“Click Certain” shall mean collectively:
Click Certain Proprietary Limited (registration number: 2015/117986/07), any direct or indirect subsidiary( within the meaning of section 3 of the Companies Act ) of Click Certain, any partnership, unincorporated joint venture or trust in which Click Certain or any Group Entity has a direct or indirect partnership of 50% or more, any company , partnership, unincorporated joint venture, website or trust which is controlled by any Group Entity and , any directors, officers, employees, agents or contractors of Click Certain or any Group Entity.
“Group Entity” shall mean Click Certain and any entity forming part of the Click Certain Group.
We respect your right to privacy and therefore aim to ensure that we comply with the legal requirement of the POPI Act which regulates the manner in which we collect, process, store, share and destroy any personal information which you have provided to us.
The information displayed on our website is provided for general information purposes only. Professional advice should therefore be sought before any action is taken based on the information displayed on this website.
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“). Personal information includes any information about a person that can be used to identify a person directly or indirectly. It includes information like a name, an identification number, location information, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person. POPI includes the personal information of juristic persons in its ambit – so we will protect the personal information of juristic persons in the same manner as any other person’s personal information.
Why we collect Personal Information:
We collect personal information in order to liaise with you telephonically, via our website or email so that we may:
1. Respond to any query or comment received from you;
2. Inform you of new offers;
3. Enable us to process, validate and verify information and requests for the supply of goods and/or services;
4. For the purposes for which you specifically provided the information; and
5. Generally to improve your experience on our website.
Processing of Information
We will share your personal information:
1. In order to comply with applicable law or with legal process served on our company;
2. In order to protect and defend the rights or property of our company;
1. Treat your personal information as strictly confidential;
2. Take appropriate technical and organisational measures to ensure that your personal information is kept secure and is protected against unauthorised or unlawful processing, accidental loss, destruction or damage, alteration, disclosure or access;
3. Promptly notify you if we become aware of any unauthorised use, disclosure or processing of your personal information;
4. Provide you with reasonable evidence of our compliance with our obligations under this policy on reasonable request; and
5. We will not retain your personal information longer than the period for which it was originally required, unless we are required by law to do so, or you consent to us retaining such information for a longer period.
ALTHOUGH WE TAKE THE AFOREMENTIONED PRECAUTIONS IN PROTECTING YOUR PERSONAL INFORMATION, WE SHALL HOWEVER NOT BE LIABLE FOR ANY LOSS OR DAMAGE, HOWSOEVER ARISING, SUFFERED AS A RESULT OF THE DISCLOSURE OF SUCH INFORMATION IF OUTSIDE OUR REASONABLE CONTROL.
You have the right at any time to:
1. Rectify the Personal Information collected by us;
2. Object to the processing of Personal Information (subject to legislation);
3. Request the return or destruction of Personal Information (subject to legislation);
4. Lodge a complaint with the company.
The Personal Information processed by us is not routed/transferred to a third country or International organisation.
How We Collect Information
Click Certain may collect personal information about you in the following ways:
(1) directly from your verbal or written input (such as by consenting to receiving marketing emails) or indirectly through third parties with whom we work closely (see below “Information We Receive From Other Sources”);
(2) automatically through the https://gwts.co.za/ website technologies including tracking online, such as by Web cookies (which are small text files created by websites that are stored on your computer), by smart devices, by combining data sets, by collecting data from a browser or device for use on a different computer or device, or by using algorithms to analyze a variety of data such as records of purchases, online behavioral data, or location data
Information You Provide
The types of information that Click Certain collects directly from you or through your use of our websites and services may include the following depending on how you interact with Click Certain:
- Contact details, such as your name, email address, postal address, username, and telephone number;
- Internet Protocol (“IP”) addresses used to connect your computer to the Internet;
- Educational and professional interests;
- Tracking codes such as cookies;
- Comments, feedback, posts and other content you provide to Click Certain (including through a Click Certain website);
- Communication preferences;
Information about your personal preferences and interests.
In order to access certain content and to make use of additional functionality and features of Click Certain’s websites and services, we may ask you to register for an account by completing and submitting a registration form, which may request additional information.
If you choose to register and sign in by using a third-party account (such as your Facebook account), the authentication of your login is handled by the third party. Click Certain will collect your name, email address and any other information about your third-party account that you agree to share with us at the time you give permission for your Click Certain account to be linked to your third-party account.
Information We Receive From Other Sources
Click Certain may receive information about you if you use any of the websites we operate or the other services we provide. We also work closely with third parties (including, for example, business partners and sub-contractors in technical and delivery services; advertising networks; data and analytics providers and search information providers) from whom Click Certain may receive information about you.
Use of Your Information
Depending on how you interact with Click Certain, Click Certain may use your personal information in the performance of any contract or transaction we enter into with you, to comply with legal obligations, or where Click Certain has a legitimate business interest.
