Privacy Policy

Last updated 29 June 2021

This Privacy Notice describes how Impophomo Rushing Waters (“The Company”, “us”, “we”, or “our”) collects, uses, discloses, retains, and protects all personal information, in accordance with the Protection of Personal Information Act (POPIA) and other relevant laws.

The Privacy Notice applies to any website, application, form, document, product, or service which references this Privacy Notice. It also supplements any other privacy policies which may apply in respect of The Company entities’ processing of personal information.

POPIA defines personal information as “information which relates to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person”. This includes, but is not limited to, your name, sex, gender, address, contact details, identity number and medical or health information.

How we collect information

We collect personal information about you and any other person whose details you provide to us in accordance with the relevant laws, either:

• Directly from you, electronically, telephonically or by way of a hard copy, when you complete:
  • Application Forms;
  • Attendance Registers;
  • Contracts;
  • Training Registers
• Indirectly from you when you interact with us electronically by way of our website, apps, or social media channels, which may include the collection of metadata (data about data)

Collection of information by third parties

The Company also uses certain social networking services such as Facebook, WhatsApp, Instagram, LinkedIn, and Twitter to communicate with the public and The Company clients. When you communicate with The Company through these services, that social networking service may collect your personal information for its own purposes. These services may track your use of our digital channels on those pages where the links are displayed. If you are logged into those services (including any Google service) while using our digital channels, their tracking will be associated with your profile with those service providers. These services have their own privacy policies which are independent of The Company’s privacy policies and practices. Please ensure that you fully acquaint yourself with the terms of any such third-party privacy policies and practices.

What information we collect

Your relationship with The Company determines the exact nature of the personal information The Company processes, and the purpose for which such personal information is collected and used. However, in many cases, if we are handling your personal information, the personal information we may process includes the following:

• Information about you – for example, your name, identity number, age, gender, date of birth, nationality, occupation.
• Contact information – in some cases, for example, we may receive your email, address, phone number and postal address.
• Online information – for example, cookies and IP address (your computer’s internet address), if you use our websites, apps and/or social media channels.
• In certain instances, we may need consent to process your personal information. If you give us your consent for a specific context, you are free to withdraw this consent at any time.

You may refuse to provide us with your personal information in which case we may not be able to provide you with a relevant service.

How we use your information

To the extent permissible under applicable laws, The Company may use your information:

• To provide you with our services, and maintain our relationship with you;
• To conclude and administer your profile;
• To execute a transaction in accordance with your request;
• To meet our contractual obligations with you and or a client;
• To comply with legislative and regulatory requirements;
• To execute the The Company’s strategic initiatives;
• To maintain the security of our digital channels and systems;
• For statistical analysis and research purposes;
• For audit and record-keeping purposes;
• For purposes of proof and legal proceedings;
• To prevent or control the spread of any disease; and

For any purpose related to and compatible with the above.

Sharing your information

Entities within the The Company will only share your personal information with third parties if there is a legitimate and or legal reason to do so.

• The Company will not sell, rent, or trade your personal information to any third party.
• The Company will disclose information when lawfully required to do so:
  • To comply with any relevant legislation;
  • To comply with any legal process; and
  • By any regulatory authority (for example, SARS).
• On occasion, The Company may – for legitimate purposes – share aggregated information with its stakeholders and business partners (for example, demographic data) in a manner that does not identify the persons to whom the information applies. However, The Company will not disclose your personal information to third parties unless there is valid processing ground as set out in section 11 of POPIA.

Security and storage of information

The Company intends to protect the integrity and confidentiality of your personal information. The Company has implemented appropriate technical and organisational information security measures to keep your information secure, accurate, current, and complete. However, we cannot guarantee the security of any information you transmit to us online and you do so at your own risk.

Your personal information will be held and used for as long as permitted for legal, regulatory, fraud prevention and legitimate business purposes.

Right of access to information

The Promotion of Access to Information Act (PAIA) coupled with POPIA offer an individual the right to access information held by a public or private body in certain instances. This right can be exercised in accordance with the The Company PAIA manual.

Correction of your information

In accordance with POPIA, you have a right to correct any of your personal information held by The Company. This right should be exercised in accordance with the procedure outlined in the The Company PAIA manual.

Objection to processing of your information

In accordance with POPIA, you may object to our processing of your personal information on reasonable grounds relating to your particular situation, unless legislation provides for such processing.

Clickstream data

In the interests of better customer service, The Company may collect anonymous information from visitors to its websites. For example, The Company keeps track of the domains from which people visit its website and also measures visitor activity on its website. In the process, The Company ensures the information cannot be used to identify you. This information is sometimes known as “clickstream data”. The Company or its analytics vendors (including Google Analytics) may use this data to analyse trends and statistics and to provide better customer service.

The information, referred to as traffic data, which may be collected includes:

• Your IP address;
• The search terms you have used;
• The pages accessed on the website and the links you’ve clicked on;
• The date and time you visited the website;
• The referring website (if any) through which you clicked through to our website; and
• The type of website browser you use.
• As mentioned, the traffic data is aggregated and not personally identifiable and our website analysis will also respect any ‘do not track’ setting you might have on your web browser.

Cookies

A cookie is a small text file that is downloaded onto ‘terminal equipment’ (for example, a computer or smartphone) when you access a website. It allows the website to recognise your device and store some information about your preferences or past actions.

What cookies do we use?

Some cookies which we use are essential to the functioning of our website. Some cookies help us with the performance and design of our website. This allows us to measure how many times a page has been visited, whether a page has been visited on the website through an advertisement or by other means. Other cookies help us to remember your settings which you may have selected or assist with other functionality when you browse and use our website. This helps us to remember what you have selected, so on your return visit – we remember your preferences. On certain pages of the website we use cookies to help us understand your interests as you browse the internet, so we can tailor and render to you more personalised content and services in the future. This assists us in delivering relevant advertising to you during various advertising campaigns we may run from time to time through participating third-party sites.

In addition, we also use cookies on certain pages of our website to communicate with third-party data suppliers in order to extrapolate your digital behaviour. This helps us to understand and target more relevant advertising in the future. The information we receive is all aggregate and anonymous, but will include statistics such as demographics, online behaviour, product interests and lifestyle.

How do I disable cookies?

If you do not want to receive a cookie from the website, you have the option of setting your browser to notify you when you receive a cookie, so that you may determine whether to accept it or not. However, please be aware that if you do turn off ‘cookies’ in your browser, you will not be able to fully experience some of the features of the website. For example, you will not be able to benefit from automatic log-on and other personalisation features.

Children

The Company’s websites are not directed towards children, however in the event of a minor accessing the websites, The Company is committed to complying with all applicable laws aimed at the protection of children and in particular the protection of their personal information.

Updates

This privacy statement was last updated on 29 June 2021. We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Particulars of The Company

Should you have a complaint or concern regarding the processing of your personal information, your complaint may be submitted to info@impophomo.co.za.

The Information Regulator

Whereas we would appreciate the opportunity to first address any complaints regarding our processing of your personal information, you have the right to complain to the Information Regulator, whose contact details are:

The Information Regulator (South Africa)

JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001

P.O. Box 31533, Braamfontein, Johannesburg, 2017

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

General enquiries email: inforeg@justice.gov.za