South Africa Privacy Policy

POPIA
DEFINITIONS
INTRODUCTION
CONTACT DETAILS
GUIDE OF SAHRC
LATEST NOTICES IN TERMS OF SECTION 52(2) OF PAIA
AVAILABILITY OF CERTAIN RECORDS IN TERMS OF PAIA
RECORDS AVAILABLE IN TERMS OF OTHER LEGISLATION
REQUEST PROCESS
GROUNDS FOR REFUSAL
REMEDIES SHOULD A REQUEST BE REFUSED
FEES
POPI

1. POPIA

Our South African Privacy Policy

The Protection of Personal Information Act, 2013 (“POPI”) came into complete commencement on 1 July 2021, in this regard we have a number of obligations and duties in terms of POPI that we must comply with. The protection of your personal information is a high priority for us and we have taken steps to ensure that your personal information is protected and remains private.

In addition to this document serving as our privacy policy, this document will also serve as our data subject notification as contemplated in section 18 of POPI. In this regard, this document will inform you of what personal information we collect, why we collect it, how we use it and what safety measures are in place to protect it.

Where we refer to “process”, it means how we collect, use, store, make available, destroy, update, disclose, or otherwise deal with your personal information. As a general rule we will only process your personal information if this is required to deliver or offer a service, provide a product or carry out a transaction.

We may combine your personal information and use the combined personal information for any of the purposes stated in this Privacy Policy.

In this document any reference to “we” or “us” or “our” is reference to Call Cabinet South Africa.

If you use our services, goods and/or products, you agree that we may process your personal information as explained under this Privacy Policy.

We may change this Privacy Policy from time to time if the law or our business practices requires it.

The version of the Privacy Policy displayed on our website at the time of your interaction with us will be applicable.

What is personal information?

Personal information refers to any information that identifies you or specifically relates to you. Personal information includes, but is not limited to, the following information about you:

Age, Financial history, Personal views, Belief, Gender, Physical address, Birth, Identity number, Physical health, Biometric, Language, Pregnancy, Colour, Location information, Race, Conscience, Marital Status, Religion, Correspondence, Mental Health, Sex, Criminal history, Medical History, Sexual orientation, Culture, Name, Social origin, Disability, National Origin, Symbol, Education, Online identifier, Telephone number, E-mail address, Other particular assignment, Well being, Employment history, Personal opinions, Ethnic origin, Personal preferences.

Is the supply of the personal information voluntary or mandatory?

The supply of certain personal information is mandatory, meaning we have to collect this personal information from you by law. If you do not supply this information, we cannot comply with our legal obligations. In this regard, if you do not supply this personal information we cannot do business with you. We collect personal information as is required by the following legislation:

Basic Conditions of Employment Act, No 75 of 1997

Continuing Education and Training Act (previously known as Further Education and Training Colleges Act) 16 of 2006

Compensation for Occupational Injuries and Diseases Act, No. 130 of 1993

Credit Agreement Act, No. 75 of 1980

The Criminal Procedure Act, No. 51 of 1977

Debt Collectors Act, No. 114 of 1998

Employment Equity Act, No. 55 of 1998

Financial Intelligence Centre Act, No. 38 of 2001

Higher Education Act 101 of 1997

Income Tax Act 58 of 1962

Labour Relations Act, No 66 of 1995

National Credit Act, No. 34 of 2005

NQF Act No 67 of 2008

Pension Funds Act, No. 24 of 1956

Skills Development Act 97 of 1998

Unemployment Insurance Act, No. 63 of 2001

Financial Advisory and Intermediary Service Act, No. 37 of 2002

Occupational Health and Safety Act No. 85 of 1993

Prevention of Organised Crime Act No. 121 of 1998

In other instances the supply of personal information is voluntary, which means there is no law imposed on us to collect this personal information. Even though there is no law that imposes the collection of the personal information, we require the personal information to deliver the products and/or services to you. In this regard, if you do not supply the personal information, we cannot do business with you.

When will we process your personal information?

We will only process your personal information for lawful purposes relating to our business if the following applies:

if you have consented thereto.
if a person legally authorised by you, the law, or a court, has consented thereto.
if it is necessary to conclude or perform under a contract, we have with you.
if the law requires or permits it.
if it is required to protect or pursue your, our or a third party’s legitimate interest.

