POPI

Introduction

This privacy policy (“Policy“) of Interact RDT (“Interact“), contractually regulates our right to collect and use certain of your information as a user of our website and services (“User” or “you“) and your rights in this regard and applies to your use of the Interact RDT website (www.interactrdt.com, including all sub-domains and our services and solutions that we offer (“Interact Solutions“) through our Website, services, and other communication channels. This Policy creates a legally binding agreement between us and you and will apply as soon as you Visit or use the Interact Solutions.

Your use of the Interact Solutions will be regulated by this Policy as well as any other terms that are available on the Website (“Additional Terms“). If there is a conflict between this Policy and the Additional Terms, the following order of preference will be applied in respect of applying such terms: (1) this Policy (the privacy policy), (2) in so far as the Additional Terms are applicable to you.

Changes to this Policy. Unless notice is required in terms of any applicable laws, we may change the content of this Policy from time to time in line with any changes that the law or our internal business operations require, without prior notice. However, we will notify you of any material changes to this Policy. The current version of this Policy that applies each time you visit and/or use the Interact Solutions will regulate our relationship. It is your responsibility to consider the Policy each time you visit and/or use the Interact Solutions. If you do not agree with any terms of this Policy, you must stop using the Solutions.

The right to privacy and this Policy is important to us. We are committed to taking steps to protect your privacy when you visit and/or use the Interact Solutions and we therefore implement business practices that comply with applicable laws, including the Protection of Personal Information Act 4 of 2013 (“POPI“) and the General Data Protection Regulation ((EU) 2016/679) (“GDPR“) (collectively “Applicable Law“). In this Policy, we explain how we will use and protect your Personal Information in light of Applicable Law.

Personal information

Where we refer to “Personal Information” in this Policy, we mean personal information as defined in Applicable Law, being information that may be used to directly or indirectly identify you, whether you are a natural or juristic person. Personal Information includes, for example, your name, surname, email address, identity number, contact details, photograph and location.

Collecting your personal information

We collect Personal Information about you from the following sources:

  • directly from you when you provide it to us, such as when you complete a contact from on our website, contact us via other means or through the course of our relationship with you;
  • public sources where you have made your Personal Information public, such as on social media;
  • your use of the Interact Solutions or use of any features or resources available on or through the Interact Solutions; and
  • third parties when you interact with them through the Interact Solutions , or your interaction with us as a result of the Services or as required of the third parties to share it with us.

Categories of personal information that we process

  • General personal details: your name and surname, gender, date of birth, age, nationality, language preferences, identity or passport number.
  • Contact details: address, contact number, email address.
  • User information: Personal Information included in correspondence, transaction documents, use of the Services or other materials that we process in the course of providing the Interact Solutions.
  • Account details: such as your username, password, usage data, and aggregate statistical information.
  • Consent records: records of any consents you have given us in respect of using your Personal Information and any related information, such as the specific details of the consent. We will also record any withdrawals or refusals of consent.
  • Payment details: payment method used, information provided by payment gateway service providers, payment amount, date and reason for payment and related information.
  • Data relating to our Services and Website: such as the type of device you use to access the Interact Solutions, the operating system and browser, browser settings, IP address, dates and times of connecting to and using the Website and using the Interact Solutions and other technical communications information.
  • Cookies and other technologies.
  • Content and advertising data: records of your interactions with our online advertising on the various websites which we advertise and with marketing content displayed on the Website and records relating to content displayed on web-pages displayed to you.
  • Views and opinions: any views and opinions that you choose to share with us, or publicly post about us on social media platforms, provide in the Solutions or elsewhere.
  • Children’s Personal Information: Personal Information of any User that qualifies as a child in terms of the Applicable law of the applicable jurisdiction necessary for us to render the Services and with the consent of a parent or guardian. We will only process the Personal Information of children with the consent of a parent or guardian of that child where required in terms of Applicable Law.

Purposes of processing personal information

We only process adequate and relevant Personal Information for the following purposes and legal bases:

  • to perform in terms of our agreement with you (provide you with the Interact Solutions);
  • operate and manage your account or your relationship with us;
  • monitor and analyse our business to ensure that it is operating properly, for financial management and for business development purposes;
  • contact you by email, sms, push notifications or other means to inform you about our Services, unless you have opted-out of such communications (direct marketing);
  • form a view of you as an individual and to identify, develop or improve the Interact Solutions and other services that may interest you;
  • carry out market research and surveys, business and statistical analysis and necessary audits;
  • fraud prevention;
  • perform other administrative and operational tasks like testing our processes and systems and ensuring that our security measures are appropriate and adequate; and • comply with our regulatory, legal or other obligations.