- Legitimate business purposes include but are not limited to one or all of the following:
- providing direct marketing and assessing the effectiveness of promotions and advertising;
- modifying, improving or personalizing our services, products and communications;
- detecting fraud; investigating suspicious activity (e.g., violations of our Terms of Service, which can be found here) and otherwise keeping our site safe and secure; and conducting data analytics.
In addition, with your prior, explicit consent (where required), we may use your information in the following ways:
- To provide you with information about products and services that you request from us;
- To send you periodic catalogues from Click Certain;
- To provide you with information about other products, events and services we offer that are either (i) similar to those you have already purchased or inquired about, or (ii) entirely new products, events and services;
- For internal business and research purposes to help enhance, evaluate, develop, and create Click Certain websites (including usage statistics, such as “page views” on Click Certain’s websites and the products therein), products, and services;
- To notify you about changes or updates to our websites, products, or services;
- To provide, activate and/or manage our services;
- For internal operations, including troubleshooting, data analysis, machine learning, testing, statistical, and survey purposes;
- To allow you to participate in interactive features of our service; and
- For any other purpose that we may notify you of from time to time.
Personal information will not be kept longer than is necessary for the purpose for which it was collected. This means that, unless information must be retained for legal or archival purposes, personal information will be securely destroyed, put beyond use or erased from Click Certain’s systems when it is no longer required or, where applicable, following a request from you to destroy or erase your personal information.
Disclosure and Sharing of Your Information
Click Certain will not disclose to or share your personal information with any unaffiliated third party except as follows:
- Where necessary in connection with services provided by third parties (i) who provide us with a wide range of office, administrative, information technology, website and platform hosting, editing, production, payment, business management, analytics, content management, indexing, archiving, or marketing services; and (ii) who are required to comply with applicable privacy laws;
- Where you voluntarily provide information in response to an advertisement from a third party;
- Where you have attended an event, webinar, or conference, we may share your information with the sponsor of the activity;
- Where third-party companies serve ads and/or collect certain information when you visit our websites. These companies may be placing and reading cookies in the cookie file of the browser on your computer’s hard disk or using web beacons or other technologies to collect information in the course of ads being served on this website. These companies may use information other than personal information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to these and other websites in order to provide advertisements about goods and services likely to be of greater interest to you;
- Where Click Certain is required to disclose personal information in response to lawful requests by public authorities and government agencies, including to meet national security or law enforcement requirements; to comply with a subpoena or other legal process;
- hen we believe in good faith that disclosure is necessary to protect our rights, to enforce our Terms of Service, or to protect the rights, property or safety of our services, users or others; and to investigate fraud;
- Where all or substantially all of the business or assets of Click Certain relating to our services are sold, assigned, or transferred to another entity; or
- Where, even if not described above, you have consented to such disclosure or Click Certain has a legitimate interest in making the disclosure.
Click Certain also may disclose navigational and transactional information in the form of anonymous, aggregate usage statistics and demographics information that does not reveal your identity or personal information.
Cross Border Transfers
Click Certain may transfer your personal information outside of your country of residence for the following reasons:
In order to process your transactions, we may store your personal information on our servers and those servers may reside outside the country where you live. Click Certain has servers and major office locations in several countries, including the United States, the United Kingdom, South Africa, Germany, Singapore, Brazil, India and Australia. Click Certain also has service providers located in India and the Philippines amongst other countries. Such processing may include, among other things, the fulfillment of your order, the processing of your payment details and the provision of support services.
In order to satisfy global reporting requirements, Click Certain may be required to provide your personal information to Click Certain affiliates in other countries.
In relation to personal data processed within the US, Click Certain has in place EU Model Clauses between entities within its group of companies that receive and process personal information from countries within the European Economic Area.
We will use appropriate physical, technical and administrative safeguards to protect your data. Access to your personal data will be restricted to only those who need to know that information and required to perform their job function. In addition, we train our employees about the importance of maintaining the confidentiality and security of your information.
Disclosure in Chat Rooms or Forums
You should be aware that identifiable personal information–such as your name or e-mail address–that you voluntarily disclose and that is accessible to other users (e.g. on social media, forums, bulletin boards or in chat areas) could be collected and disclosed by others. Click Certain cannot take any responsibility for such collection and disclosure.
As is true of most websites, we gather certain information automatically. This information may include IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.
This Website and/or App makes use of “cookies” to automatically collect information and data through the standard operation of the Internet servers. “Cookies” are small text files a Website and/or App can use (and which Click Certain may use) to recognize repeat Users, facilitate the User’s on-going access to and use of a Website and/or App and allow a Website and/or App to track usage behavior and compile aggregate data that will allow the Website and/or App operator to improve the functionality of the Website and/or App and its content.
Please note that cookies may be necessary to provide Users with certain features available on our Website and/or App, and thus if Users disable the cookies on the User’s browser Users may not be able to use those features, and the User’s access to our Website and/or App will therefore be limited. If Users do not disable “cookies”, Users are deemed to consent to our use of any personal information collected using those cookies.
For more information on cookies, please click here.
