MANAGEMENT AND DISCLOSURE OF PERSONAL INFORMATION THAT
HIGHBURY MEDIA (PTY) LTD (“HM,” “we” OR “us”) COLLECTS THROUGH
THE FOLLOWING WEBSITES:
WE RESPECT YOUR RIGHTS TO RESPONSIBLE MANAGEMENT OF
YOUR PERSONAL INFORMATION UNDER THE PROTECTION OF
PERSONAL INFORMATION ACT 4 OF 2013. YOUR USE OF THE
WEBSITES AND HM’S PRODUCTS AND SERVICES IS SUBJECT TO THIS
POLICY. BY USING THE WEBSITES, YOU SIGNIFY YOUR CONSENT TO
PROCESSING OF YOUR PERSONAL INFORMATION IN ACCORDANCE
IN THIS POLICY, PLEASE DO NOT USE THIS WEBSITES OR SUBMIT
ANY PERSONALLY IDENTIFIABLE INFORMATION THROUGH THE
1. PERSONAL INFORMATION COLLECTION AND USE
1.1 HM and/or its authorised technology agents may collect and store
certain Personal Information from You in connection with Your use of
THE WEBSITES and/or the products and/services provided to You by
in accordance with the definition in the Act. Generally, such
information is information that can be used to personally identify you. In
particular, however, HM may collect information such as:
1.2.1 first name and surname,
1.2.2 email address,
1.2.3 cell phone number,
1.2.4 profession or occupation,
from the following persons: any individual who chooses to register on
1.3 HM may also automatically collect and store non-personally identifiable
information related to your use of the THE WEBSITES. Non-personally
identifiable information may include personal information that has been
1.4 We may share non-personally identifiable information with third parties
for certain reasons, including advertising, marketing and/or other
1.5 Your Personal Information is used to provide You with the requested
products and/or services; enable ease of use of THE WEBSITES;
process transactions concluded by You; engage in electronic
communications and transactions with You; administer promotions or
survey or similar interactive activity; or to provide You with newsletters
or other periodic communications and/or marketing materials.
1.6 Personal Information is automatically collected in relation to Your visit
to THE WEBSITES, such information includes but is not limited to:
Your browser type and version, as well as Your operating system.
1.7 Cookies are small files send from THE WEBSITES to a Your computer
drive that can be used to track when You visit and re-visit a website
device with which You access THE WEBSITES and may use
anonymous cookies to determine website usage analytics and statistics
in order to optimise THE WEBSITES and Your experience. You are
able to manually delete cookies from Your browser or set Your browser
to reject cookies. PLEASE NOTE that certain pages or features may
not be available or work correctly if You have set Your browser to reject
1.8 HM uses Google Analytics and Effective Measures, which supports
data collection without browser cookies. It helps HM to understand user
interaction with THE WEBSITES and implement changes that evolve
THE WEBSITES to suit Your needs.
1.9 The WEBSITES hosting agents and/or service providers may
automatically log Your “IP address” which is a unique identifier for Your
computer and/or other access device. Such information collected is for
aggregate purposes only and cannot be used to identify You
1.10 In the event that You subscribe to newsletters and/or to receive further
information through other periodic communications, from HM, Your
Personal Information will be processed by HM to provide You with such
information and associated processes. All HM communications shall
contain an unsubscribe link and by following the unsubscribe process
You shall be removed from the relevant distribution list and HM shall no
longer send You the subscription information. Should you experience
any issues with this process please contact our legal advisor, Tracey
Stewart at email@example.com directly.
2. CONSENT TO PROCESS PERSONAL INFORMATION
2.1 You understand that Your consent to the processing of your personal
information by HM pertains to the provision of the products and
services made available on THE WEBSITES; as well as associated
purposes. Processing shall include the collection, receipt, recording,
organisation, collation, storage, updating or modification, retrieval,
alteration, consultation, use; dissemination by means of transmission,
distribution or making available in any other form; or merging, linking,
as well as blocking, degradation, erasure or destruction of information.
2.2 This consent is effective from the moment you access THE WEBSITES
and will endure until Your access and/or relationship with HM has been
2.3 You expressly consent to HM retaining Your Personal Information once
your relationship with HM has been terminated for: aggregate,
statistical and reporting purposes.
2.4 In the event that You wish to revoke all consent pertaining to Your
Personal Information and You would like HM to remove and/or delete
Your Personal Information entirely, You must notify HM via email to
HM’s legal advisor, Tracey Stewart email address: firstname.lastname@example.org.