What is special personal information?

Special personal information is personal information about the following:

Biometric information, Philosophical beliefs, Sex life, Criminal behaviour, Political persuasion, Trade union membership, Ethnic origin, Race, Health, Religious beliefs.

When will we process your special personal information?

We may process your special personal information in the following circumstances:

if you have consented to the processing.
if the information is being used for any Human resource or payroll requirement.
if the processing is needed to create, use, or protect a right or obligation in law.
if the processing is for statistical or research purposes and all legal conditions are met.
if the special personal information was made public by you.
if the processing is required by law.
if racial information is processed, and the processing is required to identify you; and / or if health information is processed, and the processing is to determine your insurance risk, or to comply with an insurance policy or to enforce an insurance right or obligation.

When and from where we obtain personal information about you?

We may collect personal information about you from the following sources:

We may collect personal information directly from you.
We may collect personal information from a public record.
We may collect personal information from an area where you have deliberately made it public.
We may collect information about you based on your use of our products, services, or service channels.
We may collect information about you based on how you engage or interact with us such as via our support desk, emails, letters, telephone calls and surveys.
We may collect personal information from a third party.
We may collect personal information from another source if you give us consent to do so.

If the law requires us to do so, we will ask for your consent before collecting personal information about you from third parties.

The third parties from whom we may collect your personal information include, but are not limited to, the following:

Partners of our company for any of the purposes identified in this Privacy Policy.
your spouse, dependents, partners, employer, and other similar sources.
attorneys, tracing agents, debt collectors and other persons that assist with the enforcement of agreements.
payment processing services providers, merchants, banks, and other persons that assist with the processing of your payment instructions, like EFT transaction partners.
insurers, brokers, other financial institutions, or other organisations that assist with insurance and assurance underwriting, the providing of insurance and assurance policies and products, the assessment of insurance and assurance claims and other related purposes.
law enforcement and fraud prevention agencies and other persons tasked with the prevention and prosecution of crime;
regulatory authorities, industry ombudsman, governmental departments, local and international tax authorities.
trustees, Executors or Curators appointed by a court of law.
our service providers, agents and sub-contractors like couriers and other persons we use to offer and provide products and services to you.
courts of law or tribunals.

Reasons we need to process your personal information.

We will process your personal information for the following reasons:

to provide you with services
to market our products, goods, and services to you.
to respond to your enquiries and complaints.
to comply with legislative, regulatory, risk and compliance requirements (including directives, sanctions, and rules), voluntary and involuntary codes of conduct and industry agreements or to fulfil reporting requirements and information requests.
to conduct market and behavioural research, including scoring and analysis to determine if you qualify for products and services or to determine your credit or insurance risk.
to develop, test and improve products and services for you.
for historical, statistical and research purposes, like market segmentation.
to process payment instruments.
to create, manufacture and print payment issues (like a payslip)
to enable us to deliver goods, documents, or notices to you.
for security, identity verification and to check the accuracy of your personal information.
to communicate with you and carry out your instructions and requests.
for customer satisfaction surveys, promotional offerings.
insurance and assurance underwriting and administration.
to process or consider or assess insurance or assurance claims.
to provide insurance and assurance policies and products and related services.
to enable you to take part in customer loyalty reward programmes, to determine your qualification for participation, earning of reward points, determining your rewards level, monitoring your buying behaviour with our rewards partners to allocate the correct points or inform you of appropriate products, goods, and services you may be interested in or to inform our reward partners about your purchasing behaviour.
to enable you to take part in and make use of value-added products and services.
to assess our lending and insurance risks; and / or
for any other related purposes.

How we use your personal information for marketing

We will use your personal information to our products and services to you.
We will do this in person, by post, telephone, or electronic channels such as SMS, email, and fax.
If you are not our customer, or in any other instances where the law requires, we will only market to you by electronic communications with your consent.
In all cases you can request us to stop sending marketing communications to you at any time.

When how and with whom we share your personal information?

In general, we will only share your personal information if any one or more of the following apply:

if you have consented to this.
if it is necessary to conclude or perform under a contract, we have with you;
if the law requires it; and / or
if it’s necessary to protect or pursue your, our or a third party’s legitimate interest.

