(Aug 2021)

INTRODUCTION

We respect your privacy and are committed to protecting your personal information.

This Privacy Notice sets out how we receive, collect, use, store, process and delete your personal information in terms of the Protection of Personal Information Act, 2013 (“POPIA”) and the Promotion of Access to Information Act, 2000.

In terms of POPIA, “personal information” means information relating to an identifiable, living, natural person or, where applicable, an identifiable existing juristic person including any identifying number, e-mail address, physical address, telephone number, location information and online identifier. 

Your legal rights in relation to how we process your personal information are set out in clause 13 below. 

This Privacy Notice applies when you use our website at www.dideye.co.za (“the Website”) and our DIDEYETM application software (“the App”). It also applies to your purchase and use of our DIDEYETM sensor (“the Products”) and related delivery, installation and subscription services (“the Services”) via the Website or App. This Privacy Notice is incorporated by reference into our Customer Terms & Conditions.

PERSONAL INFORMATION WE COLLECT

When you visit the Website or use our App, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that may be installed on your device. Additionally, as you browse the Website, we collect information about the individual Website pages, Products or Services that you view, what websites or search terms referred you to the Website, and information about how you interact with the Website. If you have purchased our Products and subscribed to our Services, we will collect your user ID and device ID. The “open” and ”closed” notifications, date and time as well as sensor state (so-called “Event Information”) generated by our sensor Products will also be collected and transmitted to you via the App, and to any third party (“Shared Member”) with whom you have agreed to share your Event Information within the App. We refer to all of this automatically-collected information as “Device Information.”

We collect Device Information using the following technologies:

    – “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org;

    – “Log files” track actions occurring on the Website, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps;

   – “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Website.

  – Event Information will be generated automatically by our sensor Products and transmitted to your and the Shared Member’s device on which our App has been downloaded.

When you make a purchase or attempt to make a purchase through the Website or App, we collect certain information from you, including your name, billing address, delivery address, payment information (including credit card numbers, email address, any text messages, and phone number).  We refer to this information as “Order Information”. 

Reference to “Personal Information” in this Privacy Notice, includes Order Information and Device Information.

HOW DO WE USE YOUR PERSONAL INFORMATION?

We use the Order Information that we collect generally to: 

  • communicate with you; 
  • meet our contractual obligations to you (including processing your payment information, providing you with invoices and/or order confirmations, arranging for Product delivery, installation and activation); 
  • screen our orders for potential risk or fraud; and 
  • when in line with the preferences you have shared with us, provide you with information or advertising relating to our Products or Services.

We use the Device Information that we collect to provide our Services to you and to, in general, improve and optimize our Website (for example, by generating analytics about how our customers browse and interact with the Website, and to assess the success of our marketing and advertising campaigns), App, Products and Services.

SHARING YOUR PERSONAL INFORMATION

We share your Personal Information with third parties to help us use your Personal Information, as described above.  

We also use Google Analytics to help us understand how our customers use the Website-you can read more about how Google uses your Personal Information here:  https://www.google.com/intl/en/policies/privacy/.  You can also opt-out of Google Analytics here:  https://tools.google.com/dlpage/gaoptout.

We may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

THIRD PARTIES & INTERNATIONAL TRANSFERS

We make use of the services of third parties (“operators”) who provide us with IT, Product and administrative support services (including for eg. cloud hosting, delivery, installation and activation services, billing and other accounting services). When doing so, the processing of personal information in our possession or under our control by these operators is only done with our knowledge and approval and under obligations of confidentiality in terms of contracts that are put in place with them. The operators are also required to establish and maintain appropriate, reasonable technical and organisational measures to (i) prevent loss of, damage to or unauthorised destruction of personal information and (ii) unlawful access to or processing of personal information as required in terms of POPIA. 

We may need to transfer your information to a foreign country if any of our service providers are situated or use systems abroad. When doing so, we will ensure that the necessary security measures are in place with those service providers to protect the processing of your personal information and further, that the service providers are either subject to laws substantially similar to POPIA or the service providers have entered into an agreement with us to include adequate levels of protection as required in terms of POPIA. 

MARKETING & ADVERTISING

As described above, we may use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you in line with the preferences you have shared with us.  

If you would like to exercise the opt out option, please contact us.

DO NOT TRACK

Please note that we do alter our Website’s data collection, device data collection and use practices when we see a Do Not Track signal from your browser.

PERSONAL INFORMATION SECURITY

We have a duty to secure the integrity and confidentiality of the personal information in our possession or under our control by taking appropriate, reasonable technical and organizational measures to prevent any loss, damage, unauthorised destruction and unlawful access to or processing of the personal information.

We maintain appropriate safeguards to address the risks to the personal information identified by us. We regularly check that the safeguards are effectively implemented and continually updated in response to new risks. The security safeguards are based on generally accepted information security practices and procedures which apply to us. 

PERSONAL INFORMATION ACCURACY

We have a duty to ensure that the personal information we process is complete, accurate, not misleading and updated where necessary. For those customers who have purchased and use our Products and Services, please update your personal information with us as soon as it changes.

DATA RETENTION

When you place an order through the Website or App, we will maintain your Order Information for our records unless and until you ask us to delete this information. This right is subject to our obligations to retain such information for a specified period in terms of law. 

MINORS

Our Products and Services (including our App) are available for use and/or purchase (where applicable) by customers over the age of 18. We do not therefore collect the personal information of minors.

CHANGES

We may update this Privacy Notice from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

YOUR RIGHTS

You have the right, upon providing us with adequate proof of your identity, to:

request that we confirm, free of charge, whether we hold in our possession or under our control your personal information;

  • request a copy of your personal information against payment of a prescribed fee;
  • request, where necessary, the correction, destruction or deletion of your personal information where we are not required by law to keep it or where we do not require it for lawful business purposes; and
  • in certain cases, object to the processing of your personal information.

For any requests about our privacy practices or queries, please contact us. 

You have the right to lodge a complaint or query with the Information Regulator as follows:

General enquiries email: inforeg@justice.gov.za

Complaints email: complaints.IR@justice.gov.za