Personal data on devices handed in for repair
Dear Customer.
Regarding: - Personal data on devices handed in for repair
We respect your privacy and take the protection of personal information very seriously. The Protection of Personal Information Act 4 of 2013 (POPIA) is South Africa's umbrella data protection law, which commenced on 1 July 2021. In terms of POPIA, personal information is any information about a living human being or an existing company, close corporation, or other juristic person, provided that someone could identify them. It includes both generic personal information, such as names, phone numbers, email and physical addresses and other kinds of identifying or contact information, and more sensitive personal information such as account numbers, special personal information (as defined by POPIA) and children’s personal information about people younger than 18.
When you hand in devices that store data, to our Service Centres, you may be required to provide to us passwords for the device. This is so that we can effectively diagnose the problem by having full access to the unit.
Our staff are aware of the requirements of protecting personal information and agree in writing to not disclose personal and confidential personal information they may have access to and not to use it for any other purpose, however, in the interest of protecting personal information we suggest that: -
1. you ensure that all data files on any such devices are backed-up.
2. personal information is removed from the hard drive; and
3. on return of the device, that the password is changed.
It is always the customer’s responsibility to ensure that all data files on any product are backed-up before the product is booked in for a repair. The customer accordingly indemnifies Hoets and Associates and holds Hoets and Associates harmless from any loss, costs, damages or expense, of whatsoever nature, which the customer may suffer in respect of the loss or exposure of any data fail pursuant to the rendering by Hoets and Associates of the Services, to the extent that applicable law allows.
Please contact the Service Manager or email us at helpdesk@hoetsassociates.co.za if you have any questions or concerns.
Updates and Newsletters
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Registered Address 18 Marina Hills, Keam rd, Baysville, EAST LONDON, 5241
Privacy Policy
Introduction
Welcome to our privacy policy. We are Hoets and Associates and this is our plan of action when it comes to protecting your privacy. We respect your privacy and take the protection of personal information very seriously. The purpose of this policy is to describe the way that we collect, store, use, and protect information that can be associated with you or another specific natural or juristic person and can be used to identify you or that person (personal information).
We respect your privacy. Callouts like this are a summary of our privacy policy and contain the most important and relevant points for you. Please read the full privacy policy because it applies to you.
Audience
This policy applies to you if you are: • a visitor to our website; or • a customer who has ordered or requested the goods or services that we provide.
This policy applies to you under certain circumstances.
Personal information
Personal information includes: • certain information that we collect automatically when you visit our website; • certain information collected on registration (see below); • certain information collected on submission; and • optional information that you provide to us voluntarily (see below); but excludes: • information that has been made anonymous so that it does not identify a specific person; • permanently de-identified information that does not relate or cannot be traced back to you specifically; and • non-personal statistical information collected and compiled by us.
Common examples
Common examples of the types of personal information which we may collect and process include your: • identifying information – such as your company name, name, or identification number of any kind; • contact information – such as your company phone number, email address, contact phone number; • address information – such as your company physical or postal address or your address; • demographic information – such as your gender or marital status. Sensitive personal information Depending on the goods or services that you require, we may also collect sensitive personal information including your: • financial information – such as your bank account details; • sensitive demographic information – such as your race or ethnicity; • medical information – such as information about your physical health collected for public health reasons; • criminal information – such as information about your commission or alleged commission of any offence or about any related legal proceedings; • employment information – including your membership of a trade union.
Acceptance
Acceptance required You must accept all the terms of this policy when you order our goods or request our services.
If you do not agree with anything in this policy, then you may not order our goods or request our services. You may not order our goods or request our services if you do not accept this policy.
Legal capacity
You may not access our website or order our goods or request our services if you are younger than 18 years old or do not have legal capacity to conclude legally binding contracts.
Deemed acceptance
By accepting this policy, you are deemed to have read, understood, accepted, and agreed to be bound by all of its terms.
Your obligations
may only send us your own personal information or the information of another data subject where you have their permission to do so.
Changes
We may change the terms of this policy at any time by updating this web page. We will notify you of any changes by placing a notice in a prominent place on the website or by sending you an email detailing the changes that we have made and indicating the date that they were last updated. If you do not agree with the changes, then you must stop using the website and our goods or services. If you continue to use the website or our goods or services following notification of a change to the terms, the changed terms will apply to you and you will be deemed to have accepted those updated terms.
