Privacy Policy

Prepared in terms of Section 51 of the Promotion of Access to Information Act No. 2 of 2000

Hereafter referred to as “the Policy”
for

PLANNED TALENT (Pty) Ltd

1. INTRODUCTION

We here at Planned Talent recognise and respect the right to privacy of our clients, customers, employees, and other stakeholders, and we are determined to work together to ensure that this right to privacy is fostered, protected and nurtured as far as it relates to the flow of personal information within our organisation.

This privacy policy sets out the systems and procedures that we follow with regard to the personal information that we collect. This policy intends to inform our stakeholders, or whomever it may concern, about the manner in which we deal with personal information.

We place great importance on the value of personal information and are determined to keep our information as well as the information we collect, secure and safeguard it against any malicious intent.

We, here at Planned Talent, also recognise the importance and authority of the Protection of Personal Information Act 04 of 2013 (hereafter POPIA) and have caused this policy to be drafted in accordance therewith. We are committed to promote the right to privacy, as envisaged in the Constitution, while at the same time protecting the flow of information and advancing the right of access to and protection of information.

This policy mainly applies to our organisation, including but not limited to our website and social media pages, you are kindly reminded and requested to ensure that to familiarise yourself with the privacy policies of any third parties or associates of Planned Talent whenever you are required to work with them.

2. THE PERSONAL INFORMATION THAT WE COLLECT ABOUT YOU

We collect and process your Personal Information mainly to provide you with access to our services and products, to help us improve our offerings to you, to support our contractual relationship with you and for certain other purposes explained below. The type of information we collect will depend on the purpose for which it is collected and used. We will only collect information that we need for that purpose.

It should be noted that Personal Information refers to the information relating to an identifiable person, including natural and juristic persons. Information that does not indicate or identify a person is not included in the description and or definition of personal information.

The personal information that we collect can be broadly summarized into the following general categories;

Identity Information: is information that concerning your name, username or similar identifier, marital status, title, date of birth, gender, race and legal status, as well as copies of your identity documents, photographs, identity number, registration number and qualifications;
Contact Information: which includes billing addresses, delivery addresses, email addresses and telephone numbers;
Transaction Information: which includes details about payments to and from you;
Service Information: which includes information relating to past and present services rendered to you by us or any of our associated, employees or contracted third parties;
Security Information: which may include records of your access to our facilities, as well as CCTV camera footage of you on or nearby our premises;
Technical Information: which may include records of your access to our facilities, as well as CCTV camera footage of you on or nearby our premises;
Usage Information: which includes information about how you use our Website, products and services; and
Marketing and Communications Information: which includes your preferences in receiving marketing from us and our third parties and your communication preferences

POPIA serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on POPIA. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services.

If our company is subject to a legal obligation by which processing of personal data is required, such as for the fulfilment of tax obligations, the processing is based on POPIA. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. In any other case or circumstance, the consent we obtain from the data subject will be the legal basis for processing of personal information.

If any information you provide us contains the processing of personal information of children (minors), for example, information given to us about a child during a complaint resolution process, this processing of personal information of children may only be carried out with the prior consent of the competent person such as a parent or legal guardian, unless lawful basis exist allowing us to process such information without the aforementioned consent.

We do not provide services directly to children, and our site is not available for use by any person under the age of 18 years without consent and supervision from a competent person such as parent or a legal guardian. This Privacy Notice also applies in a case where a child makes use of our website with the consent from a competent person. Use of our website by a child without the relevant consent from a competent person is prohibited.

3. COLLECTION OF NON-PERSONAL INFORMATION

We may automatically collect non-Personal Information about you such as the type of internet browsers you use or the website from which you linked to our website. We may also aggregate details which you have submitted to the site (for example, the products or services you are interested in). You cannot be identified from this information and it is only used to assist us in providing an effective service on this web site. We may from time to time supply third parties with this non-personal or aggregated data for uses in connection with this website.

4. HOW WE COLLECT YOUR PERSONAL INFORMATION

We collect personal information in three (3) ways, namely:

Through direct or active interaction with you;
Through automated or passive interactions with you; and
Through interactions with third parties.

4.1. Direct and Active Interactions with You

Our business processes are constructed in such a way that we may require you to submit certain information in order for you to access certain portions of the Website and to enable us to provide certain services to you. In other circumstances you might conclude an agreement with us where we would require you to provide us with certain information in order for us to provide services to you, or we might be in a position where we need to request certain information from you in order for us to fulfil our statutory obligations.

We also collect information directly from you when you communicate directly with us, for example via e-mail, telephone calls, feedback forms, site comments and forums. If you contact us, we may keep a record of that correspondence.

4.2. Automated or Passive Interactions with You and Cookies Policy

Our website uses cookies. Cookies are text files that are stored in a computer system via an Internet browser. Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.

Through the use of cookies, we can provide the users of this website with more user-friendly services that would not be possible without the cookie setting. By means of a cookie, the information and offers on our website can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognize our website users. The purpose of this recognition is to make it easier for users to utilize our website. The website user that uses cookies, e.g. does not have to enter access data each time the website is accessed, because this is taken over by the website, and the cookie is thus stored on the user's computer system. Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles that a customer has placed in the virtual shopping cart via a cookie.

