DEFINING PERSONAL INFORMATION (POPI ACT)

“Personal information” means any information relating to an identified or identifiable living individual existing juristic person (i.e company) as defined under the Protection of Personal Information Act 4 of 2013 (“POPI”). Depending on who you are and how you interact with us (e.g., telephone, online or offline), we may collect, use, receive, store, analyze, combine, transfer or otherwise process different categories of personal information.

Below is a list reflecting the categories of personal information we may collect about you:

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• Identity:

Full Name, identity document, current employment, qualifications and photo.

 

• Contact Information:

Telephone number, email address, home address, chosen billing address, information provided by you about your home, location, country and any reference information.

 

• Payment Information:

Payment and bank details, the date and amount of the transaction and other information provided by you directly.

 

• Platform usage and Technical Information:

Platform usage, information shared on the Platforms including any in-Platform chat function, technical or other details about any device which you use to access the Platforms, including: internet and/or network connection, your Media Access Control (MAC), any device Unique Device Identifier (UDID) or equivalent; your operating system, browser type or other software; your hardware or mobile device details (including your mobile device type and number and mobile carrier details), IP addresses, time zone setting, geolocation information, content and pages that you access and paths taken on our Platforms and the dates and times that you visit the Platforms or other technical details.
 

• ​Marketing and Communications Information:

Communication with customer service support, behavioural data (for example, collected using cookies), information about promotions, surveys, competitions, promotional campaigns and records of your decision to subscribe or to withdraw from receiving marketing materials.

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Please note that not all of the above information is mandatory however depending on what information is provided by you, will limit the accessibility and functionality of the Platform. In addition to the above, we may also collect, use and/or share non-personal information or anonymized data such as statistical or demographic data derived from the Platform. The Platforms may use such information and pool it with other information on an anonymised and generalised basis to track, for example, the total number of users of the Platforms, the number of visitors to the Platforms and the domain names of our visitors' internet service providers.

 

​HOW WE COLLECT PERSONAL INFORMATION

1. If we receive or collect it from you directly:
We collect personal information from you when you voluntarily provide such information, such as when you:
• register for access as a user to the Platforms and make use thereof;
• register as a professional on the Platforms (“Service Provider”);
• contact us with inquiries,
• respond to one of our surveys; and
• enter a competition, promotion or survey or you ask to have marketing materials sent to you.

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Wherever Nepoworx collects personal information we make an effort to provide a link to this Privacy Policy.

2. Collection of personal information from third parties or from publicly available sources

We obtain personal information through third parties, or if publicly available, where permitted by law, including:
• from our commercial partners in order to provide you with a specific service as offered on the Platforms or through any other means;
• from third parties who assist us with business operations;
• from social platforms or networks when you give us permission to do so or such information is available publically as permitted by applicable laws;
• from third parties within the Nepoworx group of companies, including its affiliates and subsidiaries, subject to applicable laws; or
• from external reference agencies or third parties in accordance with applicable laws.
• from publicly available sources, as permitted with applicable laws.

Please be aware that we do not accept unsolicited personal information unconnected with the Platforms and we will delete it as soon as we become aware you have sent us any such Personal (unless we are required to keep that personal information under this Privacy Policy).

 

You are responsible for any public publishing of information including personal information (for example on a discussion forum). Please remember that this may mean third parties gaining access to that information, for which you will be responsible.

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LAWFUL GROUNDS FOR COLLECTING AND PROCESSING YOUR PERSONAL INFORMATION

We process personal information only when we have a valid legal ground to do so. Most commonly, we use your personal information where:

• it is necessary to process your personal information in connection with the performance of providing you with access and use of the Platforms;

•  it is necessary for our legitimate interests (or the legitimate interests of a third party), as permitted in terms of law to comply with any legal obligations.

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We may seek your explicit consent where the applicable laws require us to do so.
Our use of your personal information and other information

The information collected by Nepoworx is used by it, it’s subsidiaries and affiliates (the "Nepoworx Related Companies”) in the following ways:
 

1. For the successful operation of the Platforms, which includes:

• the verification, authentication and authorisation of yourself during your onboarding onto the Platform. Further, should you wish to become a Service Provider or beneficiary on the Platform, you will need to be appropriately vetted by Nepoworx. The type of personal information typically required is Identity and Contact information. This is necessary in order for Nepoworx to assess your application

•  the implementation and monitoring of any bookings which you make using the Platform;

• the sharing of your personal information in order to carry out any applicable services as provided on the Platform, for example, if, as a user of the Platform, you have booked the services that Nepoworx provides.

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2. To manage and implement the Platform, which includes:

• ensuring that content from our Platforms is presented in the most effective manner for you and for your computer or other device from which you access the Platform;

• providing you with information, products or services that you request from us or which we feel may interest you;

• improving or modifying the Platform, for example based on how you use the Platform and what services you are requesting;

• calculating conversion rates and other elements of the Platform’s performance;

• researching and gaining insights into Platforms and market trends and needs and to develop or innovate our technologies, products and services to meet such market trends and needs;

• analysing your use of our Platform and compiling internal statistical insights and reports based on data received, for example: In an ongoing effort to better understand and serve the users of the Platforms, Nepoworx conducts research on its user demographics, interests and behavior based on the personal information and other information provided to us. This research will be compiled and analysed on an aggregate basis; and

• improving and personalizing our relationship with you.

3. To manage our relationship with you, which includes:

• carrying out our obligations arising from between you and us;

• allowing you to participate in interactive features of our Platforms, when you choose to do so;

• notifying you about changes to our Platforms or services offered;

• notifying you if there is any interruption of the Platform;

• receiving your feedback on the improving or developing of our Platforms and services;

• providing you with service assistance and problem solutions or to contact or send you notifications related specifically to the Platforms.

 

4. For marketing purposes (discussed further below)

OUR DISCLOSURE OF YOUR PERSONAL INFORMATION AND OTHER INFORMATION

Nepoworx is not in the business of selling your personal information or information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your personal information with certain third parties, as set out below.

 

1. Nepoworx Related Companies

We may share your personal information within the internal group of Nepoworx. This is in order to:

• provide support services and technical services to these internal third parties and to receive some of these services from them;

• contribute to the research, data analytics and studies in order to improve the Platform, products and services we provide.

 

2. External Third Parties
We may share your personal information with external third parties, such as:

• in order to maintain the Platforms and the ancillary support that the Platforms require;​

• service providers or vendors who under contract assist us with our business operations;

• with the Service Providers or Users of the Platforms, as necessary, for you to connect as provided for by the Platform;

• as we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganisation, dissolution or similar event, personal information may be part of the transferred assets;

• in terms of Nepoworx’s legal obligations to do so. In which case, Nepoworx may disclose your personal information if required to do so by law or in the good faith belief that such action is necessary to:​

  • comply with a legal obligation;

  • protect and defend the rights or property of Nepoworx; 

  • act in urgent circumstances to protect the personal safety of users of the Platform or the public;

  • or protect against legal liability.