1 Introduction
1.1
This is the Privacy Notice of Prodis (Pty) Ltd available at www.prodis.co.za (Website), which applies to the personal information of Prodis’s customers and suppliers, business partners, prospective employees, and visitors (you).
1.2
Prodis respects privacy rights and complies with all laws in respect of the handling of personal information, including collection, use, storage, sharing and disposal.
1.3
This Privacy Notice helps you understand how Prodis handles personal information when you use the Website or interact with us in other ways such as at our offices or over the telephone or email.
1.4
This Privacy Notice does not apply to any third-party websites which may be accessible through links on the Website. Prodis makes no representations or warranties about the privacy practices of any third party and does not accept any responsibility for the privacy practices of, or content displayed on, third party websites. Third party website providers are responsible for informing you about their own privacy practices.
2 Changes to Privacy Notice
Prodis may change or update this Privacy Notice from time to time. Any updated versions of this Privacy Notice will be posted on the Website and will be effective from the date of posting. Where practical, and at Prodis’s discretion, notice of the change will be displayed on the Website.
3 What personal information does Prodis handle?
3.1
When used in this Notice, the term “personal information” has the meaning given to it in the Protection of Personal Information Act, 2013 (POPIA). Personal information is any information that can be used to personally identify a natural or juristic person. Special personal information is any information that is considered by law to be particularly sensitive information. This includes information related to your health, sex life, race, ethnic origin, religious or philosophical beliefs, trade union membership, political persuasion and criminal behaviour and biometric information. More restrictions apply to the handling of special personal information and the information of children because they are particularly sensitive.
3.2
We may collect, use, store and otherwise handle by any means (also known as “processing”) the following personal information, whether that information is provided by you or by a third party:
- Your biographical information ► including your name, gender, date of birth, language, nationality;
- Your contact information ► including your telephone number(s), address, email address, country of residence;
- Supplier onboarding information ► including black economic empowerment certificate, tender information, references
- Communications ► including correspondence with you;
- Website information ► including information collected through cookies when you use our website to which our cookies policy applies, or other information you provide to us when using our website;
- In addition, we may collect any other information relating to you which we lawfully receive, and which may be relevant to your dealings with Prodis. If the information that Prodis collects personally identifies you, or you are reasonably identifiable from it, Prodis will treat it as personal information.
4 How does Airlink collect your personal information?
4.1
Prodis collects your personal information directly from you in the following ways, namely when you:
- access to and use of the Website or any of our mobile platforms or applications;
- visit Prodis’s offices or other premises;
- register an account with us;
- purchase products and other services from Prodis;
- address a query to us;
- interact with us on social media; or through direct messaging systems
- enter a promotional competition run by us;
- apply to Prodis for employment;
- communicate with Prodis in any way; and
- have a business relationship with Prodis.
4.2
Prodis also collects your personal information from third parties when you sign up for industry specific events.
5 What happens if you do not permit Prodis to collect your personal information?
If you do not provide Prodis with your personal information where Prodis requires it, you may not be able to stay in contact in regard to Prodis news and offerings, or have no access to certain portions of the Website which may restrict your dealings with Prodis.
6 For what purposes does Prodis handle your personal information?
6.1
The law permits us to handle personal information where there is a lawful purpose and justification for doing so. Justifications include where we have your consent, where it is necessary to perform or conclude a contract with you, where it is in our or your legitimate interests or where the law requires us to do so. The purposes for which we handle personal information are set out below
6.2
We are only permitted to handle your special personal information under limited circumstances. We will only do so with consent or where we are otherwise permitted by the law.
6.3
We will only handle your personal information for the purposes for which we have obtained it and on a ground of justification stated in POPIA. The purposes include:
- To manage our relationship with you ► to ensure compliance with laws and to be able conduct our business with you, engage with you or market and provide our services to you, authenticate your identity, to enable us to communicate with you and provide information to you and keep our records updated. Justification: (i) To conclude or perform in terms of a contract with you; (ii) Your consent where we ask for it and no other ground of justification applies.
