Last updated: July 01, 2021
1. This policy explains how we obtain, process and disclose your personal information, in accordance with the requirements of the Protection of Personal Information Act (“POPIA”).
2. We are committed to protecting your privacy and to ensure that your personal information is collected and process properly, lawfully and transparently.
3. RESPONSIBLE PARTY
3.1. The entity responsible for the processing of your personal information (the Responsible Party) is: Name: Citiblu Proprietary Limited Address: First Floor, Block D, Midridge South, International Business Gateway,Midrand,1685
4. DEFINITION
“Data Subject” means an individual who is the subject of personal data. In other words, the data subject is the individual whom particular personal data is about. The Act does not count as a data subject individual who has died or who cannot be identified or distinguished from others.
“Personal information’’ means information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person. Further to the POPI Act, Promote Balance also includes the following items as personal information:
All addresses including residential, postal and email addresses.
Change of name – for which we require copies of the marriage certificate or official change of name document issued by department of Home Affairs or state department.
5. INFORMATION WE COLLECT AND RECEIVE
5.1. We collect and receive information about you in the following ways:
5.2. Information you provide us which includes any information that you provide to us directly:
5.2.1. when you sign-up to utilise our services;
5.2.2. by filling in forms on our websites, or those provided to you;
5.2.3. when you enter a competition, promotion or complete a survey;
5.2.4. by posting comments or content on our social media pages; or
5.2.5. when you contact us or we contact you and you provide information directly to us.
5.3. What personal information we collect
5.4. When you register to use our services, you will be required to provide us with the following information, your:
5.4.1. names and surname; contact details; company information; physical addresses; identity number/s and or passport numbers; date of birth;
5.4.2. electronic identification data: IP address;
5.4.3. education history; employment history; financial information; gender; language; nationality; marital status tax related information; a copy of your current electricity bill; and bank account information.
5.5. Information we collect or receive when you use our website or social media platforms
5.5.1. We collect information when you use our website or social media platforms by using cookies, web beacons and other technologies. Depending on how you access and use websites, we may receive:
5.5.1.1. log information (information about your interactions with us on our website, the time and date of your visit, the time spent on our website, the content you view and the search queries you submit);
5.5.1.2. information we infer about you based on your interaction with products and services;
5.5.1.3. device information (for example the type of device you’re using, how you access platforms, your browser or operating system and your Internet Protocol (“IP”) address, your device’s serial number);
5.5.1.4. location information (your device’s GPS signal and information about nearby WiFi networks and cell towers). We get this information when you use location-enabled services. You can disable location services when you use the website, or through your device settings.
5.5.1.5. Please refer to our cookie policy for more information on our use of cookies.
5.5.1.6. Information from third-party sources
5.6. We may receive additional information about you that is publicly or commercially available and combine that with the information we have collected or received about you in in other ways.
6. HOW WE USE THE INFORMATION WE COLLECT AND RECEIVE
6.1. We use the information we collect and receive for the following general purposes:
6.1.1. to provide you with information, products or services you request from us;
6.1.2. to communicate with you over various communication channels, including email, through WhatsApp or on the phone;
6.1.3. to provide you with support;
6.1.4. to conduct a credit check; and
6.1.5. to provide effective advertising (for example, to be provide you with news, special offers and general information about other goods, services and events which we offer, that are similar to those that you have already hired or enquired about).
7. HOW WE SHARE THE INFORMATION WE COLLECT AND RECEIVE
7.1. We do not sell your personal information to third parties for their marketing purposes.
7.2. We may share information with:
7.2.1. to a limited number of our employees and third party service providers (other than those who we refer you to), who we assist you to interact with;
7.2.2. our business partners. We may share non-personally identifiable information with select business partners;
7.2.3. other parties in response to legal process or when necessary to conduct or protect our legal rights;
7.2.4. Companies that provide services to us or act on our behalf may have access to information about you. These companies are limited in their ability to use information they receive in the course of providing services to us or you; and
7.2.5. third-parties where you provide consent. In some cases, third-parties (often advertisers) may wish to attain information about you in order to promote their products to you, or for whatever other reason. We may share information with third-parties where you provide consent in the form of an explicit opt-in. Before we ask you to opt-in, we will endeavour to provide you with a clear description of what data would be shared with the third-party. Remember that once you have opted in to allow us to send your information to the third-party, we cannot control what they do with
your data; therefore, be sure to investigate their privacy policies before providing permission for us to share your information.
