PRIVACY POLICY
OF BRANDY SPECIAL PROPRIETARY LIMITED
Brandy Special Proprietary Limited is a company registered and incorporated in accordance with the laws of South Africa under registration number 2024/158117/07 (“Brandy Special“, “we“, “us” or “our“).
We provide the following services:
Brandy Special owns and makes an application available for use on mobile devices, in association with the trade mark “BRANDY SPECIAL” (“App”). Through the App, we enable users of the App (each a “User”, “you”) to submit and receive information pertaining to these services.
This privacy policy should be read together with our Terms of Use for the App (“Terms“) and describes how we process information we collect and/or receive from you, what we use it for, how you might access it and with whom we might share it.
We process your personal information on the lawful basis that is appropriate to each purpose under section 11 of the Protection of Personal Information Act, 2013 (“POPIA”), namely: the performance of a contract with you, for the account, profile and information-submission functions of the App; the legitimate interests of Brandy Special, for device-identifier analytics, market research and the curating of specials; and your consent, where the law requires it (notably for direct marketing by electronic communication). Where we rely on your consent, that consent is voluntary, specific and informed, and you may withdraw it at any time.
1.
INFORMATION WE COLLECT AND
RECEIVE
We collect and receive information about
you in the following ways:
1.1. Information you give us (direct collection)
When using or registering to use the App you may provide or make the
following information available to us:
1.1.1. Information that you directly communicate to us when you submit
information to us;
1.1.2. by posting comments or content using the App; or
1.1.3. when you contact us or we contact you, and you provide information
directly to us.
1.2. Information we collect or infer from your use of our App (indirect
collection)
When you download and use the App, we
collect information that can be inferred from the device that you use, or the
time and manner of your use.
Even where you browse or use the App
without registering or logging in, we collect device identifiers (device IDs)
from your device. We collect this information for our legitimate-interest
purposes of analytics, market research (on a de-identified and aggregated
basis) and curating specials, and we notify you of this collection and its
purpose at or before the time of collection, in accordance with section 18 of
POPIA.
1.3. Information from third-party sources
We may collect additional information
about you that is publicly or commercially available and combine that with the
information we have collected or received about you in in other ways.
1.4. What personal information we collect
1.4.1. When you use the App or when you register to use the App, you may
provide us or we may gain access to, the following information about you:
¾
your name and surname;
¾
registration information, such
as your chosen username;
¾
company details, including full
name and registration number;
¾
contact number and email
address;
¾
your location;
¾
your trading hours;
¾
the physical address of your
business;
¾
the goods/services that on you
offer and the terms on which you offer them;
¾
the times that you use the App;
and
¾
information about the device
onto which the App is downloaded and used (including your telephone number and
the type of device).
2.
HOW WE USE THE INFORMATION WE
COLLECT AND RECEIVE
As a customer of ours, We use, and you give consent to us using, the information we collect and receive for the
following general purposes:
2.1. to process, analyse or verify your submissions;
2.2. to provide you with information,
content or services, that we think will be of interest to you, by virtue of the
fact that you are a user of the App;
2.3. to respond to any queries you may have;
2.4. to perform our services, as described at the beginning of this
privacy policy;
2.5. to keep a record of your relationship with us and for administrative
and archiving purposes;
2.6. to communicate with you about our services;
2.7. to provide you with support, so you can obtain the full benefit of
the App;
2.8. for campaigning (e.g. inviting you to events, sharing information on
offers and discounts) by mail, email, phone or social media, and every
electronic marketing message will offer you a free and easy means to opt out or
to object; and
2.9. to send you information about our latest news and campaigns, subject
to the same opt-out requirements set out above.
3.
HOW WE SHARE THE INFORMATION WE
COLLECT AND RECEIVE
3.1. We won’t sell your personal information to third parties for their
marketing purposes.
3.2. We may share information:
3.2.1. with our employees and third party service providers, to the extent
required to run our business;
3.2.2. from which the identity of a person is not determinable, with select
business partners of ours;
3.2.3. with other parties in response to a legal process or when necessary
to enforce or protect our legal rights; and
3.2.4. companies that provide services to us. Companies that provide services to us or act
on our behalf may have access to information about you. These companies are only authorised by us to
use information they receive, to the extent strictly necessary to provide their
services to us, for and on our behalf.
4.
RETENTION OF DATA
We will retain your personal information
only for as long as is necessary for us to lawfully use this information as set
out in this privacy policy or to comply with our legal obligations, resolve
disputes, and enforce our legal agreements and policies.
5.
OUR COMMITMENT TO SECURITY
The security of your data is important to
us. While we strive to use commercially acceptable means to protect your
personal information, we cannot guarantee its absolute security. However, we do
employ various safeguards intended to mitigate the risk of unauthorised access
or disclosure of your information. We will use reasonable efforts to protect
your personal information and we will use up to date technology that will help
us to do this. We will at all times comply with our obligation under applicable
law.
6.
TRANSFER OF DATA
6.1. We are based in and operate from South Africa. Your information, including personal
information, may be transferred to and maintained on servers located outside of
your country of residence, where the data privacy laws, regulations and
standards, may not be equivalent to the laws in your country of residence.
6.2. We might transfer your personal information to places outside of
South Africa and store it there, where our suppliers/service providers might
process it. If that happens, your
personal information will only be transferred in accordance with applicable
laws.
6.3. Your use of our App, followed by your submission of information to
us, represents your consent to such transfer.
6.4. We will take all steps reasonably necessary to ensure that your data
is treated securely and in accordance with this privacy policy.
7.
LINKS TO OTHER WEBSITES
Our App may contain links to and from
websites, mobile applications or services of third parties, advertisers or
affiliates. Please note that we are not
responsible for the privacy practices of such other parties and advise you to
read the privacy statements of each website or application you visit which
collects personal information.
8.
CHANGES TO THIS PRIVACY POLICY
We may update this privacy policy from
time to time. Any changes that we may
make to our privacy policy will be posted on our App and will be effective from
the date of posting.
9.
ACCESS TO YOUR PERSONAL
INFORMATION
9.1. We want to make sure that any data we hold about you is up to date.
So, if you think your personal information is inaccurate, you can ask us to
correct or remove it.
9.2. You
may at any time request:
9.2.1. confirmation
that we hold your personal information;
9.2.2. access
to your personal information;
9.2.3. the
identities or categories of third parties to whom we have disclosed your
personal information; or
9.2.4. that
we correct or delete any personal information that is incomplete, misleading,
inaccurate, excessive or out of date.
9.3. Requests may be made in writing to [support@brandyspecial.co.za].