Collection
On order or request
When you order our goods or request our services from us, you will be asked to provide us with additional information on a voluntary basis (goods or services information). We collect certain information when you order our goods or request our services from us.
From browser
We automatically receive and record Internet usage information on our server logs from your browser, such as your Internet Protocol address (IP address), browsing habits, click patterns, version of software installed, system type, screen resolutions, colour capabilities, plug-ins, language settings, cookie preferences, search engine keywords, JavaScript enablement, the content and pages that you access on the website, and the dates and times that you visit the website, paths taken, and time spent on sites and pages within the website (usage information). Please note that other websites visited before entering our website might place personal information within your URL during a visit to it, and we have no control over such websites. Accordingly, a subsequent website that collects URL information may log some personal information. We collect certain information from your web browser, including your Internet usage information when you visit our website.
Cookies
We may place small text files called ‘cookies’ on your device when you visit our website. These files do not contain personal information, but they do contain a personal identifier allowing us to associate your personal information with a certain device. These files serve a number of useful purposes for you, including: • tailoring our website’s functionality to you personally by letting us remember your preferences; • improving how our website performs; • allowing third parties to provide services to our website; and • helping us deliver targeted advertising where appropriate in compliance with the applicable laws. Your internet browser generally accepts cookies automatically, but you can often change this setting to stop accepting them. You can also delete cookies manually. However, no longer accepting cookies or deleting them will prevent you from accessing certain aspects of our website where cookies are necessary. Many websites use cookies and you can find out more about them at www.allaboutcookies.org. We collect certain information from cookies that we may send to your computer to try and give you a personalised experience.
Third party cookies
Some of our business partners use their own cookies or widgets on our website. We have no access to or control over them. Information collected by any of those cookies or widgets is governed by the privacy policy of the company that created it, and not by us.
Web beacons
Our website may contain electronic image requests (called a single-pixel gif or web beacon request) that allow us to count page views and to access cookies. Any electronic image viewed as part of a web page (including an ad banner) can act as a web beacon. Our web beacons do not collect, gather, monitor or share any of your personal information. We merely use them to compile anonymous information about our website. We collect certain information from web beacons on our website to compile anonymous information about our website.
Optional details
You may also provide additional information to us on a voluntary basis (optional information). This includes content or products that you decide to upload or download from our website or when you enter competitions, take advantage of promotions, respond to surveys, order certain additional goods or services, or otherwise use the optional features and functionality of our website. We collect certain optional information, that you provide when you upload or download content from our website or when you enter competitions, take advantage of promotions, respond to surveys or register and subscribe for certain additional goods or services.
Recording calls
We may monitor and record any telephone calls that you make to us, in compliance with relevant monitoring laws.
Purpose for collection
We may use or process any goods or services information, or optional information that you provide to us for the purposes that you indicated when you agreed to provide it to us. Processing includes gathering your personal information, disclosing it, and combining it with other personal information. We generally collect and process your personal information for various purposes, including: • goods or services purposes – such as collecting orders or requests for and providing our goods or services; • marketing purposes – such as pursuing lawful related marketing activities; • business purposes – such as internal audit, accounting, business planning, and joint ventures, disposals of business, or other proposed and actual transactions; and • legal purposes – such as handling claims, complying with regulations, or pursuing good governance. We may use your usage information for the purposes described above and to: • remember your information so that you will not have to re-enter it during your visit or the next time you access the website; • monitor website usage metrics such as total number of visitors and pages accessed; and • track your entries, submissions, and status in any promotions or other activities in connection with your usage of the website. We may use any of your personal information that you provide to us for the purposes that you indicated when you agreed to provide it to us.
Consent to collection
We will obtain your consent to collect personal information: • in accordance with applicable law; • when you provide us with any registration information or optional information. We will get your consent to collect your personal information in accordance with applicable law when you provide us with it.
Use
Our obligations
We may use your personal information to fulfil our obligations to you.
