PRIVACY STATEMENT

This Privacy Statement provides important information regarding how and why The Closet Collective collects, stores, shares and uses the personal information about you, in accordance with the Protection of Personal Information Act 4 of 2013 (POPIA). Furthermore, this Privacy Statement will outline your rights in relation to your personal information and how you can contact The Closet Collective and State authorities in the event that you have a complaint.

Personal data or information means any information about an individual or juristic person from which that person can be identified. The Closet Collective collects and uses personal information in order to:

• Respond to queries or requests submitted by you;
• Process orders or applications submitted by you;
• Administer or otherwise carry out our obligations in relation to any agreement you have with The Closet Collective; and
• Resolve problems regarding any goods and/or services supplied to you.

The Closet Collective endeavours to take all reasonable measures when collecting, processing, storing and destroying personal information of users, suppliers and clients and shall only collect, process, store and destroy such personal information when necessary and in order to comply with legislation or to fulfil a specified purpose for which the information is intended.

The Closet Collective shall only share your personal information as follows:

• With law enforcement or other authorities if required to do so by applicable law;
• The Closet Collective will not share your personal information with any other third parties and will only provide your personal information which we consider is necessary for the performance of the reason.

The Closet Collective is dedicated to collecting, processing, storing and destroying personal information in a lawful and transparent manner and will only retain your personal information for as long as necessary to fulfil the purposes for which The Collective Closet collected it, including the purposes of satisfying any legal, accounting or reporting requirements.

The Closet Collective takes serious measures to ensure the security, confidentiality, integrity, and availability of your personal information in The Closet Collective’s possession. The Closet Collective has various technical and organisational measures in place to ensure that personal information remains secure and confidential by safeguarding the data against unlawful access, processing, loss, or damage. Furthermore, The Closet Collective has procedures in place to deal with any suspected data security breach. The Closet Collective will notify you, and any applicable regulator, of a suspected data security breach where legally required to do so.

Should you wish to have access to your personal information in order to amend, update, remove or query any of your personal information in the Closet Collective’s possession, you may contact The Closet Collective via email at info@theclosetcollective.co.za.

In the event that you have exhausted all of The Closet Collective’s internal procedures to resolve any queries or concerns regarding your personal information, and you remain dissatisfied with the resolution, then please take note that you may approach the Information Regulator to assist. The Information Regulator details are as follows:

The Information Regulator (South Africa)

33 Hoofd Street, Forum III, 3rd Floor
Braampark
P.O Box 31533
Braamfontein, Johannesburg
2017

(010) 023 5207
(011) 403-0668

complaints.IR@justice.gov.za
inforeg@justice.gov.za

For more information, please see our Privacy Policy below.

PRIVACY POLICY
  1. INTRODUCTION

This document applies to The Closet Collective.

  1. DEFINITIONS
“POPIA” Protection of Personal Information Act

 

  1. OBJECTIVES

The objective of this document is to:

  • explain how we obtain, use, and disclose your personal information, in accordance with the requirements of POPIA; and
  • illustrate how we are commitment to protecting your privacy and to ensure that your personal information is collected and used properly, lawfully and transparently.
  1. PERSONAL INFORMATION

Personal information includes:

  • certain information that we collect automatically when you visit our website;
  • certain information collected on registration (see below);
  • certain information collected on submission; and
  • optional information that you provide to us voluntarily (see below).but excludes:
  • information that has been made anonymous so that it does not identify a specific person;
  • permanently de-identified information that does not relate or cannot be traced back to you specifically;
  • non-personal statistical information collected and compiled by us; and
  • information that you have provided voluntarily in an open, public environment or forum including any blog, chat room, community, classifieds, or discussion board (because the information has been disclosed in a public forum, it is no longer confidential and does not constitute personal information subject to protection under this policy).
  1. THE INFORMATION WE COLLECT

5.1 We collect and process your personal information mainly to contact you for the purposes of understanding your requirements, and delivering services accordingly.  For this purpose we will collect contact details including your name and organisation.

5.2 We collect information directly from you where you provide us with your personal details.  Where possible, we will inform you what information you are required to provide to us and what information is optional.

5.3 Website usage information may be collected using “cookies” which allows us to collect standard internet visitor usage information.

5.4 Common examples of the types of personal information which we may collect and process include your:

  • identifying information – such as your name, date of birth, or identification number of any kind;
  • contact information – such as your phone number or email address;
  • address information – such as your physical or postal address; or
  • demographic information – such as your gender or marital status.

5.5 Depending on the goods or services that you require, we may also collect sensitive personal information including your:

  • financial information – such as your bank account details;
  • sensitive demographic information – such as your race or ethnicity;
  • medical information – such as information about your physical or mental health;
  • sexual information – such as information about your sex life or sexual orientation;
  • criminal information – such as information about your commission or alleged commission of any offence or about any related legal proceedings;
  • employment information – including your membership of a trade union; and
  • beliefs – including your political or religious beliefs.
  1. ACCEPTANCE

6.1 You must accept all the terms of this policy when you order our goods or request our services. If you do not agree with anything in this policy, then you may not order our goods or request our services.

