Privacy Statement
& Consent Clause
CONSENT TO RECEIVE DIRECT MARKETING
By submitting my details, I hereby give consent to Business Connexion (Pty) Ltd (“BCX”), the Original Equipment Manufacturers that are marketed by BCX (Technology Partners) and their duly appointed agents to process my personal information as provided, for the purposes of direct marketing by means of electronic communication in respect of information and communications technology-related goods and services.
I understand that my data will be used solely for the purposes for which it was provided, I understand that I can at any time unsubscribe, should I choose to do so, through the BCX Profile centre link provided to me in email when submitting data to BCX.
1. INTRODUCTION
Business Connexion (Pty) Ltd (hereafter “BCX” or “we” or “us” or “our”) respects your privacy, and protection of your personal information is important to us. We are committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection.
This privacy statement, together with the BCX POPIA & PAIA manual, aim to let you know how BCX will treat any personal information that it may have about you and how you can access such personal information held. Reference made to “POPIA” means the Protection of Personal Information Act 4 of 2013 and reference made to “PAIA” means the Promotion of Access to Information 2 of 2000 as amended.
By visiting our website, communicating electronically with us and using our products and services, you consent to the processing and transfer of your personal information as set out in this privacy statement below. BCX will take all reasonable measures, in accordance with this statement, to protect your personal information and to keep it confidential.
For purposes of this privacy statement, “personal information”, “data subject” and “processing” will have the meanings given to them in the POPIA.
We may collect website usage information using “cookies” which allows us to collect standard internet visitor usage information. Details of all other documents pertaining to terms and conditions of personal information are available on our website.
We reserve the right to amend this privacy statement at any time, without prior notice, by posting the amended statement on our website.
2. APPLICATION OF THE PRIVACY STATEMENT
2.1. Our privacy practices apply to the processing of your personal information collected by us or on our behalf, such as data subjects who use our website and/or our products and services, and/or who provide us with products and services, customers and any other data subjects who engage with us.
2.2. This privacy statement does not apply to third party websites linked to our website, or websites that link to or advertise on our website.
3. COLLECTION OF PERSONAL INFORMATION
3.1. The personal information may be provided to us by you and/or collected by us when you engage with us and/or on your use of our products and services, and/or when you provide us with your products and services, and/or when you access our website or from third parties (such as regulators).
3.2. The type of personal information we collect will depend on the purpose for which it is collected and used. The specific purpose for which the information is collected will be apparent from the context in which the information is requested including but not limited to when:
3.2.1. You purchase and/or use our products and services.
3.2.2. You submit enquiries to us or contact us and you may be required to provide your name and surname, identity or passport number, BCX account number, postal or street address, title, contact numbers or email address.
3.2.3. You make use of our website or interact with us on social media, we may collect your non-personal browsing habits and click patterns, email address, IP address, telephone data information, or username and password.
3.2.4. You apply for employment opportunities at BCX, you may be required to provide your name and surname, identity number, employment history and criminal behaviour.
3.2.5. You visit our premises where CCTV cameras are installed.
3.2.6. Where possible, we will inform you of what information is voluntary or mandatory for you to provide to us and the consequences for failing to provide the requested information.
3.2.7. We will only retain your personal information as long as is necessary for the fulfilment of those purposes as have been identified by us and/or as required by law and/or as agreed with you.
4. HOW WE USE YOUR INFORMATION
4.1. Personal information will only be processed for the purposes for which it was collected and/or to comply with legal and regulatory obligations and/or as authorised by law and/or with your consent.