2.5 By Using THE WEBSITES, You represent that You are of the age of 18
or that a Competent Person has given consent to allow Your minor
child to utilise THE WEBSITES. You, or a ‘Competent Person’ in the
case of a minor, consent/s to the processing of personal information
that belongs to You or, in the case of a minor, to the minor for whom
You are responsible, in the manner described in this Policy. You agree
that giving such consent means that You have given HM permission to
collect and process the child’s personal information in the ways
described in this Policy.
3. HANDLING OF PERSONAL INFORMATION
3.1 HM endeavors to comply with all laws and regulations pertaining to
information and communications privacy including, but not limited to,
the 1996 South African Constitution and the Protection of Personal
Information Act 4 of 2013 (“the Act”). HM applies the principles of
protection of personal information under such Act in further legislation
referred to in the Act.
3.2 You have the right to correct Your Personal Information as well as to
revoke Your consent to the processing of Your Personal Information by
HM. You do, however, understand that HM requires Your Personal
Information to render the HM products and/or services and should You
decide to revoke Your consent HM may not be able to provide You with
such products and/or services.
3.3 HM will take all reasonable measures in order to ensure Your Personal
Information is appropriately safeguarded, these precautions include,
but are not limited to: the use of a sufficiently secure server and
providing suitably secure payment mechanisms.
3.4 Should any unauthorised person/s gain access to Your personal
information HM will contact You within a reasonable time to inform You
of the security breach.
3.5 HM seeks to ensure the quality, accuracy and confidentiality of
Personal Information in its possession.
3.6 HM may share Your personal information with authorised third parties
these include persons such as employees and service providers to HM.
HM does not permit these parties to use such information for any other
purpose than to perform the services that HM has instructed them to
provide and in accordance with this Policy.
3.7 From time to time, HM may appoint certain agents, third parties and/or
service providers which operate outside the borders of the Republic of
South Africa. In these circumstances HM will be required to transmit
Your Personal Information outside South Africa. The purpose of the
trans-border flow of Your Personal Information may include, but is not
limited to: data hosting and storage. You expressly consent to the
trans-border flow of Your Personal Information. Furthermore, You
warrant in this regard that You have obtained the necessary consents
required in terms of the Act, in order to enable the trans-border flow of
any personal information submitted by You. HM warrants in this regard
that it shall only engage the services of third parties (in relation to the
aforesaid trans-border flow of information) which subscribe acceptable
safeguards in accordance with HM’s legal obligations.
3.8 HM will not sell, exchange or transfer Your Personal Information to any
third party except as required in the provision of the HM products
and/or services and in accordance with the consents provided by You.
occasion. Amendments made to this Policy shall become immediately
effective. We encourage You to periodically review this Policy to keep
informed about how HM is protecting Your Personal Information. You
can find the last date of change made to the Policy above for Your
reference. Your continued Use of THE WEBSITES evidences Your
3.10 THE WEBSITES may contain links to other WEBSITES. HM is not
responsible for the privacy practices of third party sites.
4. DISCLOSURE OF PERSONAL INFORMATION
4.1 Records relating to the provision of the HM products and/or services by
HM to You and the Personal Information submitted by You may be
required to be retained in terms of legislated records retention
requirements, HM’s operational purposes and/or for production as
evidence by HM in legal proceedings.
4.2 HM may disclose Your Personal Information under the following
4.2.1 To comply with the law or with legal process;
4.2.2 To protect and defend HM’s rights, equipment, facilities and other
4.2.3 To protect HM against misuse or unauthorised use of THE WEBSITES
and/or products and/or services; and/or
4.2.4 To protect other WEBSITES their Users or third parties affected
negatively by Your actions in use of the products/services and/or THE
5. OBJECTIONS, COMPLAINTS AND QUERIES
5.1 Should You require a correction to be made to Your Personal
Information that HM keeps on record, or a copy of the record itself, or
should You feel that You would like to object to the collection, Use or
processing of Your Personal Information by HM, or that you would like
us to delete your personally identifiable information, then kindly send
an e-mail to our Information Officer, whose name and details are set
out below. We will endeavour to make the correction, provide You with
the record (We reserve our right to charge a small fee in this case),
cease processing of Your Personal Information and/or delete it, in
accordance with Your request.
INFORMATION OFFICER: HM LEGAL ADVISOR – TRACEY STEWART
EMAIL ADDRESS: email@example.com
TEL: 021 416 0141