Novation Technologies' Privacy and Personal information Policy

Privacy Policy

Background

Novation Technologies understands that your privacy is important to you and that you care about how your personal information is used. We respect and value the privacy of all our customers and we will only collect and use personal information in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

1. Information about us

Novation Technologies (Pty) Ltd
Registration number: 2012 / 202456 / 07

Registered address: Regent Square, Doncaster Rd, Kenilworth, Cape Town, 8000

VAT number: 4570262313
Information Protection Officer: Ricardo Bourne
Postal Address: Regent Square, Doncaster Rd, Kenilworth, Cape Town, 8000

2. What does this policy cover?

This Privacy Information explains how we use your personal information: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal information.

3. What is personal information?

Personal information is defined by the Protection of Personal Information Act 4 of 2013 as information that identifies and characterises a data subject. Personal information is, in simpler terms, refers to any information about you that enables you to be identified. Personal information covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location information, and other online identifiers. The personal information that we use is set out in Part 5, below.

4. What are my rights?

Under POPI, you have the following rights, which we will always work to uphold:

• The right to be informed about our collection and use of your personal information. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
• The right to access the personal information we hold about you. Part 10 will tell you how to do this.
• The right to have your personal information rectified if any of your personal information held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
• The right to be forgotten, i.e., the right to ask us to delete or otherwise dispose of any of your personal information that we have. Please contact us using the details in Part 11 to find out more.
• The right to restrict (i.e., prevent) the processing of your personal information.
• The right to object to us using your personal information for a particular purpose or purposes.
• The right to information portability. This means that, if you have provided personal information to us directly, we are using it with your consent or for the performance of a contract, and that information is processed using automated means, you can ask us for a copy of that personal information to re-use with another service or business in many cases.
• Rights relating to automated decision-making and profiling. we do not use your personal information in this way.
• For more information about our use of your personal information or exercising your rights as outlined above, please contact us using the details provided in Part 11.

5. What personal information do we collect?

We may collect some or all the following personal information (this may vary according to your relationship with us):

• Name
• Address
• Email address
• Telephone number
• Business name
• Payment information
• IP Address

6. How do we use your personal information?

Under POPI, we must always have a lawful basis for using personal information. This may be because the information is necessary for our performance of a contract with you, because you have consented to our use of your personal information, or because it is in our legitimate business interests to use it. Your personal information will be used for the following purposes:

• Providing and managing your account.
• Supplying our products and services to you. Your personal details are required for us to enter a contract with you.
• Personalising and tailoring our products and services for you.
• Communicating with you. This may include responding to emails or calls from you and providing overall updates about our services.
• Supplying you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time by amending your settings.

With your permission and/or where permitted by law we may also use your personal information for marketing purposes, which may include contacting you by email and telephone and text message and post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under POPI, and you will always have the opportunity to opt-out. We use the following automated system for carrying out certain kinds of decision making. If at any point you wish to query any action that we take based on this or wish to request 'human intervention' (i.e., have someone review the action themselves, rather than relying only on the automated method), POPI gives you the right to do so. Please contact us to find out more using the details in Part 11.

• Latest Updates to the software and mobile app including any security updates.
• Sending invoices monthly

7. How long will we keep your personal information?

We will not keep your personal information for any longer than is necessary considering the reason(s) for which it was first collected. Your personal information will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept): We will keep personal information whilst you are an active customer and as a reference in our financial systems whilst you are an inactive customer for historical reference and tax purpose.

8. How and where do we store or transfer your personal information?

We will only store or transfer your personal information in South Africa and the United Kingdom. This means that it will be fully protected under the GDPR (General Data Protection Regulation EU Regulation 2016/679) and POPI Act. Please contact us using the details below in Part 11 for further information about the information protection mechanism used by us when transferring your personal information to a third country. The security of your personal information is essential to us, and to protect your information, we take several important measures, including the following:

• We make sure we use the latest technology to protect all personal information.
• Multifactor authentication is enforced to enhance identity management of your data.

9. Do we share your personal information?

We will not share any of your personal information with any third parties for any purposes, subject to one important exception. In some limited circumstances, we may be legally required to share certain personal information, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority. We may sometimes contract with product or service enhancing third parties to supply you on our behalf. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all your personal information that we hold. If any of your personal information is required by a third party, as described above, we will take steps to ensure that your personal information is handled safely, securely, and in accordance with your rights, our obligations, and the third party's obligations under the law, as described above in Part 8. If any personal information is transferred outside of South Africa or the United Kingdom, we will take suitable steps to ensure that your personal information is treated just as safely and securely as it would be within the UK and under the GDPR as well as within South Africa and under the POPI Act, as explained above in Part 8.

10. How can you access your personal information?

If you want to know what personal information we have about you, you can ask us for details of that personal information and for a copy of it (where any such personal information is held). This is known as a 'subject access request' or 'data subject request'. All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible. There is not normally any charge for a subject access request. If your request is 'manifestly unfounded or excessive' (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding. We will respond to your subject access request within 21 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal information within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

11. How do you contact us?

To contact us about anything to do with your personal information and information protection, including to make a subject access request, please use the following details (for the attention of Ricardo Bourne):

• Email address: info@novationtech.co.za
• Telephone number: +27 (0) 861 117 772
• Postal Address: Regent Square, Doncaster Rd, Kenilworth, Cape Town, 8000

12. Changes to this privacy policy.

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal information protection. Any changes will be made available on our website.