Under what circumstances will we transfer your information to other countries?

We will only transfer your personal information to third parties in another country in any one or more of the following circumstances:

where your personal information will be adequately protected under the other country’s laws or an agreement with the third-party recipient.
where the transfer is necessary to enter into or perform under a contract with you, or a contract with a third party that is in your interest.
where you have consented to the transfer; and / or
where it is not reasonably practical to obtain your consent, the transfer is in your interest.

This transfer will happen within the requirements and safeguards of the law. Where possible, the party processing your personal information in the other country will agree to apply the same level of protection as available by law in your country or if the other country’s laws provide better protection the other country’s laws would be agreed to and applied.

How we secure your personal information

We will take appropriate and reasonable technical and organisational steps to protect your personal information according to industry best practices. Our security measures (including physical, technological, and procedural safeguards) will be appropriate and reasonable. This includes the following:
keeping our systems secure (like monitoring access and usage);
storing our records securely.
controlling the access to our buildings, systems and/or records; and
safely destroying or deleting records.
Ensure compliance with best practice standards.

How long do we keep your personal information?

We will keep your personal information for as long as:

the law requires us to keep it.
a contract between you and us requires us to keep it.
you have consented for us keeping it.
we are required to keep it to achieve the purposes listed in this Privacy Policy.
we require it for statistical or research purposes.
a code of conduct requires us to keep it; and / or
we require it for our lawful business purposes.

Take note: We may keep your personal information even if you no longer have a relationship with us, for the historical data that may be required by your employer or employee.

Our cookie policy

Our cookies policy is informed by the Call Cabinet global policy which is found under paragraph 3 or our Global privacy policy, and can be accessed by following this link https://www.callcabinet.com/privacy-policy/

Your duties and rights about the personal information we have about you.

You must provide proof of identity when enforcing the rights below.

You must inform us when your personal information changes.

Please contact our Information Officer to give effect to any of the below rights.

You have the right to request access to the personal information we have about you by contacting us. This includes requesting:

confirmation that we hold your personal information.
a copy or description of the record containing your personal information; and
the identity or categories of third parties who have had access to your personal information.

We will attend to requests for access to personal information within a reasonable time. You may be required to pay a reasonable fee to receive copies or descriptions of records, or information about third parties. We will inform you of the fee before attending to your request.

Please note that the law may limit your right to access information.

You have the right to request us to correct or delete the personal information we have about you if it is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, obtained unlawfully or we are no longer authorised to keep it. You must inform us of your request in writing. It may take up to 15 business days for the change to reflect on our systems. We may request documents from you to verify the change in personal information.

A specific agreement that you have entered into with us may determine how you must change your personal information provided at the time when you entered into the specific agreement. Please adhere to these requirements. If the law requires us to keep the personal information, it will not be deleted upon your request. The deletion of certain personal information may lead to the termination of your business relationship with us.

You may object on reasonable grounds to the processing of your personal information.

We will not be able to give effect to your objection if the processing of your personal information was and is permitted by law; you have provided consent to the processing and our processing done according to your consent or the processing is necessary to conclude or perform under a contract with you.

Where you have provided your consent for the processing of your personal information, you may withdraw your consent. If you withdraw your consent, we will explain the consequences to you. We may proceed to process your personal information even if you have withdrawn your consent if the law permits or requires it. It may take up to 15 business days for the change to reflect on our systems, during this time we may still process your personal information. You must inform us of any objection in writing.

You have a right to file a complaint with us or any Regulator with jurisdiction about an alleged contravention of the protection of your personal information by us. We will address your complaint as far as possible.

The contact details for the Information Regulator is as follows:

Email: POPIAComplaints@inforegulator.org.za

Postal Address: P.O. Box 31533, Braamfontein, Johannesburg, 2017

Physical Address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001.

