Last updated: 27 September 2017
What does this policy do?
When does this policy apply?
You agree that this policy will apply when you access or use our website at https://tokensales.newtownpartners.com.
Legally binding contract
This policy will apply to you, and will create a legally binding contract between us, whenever you use or access our website.
Other applicable terms
There are also website browsing terms that apply to your use of our website. Additional terms may also apply for specific products or services or subscriptions available through our website. If there is a conflict between these terms and the specific terms, the specific terms will apply.
Changes to this policy
Unless notice is required in terms of the law, we may change the terms of this policy from time to time in line with any changes that the law or our internal business operations require, without prior notice. The current version of this policy that applies at the time you visit and/or use our website will regulate our relationship. It is your responsibility to consider the policy each time you use our website. If you do not agree with any terms of this policy, you must stop using our website.
This policy is important to us. We are committed to taking steps to protect your privacy when you use our website and implementing business practices that comply with all relevant legislation, including the Protection of Personal Information Act, 4 of 2013 (“POPI“). In this policy, we explain how we will use and protect your personal information.
What is personal information?
If we refer to “personal information” or “information” in this policy, we mean personal information as defined in POPI. It includes, for example, your full name, surname, email address, identity number, contact details, and location.
Collecting your personal information
We collect information about you when you use our website and communicate with us. We may also collect information about you from third parties.
When you use our website, we automatically receive and record information on our server logs from your browser which may include your location, IP address, cookie information, and the page you requested. This is statistical data about browsing actions and patterns and does not identify any individual. We may also obtain information about your general internet usage through a cookie file which is stored on the hard drive of your computer. Cookies enable us to improve our service to you, estimate our audience size and usage patterns, store information about your preferences and recognise when you return to our website.
In some instances, we collect and store information about your location. We convert your IP address or mobile GPS data into a rough geo-location. We may use location information to improve and personalise our services for you.
Links on our website
Our website may include links to other apps or third party websites which do not fall under our supervision. We cannot accept any responsibility for your privacy or the content of these apps, but we display these links to make it easier for our visitors to find information about specific subjects.
How we use your information
We use your information to provide our website and services to you and generally for purposes of our relationship.
Information that we store and use
We generally store and use the following information: your first name(s), surname, address, phone numbers, email address, IP address or cookie information, location information, demographic information including your age and gender and any other information which we reasonably need to perform our obligations in terms of any pitch you may submit to us.
Purposes for processing information
We will only process adequate and relevant information to:
- Operate and manage your account.
- Process your pitch submissions.
- Monitor and analyse our business.
- Contact you by email, sms, or other means to tell you about our services (you can always opt out from future marketing).
- Form a view of you as an individual and to identify, develop or improve services that may interest you.
- Carry out market research, business and statistical analysis.
- Carry out audits.
- Perform other administrative and operational tasks like testing our processes and systems.
- Comply with our regulatory or other obligations.
We may use your information for other purposes if the law allows for it, or if you consent to it, or if it is in the public interest.
Right to object
You may, on reasonable grounds, object to us using your information. If you object, we will stop using your information, except if the law allows its use.
Lodging a complaint
If you believe we are using your information unlawfully, you may lodge a complaint to the Information Regulator with the following contact details:
Children’s information and special personal information
We do not intentionally collect or use information of children (persons under the age of 18 (eighteen) years) unless with consent. Our intention is to only process information of children with the consent of a competent person (someone like the parent or guardian) or if the law otherwise allows or requires us to process such information.
Sharing of personal information
We will keep your personal information confidential and only share it with others in terms of this policy, or if you consent to it, or if the law requires from us to share it. We have trusted relationships with carefully selected third parties who perform services for us. All these service providers have a contract with us in terms whereof they have a legal obligation to secure your personal information and to use it only in a way that we permit.
In general, we may share your information with our affiliates, third party service providers, regulatory and governmental authorities or tax authorities (if they request us to do so), and any other third party if the law requires from us to share it.
Our website may connect to various social media sites or apps, including Facebook, Twitter, LinkedIn, Instagram and Google+. If you want to use our website for social media integration, including to create user profiles and login functionality, we will share your information with the relevant social media sites or apps.
How secure is your information?
We are committed to implement appropriate technical and other security measures to protect the integrity and confidentiality of your information. We protect and manage information that we hold about you, by using electronic and computer safeguards like data encryption. We only authorise access to information to those employees who require it to fulfil their designated responsibilities.
Quality and access to your information
We want to ensure that your information is accurate and up to date. You may ask us to correct or remove any information that you think is inaccurate, by sending us an email to email@example.com.
You have the right to request us to provide you with information that we hold about you. You must contact us directly to do so or send an email to firstname.lastname@example.org.
Retention of information
We retain information in accordance with the required retention periods in law or for legitimate business purposes. We will only retain your information for the purposes explicitly set out in this policy. We may keep information indefinitely in a de-identified format for statistical purposes. This policy also applies when we retain your information.
Trans-border flow of information
We may transfer your information to foreign countries mainly for retention purposes or if our service providers are cross border or use systems cross border. If you continue to use our website, you expressly agree that we may transfer the information cross border for these purposes. We will only share information cross border to recipients who have similar laws like POPI that apply to them, or who entered into an agreement with us to include the relevant POPI principles.
We will report any security breach to the Information Regulator and to the individuals or companies involved. If you want to report any concerns about our privacy practices or if you suspect any breach regarding your information, kindly notify us by sending an email to email@example.com.