Messages and updates
We may send administrative messages and email updates to you about the website or your orders. We may wish to provide you with information about new goods or services in which we think you may be interested. This means that in some cases, we may also send you primarily promotional messages. We will not send you promotional messages unless you have chosen to opt-into them. We may use your information to send you administrative messages and email updates to you regarding the website and for marketing purposes where lawful.
Disclosure
Sharing
We may share your personal information with: • other divisions or companies within the group of companies to which we belong so as to provide joint content and services like registration, for transactions and customer support, to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about our products, services, and communications (they will only use this information to send you marketing communications if you have requested their goods or services); • an affiliate, in which case we will seek to require the affiliates to honour this privacy policy; • our goods or services providers who help provide certain goods or services or help with parts of our business operations, including fraud prevention, bill collection, marketing, technology services, rebatesschemes(These goods or services providers will only use your information in connection with the goods or services they supply or services they perform for us and not for their own benefit); • credit bureaus to report account information, as permitted by law; • banking partners as required by credit card association rules for inclusion on their list of terminated merchants (in the event that you utilise the services to receive payments and you meet their criteria); and • other third parties who provide us with relevant services where appropriate. We may share your personal information with third parties for the purposes of fulfilling our obligations to you among other purposes.
Regulators
We may disclose your personal information as required by law or governmental audit.
Law enforcement
We may disclose personal information if required: • by a subpoena or court order; • to comply with any law; • to protect the safety of any individual or the general public; and • to prevent violation of our customer relationship terms. We may disclose personal information to third parties if required for legal reasons.
No selling
We will not sell personal information. No personal information will be disclosed to anyone except as provided in this privacy policy.
Marketing purposes
We may disclose aggregate statistics (information about the customer population in general terms) about the personal information to advertisers or business partners.
Employees
We may need to disclose personal information to our employees that require the personal information to do their jobs. These include our responsible management, human resources, accounting, audit, compliance, information technology, or other personnel.
Change of ownership
If we undergo a change in ownership, or a merger with, acquisition by, or sale of assets to, another entity, we may assign our rights to the personal information we process to a successor, purchaser, or separate entity. We will disclose the transfer on the website. If you are concerned about your personal information migrating to a new owner, you may request us to delete your personal information.
Security
We take the security of personal information very seriously and always do our best to comply with applicable data protection laws. Our hosting company will host our website in a secure server environment that uses a firewall and other advanced security measures to prevent interference or access from outside intruders. We authorize access to personal information only for those employees who require it to fulfil their job responsibilities. We implement disaster recover procedures where appropriate. Our website is hosted on a secure server and uses security measures to prevent interference by intruders.
Accurate and up to date
We will try to keep the personal information we collect as accurate, complete and up to date as is necessary for the purposes defined in this policy. From time to time we may request you to update your personal information. You are able to review or update any personal information that we hold on you by, emailing us, or phoning us. Please note that in order to better protect you and safeguard your personal information, we take steps to verify your identity before making any corrections to your personal information. Please keep your personal information accurate and up to date by accessing your account online, emailing us, by phoning us.
Retention
We will only retain your personal information for as long as it is necessary to fulfil the purposes explicitly set out in this policy, unless: • retention of the record is required or authorised by law; or • you have consented to the retention of the record. During the period of retention, we will continue to abide by our non-disclosure obligations and will not share or sell your personal information. We may retain your personal information in physical or electronic records at our discretion. We will only retain your personal information for as long as is necessary.
Transfer to another country
We may transmit or transfer personal information outside of the country in which it was collected to a foreign country and process it in that country. Personal information may be stored on servers located outside the country in which it was collected in a foreign country whose laws protecting personal information may not be as stringent as the laws in the country in which it was collected. You consent to us processing your personal information in a foreign country whose laws regarding processing of personal information may be less stringent. We may transfer your personal information outside the country in which it was collected to a foreign country.
Updating or removing
You may choose to correct or update the personal information you have submitted to us, by clicking the relevant menu in any of the pages on our website or contacting us by phone or email. You may choose to update or remove the personal information you have submitted to us.
Limitation
We are not responsible for, give no warranties, nor make any representations in respect of the privacy policies or practices of linked or any third-party websites.
Enquiries
If you have any questions or concerns arising from this privacy policy or the way in which we handle personal information, please contact us.