POPIA
CONCLUDE (PTY) LTD PRIVACY NOTICE

This Notice explains how we obtain, use, and disclose your personal information, in accordance with the requirements of the Protection of Personal Information Act (“POPIA”).

At Conclude (Pty) Ltd (and including this website and all of Conclude’s products and businesses) we are committed to protecting your, and your clients’, privacy and ensuring that your personal information is collected and used properly, lawfully, and transparently.  

By accessing this site or working with Conclude (or using its products and services) it is acknowledged that you will be sharing personal data with us in either physical or electronic format and you consent to allow Smart Assistant to store and process this information to provide you the products,  services, and content requested.

Definition of personal information

According to the Act ‘‘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, Conclude also includes all addresses, including residential, postal, and email addresses.

The information we collect

We collect personal information directly from you where you specifically provide us with such information.  Where possible, we will inform you what information you are required to provide to us and what information is optional. If you fail to provide the requested personal data, we may be unable to process or respond to your query or service.

Examples of the personal data we use may include: 

  • Full name and personal details including contact information (e.g. home address and address history, email address, home and mobile telephone numbers); 
  • Records of products and services you’ve obtained or applied for, how you use them and the relevant technology used to access or manage them (e.g. mobile phone location data, IP address, MAC address); 
  • Biometric data (e.g. digital signatures, fingerprints and voice recordings for TouchID and voice recognition); 
  • Personal data about other named individuals as required. Where you provide the personal data of others you must have their authority to provide their personal data to us and share this Privacy Statement and any related data protection statement with them beforehand together with details of what you’ve agreed on their behalf.

How we use your information

We will use your, or your clients’, personal information only for the purposes for which it was collected.

The types of personal information we collect and use will depend on what you are doing on the website,  and we’ll use your personal data for some or all of the reasons set out in this Privacy Notice.

If you become a customer we’ll also use it to manage, or provide, the product or service you’ve requested, as necessary for our own legitimate interests, or as necessary to comply with a legal obligation.

For example:

  • To administer your account, contact you for the purposes of understanding your requirements, and provide the products, services, and content you requested from us;
  • To confirm and verify your identity or to verify that you are an authorised user for security purposes;
  • To search at credit bureaux at your home and business address if you apply for credit;
  • For good governance, accounting, and managing and auditing our business operations;
  • To monitor emails, calls, other communications, and activities on your account
  • When you exercise your rights under data protection law and make requests;
  • For the detection and prevention of fraud, crime, money laundering, or other malpractice;
  • To conduct market or customer satisfaction research or for statistical analysis; For audit and record-keeping purposes;
  • For compliance with legal and regulatory requirements and related disclosures;
  • For establishment and defense of legal rights
  • In connection with legal proceedings.

From time to time, we would like to contact you about our products and services, as well as other content that may be of interest to you. By ticking the communications consent boxes on this site, you consent to us contacting you for this purpose. You can unsubscribe from these communications at any time.

We will also use your, or your clients’ personal information based on your consent – for example, when you ask us to disclose your personal data to other people or organisations.

For products and services where Conclude and its employees have access to your or your clients’ personal information, all data will only be accessed by Conclude and its authorised employees for the business purposes agreed with you.

You are free at any time to change your mind and withdraw your consent. The consequence might be that we cannot do certain things for you.

Disclosure of information

We will not disclose or permit the disclosure of your, or your clients’, personal information to any third party unless specifically requested and/or authorised to do so by yourself, or as required by law, or any regulatory body and will take all such steps as may be necessary to safeguard it.

Subject to applicable data protection laws, we may disclose your, or your clients’, personal information to:

  • Our subcontractors and service providers who are involved in the delivery of products or services to you. 
  • Companies and other persons providing services to us
  • Our legal and other professional advisors, including our auditors; 
  • Law enforcement bodies
  • Courts, to comply with legal requirements, and for the administration of justice
  • In an emergency or to otherwise protect your vital interests; 
  • To protect the security or integrity of our business operations;
  • If we restructure or sell our business or its assets or have a merger or re-organisation
  • Anyone else where we have your consent or as required by law.