4.2. The purposes for which we process personal information includes, but is not limited to:
4.2.1. Respond to your enquiry.
4.2.2. Provide services or products to you.
4.2.3. Provide access to restricted pages on our website.
4.2.4. Comply with legal requirements or industry codes.
4.2.5. Market or promote our services and products.
4.2.6. Safety and security reasons.
4.2.7. Compile non-personal statistical information about browsing habits, click patterns and access to the BCX website.
5. DISCLOSURE OF INFORMATION
5.1. BCX may disclose your personal information to third parties in certain circumstances, which include, but are not limited to:
5.1.1. Where we have your consent.
5.1.2. Where we are required to do so by law.
5.1.3. To our service providers who are involved in the delivery of products or services to you, where we have agreements in place to ensure that they comply with these privacy terms.
5.2. Third parties who we disclose personal information to include, but are not limited to:
5.2.1. Service providers to BCX.
5.2.2. Accredited debt collection agencies.
5.2.3. Regulators, courts, tribunals and law enforcement agencies.
5.3. We may compile, use and share any information that does not relate to any specific individual and retain all rights to non-personal statistical information collected and compiled by us.
6. TRANSFER OF INFORMATION
6.1.We may need to transfer your personal information to another country for processing or storage. We will ensure that anyone to whom we pass your personal information agrees to treat your information with similar protection as provided for in the POPIA.
6.2. We may transfer your information to other countries which do not have similar protection as provided for in the POPIA, with your consent.
7. INFORMATION SECURITY
7.1. We take appropriate and reasonable technical and organisational measures to prevent any unauthorised or unlawful access, loss of, damage to or unauthorised destruction of personal information.
7.2. We have implemented various policies, procedures and standards to safeguard personal information.
7.3. We regularly verify that the safeguards are effectively implemented and ensure that they are continually updated in line with best practice.
7.4. BCX has implemented procedures to address actual and suspected data breaches, and undertake to notify you and the relevant regulatory authorities of breaches in instances in which BCX is legally required to do so and within the period in which such notification is necessary.
7.5. Notwithstanding paragraphs 7.1 to 7.3 above, to the extent permissible by law, we shall not be liable for any loss, claim and/or damage arising from any unauthorised access, disclosure, misuse, loss, alteration or destruction of your personal information.
8. DATA SUBJECT RIGHTS
Subject to the POPIA provisions, you have the right to:
8.1. Request access to your personal information.
8.2.Request, where necessary, the correction, destruction or deletion of your personal information.
8.3. Object to the processing of your personal information.
8.4. Submit a complaint to the Information Regulator regarding the alleged interference with the protection of the personal information.
8.5. Institute civil proceedings regarding the alleged interference with the protection of your personal information.
9. SUPPORTING TERMS AND CONDITIONS
The privacy statement can be read in conjunction with privacy matters and conditions for lawful processing of personal information that is contained in various supporting documents on BCX’s corporate website: https://bcx.dev.treemind.solutions/
10. USE OF COOKIES
10.1. BCX may use “cookies” to enhance your experience as a customer (referred to as the “user”). The user’s web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. The user may choose to set their web browser to refuse cookies, or to be notified when cookies are being sent. If the user does so, note that some parts of the website service may not function properly.
10.2. BCX collects, stores and uses the above mentioned information for the following purposes:
10.2.1. To communicate requested information to the user.
10.2.2. To provide services to the user as requested by the user.
10.2.3. To authenticate the user.
10.2.4. To provide the user with access to restricted pages on this website.
10.2.5. To compile non-personal statistical information about browsing habits, click patterns and access to the BCX website.
10.3. Information detailed above is collected either electronically by using cookies or is provided voluntarily by the User. Users may determine cookie use independently through their browser settings. For purposes of this clause, a cookie means a small computer file created by a web browser to save user information for website.
10.4. Cookies ensure that BCX is able to continually improve its website. We utilise “first party cookies” (originating from us) to simply track the user’s visits between sessions and deliver a more personalised experience. We also utilise “third party cookies” (not originating from us) to provide traffic analysis and tracking.