2. DEFINITIONS

Client: any natural or juristic person that received or receives services from Call Cabinet

Conditions for Lawful Processing: the conditions for the lawful processing of Personal Information as fully set out in chapter 3 of POPI and in paragraph 12 of this Manual

Data Subject: the person to whom personal information relates

Information Officer: the individual who is identified in paragraph 3 of this manual

Manual: this manual

PAIA: the Promotion of Access to Information Act 2 of 2000

Personal Information: means information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person, including, but not limited to—

information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth of the person;
information relating to the education or the medical, financial, criminal or employment history of the person;
any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier or other particular assignment to the person;
the biometric information of the person;
the personal opinions, views or preferences of the person;
correspondence sent by the person that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence;
the views or opinions of another individual about the person; and
the name of the person if it appears with other personal information relating to the person or if the disclosure of the name itself would reveal information about the person

Personnel: any person who works for, or provides services to or on behalf of Call Cabinet, and receives or is entitled to receive remuneration and any other person who assists in carrying out or conducting the business of Call Cabinet, which includes, without limitation, directors (executive and non-executive), all permanent, temporary and part-time staff as well as contract workers

POPI: the Protection of Personal Information Act 4 of 2013

POPI Regulations: the regulations promulgated in terms of section 112(2) of POPI

Private Body: means—

a natural person who carries or has carried on any trade, business or profession, but only in such capacity;
a partnership which carries or has carried on any trade, business or profession; or
any former or existing juristic person, but excludes a public body

Processing: means any operation or activity or any set of operations, whether or not by automatic means, concerning personal information, including—

the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use;
dissemination by means of transmission, distribution or making available in any other form; or
merging, linking, as well as restriction, degradation, erasure or destruction of information

SAHRC: the South African Human Rights Commission

Any other terms not described herein will have the meaning as ascribed to it in terms of PAIA or POPI.

3. INTRODUCTION

For the purpose of POPI and PAIA, Call Cabinet is defined as a private body. In accordance with Call Cabinet’s obligations in terms of POPI and PAIA, Call Cabinet has produced this manual.
This manual sets out all information required by both PAIA and POPI.
This manual also deals with how requests are to be made in terms of PAIA.
This manual also establishes how compliance with POPI is to be achieved.

4. CONTACT DETAILS

Business Name Call Cabinet Southern Africa (Pty) Ltd

Registration Number 2012/117385/07

Registered Office 76 Lynburn Road, Lynwood Manor, Pretoria 0081

Postal Address P O Box 31602, Kyalami 1684

Contact Number 011 – 554 4450

Information Officer Judith Bowyer

Email address judithb@callcabinet.co.za

5. GUIDE OF SAHRC

A guide to PAIA and how to access information in terms of PAIA has been published pursuant to section 10 of PAIA.
The guide contains information required by an individual who may wish to exercise their rights in terms of PAIA.
Should you wish to access the guide you may request a copy from the Information Officer by submitting ANNEXURE A, attached hereto, to the details specified above.
You may also inspect the guide at Call Cabinet’s offices during ordinary working hours.
You may also request a copy of the guide from Information Regulator at the following details:

Information Regulator:

Postal Address: P.O. Box 31533, Braamfontein, Johannesburg, 2017

Telephone: (010) 023 5200

Website: www.justi.gov.za

Email: PAIAComplaince.IR@justice.gov.za

6. LATEST NOTICES IN TERMS OF SECTION 52(2) OF PAIA

At this stage no Notice(s) has / have been published on the categories of records that are available without having to request access to them in terms of PAIA

7. AVAILABILITY OF CERTAIN RECORDS IN TERMS OF PAIA

Call Cabinet holds and/or process the following records for the purposes of PAIA and POPI.
The following records may be requested, however it should be noted that there is no guarantee that the request will be honoured. Each request will be evaluated in terms of PAIA and any other applicable legislation.

Products and/or Services:

All products and/or services are available freely on Call Cabinet’s website as set out above.

Human Resources:

Employment Contracts
Employee benefits
Personnel records and correspondence
Training records
Internal policies
Information pertaining to share options, share incentives, bonus or profit
sharing agreements of each employe
Pension and provident find records

Legal:

Agreements with Clients
Agreement with Suppliers
Shareholder agreements
Partnership agreements
Licenses and Permits
Power of Attorneys
Sale agreements
Lease agreement

Company Secretarial:

Memorandum of Incorporation
Secretarial records
Tradename registrations
Trademark registrations
Company registration documents
Statutory registers
Minutes of Shareholder’s meetings
Minutes of Director’s meetings
Register of Directors
Share Certificates

Financial:

