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This privacy notice will inform you as to how we collect, use and protect your personal information. It will also tell you about your privacy rights and how the law protects you.

1 – Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how we collect and process your personal information.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Responsible party

This privacy notice is issued on behalf of Keepup.co.za, Registration no. 1234/001234/01 located at: 123 Wall Street, Bryanston, Gauteng 2191

Contact details

If you have any questions about this privacy notice or any questions or concerns regarding the manner in which your personal information is being processed please send your query to: compliance@Keepup.com

Changes to the privacy notice

We keep our privacy notice under regular review. This version has been published on 17 November 2021. Historical versions of our privacy notice can be obtained by contacting us. Details of previous versions of this privacy notice can be found at paragraph 9.

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes by contacting us.

Third-party links and embedded content

This website may include links to third-party websites and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements or the manner in which they process your personal information. When you leave our website, we encourage you to read the privacy notice of every website you visit.

This website may also include embedded third-party content. Any embedded content that references a third party’s name or trade mark may be embedded third-party content. Interacting with that third-party content may allow third parties to collect or share data about you. We are not responsible for the manner in which third parties may process your personal information following your access of such content (including their delivery of cookies); nor are we responsible for third-party privacy statements. When you access embedded third-party content, we encourage you to read any associated privacy notice provided by a third party related to the embedded content (which may require you to follow links to the third party’s privacy notice or website).

2 – The personal information we collect about you

Personal information means any information about a living individual and where applicable, an existing juristic person, from which that person can be identified. It does not include anonymized or aggregated data, where it is not possible to identify an individual or a juristic person from that data.

We may collect, use, store and transfer different kinds of personal information about you, and we have grouped this together as follows:

Identity data – includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender (for companies, it also includes any personal information from the company registration documents). If you attend our offices, we may collect details of your car registration.

Contact data – includes billing address, postal address, email address and telephone numbers (of billing contacts and users).

Financial data – includes bank account and payment card details, information included in VAT certificate/TAX clearance certificates, debit order forms and bank statements for certain clients.

Transaction data – includes details about payments to and from you and other details of products and services you have purchased from us.

Technical data -includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website, products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs).

Profile data – includes your username and password, purchases or orders made by you and any requests for support, your interests, preferences, feedback, survey responses, entries to competitions or promotions, and where you have registered for training or an event.

Usage data – includes information about how you use our products and services, this website, or any other Keepup websites you may visit, for example, the ‘Keepup Community’ website or the ‘Keepup Learning Centre’ website.

Marketing and communications data – includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data. aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any special personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you do not provide personal information

Where we need to collect personal information by law, or under the terms of a contract we have with you and you do not provide that data when requested, we may not be able to perform the contract we have in place with you, or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3 – How your personal information is collected

We use different methods to collect personal information from and about you including through:

Direct interactions. You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal information you provide when you:

  • Register as a user of our products or services;
  • Subscribe to our publications;
  • Request marketing communications to be sent to you or you update your marketing preferences;
  • Enter a competition, promotion or survey;
  • Attend seminars, training or other events;
  • Give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Please see our cookies policy for further details.

Third parties or publicly available sources. We may receive personal information about you from various third parties and public sources as set out below:

  • Third parties to whom you have provided your personal information where you have expressly consented to them sharing your contact details with Keepup or to a category in which Keepup’ business activities would fall (including where you have attended an event which has been sponsored by Keepup and you have agreed to the event organiser sharing your contact details with event sponsors);
  • Publicly available sources.

4 – How we use your personal information

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information:

  • Where we need to perform the contract we are about to enter into or have entered into with you; or
  • Where it is necessary for our legitimate interests (or those of a third party); or
  • Where we need to comply with a legal or regulatory obligation; or
  • Where you have agreed to us processing your personal information.

Purposes for which we will use your personal information

We have set out below a description of all the ways we plan to use your personal information:

  • To register you as a new customer
  • To deliver services to you including: (a) to manage payments, fees and charges; (b) to collect and recover money owed to us; (c) to manage licensing and permissions granted to you in relation to our software and services; (d) to provide you with support and training materials/ services and general know how regarding use of our products and services
  • To manage our relationship (and, if applicable, our agreement) with you which will include: (a) updating our customer relationship management system and other internal systems with information about you and our dealings with you; (b) notifying you about changes to our terms or privacy notice; and (c) asking you to leave a review or take a survey
  • To enable you to partake in a prize draw, competition or complete a survey
  • To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  • To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
  • To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
  • To make suggestions and recommendations to you about goods or services that may be of interest to you

Marketing

We will only send you marketing communications by electronic means (for example by email) if:

  1. you have expressly provided your consent to receiving such communications; OR
  2. you are an existing customer of Keepup and you have not previously unsubscribed to receiving marketing communications from us.

