Privacy Policy | AfroCentric Corporate Solutions

AFROCENTRIC CORPORATE SOLUTIONS PRIVACY POLICY

PREAMBLE
1. AfroCentric Corporate Solutions (“ACS”), a division of AfroCentric Group (“ACS, we, us, our”), respects your privacy and your personal information.
2. The “AfroCentric Group” means AfroCentric Investment Corporation Limited, the holding company and its subsidiaries, which include but are not limited to AfroCentric Healthcare Assets Proprietary Limited, AfroCentric Health Proprietary Limited and AfroCentric Corporate Solutions cluster of companies, and all other affiliates, licensees and/or service providers, and, for the sake of clarity, the AfroCentric Group includes subsidiaries that are authorised financial services providers.
3. This privacy policy (“this Policy”) explains how we will endeavour to protect and use your Personal Information.
4. By providing us with your Personal Information, you –
  1. agree to this Policy and authorise us to process such information as set out herein; and
  2. authorise ACS, its affiliates, directors, employees, consultants, service providers and other third parties to Process your Personal Information for the purposes stated in this Policy.
5. We will not use your Personal Information for any purpose other than that set out in this Policy and will endeavour to protect your Personal Information that is in our possession from unauthorised alteration, loss, disclosure or access.
6. Please note that we may review and update this Policy from time to time. The latest version of this Policy is available on request.
7. This Policy applies to all external parties with whom we interact;
8. Defined terms used in this Policy are:
  1. “Operator” means any person or entity that Processes Personal Information on behalf of the Responsible Party.
  2. “Personal Information” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
  3. “Process”, “Processing” or “Processed” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
  4. “Responsible Party” means the entity that decides how and why Personal Information is Processed.
  5. “Sensitive Personal Information” means Personal Information about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that may be deemed to be sensitive under applicable law.
  6. “Service Provider” – third party providers of various services whom we engage, including, but not limited to, providers of information technology, communication, file storage, data storage, copying, printing, transport, delivery, accounting or auditing services and our insurers and professional advisors;
  7. “Website” means any website operated, or maintained, by us or on our behalf.
CATEGORIES OF PERSONAL INFORMATION WE MAY PROCESS

We may Process the following categories of Personal Information about you –
1. personal details: name; and photograph;
2. demographic information: gender; date of birth or age; nationality; salutation; title; and language preferences;
3. identifier information: passport or national identity number; vehicle registration number, utility provider details; bank statements; tenancy agreements;
4. contact details: correspondence address; telephone number; email address; and details of your public social media profile(s);
5. consent records: records of any consents you may have given, together with the date and time, means of consent and any related information;
6. information relating to our relationship with you;
7. information relating to your visits to our WebSite: your device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to our and App; and other technical communications information;
8. geo-location data, used for security purposes and to assist you in navigating the and tailoring our services for you; and
9. content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages displayed to you, and any interaction you may have had with such content or advertising (including, but not limited to, mouse hover, mouse clicks and any forms you complete).
SENSITIVE PERSONAL INFROMATION

Where we need to Process your Sensitive Personal Data, we will do so in the ordinary course of our business, for a legitimate purpose, and in accordance with applicable law.
COLLECTION OF PERSONAL INFORMATION
1. We may collect or obtain Personal information about you –
  1. directly from you;
  2. in the course of our relationship with you;
  3. in the course of providing services to you;
  4. when you make your Personal Information public;
  5. when you visit and/or interact with our Website or App or our various social media platforms;
  6. when you register to use any of our services; or
  7. when you interact with any third party content or advertising on our Website or App.
2. We may also receive Personal Information about you from third parties including, but not limited to, law enforcement authorities.
3. In addition to the above, we may create Personal Information about you such as records of your communications and interactions with us, including, but not limited to, your attendance at events, subscription to our newsletters and other mailings and interactions with you during the course of our digital marketing campaigns.
PURPOSES OF PROCESSING AND LEGAL BASES FOR PROCESSING
1. We will Process your Personal Information in the ordinary course of our business and to contact you upon your request for a customised consultation with AIS. We will use your Personal Information only for the purpose for which it was originally collected. We will use your Personal Information for a secondary purpose only if such purpose constitutes a legitimate interest and is closely related to the original or primary purpose for which the Personal Information was collected. We may subject your Personal Information to Processing in order to –
  1. identify you;
  2. combine all the information that we have about you to compile a profile for you in order for us to personalise and tailor our services to meet your specific needs;
  3. contact you upon your request, and communicate with you when you have completed the contact form on WebSite;
  4. generate statistics and develop strategic and marketing plans;
  5. allow you to participate in interactive features of our services, when you choose to do so;
  6. carry out any contracts that may exist between us;
  7. notify you about changes to the services we offer or introduce you to new services.
DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES
1. We may disclose your Personal Information to our Service Providers, for legitimate business purposes, in accordance with applicable law and subject to applicable professional and regulatory requirements regarding confidentiality. In addition, we may disclose your Personal Information to –
  1. legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
  2. third party Operators (including, but not limited to, data processors such as providers of data hosting services and document review technology and services), located anywhere in the world, subject to 6.2;
  3. any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights;
  4. any relevant party for the purposes of the prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including, but not limited to, safeguarding against and the prevention of threats to public security;
  5. any relevant third party acquirer(s), in the event that we sell or transfer all or any portion of our business or assets including, but not limited to, in the event of a reorganization, dissolution or liquidation; and
  6. any relevant third party provider, where our Website or App uses third party advertising, plugins or content.
2. If we engage a third party Operator to Process any of your Personal Data, the Operator will be subject to binding contractual obligations to –
  1. only Process such Personal Information in accordance with our prior written instructions; and
  2. use measures to protect the confidentiality and security of such Personal Data.
FROM WHOM WE COLLECT PERSONAL INFORMATION