Accounting records
Annual reports
Interim reports
Auditor details and reports
Tax returns
Insurance records

Client:

Client database
Client recordings
Credit Applications
Correspondence with Clients
Documentation prepared for Clients.
Invoices, receipts, credit and debit notes

Marketing:

Published Marketing material

Miscellaneous:

Internal Correspondence
Information technology records
Trade secrets
Domain name registrations
Website information
Asset registers
Title deeds

8. RECORDS AVAILABLE IN TERMS OF OTHER LEGISLATION

Call Cabinet may be in possession of records in terms of the following legislation as and when applicable:
1. Basic Conditions of Employment Act, No. 75 of 1997
2. Companies Act, No. 71 of 2008
3. Compensation for Occupational Injuries and Diseases Act, No. 130 of 1993
4. Competition Act, No. 89 of 1998
5. Constitution of the Republic of South Africa Act, No. 108 of 1996
6. Credit Agreement Act, No. 75 of 1980
7. The Criminal Procedure Act, No. 51 of 1977
8. Debt Collectors Act, No. 114 of 1998
9. Deed Registries Act, No. 47 of 1937
10. Employment Equity Act, No. 55 of 1998
11. Financial Intelligence Centre Act, No. 38 of 2001
12. Identification Act, No. 68 of 1997
13. National Credit Act, No. 34 of 2005
14. Insolvency Act, No. 24 of 1936
15. Inspection of Financial Institutions Act, No. 18 of 1998
16. The Labour Relations Act, No. 66 of 1995
17. The Long Term Insurance Act, No. 52 of 1998
18. Pension Funds Act, No. 24 of 1956
19. Short Term Insurance Act, No. 53 of 1998
20. Skills Development Levies Act, No. 9 of 1999
21. Unemployment Insurance Act, No. 63 of 2001
22. Unit Trust Control Act, No. 54 of 1981
23. Value Added Tax Act, No. 89 of 1991
24. Electronic Communication and Transactions Act, No. 25 of 2002
25. Financial Advisory and Intermediary Service Act, No. 37 of 2002
26. Patents, Designs and Copyright Merchandise Marks Act, No. 17 of 1941
27. Income Tax Act, No. 58 of 1962
28. Occupational Health and Safety Act No. 85 of 1993
29. Co-operatives Act No. 14 of 2005
30. Customs and Excise Act No. 91 of 1964
31. Insider Trading Act No. 135 of 1998
32. Prevention of Organised Crime Act No. 121 of 1998
33. Road Transportation Act No. 74 of 1977
34. Stock Exchanges Control Act No. 54 of 1995
35. Transfer Duty Act No. 40 of 1949
36. Machinery and Occupational Safety Amendment Act No. 181 of 1993
37. National Payment Systems Act No. 78 of 1998
38. National Water Act No. 36 of 1998
39. Prescription Act No. 68 of 1969
40. Trademark Act No. 194 of 1993
41. Intellectual Property Laws Amendment Act No.38 of 1997
42. Financial Markets Act No. 19 of 2012

9. REQUEST PROCESS

An individual who wishes to place a request must comply with all the procedures laid down in PAIA.
The requester must complete ANNEXURE B, which is attached hereto and submit it to the Information Officer at the details specified above.
The prescribed form must be submitted as well as payment of a request fee and a deposit, if applicable to the information officer at the postal or physical address, fax number or electronic mail as is stated herein.
The prescribed form must be completed with enough particularity to enable the information officer to determine:
1. The record(s) requested;
2. The identity of the requestor;
3. What form of access is required; and
4. The Postal address or fax number of the requestor.
The requestor must state that the records are required for the requestor to exercise or protect a right, and clearly state what the nature of the right is so to be exercised or protected. An explanation of why the records requested is required to exercise or protect the right.
The request for access will be dealt with within 30 days from date of receipt, unless the requestor has set out special grounds that satisfies the Information Officer that the request be dealt with sooner.
The period of 30 days may be extended by not more than 30 additional days, if the request is for a large quantity of information, or the request requires a search for information held at another office of CALL CABINET and the information cannot be reasonably obtained within 30 days. The information officer will notify the requestor in writing should an extension be necessary.
The Information Officer must communicate a response to the request for access using “Annexure E”, this communication shall inform the requestor of:
1. The decision;
2. Fees payable in terms of paragraph 11.
  1. In the event that the Information Officer is of the opinion that the searching and preparation of the record for disclosure would amount to more than 6 hours, he/she shall inform the requestor to pay a deposit not exceeding one third of the amount payable.
Should the requestor have any difficulty with the form or the process laid out herein, the requestor should contact the Information Officer for assistance.
An oral request can be made to the Information Officer should the requestor be unable to complete the form due to illiteracy or a disability. The Information Officer will complete the form on behalf of the requestor and provide a copy of the form to the requestor.