If you would like to tailor the way we contact you, please visit our marketing communications preference centre.

Opting out

You can ask us to stop sending you marketing messages at any time by visiting our preference centre and checking or unchecking relevant boxes to adjust your marketing preferences.

Where you opt out of receiving these marketing messages, we will stop sending you marketing messages but if you are an Keepup customer then we will still need to process your personal information for the purpose of supplying you with our products or services.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

For detailed information on the cookies we use and the purposes for which we use them, please see our cookies policy.

5 – Third parties to whom we may provide your personal information

We may have to share your personal information with the parties set out below, or use certain third parties in the course of collecting your personal information, for the purposes mentioned in paragraph 4 above.

Internal third parties

Other companies in the Keepup Group and who are based in Australia, the United Kingdom, France, Canada, Singapore and New Zealand and provide IT and system administration services, service delivery and payment administration, provision of support services, training and reporting.

This includes staff engaged in the fulfilment of any contracts we have with you, the processing of your payment details and the provision of support services.

External third parties

  • Third party service providers (including contractors and designated agents). We use third party service providers to help us with the following activities: workplace technology (e.g. document management and storage), hosting (including the hosting of our customer relationship management system, the Keepup Learning Centre and the Keepup Community), training (platform and materials), communications (including audio and video conferencing) and marketing (e.g. notifications, surveys). Please contact us if you would like to receive a full list of the third party service providers who may process your personal information in the course of assisting us with these activities.
  • If you are a client, or a user of our products in an organisation with whom we have a contract – third party processors who we are authorised to use pursuant to our contract with you.
  • Professional advisers: including lawyers, bankers, auditors and insurers who provide consultancy and accounting services.
  • the South African Revenue Service (SARS), regulators and other authorities based in South Africa to whom we have a reporting obligation in certain circumstances.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

6 – International transfers of your personal information

We may disclose personal information to members of our corporate group located overseas. Countries in which we are based include Australia, the United Kingdom, France, Singapore, Malaysia, Hong Kong, New Zealand and Canada. We have appropriate controls in place in relation to intra-group transfers of data.

We will only transfer personal information across South African borders if the relevant situation requires trans-border processing, and will do so only in accordance with POPIA.

When our operators are located overseas, we will take steps to ensure that our operators are bound by laws, binding corporate rules or binding agreements that provide an adequate level of protection and uphold principles for the reasonable and lawful processing of personal information, in accordance with POPIA.

7 – Data security

We ensure that there are appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

Following an audit by the British Standards Institution (BSI) we have achieved ISO/IEC 270001 accreditation. This is an internationally recognised certificate for best practice framework for managing information security.

We have put in place procedures to deal with any suspected security compromises and will notify you and the Information Regulator of a breach where we are legally required to do so.

8 – Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal information, including but not limited to:

a) the right to establish whether we hold personal information about you and to request access to it;

b) the right to request, where necessary, the correction, destruction or deletion of your personal information;

c) the right to object, on reasonable grounds relating to your particular situation, to the processing of your personal information;

d) the right to object, at any time, to the processing of your personal information for purposes of direct marketing by means of unsolicited electronic communications.

If you wish to find out more about your rights, or wish to exercise any of them, please contact us or access our Global Data Protection Policy available at: https://www.Keepup.com/resources/legal/data-protection

You have the right to make a complaint at any time to the Information Regulator, the South African supervisory authority for data protection issues, with the following contact details:

Physical address: 33 Hoofd Street, Forum III, 3rd Floor Braampark, Johannesburg, 2001

(From 1st April 2021 – JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001

P.O Box 31533, Braamfontein, Johannesburg, 2017

Website: https://www.justice.gov.za/inforeg

Email: complaints.IR@justice.gov.za

We may ask you to pay a fee to access your personal information. In this case, we will give you a written estimate of the fee before providing you access to your personal information and we may request you to pay a deposit for all or part of the fee.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.