You have the right to make a written request to be informed whether or not we hold or process any of your personal information (by emailing privacy(at)clickcertain.co.za). In your written request, you may:
- Request that we provide you with details of your personal information that we process, the purpose for which it is processed, the recipients of such information, the existence of any automated decision making involving your personal information, and what transfer safeguards we have in place;
- Request that we rectify any errors in your personal information;
- Request that we delete your personal information if our continued processing of such information is not justified;
- Request that we transfer your personal information to a third party;
- Object to automated decision-making and profiling based on legitimate interests or the performance of a task in the public interest (in which event the processing will cease except where there are compelling legitimate grounds, such as when the processing is necessary for the performance of a contract between us);
- Object to direct marketing from us; and
- Object to processing for purposes of scientific, historical research and statistics.
Where applicable under your local laws, we will not use your personal information for marketing purposes, nor disclose your information to any third parties, unless we have your prior consent, which we will seek before collecting your personal information. You can exercise your right to prevent such processing by checking certain boxes on the consent forms we use when collecting your personal information. If at any point you wish to review or change your preferences, you can use the “opt-out” or unsubscribe mechanism or other means provided within the communications that you receive from us. Note that you may still receive transactional communications from Click Certain. Some territories have national laws requiring a local Data Protection Officer (for example Singapore and Germany).
Your California Data Privacy Rights
Information About Data We Have Collected or Disclosed About You
The California Consumer Privacy Act (“CCPA”) provides additional data privacy rights to California residents. You have the right to request that we provide, not more than twice every 12 months, certain information about the data we have collected or disclosed about you over the past 12 months, including:
the categories of personal information we have collected about you;
the categories of sources from which we have collected your personal information;
the business or commercial purpose for collecting your personal information;
the categories of third parties with whom we share your personal information;
the specific pieces of personal information we have collected about you; and
the categories of personal information that we have disclosed about you for a business purpose.
For the purposes of your rights as a California resident, “personal information” means any non-publicly available information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked with you or your household, such as biometric information or information about your location.
Disclosure of Personal Information
For certain of our business functions, we may disclose personal information for a business purpose. When we disclose personal information for a business purpose, the third party must agree to retain, use, or disclose the personal information solely for the business purpose. We prohibit the third party from selling the personal information that we provide [for a business purpose]. In the past 12 months, depending on how you interact with Click Certain, we may have disclosed your information as set forth in the section above entitled “Disclosure and Sharing of Your information.”
Deletion of Data
California residents also have the right to request that we delete the personal information we have collected from you (and direct our service providers to do so), except where retaining your personal information is necessary for Click Certain to:
- Complete your transaction, provide a good or service you requested, or perform a contract between you and us;
- Protect you or us from security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity;
- Fix errors in our systems;
- Protect your, our, or others’ right to free speech, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act (California Penal Code Section 1546 and following);
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws;
- Use your personal information internally in a way that is reasonably aligned with your expectations based on your relationship with us or in another lawful manner that is compatible with the context in which you provided the information; or
- Comply with a legal obligation.
- “Do Not Track” (for California and Delaware Residents)
Please note that we do not respond to or honor “do not track” (a/k/a/ DNT) signals or similar mechanisms transmitted by web browsers. For more information about “do not track”, go to allaboutdnt.com.
How to Exercise Your Rights
To exercise your rights under CCPA, you may submit a verifiable consumer request to us by phone at +27 10 300 7921 or by email at privacy(at)clickcertain.co.za. Only you, a person registered with the Secretary of State authorized to act on your behalf, or you on behalf of your minor child may submit a verifiable consumer request. The request must provide enough information for us to reasonably verify you are, or are the authorized representative of, the person about whom we collected personal information.
Links to Third-Party Websites
Any comments, complaints or questions concerning this policy or complaints or objections about our use of your personal information should be addressed by directing your comments to Click Certain’s Data Protection Officers, whose contact information is found here.
Lodging a complaint
If you believe we are using your personal information unlawfully, please let us know first (on privacy(at)clickcertain.co.za or 010 300 7916). You may lodge a complaint to the Information Regulator (South Africa) with the following contact details:
Address: SALU Building, 316 Thabo Sehume Street, Pretoria.
Contact number: 012 406 4818.
Fax number: 086 500 3351.
If you are in the European Union or the United Kingdom, the following details may be used for the relevant regulatory authority.
GDPR: The European Commission Online complaint procedure: https://ec.europa.eu/info/about-european-commission/contact/problems-and-complaints/how-make-complaint-eu-level/submit-complaint_en
Address: European Commission, Secretary-General
B-1049 Brussels, BELGIUM
The independent Data Protection Authority (“DPA“) per member state Website listing all DPA’s per member state: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
Data Protection Act, 1998 (UK) The Information Commissioner’s Office Website: https://ico.org.uk/global/contact-us/
Tel: 0303 123 1113
Children’s personal information and special personal information
We do not intentionally collect or use personal information of children (persons under the age of 18 years), unless with express consent of a parent or guardian or if the law otherwise allows or requires us to process such personal information.