10. GROUNDS FOR REFUSAL

The following are grounds upon which Call Cabinet may, subject to the exceptions in Chapter 4 of PAIA, refuse a request for access in accordance with Chapter 4 of PAIA
1. Mandatory protection of the privacy of a third party who is a natural person, including a deceased person, where such disclosure of Personal Information would be unreasonable
2. Mandatory protection of the commercial information of a third party, if the Records contain
  1. Trade secrets of that third party;
  2. Financial, commercial, scientific or technical information of the third party, the disclosure of which could likely cause harm to the financial or commercial interests of that third party; and/or
  3. information disclosed in confidence by a third party to Call Cabinet, the disclosure of which could put that third party at a disadvantage in contractual or other negotiations or prejudice
    the third party in commercial competition;
3. Mandatory protection of confidential information of third parties if it is protected in terms of any agreement;
4. Mandatory protection of the safety of individuals and the protection of property;
5. Mandatory protection of Records that would be regarded as privileged in legal proceedings;
6. Protection of the commercial information of Call Cabinet, which may include
  1. Trade secrets;
  2. Financial/commercial, scientific or technical information, the disclosure of which could likely cause harm to the financial or commercial interests of Call Cabinet;
  3. Information which, if disclosed, could put Call Cabinet at a disadvantage in contractual or other negotiations or prejudice Call Cabinet in commercial competition; and/or
  4. Computer programs which are owned by Call Cabinet, and which are protected by copyright and intellectual property laws;
7. Research information of Call Cabinet or a third party, if such disclosure would place the research or the researcher at a serious disadvantage; and
8. Requests for Records that are clearly frivolous or vexatious, or which involve an unreasonable diversion of resources.

11. REMEDIES SHOULD A REQUEST BE REFUSED

Call Cabinet does not have an internal appeal procedure in light of a denial of a request, decisions made by the information officer is final;
The requestor may in accordance with sections 56(3) (c) and 78 of PAIA, apply to a court for relief within 180 days of notification of the decision for appropriate relief.

12. Fees

The following fees shall be payable upon request by a requestor:

Request fee (payable on every request) R140.00

Photocopy of an A4 page or part thereof R2.00

Printed copy of an A4 page or part thereof R2.00
Hard copy on flash drive (flash drive to be provided by requestor) R40.00

Hard copy on a compact disc (compact disc to be provided by requestor) R40.0

Hard copy on a compact disc (compact disc to be provided by Call Cabinet) R60.00

Transcription of visual images per A4 page As per quotation of service provider

Copy of visual images As per quotation of service provider

Transcription of an audio record per A4 page R24.00
Copy of an audio record on flash drive (flash drive to be provided by requestor) R40.00

Copy of an audio on a compact disc (compact disc to be provided by requestor) R40.0

Copy of an audio on a compact disc (compact disc to be provided by Call Cabinet) R60.00

To search for and prepare the record for disclosure for each hour or part of an hour, excluding the first hour,
reasonably required for such search and preparation R145.00

To search for and prepare the record for disclosure for each hour or part of an hour, excluding the first hour,
reasonably required for such search and preparation (cannot exceed total cost) R435.00

Postage, email or any other electronic transfer Actual expense, if any.