We have agreements in place to ensure that they comply with the privacy requirements as required by the Protection of Personal Information Act.

We may also disclose your information:

  • Where we have a duty or a right to disclose in terms of law or industry codes;
  • Where we believe it is necessary to protect our rights.

Cookies

Cookies are small text files placed on your computer, smartphone or other device and are commonly used on the internet. Website usage information may be collected using “cookies” which allows us to collect standard internet visitor usage information.

We use cookies and similar technologies to:

  • Collect information that will help us understand visitors’ browsing habits on our website;
  • Compile statistical reports on website activity, e.g. number of visitors and the pages they visit;
  • Temporarily store any information which you may enter in tools, such as calculators or demonstrations on our website; and
  • in some cases, remember information about you when you visit our site. We may need to do this to provide some of our services.

Monitoring of communications

Subject to applicable laws, we’ll monitor and record your calls, emails, text messages, social media messages and other communications in relation to your dealings with us. We’ll do this for regulatory compliance, self-regulatory practices, crime prevention and detection, to protect the security of our communications systems and procedures, to check for obscene or profane content, for quality control and staff training, and when we need to see a record of what’s been said. If you take out an account or service with us, we may also monitor activities on your account/service where necessary for these reasons and this is justified by our legitimate interests or our legal obligations.

Data anonymisation and aggregation

Your personal data may be converted into statistical or aggregated data that can’t be used to identify you, then used to produce statistical research and reports. This aggregated data may be shared and used in all the ways described above.

Information Security

We are legally obliged to provide adequate protection for the personal information we hold and to stop unauthorized access and use of personal information. We will ensure that appropriate technical and organizational measures are taken against the unauthorised or unlawful processing of your, or your clients’, data or personal information on an on-going basis.  We will also continue to review our security controls and related processes to ensure that it remains secure.

Our security policies and procedures cover:

  • Physical security;
  • Computer and network security;
  • Access to personal information;
  • Secure communications;
  • Security in contracting out activities or functions;
  • Retention and disposal of information;
  • Acceptable usage of personal information;
  • Governance and regulatory issues;
  • Monitoring access and usage of private information;
  • Investigating and reacting to security incidents.

When we contract with third parties, we impose appropriate security, privacy, and confidentiality obligations on them to ensure that personal information that we remain responsible for, is kept secure.

We will ensure that anyone to whom we pass your personal information agrees to treat your information with the same level of protection as we are obliged to.

We will notify you as soon as we become aware of any unauthorised, unlawful, or dishonest conduct or activities, or any breach of the terms of this agreement relating to personal information.

We will work together with you in complying with any request for access or query from an individual who is the subject of personal information and/or responding to any enquiry made, or investigation or assessment of any processing initiated by a relevant regulatory authority in respect of such personal information.

We will relinquish to you and/or destroy any and all possession and/or access to such personal information on demand.

Your Rights

Access to information

You have the right to request a copy of the personal information we hold about you, or your clients. To do this, simply contact us at the numbers/addresses as provided on our website and specify what information you require.  We will need a copy of your ID document to confirm your identity before providing details of your personal information.

Please note that any such access request may be subject to payment of a legally allowable fee.

Correction of your information

You have the right to ask us to update, correct, or delete your, or your clients’, personal information. We will require a copy of your ID document to confirm your identity before making changes to the personal information we may hold about you. We would appreciate it if you would keep your personal information accurate.

Customer responsibility

It is your responsibility to ensure that your computer is virus protected. We accept no responsibility for any loss you may suffer as a result of accessing and downloading information from this site.

Links to other websites

Certain hypertext links in this website may lead you to websites which are not under the control of Conclude (Pty) Ltd. These links are provided solely for your convenience and do not represent any endorsement or recommendation by Conclude (Pty) Ltd.

We accept no responsibility or liability for the contents of any website to which a hypertext link exists and gives no representation or warranty as to the information on such websites. We accept no responsibility or liability for any loss arising from any contract entered into with any website to which a hypertext link exists.

How to contact us

If you have any queries about this notice; you need further information about our privacy practices; wish to withdraw consent; exercise preferences or access or correct your personal information, please contact us at the numbers/addresses listed on our website.