In addition to the above purposes, we may use your Personal Information for other purposes if the law allows for it, if you consent to it, or if it is in the public interest to do so. All purposes for the processing of your Personal Information will be legal in terms of Applicable Law.

Direct marketing

We may process your Personal Information to contact you to provide you with information regarding the Interact Solutions that may be of interest to you. Where we provide Services to you (where you are a customer of ours), we may send information to you regarding our Services and other information that may be of interest to you, using the contact details that you have provided to us. We will only send you direct marketing communications where you have consented to us sending you direct marketing or otherwise in compliance with Applicable Laws.

You may unsubscribe from any direct marketing communications at any time by clicking on the unsubscribe link that we include in every direct marketing communication or by contacting us and requesting us to do so.

After you unsubscribe, we will not send you any direct marketing communications, but we will continue to contact when necessary in connection with providing you with the Services or in connection with our business.

Disclosure of personal information to third parties

We will keep your Personal Information confidential and only share it with others in terms of this Policy, or if you consent to it, or if the law requires from us to share it. We may disclose your Personal Information to:

  • our business partners or third party processors in order to provide you with the Interact Solutions, such as resellers, data storage service providers, third party payment processors, software licensors or partners etc. in accordance with written agreements;
  • legal and regulatory authorities, upon their request, or for the purposes of reporting any breach of Applicable Law;
  • accountants, auditors, lawyers and other external professional advisors in terms of written agreements with them;
  • any relevant party to the extent necessary for the establishment, exercise or defence of legal rights, criminal offences, threats to public security, etc.;
  • any relevant third party in the event that we sell or transfer all or any portion of our business or assets; and
  • any relevant third party provider where the Interact Solutions uses third party advertising, plugins or content.

If we engage third party processors to process your Personal Information, the processors will only be appointed in terms of a written agreement which will require the third party processors to only process Personal Information on our written instructions, use appropriate measures to ensure the confidentiality and security of your Personal Information and comply with any other requirements set out in the agreement and required by Applicable Law.

International transfers of personal information

Due to the nature of the Services and our business being established in different countries, we may need to transfer Personal Information to and from the different countries for our business purposes.

We may transfer your Personal Information to recipients in other countries. We will only transfer Personal Information to third parties in countries with adequate data protection laws or do so in terms of a written agreement with the recipient which imposes data protection requirements on that party as required by Applicable Law.

Please note that when you transfer any Personal Information directly to a third party in another country (i.e. we do not send your Personal Information to the third party), Interact Solutions is not responsible for that transfer of Personal Information (and such transfer is not based on or protected by this Policy). Any Personal Information that we receive from a third party country will nevertheless be processed in terms of this Policy.

Security

We have implemented appropriate technical and organisational security measures designed to protect Personal Information against accidental or unlawful destruction, loss, alteration, disclosure, access and other unlawful or unauthorised forms of processing. These measures are in accordance with Applicable Law.

The internet is an open and often vulnerable system and the transfer of information via the internet is not completely secure. Although we will implement all reasonable measures to protect Personal Information, we cannot guarantee the security of your Personal Information transferred to us using the internet. Therefore, you acknowledge and agree that any transfer of Personal Information via the internet is at your own risk and you are responsible for ensuring that any Personal Information that you send is sent securely.

Your legal rights

You have certain rights in relation to your Personal Information. As available and except as limited under Applicable Law, you have the following rights in respect of your Personal Information:

  • Right of access – the right to be informed of and request access to the Personal Information that we process about you;
  • Right to rectification – you may request that your Personal Information be amended or updated where it is inaccurate or incomplete;
  • Right to erasure – the right to request that we delete your Personal Information, subject to applicable limitations and exceptions;
  • Right to restrict processing – you may request that we temporarily or permanently stop processing your Personal Information;
  • Right to object
    • you may object to us processing your Personal Information; and
    • to your Personal Information being processed for direct marketing purposes;
  • Right to information portability – you may request a copy of your Personal Information and request that information to be transmitted for use by another person; and
  • Right not to be subject to automated decision-making – where a decision that has a legal or other significant effect is based solely on automated decision making, including profiling, you may request that your Personal Information not be processed in that manner.