13. POPI

1. Conditions fort lawful processing:
  1. POPI has eight conditions for lawful processing and includes:
    1. Accountability
    2. Processing limitation
    3. Purpose specification
    4. Further processing limitation
    5. Information quality
    6. Openness
    7. Security safeguards
    8. Data subject participation
  2. Call Cabinet is involved in the following types of processing:
    1. Collection
    2. Recording
    3. Organization
    4. Structuring
    5. Storage
    6. adaptation or alteration
    7. retrieval
    8. consultation
    9. use
    10. disclosure by transmission
    11. dissemination or otherwise making available
    12. alignment or combination
    13. restriction
    14. erasure
    15. destruction
  3. Call Cabinet processes information for the following purposes:
    1. to fulfil agreements in relation to its employees;
    2. Answers to your questions.
    3. To improve the quality of your Website visit.
    4. To complete requests made to us.
    5. To notify you of any changes to requests made to us.
    6. To create your Call Cabinet user account on our servers.
    7. To send marketing communications and purchase confirmations that you have opted-in to or otherwise agreed to receive.
    8. To send surveys to you, as and when you have consented to say.
    9. To update your user account with any information we receive from you or from third-party sources about you.
    10. To post Messages to your account and publish, market and distribute those Messages as contemplated in the Application.
      NB, CallCabinet may use your personal information collected during your Website visit, Application usage, during your interaction with our e-mails or during your interaction with our third-party marketing efforts for other purposes including without limitation, the following:
    11. To provide marketing reports, demographic reports and other information to Sponsors to demonstrate the effectiveness of Call Cabinet and usage and of individual Messages
    12. To better monitor in the aggregate the effectiveness of our Messages, advertising and marketing campaigns.
    13. To better monitor in the aggregate how visitors and users are using our Website.
    14. To ensure that our Application, Website and email communications continue to provide relevant content that is interesting and useful to our Sponsors and users.
    15. To uncover and diagnose problems with our servers.
    16. For day-to-day system administration needs.
    17. to provide services to its Clients in accordance with terms agreed to by the Clients;
    18. to monitor and record calls and electronic communications with the Client for quality, training, investigation and fraud prevention purposes;
    19. to enforce or defend Call Cabinet or our affiliates’ rights;
    20. the purposes related to any authorised disclosure made in terms of agreement, law or regulation;
    21. any additional purposes expressly authorised by Call Cabinet client;
2. Call Cabinet processes personal information the following categories of Data Subjects:
  1. Juristic persons –
    1. Corporate clients
    2. Suppliers
  2. Natural persons –
    1. Individuals
    2. Staff
    3. Clients
    4. Suppliers
3. Call Cabinet process the following categories personal information:
  1. Client profile information;
  2. Bank account details;
  3. Payment information;
  4. Client representatives;
  5. Names;
  6. Email Addresses;
  7. Telephone numbers;
  8. Facsimile numbers;
  9. Physical addresses;
  10. Tax numbers;
  11. Identity Numbers;
  12. Passport Numbers;
4. Recipients of Personal Information:
  1. Call Cabinet, it’s affiliates, their respective representatives.
5. When making authorised disclosures or transfers of personal information in terms of Section 72 of POPI, personal information may not be disclosed to recipients in countries that do not have the same level of protection for personal information as South Africa does.
6. The following Security measures are implemented by Call Cabinet:
7. Call Cabinet implements numerous Security measures to protect personal information that is stored electronically and physically.
  1. Call Cabinet ensures that appropriate security measures are taken and updates these measures on a regular basis.
  2. Call Cabinet have also implemented various policies for additional security for personal information stored both physically and electronically.
  3. The personal information that is stored physically is protected as follows:
    1. Where physical records of the data exist, such records will be stored in a secure area that can be ‘locked-away’ as to avoid a breach of the personal information.
    2. Such physical data records will be ‘locked-away’ and secured when not in use.
8. Call Cabinet may share personal information with third parties and in certain instances this may result in cross border flow of the personal information. The personal information will always be subject to protection, not less than the protection it is afforded under the Protection of Personal Information Act No.4 of 2013.
9. Objection to the processing of personal information by a data subject:
  1. Section 11(3) of POPI and regulation 2 of the POPI regulations provides that a data subject may, at any time object to the processing of their personal information in the prescribed form attached to this manual as ANNEXURE “C”.
10. Request for correction or deletion of personal information:
  1. Section 24 of POPI and regulation 3 of the POPI regulations provides that a data subject may request for their personal information to be corrected and/or deleted in the prescribed form attached hereto as ANNEXURE “D”.

Download Annexures A to D

This Privacy Policy was last updated on December 12, 2023