform yourself of any changes.

14. CONTACTING US
If you have questions about this Statement or believe we have not adhered to it, or need further information about our POPI standards or wish to give or withdraw consent, exercise preferences or access or correct your personal information, please contact us at the following numbers / addresses:
Information Officer
Tel: 087 354 9005
Email: POPI@twcgroup.co.za

15. Contacting the Information Regulator
You have the right to complain to the Information Regulator, whose contact details are:

The Information Regulator

JD House
27 Stiemens Street
Braamfontein
Johannesburg
2001

Tel: +27 (0) 10 023 5200

Complaints email: complaints.IR@justice.gov.za

General enquiries email: inforeg@justice.gov.za