Personal Information will be collected directly from you, or our affiliates, except if –
1. the information is contained in a public record or has deliberately been made public by you;
2. you have consented to the collection of the information from another source, including our social media platforms;
3. collection of the information from another source would not prejudice a legitimate interest you may have;
4. collection of the information from another source is necessary –
  1. to avoid prejudice to the maintenance of the law by any public body, including the prevention, detection, investigation, prosecution and punishment of offences;
  2. to enforce a law imposing a pecuniary penalty;
  3. to enforce legislation concerning the collection of revenue as defined in relevant local legislation;
  4. for the conduct of proceedings in any court or tribunal that have commenced or are reasonably contemplated; or
  5. in the legitimate interests of national security.
PROTECTION OF PERSONAL INFORMATION
1. We implement reasonable technical and organisational security measures to protect your Personal Information that is in our possession against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or unauthorised access.
2. As the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your personal data that is in our possession, we cannot guarantee the security of any information transmitted to us using the internet. Any such transmission is at your own risk and you are responsible for ensuring that any information that you send to us is sent securely.
3. ACS will not be responsible for unauthorised access to your personal data and, to the extent permitted in terms of the applicable law, any liability to you which may otherwise have been attributable to ACS as a result of or in connection with such unauthorised access, is hereby excluded.
INTERNATIONAL TRANSFER OF PERSONAL INFORMATION
1. We may transfer your Personal Information to recipients outside of the Republic of South Africa.
2. Personal Information may be transferred to a third party outside of the Republic of South Africa provided that the third party is subject to a law, binding corporate rules or a binding agreement that seeks to protect the Personal Information in line with this Policy and the transfer is necessary in order to provide the services that are required by you.
INFORMATION ACCURACY

The Personal Information provided to ACS should be accurate, complete and up-to-date. Should Personal Information change, the onus is on the provider of such data to notify ACS of the change and provide ACS with the accurate data.
INFORMATION MINIMISATION

ACS will restrict the processing of Personal Information to data which is sufficient for the fulfilment of the primary purpose and applicable legitimate purpose for which it was collected, subject to the provisions of this Policy.
INFORMATION RETENTION

ACS shall only retain and store Personal Information for the period for which the data are required to serve their primary purpose or a legitimate interest or for the period required to comply with an applicable legal requirement, whichever is longer.
YOUR LEGAL RIGHTS

You have rights under the South African and other laws to access your Personal Information and to ask us to rectify, erase and restrict use of, your Personal Data. You also have the right to object to your Personal Information being used, to ask for the transfer of Personal Information you have made available to us and to withdraw consent to the use of your Personal Data.
COOKIES AND SIMILAR TECHNOLOGIES
1. Cookies are a small file that are placed on your device when you visit a website or application. In this Policy, a reference to a “Cookie” includes analogous technologies such as web beacons and clear graphic interchange format files.
2. We may Process your Personal Information by our use of Cookies and similar technologies.
3. When you visit our Website or App we may place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We may Process your Personal Information through Cookies and similar technologies.
DIRECT MARKETING
1. We will Process your Personal Information for the purposes of providing you with information regarding services that may be of interest to you only if you provide us with your consent to do so or if such Processing is permitted in terms of the applicable laws.
2. You may sign up for our newsletter and consent to receiving marketing information by registering on the Website or App and by ticking the opt-in box that states “I want to receive news and marketing information from ACS”.
3. If you no longer want wish to receive our newsletters or marketing information, you may unsubscribe for free at any time by notifying us by e-mail or telephonically using the details reflected in clause 17.
HYPERLINKS TO OTHER WEBSITES

Third party operators of websites, which may be accessed via hyperlinks from our WebSite or App, may gather and store Personal Information as soon as you access their websites. We do not accept any liability for those Operators in the event that your Personal Information is collected, used, disclosed or shared by them. We encourage you to read their privacy policies separately.
HOW DO YOU CONTACT US?

If you have questions about this Privacy Policy, or wish to amend or update any of your Personal Information you may contact us at info.acs@afrocentrichealth.com.