unitalentza Privacy Policy

UNITALENTZA.CO.ZA PLATFORM: PRIVACY POLICY

1. General terms

Purpose of this privacy policy

Executive Leadership (Pty) Ltd respects your privacy and is committed to protecting your personal information. This privacy policy explains how we collect and process the personal information that you provide through your use of our website located at https://www.unitalentza.co.za/ ("Website”), communications or any of our services. Where we refer to “personal information”, it means “personal information” as defined in the Protection of Personal Information Act, 4 of 2013 (“POPI“), and “personal data” as per the General Data Protection Regulation 2016/679 (“the GDPR“). Please also see the Glossary that gives the meaning of some of the terms used in this privacy policy. This privacy policy applies in addition to any other agreement that you might enter into with us.

Contact details

We have appointed an Information Officer who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the Information Officer at unitalentza@talenting.co.za

If you have any questions about this privacy policy please contact Support Services at feedback@unitalentza.co.za. If you believe we are using your personal information unlawfully, please contact us in the first instance. You have the right to make a complaint at any time to the Information Regulator (South Africa) or other relevant supervisory authority (EU).

Changes to the privacy policy and your duty to inform us of changes

This privacy policy was last updated on 2 February 2021. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

Third-party links

Our Website, communications and services may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. We encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal information, or personal data, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal information about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, South African identity number, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account, payment information, VAT number and card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our Website and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal information but is not considered personal information in law as this data will not directly or indirectly reveal your identity.

We do not collect any Special Personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences, or about children.

If you fail to provide personal information

Where we need to collect personal information by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with. In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

3. How is your personal information collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact, Profile and Financial Data by registering on our Website or by filling in forms or by corresponding with us by email, phone or otherwise. This includes personal information you provide when you apply for our services or subscribe to our marketing communications.
• Automated technologies or interactions. We automatically collect Technical Data and Usage Data as you use our Website. We collect this personal information by using cookies and other similar technologies. You can prevent us from doing this through a setting on your browser. Cookies only store information from your browser and cannot access data on your computer.
• Third parties or publicly available sources. In limited instances, we collect personal information from third parties, some of which may be based outside of South Africa or the EU. We will only collect personal information this way where such information is publicly available or for legitimate business purposes, for example Technical Data from analytics providers such as Google.

4. How we use your personal information

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

• Where we need to perform the services and contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal information. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal information

We have set out below, in a table format, a description of the ways we plan to use your personal information and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. We may process your personal information on more than one lawful ground.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new client or user	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver your services including: (a) Manage payments and fees (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Responding to your email or other communications (b) Notifying you about changes to our terms or privacy policy	(a) Identity (b) Contact (c) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to keep our records updated and to develop our business) (c) Necessary to comply with a legal obligation
To deliver relevant Website content to you and measure or understand the effectiveness of the content we serve to you	(a) Technical (b) Usage (c) Identity (d) Contact (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to study how clients use our Website, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Website and marketing	(a) Technical (b) Usage	Necessary for our legitimate interests (to keep our Website updated and relevant, to develop our marketing strategy)
To administer and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To make suggestions and recommendations to you about services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Marketing and Communications	Necessary for our legitimate interests (to develop our services and grow our business)

Marketing

When you become a client or candidate of ours you will be added to our mailing list. You can also add yourself to our mailing list on our Website. We will send you marketing communications about the services we offer and other important information. We will include a link on all marketing communications that enables you to unsubscribe or you can contact us to request removal from our mailing list. If you unsubscribe, we may still contact you in other instances such as communications about the services we provide to you, or matters to do with collecting fees. In these instances we will contact you directly and not through a mailing list.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Website may become inaccessible or not function properly.

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. We may also process your personal information without your knowledge or consent where this is required or permitted by law.

5. Disclosures of your personal information

We will only share your personal information for purposes of providing services to you or any other legitimate business purpose relating to our business activities. Where required for business activities, we may share your personal information with our third-party service providers. We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions. Where the law requires us to do so, we may also share your personal information with third party service providers, agents, contractors, employees, law enforcement agencies or business affiliates. We will only share your personal information in these instances where it is necessary for us to do so and only to the extent that your personal information is needed.

Examples of third parties that we may share your personal information with includes:

• Service providers based in the US who provide cloud hosting services.
• Professional advisers including lawyers, accountants and auditors based in South Africa who provide legal, accounting and auditing services.
• The South African Revenue Service (SARS) and other regulators based in South Africa who require reporting in certain circumstances.
• Any other typical third parties.

6. International transfers

Some of our third parties, for example cloud hosting providers, may be based outside of South Africa or the EU so their processing of your personal information will involve a transfer of data. Whenever we transfer your personal information internationally, we ensure a similar and adequate degree of protection is afforded to it by ensuring safeguards are implemented, for example:

• We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information.
• Where we use certain service providers, we may use specific standard contracts which give personal information an adequate level of protection.

Please contact us if you want further information on how we transfer your personal information internationally.

7. Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal information.

Request access to your personal information. This enables you to receive a copy of the personal information we hold about you.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.

Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you.

Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information.

Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios:

• If you want us to establish the personal information's accuracy.
• Where our use of the personal information is unlawful but you do not want us to erase it.
• Where you need us to hold the personal information even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your personal information but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal information to you or to a third party. This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal information. This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact Support Services at feedback@unitalentza.co.za.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you unless we have your consent or are otherwise required or permitted to by law.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal information where it is necessary for compliance with a legal obligation that we are subject to.