10.5. Cookies may be set through our site by our advertising partners. These cookies may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites. They do not store personal information directly, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
11. GOOGLE ANALYTICS USE OF COOKIES
11.1. On our website we use “Google Analytics”, a web analytics service of Google Inc. (“Google”). Google Analytics uses cookies on your device which assists in evaluating the use of our website (more information can be found here: https://policies.google.com/technologies/types
11.2. We use the code “get.anonymizeIP (); “This results in Google shortening your IP address and allowing an anonymised evaluation. The reduction of IP addresses occurs within the EU or the European Economic Area. The IP address submitted by your browser as part of Google Analytics will not be merged with other google data.
11.3. The data collected with the help of cookies is usually transferred to a google server and stored there. Compliance with data protection standards and data rights is ensured by a certification under the EU- US privacy shield. See the Google Privacy statement [https://policies.google.com/privacy] for more information.
11.4. On our behalf, Google uses the data collected through Google Analytics to evaluate the use of our website, to compile reports on the website activities and to provide further information related to the use of the website.
11.5. Data is processed based on your consent by clicking the button on our cookie banner.
11.6. Data is stored for a period of 14 months. You can prevent the storage of the Google Analytics cookies by a corresponding setting in your browser. This may restrict the functionality of our website.
11.7. You may also prevent the collection of data generated by cookies and use of the website (including your IP address) by Google and the processing of such data by Google by clicking the Opt-Out Button located on our cookie banner, this will place an opt-out cookie on your browser. Learn more by clicking on the link below: https://policies.google.com/technologies/managing
12. APPLICATIONS
PERSONAL DATA WE COLLECT AND PROCESS
12.1. When downloading our Applications “Apps”, we process the information required to download it from the respective marketplace, in particular user name, email address and the customer number of your account, time of download, payment information,and individual device ID. We do not control the purpose and means for the collection of this data and are therefore not responsible for it. We only process the data to the extent necessary for downloading the App to your device and for other technical purposes related to the availability and development of the App.
REQUIRED FOR THE PROVISION OF OUR SERVICE
12.2. The categories of personal data described below is processed and generated when using the App. This data is required for technical purposes to increase ease of use for App functions and to ensure stability and security.
-
- User information
- Contact information
- Traffic data
- Business contacts
- Device contact list (Consent required)
- Photo and media (Consent required)
- Usage statistics (Consent required)
- Chat information
USER INFORMATION
12.3. When you log into our App we will process the User information connected to your profile. This data consists of: User name and password.
12.4. We process this data on the basis of a contractual obligation agreed to with your employer.
CONTACT INFORMATION
12.5. If you contact us via email or via our contact form, we will process information required to answer your query. This data consists of: Email address and, if provided, your name and telephone number.
12.6. We process this data on the basis of our legitimate interest to answer your business-related queries.
TRAFFIC DATA
12.7. When using our App, traffic data will be processed. This data is required to facilitate communication. Traffic data is generated and processed automatically when end users communicate via the App and consists of: information about the participants, calling and called number, the connected IP address, the date, the time, the duration of the call, the amount of data used, and when roaming, we register the network that was used.
12.8. We process this data on the basis of a contractual obligation agreed to with the party that has provided you with access to the App. In most cases, this will be your employer.
BUSINESS CONTACTS
12.9. When using our app, business contacts can be processed by the service for which you, your company or your employer has purchased and configured a licensed version of the BCX communication software. The business contacts are managed and configured by your employer and, if applied, will provide you with an overview of other business end users registered by your employer.
12.10. Business contacts are access and processed after authentication and synchronisation of the data with the corresponding servers.
12.11. We process this data on the basis of a contractual obligation agreed to with the party that has provided you with access to the App. In most cases, this will be your employer.
DEVICE CONTACT LIST
12.12. When you make use of certain features, we ask you for your consent to use your device contacts. We will not use this data if you do not consent. If you do not consent, you may not be able to use all functions of our App.
12.13. You may subsequently grant or withdraw your consent at any time by using the settings in the App or your operating system.