We are entitled to keep, store, and utilise the information that we obtain via the implementation of Cookies Technology.

4.3. Interactions with Third Parties

Our business structure incorporates our relationships with various third parties whose services we use to obtain information to empower us to provide various services to you. For example, by employing the services of MIE to do a thorough background check on prospective applicants. You will participate in this arrangement and the process will be voluntary and with your consent.

We are also entitled to receive information about you from various third parties and public sources as far as it relates to providing services to you and to conduct our business.

The legal basis for using these services to obtain information will always be consent. By reading this policy and continuing to use our various digital platforms you consent to the way we use and collect your personal information.

5. HOW WE USE YOUR PERSONAL INFORMATION

We will use your Personal and Non-Personal Information only for the purposes for which it was collected or agreed with you, for example:

To provide services to you;
Analyse the effectiveness of our advertisements, communication and promotions;
Collect information about the device you are using to view the site, such as your IP address or the type of Internet browser or operating system you are using, and link this to your Personal Information so as to ensure that the site presents the best web experience for you;
Evaluate the use of the site, products and services;
For audit and record keeping purposes;
For market research purposes;
For monitoring and auditing site usage;
Help speed up your future activities and experience on the site. For example, a site can recognise that you have provided your Personal Information and will not request the same information a second time;
In connection with legal proceedings;
Make the site easier to use and to better tailor the site and our products to your interests and needs;
Offer you the opportunity to take part in competitions or promotions;
Personalise your website experience, as well as to evaluate (anonymously and in the aggregate) statistics on website activity, such as what time you visited it, whether you’ve visited it before and what site referred you to it;
Suggest products or services (including those of relevant third parties) which we think may be of interest to you;
To assist with business development;
To carry out our obligations arising from any contracts entered into between you and us;
To conduct market or customer satisfaction research or for statistical analysis;
To confirm and verify your identity or to verify that you are an authorised customer for security purposes;
To contact you regarding products and services which may be of interest to you, provided you have given us consent to do so or you have previously requested a product or service from us and the communication is relevant or related to that prior request and made within any timeframes established by applicable laws;
To notify you about changes to our service;
To respond to your queries or comments;
We will also use your Personal Information to comply with legal and regulatory requirements or industry codes to which we subscribe or which apply to us, or when it is otherwise allowed by law;

Where we collect Personal Information for a specific purpose, we will not keep it for longer than is necessary to fulfil that purpose, unless we have to keep it for legitimate business or legal reasons. In order to protect information from accidental or malicious destruction, when we delete information from our services we may not immediately delete residual copies from our servers or remove information from our backup systems;

6. DISCLOSURE OF YOUR PERSONAL INFORMATION

We may disclose your Personal Information to our business partners who are involved in the delivery of products or services to you. You consent to us disclosing your personal information with the following parties:

To third parties for the purposes listed above;
To our employees, suppliers, service providers and agents if and to the extent that they need to know the information in order to provide the services for or to us for which they have been appointed, such as hosting, development and administration, technical support and other support services relating to the Website or the operation of the ADvTECH business. We will authorise any information processing done by a third party on our behalf, amongst other things by entering into written agreements with those third parties governing our relationship with them and containing confidentiality and non-disclosure provisions;
To other companies in our industry when we believe it will enhance the services and products we can offer to you, but only where you have not objected to such sharing;
To other third parties from whom you have chosen to receive marketing information;
To anyone where we have a duty or a right to disclose in terms of law or industry codes;
To anyone where we believe it is necessary to protect our rights;
To anyone insofar as it relates to our legal obligation to provide adequate protection for the personal information we hold and to stop unauthorised access and use of personal information. we will, on an on-going basis, continue to review our security controls and related processes to ensure that your personal information is secure;
To anyone that has the legal right to access your personal information;
To anyone that is appointed by our company to update and set up computer and network security insofar as it relates to this purpose;

7. HOW WE STORE YOUR PERSONAL INFORMATION

We only keep and store personal information for as long as it is necessary to provide our services to you or as may be required in terms of legislation, internal business requirements, whichever period is longer. You are welcome to contact us to find out more about how long we store and retain your information.

The Personal information that you provide to us with, will be stored electronically on our servers or those of our service providers, as well as in hard copy format (when and where we find it necessary and in accordance with the nature of the services that we provide to you), with reasonable organisation and technical safeguards in place to protect your information. However, we do work with third party contractors, some of whom host and operate certain features of the website. Some of your information might also be stored and retained by them.

We may keep and process some or all of your personal information if and for as long as;

We are required or permitted by law or a contract with you to keep it;
We reasonably need it for lawful purposes related to our functions and activities;
We reasonably need it for evidentiary purposes; and or
You agree to us keeping it for a specified further period.