6.2 You may not access our website or order our goods or request our services if you are younger than 18 years old or do not have legal capacity to conclude legally binding contracts.

6.3 By accepting this policy, you are deemed to have read, understood, accepted, and agreed to be bound by all of its terms.

6.4 You may only send us your own personal information or the information of another data subject where you have their permission to do so.

  1. CHANGES

We may change the terms of this policy at any time by updating our web page(s). We will notify you of any changes by placing a notice in a prominent place on our website(s) or by sending you an email detailing the changes that we have made and indicating the date that they were last updated. If you do not agree with the changes, then you must stop using the website and our goods or services. If you continue to use the website or our goods or services following notification of a change to the terms, the changed terms will apply to you and you will be deemed to have accepted those updated terms.

  1. COLLECTION

On registration

8.1 Once you register on our website, you will no longer be anonymous to us. You will provide us with certain personal information when you register on our website(s).

8.2 This personal information may include:

  • your name and surname;
  • your email address;
  • your telephone number;
  • your company name, company registration number, and VAT number;
  • your postal address or street address; and
  • your username and password.

8.3 We will use this personal information to fulfil your account, provide additional services and information to you as we reasonably think appropriate, and for any other purposes set out in this policy.

On order or request

8.4 When you order our goods or request our services from us, you will be asked to provide us with additional information on a voluntary basis (goods or services information).

From browser

8.5 We automatically receive and record Internet usage information on our server logs from your browser, such as your Internet Protocol address (IP address), browsing habits, click patterns, version of software installed, system type, screen resolutions, colour capabilities, plug-ins, language settings, cookie preferences, search engine keywords, JavaScript enablement, the content and pages that you access on the website, and the dates and times that you visit the website(s), paths taken, and time spent on sites and pages within the website (usage information). Please note that other websites visited before entering our website(s) might place personal information within your URL during a visit to it, and we have no control over such websites. Accordingly, a subsequent website that collects URL information may log some personal information.

Cookies

8.6 We may place small text files called ‘cookies’ on your device when you visit our website. These files do not contain personal information, but they do contain a personal identifier allowing us to associate your personal information with a certain device. These files serve a number of useful purposes for you, including:

  • granting you access to age restricted content;
  • tailoring our website’s functionality to you personally by letting us remember your preferences;
  • improving how our website performs;
  • allowing third parties to provide services to our website; and
  • helping us deliver targeted advertising where appropriate in compliance with the applicable laws.

8.7 Your internet browser generally accepts cookies automatically, but you can often change this setting to stop accepting them. You can also delete cookies manually. However, no longer accepting cookies or deleting them will prevent you from accessing certain aspects of our website where cookies are necessary. Many websites use cookies and you can find out more about them at allaboutcookies.org.

Third party cookies

8.8 Some of our business partners use their own cookies or widgets on our website. We have no access to or control over them. Information collected by any of those cookies or widgets is governed by the privacy policy of the company that created it, and not by us.

Web beacons

8.9 Our website may contain electronic image requests (called a single-pixel gif or web beacon request) that allow us to count page views and to access cookies. Any electronic image viewed as part of a web page (including an ad banner) can act as a web beacon. Our web beacons do not collect, gather, monitor or share any of your personal information. We merely use them to compile anonymous information about our website.

Optional details

8.10 You may also provide additional information to us on a voluntary basis (optional information). This includes content or products that you decide to upload or download from our website or when you enter competitions, take advantage of promotions, respond to surveys, order certain additional goods or services, or otherwise use the optional features and functionality of our website.

Recording calls

8.11 We may monitor and record any telephone calls that you make to us, unless you specifically request us not to.

Purpose for collection

8.12 We may use or process any goods or services information, or optional information that you provide to us for the purposes that you indicated when you agreed to provide it to us. Processing includes gathering your personal information, disclosing it, and combining it with other personal information. We generally collect and process your personal information for various purposes, including:

  • goods or services purposes – such as collecting orders or requests for and providing our goods or services;
  • marketing purposes – such as pursuing lawful related marketing activities;
  • business purposes – such as internal audit, accounting, business planning, and joint ventures, disposals of business, or other proposed and actual transactions; and
  • legal purposes – such as handling claims, complying with regulations, or pursuing good governance.

8.13 We may use your usage information for the purposes described above and to:

  • remember your information so that you will not have to re-enter it during your visit or the next time you access the website(s);
  • monitor website usage metrics such as total number of visitors and pages accessed; and
  • track your entries, submissions, and status in any promotions or other activities in connection with your usage of the website(s).