12.14. If you do consent, your device contacts will be accessible through the App. The data is stored on the device and on per single contact base the user can request to sync this data to our server to enhance the user experience.
12.15. We process this data on the basis of your consent.
PHOTO AND MEDIA
12.16. When you make use of certain features on our App, we ask you for your consent to use your photos and media. We will not use this data if you do not consent. If you do not consent you may not be able to use all functions of our App.
12.17. You may subsequently grant or withdraw your consent at any time by using the settings in the App or your operating system.
12.18. If you do consent and make use of the feature, your data will can stored on our servers relating to the party that has provided you with access to the App. In most cases, this will be your employer.
12.19. We process this data on the basis of your consent.
USAGE STATISTICS
12.20. Subject to appropriate consent, our App collects anonymous usage data to determine usage-related statistical indicators that we can use for business intelligence purposes to improve our App and make it more attractive for you as an end user. The data is anonymised from the outset and cannot be associated with an identified or identifiable person at any time. 12.21 You may subsequently grant or withdraw your consent at any time by using the settings in the App.
12.22. We process this data on the basis of your consent.
CHAT INFORMATION
12.23. When using our messaging functionality within our App, we will process the data necessary to facilitate communication, this data consists of: IP address, login data, chat messages, chat partner, status of the chat messages, transmitted files.
12.24. The data is collected in the App and then synchronised with the corresponding server on which the software is installed to the extent necessary to provide the relevant functions. Only you have access to data stored solely in the App. The corresponding party that has provided you with access to the App, has access to the data located on the server.
12.25 We process this data on the basis of a contractual obligation agreed to with the party that has provided you with access to the App. In most cases, this will be your employer.
ENHANCED SECURITY
12.26. Only authorised subscribers are provided access to personal data and these employees are contractually or statutorily obliged to ensure confidentiality of this data.
12.27. The App uses SSL encryption for the data and audio connection to the server. The data is therefore not accessible by third parties.
APPLICABLE APPLICATIONS:
- BCX HBT plus
- BCX AR
13. LINKS TO BCX SOCIAL MEDIA PAGES
13.1. BCX has links to their Social Media pages (Instagram, LinkedIn, Twitter and Youtube). If you visit these websites the Privacy Policy and Terms and Conditions of the specific website apply.
13.2. When you contact us via a contact form, via email or phone we process the personal data you communicate to us, e.g. your name, your email address and your request. The data will be stored in a BCX repository. The data marked as mandatory has to be provided in order to action your request.
12.2.1. We use your data to process and answer your request.
12.2.2. We process data to take steps to action your request.
12.2.3. We store your data if it is necessary to fulfil the purposes mentioned above.
14. DATA SUBJECT RIGHTS
Subject to the POPIA provisions, you have the right to:
13.1. Request access to your personal information.
13.2. Request, where necessary, the correction, destruction or deletion of your personal information.
13.3. Request to BCX to amend incorrect data, or delete your personal data provided the request does not conflict with a statutory or contractual obligation to retain data.
13.4. Object to the processing of your personal information for any reason including direct marketing.
13.5. Submit a complaint to the Information Regulator regarding the alleged interference with the protection of the personal information.
13.6. Institute civil proceedings regarding the alleged interference with the protection of your personal information.
15. CONTACT DETAILS
Privacy enquiries may be submitted to POPIA@bcx.co.za or to the address below:
The Information Officer
Private Bag X881
Pretoria
0001
16. INFORMATION REGULATOR
You have the right to lodge a complaint with the Information Regulator in writing if you believe that our data processing does not meet the legal requirements, or we did not facilitate the exercise of your rights accordingly as per their website https://www.justice.gov.za/inforeg/contact
Email
Complaints email: complaints.IR@justice.gov.za
General enquiries email: inforeg@justice.gov.za
Physical address
House 27 Stiemens Street
Braamfontein
Johannesburg
2001
Postal address
PO Box 31533
Braamfontein
Johannesburg
2107