Where you have provided consent for us to process your Personal Information, you may also withdraw your consent where our processing is based on your consent. However, we may continue to process your Personal Information if another legal justification exists for the processing.

Use of cookies and similar technologies

When you use the Interact Solutions, we automatically receive and record information on our server logs from your browser. This information may include, amongst others, your location, IP address, cookie information and Google Analytics information. This is statistical data about browsing actions and patterns. We may also obtain information about your general internet usage through a cookie file which is stored on the hard drive of your computer. Cookies enable us to improve the Interact Solutions, estimate our audience size and usage patterns, store information about your preferences and recognise when you return to our Website.

In some instances, we collect and store information about your location through cookies (other than when you share your location with us). We convert your IP address or mobile GPS data into a rough geo-location, and we may use location information to improve and personalise our Website and Services for you.

You can set your web browser to refuse cookies, but if you do this you may not be able to enjoy the full use of the Interact Solutions and you may not be able to take advantage of certain promotions we may run.

Please note that third parties may also use cookies, but we do not have access to, or control over them, and therefore cannot take responsibility for them.

Links on our website

The Interact Solutions may include links to other apps or third party websites which do not fall under our supervision. We cannot accept any responsibility for your privacy or the content of these third party sites, but we display these links in order to make it easier for you to find information about specific subjects. Your use of and reliance on these links is at your own risk.

Right to object

You may, on reasonable grounds, object to us using your Personal Information for certain purposes. If you object, we will stop using your Personal Information, except if Applicable Law allows its use. To exercise this right or to discuss it with us, please contact us at info@interactrdt.com.

Children’s information and sensitive / special personal information

We do not intentionally collect or use children’s Personal Information. If we do collect Personal Information of children, we will only do so for a lawful purpose, in terms of this Policy and with the consent of a parent or guardian of the child unless the User is capable of consenting to the processing of his/her Personal Information in terms of the Applicable Laws in his/her jurisdiction.

Similarly, we do not intentionally collect or process special/sensitive Personal Information and will only do so with consent or if allowed by Applicable Law.

Quality and access to your information

Quality. We want to ensure that your Personal Information is accurate and up to date. You may ask us to correct or remove any Personal Information that you think is inaccurate, by sending us an email to info@interactrdt.com.

Access. You have the right to request us to provide you with Personal Information that we hold about you. You must contact us directly to do so or send an email to info@interactrdt.com. This request may be subject to an access to information request in terms of Applicable Laws and may require you to verify your identity, identify the rights you are wishing to exercise and pay a fee.

The right to access your Personal Information may further be limited in terms of Applicable Law.

Retention of information

We take every reasonable step to ensure that your Personal Information is only processed for the minimum period necessary for the purposes set out in this Policy.

We retain Personal Information in accordance with the required retention periods in Applicable Law or for legitimate business purposes. We will only retain your Personal Information for the purposes explicitly set out in this Policy. We may keep Personal Information indefinitely in a de-identified format for statistical purposes, which may include for example statistics of how you use the Interact Solutions.

This Policy also applies when we retain your Personal Information.

We may also retain your Personal Information for the duration of any period necessary to establish, exercise or defend any legal rights.

Security breach

We will report any security breach to the applicable regulatory authority in terms of Applicable Law and to the individuals or companies whose Personal Information is involved in the breach. If you want to report any concerns about our privacy practices or if you suspect any breach regarding your Personal Information, kindly notify us by sending an email to info@interactrdt.com.

Lodging a complaint

If you want to raise any objection or have any queries about our privacy practices, you can contact our data protection officer at info@interactrdt.com.

You also have the right to formally lodge a complaint in terms of applicable laws as follows:

Applicable Law: POPI

Applicable Law: GDPR

Legal disclosure

For interact RDT:

  • Name and Registration Number: Spawn Tech Proprietary Limited (trading as “SpawnTech“), registration number 2019/124783/07.
  • Legal Status: SpawnTech is a private company, duly incorporated in terms of the applicable laws of South Africa.
  • Directors: D Benjamin and GH Greenfield.
  • Description of Main Business: Spawntech is a software development company.
  • Email Address: info@interactrdt.com
  • Website address http://www.interactrdt.com
  • Physical and Registered Address: 3 Sandown Valley Crescent, Sandton, Gauteng, 2196.
  • Postal address: Postnet Suite 455, Private bag X1, Melrose Arch, Gauteng, 2076.