The period for which we retain your information will depend on the nature of services we provide to you, the legal requirements that we are required to adhere to, and or the agreement that you have with us. If the storage purpose is not applicable, or if a storage period prescribed by the POPIA or another competent legislator expires, your personal data will be erased. It is important to note that in order to avoid wrongful deletion of your personal information we retain all our data on various back-up drives, however your personal information will no longer be in use when it is erased from our main operating system.

8. THE ACCURACY AND SAFEGAURDING OF YOUR PERSONAL INFORMATION

You have the right to ask us to update, correct or delete your personal information. Even though, we take various reasonable steps to confirm your identity before making changes to Personal Information we may hold about you, we would appreciate it if you would take the necessary steps to keep your Personal Information accurate and up-to-date by notifying us of any changes we need to be aware of.

We value correct and reliable information and we will continue to make an effort to make sure that our information is of good quality, however, we cannot guarantee that your information is 100% correct and accurate and we appreciate your continuous support by notifying us of any changes.

9. ACCESS TO YOUR PERSONSONAL INFORMATION

You have the right to request a copy of the Personal Information we hold about you. To gain access to your information, please consult our PAIA Manual that is available on our website. You are also welcome to contact our information officer whose details are available below.

10. WAIVER OF CERTAIN RIGHTS

Taking this Privacy Policy into consideration and by continuing to work with us or continuing to utilise our facilities, including but not limited to the use of our website, you agree to waive the right to being notified and or informed of anything other than what has already been provided for in this policy document insofar as it is allowed in terms of legislation. We limit our duty to inform and notify you of any matters relating to your personal information to rights and responsibilities set out in this Privacy Policy. This waiver, however, does not influence your right to request access to your information or enquire as to how your information is being used.

We are committed to our stakeholders, including but not limited to, our customers, clients, employees, investors, contractors and any other relevant third parties, and we assure you that we will never do anything malicious, illegal or anything with ill intent. We strive to uphold our good reputation and to continuing to provide you with the best possible service.

11. YOUR RIGHTS

It is important for us that you know the rights that you have with regard to the personal information that collect from you. Kindly take notice that you have the following rights in respect of your personal information;

11.1. The Right of Confirmation

The South African Regulator has given you the right to obtain confirmation from us to whether or not we are processing your personal information. You are entitled to ask the information officer at any time during working hours to provide you with the detail of the manner in which your information is being process.

11.2. The Right to Access to your Personal Information

As stated above, you have the right to obtain the personal information that is in our possession insofar as it relates to you personally. You are specifically entitled to know if your personal information has been shared with any international entities. For information of this right, please consult our PAIA Manual that is available on our website.

11.3. The Right of Ratification

As stated above, you have the right to ratify any inaccurate information regarding you that is in our possession. You are also entitled to receive confirmation that your information has been corrected. For any amendments, additions or corrections of your personal information, you are required to contact the information officer whose details are set out below.

11.4. The Right of Erasure

The South African Regulator has granted you the right to request us to erase and or delete the personal information that we have in possession insofar as it relates to you personally. You are entitled to request us to erase your personal information on the following grounds;

The personal information is no longer necessary for the purposes for which it was collected or otherwise processed;
You withdraw your consent for us to processing the information and that consent is the legal bases for our right to process it and there is no other legal ground for the processing;
You object to the processing pursuant to POPIA and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to any right envisioned by POPIA;
The personal information has been unlawfully processed;
The personal information must be erased for compliance with a legal obligation in South Africa which we are subject to;

If any of the grounds listed above is present in the circumstances you are entitled to contact the information officer whose details are set out below.

11.5. Right to Object

You have the right to object in accordance with applicable data protection or privacy legislation, at any time, to us processing or using your personal information.

Should you wish to exercise your right to object, you should inform our information officer that you do not want us to process your personal information and state the reasons why we should stop using such personal information that you object to.

Should we lack any lawful basis for processing the information you object to, we will stop using such personal information. We are however entitled to continue to use such personal information where data protection or privacy legislation or other agreements with you provide us with a lawful basis for or justifies us in continuing to process such information. We will inform you of the result of your objection as soon as reasonable possible and without undue delay.

11.6. The Right to Withdraw Consent

The South African Regulator has also given you the right to withdraw your consent to us using your personal information. Should you wish to exercise your right to withdraw your consent you are entitled to contact our information officer and inform him or her of your decision to do so.

11.6. The Right to Withdraw Consent

12. CHANGES TO THE PRIVACY POLICY

This document is subject to change from time to time in order to remain compliant to any developments in law or otherwise. The latest and most recent volume of this policy will always be available on our website.

13. INFORMATION OFFICER

All requests for access to information held by Planned Talent must be made in writing and addressed to the Information Officer.

Details of the Information Officer:

Information Officer:	Michelle Snyman
Registered Address:	5th Floor, Bloukrans Building, Lynnwood Bridge, Pretoria, 0081
Postal Address:	5th Floor, Bloukrans Building, Lynnwood Bridge, Pretoria, 0081
Telephone Number:	010 824 1295
Email Address:	michelle@plannedtalent.co.za
Website:	plannedtalent.co.za