- To manage loyalty membership programmes ► including administering loyalty benefits Justification: To conclude or perform in terms of a contract with you.
Justification: (i) To enable us to comply with legal obligations; (ii) Our legitimate interest.
6.4
Where we cannot rely on an alternative legal justification for our handling of your personal information above, we will rely on your consent. Where we do so, you are free to withdraw your consent at any time by contacting us. However, where you withdraw your consent, the consequences in section 6 may apply.
6.5
Generally, where you are our supplier, we handle your personal information on the basis that it is necessary to do so in connection with our contract with you. We may also handle your personal information to further our legitimate interests, such as to optimise the working environment, and our other business interests or in terms of the law. In all instances we will have a lawful justification to handle your personal information.
7 To whom does Prodis disclose your personal information?
7.1
Prodis will not disclose your personal information to any employees, affiliates, contractors or third-party service providers
7.2
We will never sell personal information.
8 Direct marketing
8.1
If you are a customer of Prodis we may send you marketing communications from time to time that may be of interest to you. Each time you receive such a communication from us, there will be a simple and convenient method of opting out of receiving future marketing communications from us.
8.2
If you are not a customer of Prodis we may request your permission to send you marketing communications from time to time that may be of interest to you. If you decline the request, Prodis will not send you marketing communications.
9 Security and storage
9.1
We may hold personal information in either electronic form. In both cases we will take reasonable and appropriate steps to ensure that the personal information is protected from misuse and loss and from unauthorised access, modification, or disclosure.
9.2
We keep personal information for as long as we need to achieve the purpose for which it was collected and any other permitted linked purpose (for example your personal information which is relevant to a transaction may be retained until the time limit for claims in respect of the transaction has expired or to comply with regulatory requirements regarding the retention of such information). If personal information is handled for 2 purposes, we will retain it until the purpose with the latest period expires but we will stop using it for the purpose with a shorter period once that period expires.
9.3
Personal information is destroyed or irreversibly anonymised when no longer needed or when we are no longer required by law to retain it (whichever is the later).
9.4
We restrict access to the personal information to those authorised persons who need to use it for the relevant purpose(s).
10 How can you exercise your rights?
10.1
You have the right to contact us at any time requesting:
- confirmation that we have your personal information; and
- access to the records containing your personal information or a description of the personal information that we hold about you.
10.2
You also have the right to object to our handling of your personal information on reasonable grounds where our justification for doing so is our or your legitimate interests.
10.3
When making a request we require adequate proof of identity which will include providing a certified copy of your identity or registration document/s.
10.4
We will try to provide you with suitable means of accessing information, where you are entitled to it, by for example, posting or emailing it to you.
10.5
If you believe that any personal information that we hold about you is inaccurate, irrelevant, outdated, incomplete or misleading, you may request us to correct it. If you believe that any personal information that we hold about you is excessive or has been unlawfully obtained or that we are no longer authorised to retain the information, you may request that we destroy or delete it. We will consider if the information requires correction, deletion or destruction and if we do not agree that there are grounds for action, you may request that we add a note to the personal information stating that you disagree with it.
You also have the right to complain to the Information Regulator where you believe that we are not handling your personal information in accordance with the law. Complaints may be sent to the following email address: complaints.ir@justice.gov.za
11 Unlawful access to your personal information
If you believe that your personal information has been unlawfully accessed or acquired, you may contact Prodis’s Information Officer using the contact information below and provide details of the incident so that Prodis can investigate it.
12 Changes to personal information
We are required to take steps to ensure that the personal information we hold is accurate, complete, relevant, not misleading and up to date. Should your personal information (or the personal information you provide) change, you must inform us and provide us with all changes as soon as reasonably possible to enable us to update the personal information.
13 Contact information
If you have any questions about this Privacy Policy, or you wish to update your personal information or exercise any of your data subject rights you may contact Prodis’s Information Officer at: yolandi@prodis.co.za
When contacting us, please provide your name and other identifying information that you know we have in connection with you and a means through which we may reply to you (preferably an email address) so that we can deal with your communication efficiently.