8. YOUR RIGHTS
8.1. You have the right to ask us not to contact you for marketing purposes. You can exercise this right at any time by using any of the various “opt-out” options that we will always provide to you when we communicate with you. We will not send you marketing messages if you tell us not to but we will still need to send you service-related messages.
8.2. We want to make sure that any data we hold about you is up to date. So, if you think your personal information is inaccurate, you can ask us to correct or remove it.
9. DIRECT MARKETING
9.1. Citiblu shall ensure that:
9.1.1. It does not process any personal information for the purpose of direct marketing (by means of any form of electronic communication, including automatic calling machines, SMS’s or e-mail) unless the data subject has given his, her or its consent to the processing or is an existing client.
9.1.2. It will only approach data subjects, whose consent is required and who have not previously withheld such consent, once in order to request the consent. This will be done in the prescribed manner and form.
9.1.3. The data subjects will only be approached for the purpose of direct marketing of the Citiblu’s own services. In all instances, the data subject shall be given a reasonable opportunity to object, free of charge and in a manner free of unnecessary formality, to such use of his, her or its electronic details at the time when the information is collected.
9.1.4. Any communication for the purpose of direct marketing will contain details of the identity of the sender or the person on whose behalf the communication has been sent and an address or other contact details to which the recipient may send a request that such communications cease.
10.
11. MINORS
You must be 18 years or older to use this website. We do not knowingly collect, disclose, or sell the personal data of minors. If you are a minor please do not provide any personal data even if prompted to do so. If you believe that you have inadvertently provided personal data, please ask your parent(s) or legal guardian(s) to notify us and we will delete your personal data.
12. RETENTION OF DATA
We will retain your personal information only for as long as is necessary for the purposes set out in this privacy policy or to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.
13. SECURITY
The security of your data is important to us. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. However, we do employ a number of safeguards intended to mitigate the risk of unauthorised access or disclosure of your information. We will do our best to protect your personal information and we will use up
to date technology that will help us to do this. We will at all times comply with our obligation under applicable law.
14. TRANSFER OF DATA
14.1. We are based in and operate from South Africa. Your information, including personal information, may be transferred to and maintained on servers located outside of your country of residence, where the data privacy laws, regulations and standards, may not be equivalent to the laws in your country of residence.
14.2. We might transfer your personal information to places outside of South Africa and store it there, where our suppliers might process it. If that happens, your personal information will only be transferred to and stored in country that has equivalent, or better, data protection legislation than South Africa or with a service provider which is subject to an agreement requiring it to comply with data protection requirements equivalent or better than those applicable in South Africa.
14.3. Your use of our website, followed by your submission of information to us, represents your consent to such transfer.
14.4. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
15. LINKS TO OTHER WEBSITES
Our website or social media platforms may contain links to and from websites, mobile applications or services of third parties, advertisers or affiliates. Please note that we are not responsible for the privacy practices of such other parties and advise you to read the privacy statements of each website you visit which collects personal information.
16. CHANGES TO THIS PRIVACY POLICY
We may update this privacy policy from time to time. Any changes that we may make to our privacy policy will be posted on our website and will be effective from the date of posting.
17. ACCESS TO YOUR PERSONAL INFORMATION
17.1. You may at any time request:
17.1.1. confirmation that we hold your personal information;
17.1.2. access to your personal information;
17.1.3. the identities or categories of third parties to whom we have disclosed your personal information; or
17.1.4. that we correct or delete any personal information that is incomplete, misleading, inaccurate, excessive or out of date.
17.1.5. In order to exercise these rights, please refer to our PAIA Manual.
18. CONTACT US
1. If you have a question, concern or complaint regarding the way in which we handle your personal information, please contact Abelphard Murimbika at abelphard@citiblu.com
2. You can also lodge a complaint with the Information Regulator of South Africa using the contact details listed below:
1. Tel: 012 406 4818
2. Fax: 086 500 3351
3. Email: complaints.ir@justice.gov.za.