Consent to collection

8.14 We will obtain your consent to collect personal information:

  • in accordance with applicable law;
  • when you provide us with any registration information or optional information.
  1. USE

Our obligations

9.1 We may use your personal information to fulfil our obligations to you.

Messages and updates

9.2 We may send administrative messages and email updates to you about the website. In some cases, we may also send you primarily promotional messages. You can choose to opt-out of promotional messages. OR We may send administrative messages and email updates to you about the website. We may wish to provide you with information about new goods or services in which we think you may be interested. This means that in some cases, we may also send you primarily promotional messages. We will not send you promotional messages unless you have chosen to opt-into them. But, we may send you one message asking you to opt-into promotional messages without you having opted-into promotional messages.

Targeted content

9.3 While you are logged into the website, we may display targeted adverts and other relevant information based on your personal information. In a completely automated process, computers process the personal information and match it to adverts or related information. We never share personal information with any advertiser, unless you specifically provide us with your consent to do so. Advertisers receive a record of the total number of impressions and clicks for each advert. They do not receive any personal information. If you click on an advert, we may send a referring URL to the advertiser’s website identifying that a customer is visiting from the website. We do not send personal information to advertisers with the referring URL. Once you are on the advertiser’s website however, the advertiser is able to collect your personal information.

  1. DISCLOSURE

Sharing

10.1 We may share your personal information with:

  • other divisions or companies within the group of companies to which we belong so as to provide joint content and services like registration, for transactions and customer support, to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about our products, services, and communications (they will only use this information to send you marketing communications if you have requested their goods or services);
  • an affiliate, in which case we will seek to require the affiliates to honour this privacy policy;
  • our goods or services providers under contract who help provide certain goods or services or help with parts of our business operations, including fraud prevention, bill collection, marketing, technology services (our contracts dictate that these goods or services providers only use your information in connection with the goods or services they supply or services they perform for us and not for their own benefit);
  • credit bureaus to report account information, as permitted by law;
  • banking partners as required by credit card association rules for inclusion on their list of terminated merchants (in the event that you utilise the services to receive payments and you meet their criteria); and
  • other third parties who provide us with relevant services where appropriate.

Regulators

10.2 We may disclose your personal information as required by law or governmental audit.

Law enforcement

10.3 We may disclose personal information if required:

  • by a subpoena or court order;
  • to comply with any law;
  • to protect the safety of any individual or the general public; and
  • to prevent violation of our customer relationship terms.

No selling

10.4 We will not sell personal information. No personal information will be disclosed to anyone except as provided in this privacy policy.

Marketing purposes

10.5 We may disclose aggregate statistics (information about the customer population in general terms) about the personal information to advertisers or business partners.

Employees

10.6 We may need to disclose personal information to our employees that require the personal information to do their jobs. These include our responsible management, human resources, accounting, audit, compliance, information technology, or other personnel.

Change of ownership

10.7 If we undergo a change in ownership, or a merger with, acquisition by, or sale of assets to, another entity, we may assign our rights to the personal information we process to a successor, purchaser, or separate entity. We will disclose the transfer on the website. If you are concerned about your personal information migrating to a new owner, you may request us to delete your personal information.

  1. SECURITY

We take the security of personal information very seriously and always do our best to comply with applicable data protection laws. Our hosting company will host our website in a secure server environment that uses a firewall and other advanced security measures to prevent interference or access from outside intruders. We authorize access to personal information only for those employees who require it to fulfil their job responsibilities. We implement disaster recover procedures where appropriate.

  1. ACCURATE AND UP TO DATE

We will try to keep the personal information we collect as accurate, complete and up to date as is necessary for the purposes defined in this policy. From time to time we may request you to update your personal information on the website. You are able to review or update any personal information that we hold on you by accessing your account online, emailing us, or phoning us. Please note that in order to better protect you and safeguard your personal information, we take steps to verify your identity before granting you access to your account or making any corrections to your personal information.

  1. RETENTION

13.1 We will only retain your personal information for as long as it is necessary to fulfil the purposes explicitly set out in this policy, unless:

  • retention of the record is required or authorised by law; or
  • you have consented to the retention of the record.

13.2 During the period of retention, we will continue to abide by our non-disclosure obligations and will not share or sell your personal information.

13.3 We may retain your personal information in physical or electronic records at our discretion.

  1. TRANSFER TO ANOTHER COUNTRY

We may transmit or transfer personal information outside of the country in which it was collected to a foreign country and process it in that country. Personal information may be stored on servers located outside the country in which it was collected in a foreign country whose laws protecting personal information may not be as stringent as the laws in the country in which it was collected. You consent to us processing your personal information in a foreign country whose laws regarding processing of personal information may be less stringent.

  1. UPDATING OR REMOVING

You may choose to correct or update the personal information you have submitted to us, by clicking the relevant menu in any of the pages on our website or contacting us by phone or email.

  1. LIMITATION

We are not responsible for, give no warranties, nor make any representations in respect of the privacy policies or practices of linked or any third-party websites.

  1. ENQUIRIES

If you have any questions or concerns arising from this privacy policy or the way in which we handle personal information, please contact us.