Privacy Policy
1. Introduction
We respect your privacy and take it very seriously. We are Jula Media (Pty) Ltd (Registration number 2021/858783/07), and this is our plan of action to protect your personal information. The purpose of this policy is to describe how we collect, store, use, and protect data that can
be associated with you or another specific natural or juristic person (like a company) and can be used to identify you or that person (personal data).
2. Application
This policy applies to you when you:
• sign a contract with us;
• visit our website;
• and filled out the ‘contact us’ form or
• request our services as a customer (i.e. when we run a campaign for you).
3. Personal information
Personal data includes:
• certain information that we collect automatically when you visit our website or use our application;
• 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, social media platform, 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).
3.1. Common examples
Common examples of the types of personal data 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.
3.2. Sensitive personal data
Depending on the goods or services that you require, we may also collect sensitive personal data 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 in a trade union and
• beliefs – including your political or religious beliefs.
4. Acceptance and changes
4.1. Acceptance required
You must accept all the terms of this policy when you order any of our goods, register for, or use the website, application or any of our services. If you disagree with this policy, you may not order any of our goods or order, register for, or use the website, application or any of our
services. You may not order any of our goods or order, register for, or use the website, application or services if you do not accept this policy.
4.2. Legal capacity
You may not access our website or application or order our goods or services if you are younger than 18 years old or do not have the legal capacity to conclude legally binding contracts.
4.3. Deemed acceptance
By accepting this policy, you are deemed to have read, understood, accepted, and agreed to be bound by all its terms.
4.4. Changes
We may change the terms of this policy at any time by updating this web page. We will notify you of any changes by placing a notice prominently on the website or the application or by email detailing the changes we have made and indicating the date they were last updated. If you disagree with the changes, you must stop using the website, the application and our goods and services. If you continue to use the website, the application 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.
5. Collection
5.1. Automatic
When you visit our website, we automatically collect your Internet usage information, including your IP address, browser details, and usage information. We may use this information to display our website correctly, track your activities, or for other necessary purposes.
5.2. On submission
We ask you to provide specific identifying information when you submit information through our ‘Contact Us’ form. We will use this personal data to fulfil your account and provide additional services and information as we reasonably think appropriate and for any other purposes in this policy.
This personal data 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.
5.3. Through a request
We ask you to provide us with certain service information when you request our services.
5.4. Voluntarily
We may ask you to provide us with certain optional information on a voluntary basis. This includes content or products that you decide to upload or download from our website or application or when you enter competitions, take advantage of promotions, respond to surveys, order certain additional goods or services, or otherwise use our website or application's optional features and functionality.
5.5. Consent to collection
When you provide us with your personal information, we will obtain your consent to collect it in accordance with applicable law.
5.6. Purpose for collection
We may process your information for the purposes that you indicated when you provided it to us. We generally collect and process your personal information for various purposes, including:
• services purposes – such as collecting requests for our services and supplying you with those services; and
• business purposes –proposed and actual transactions;
Processing includes gathering your personal information, disclosing it, and combining it with other personal information.
6. Use
6.1. Information from browser
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, paths taken, and time spent on sites and pages within the website (usage information). Please note that other websites visited before entering our website might place personal data within your URL during a visit, and we have no control over such websites. Accordingly, a subsequent website that collects URL information may log some personal data.
6.2. Processing
We may process your personal information to fulfil our obligations to you.
6.3. Cookies
We may place small text files called ‘cookies’ on your device when you visit our website or use our application. These files do not contain personal data, but they do contain a personal identifier allowing us to associate your data with a particular device. These files serve several functional purposes for you, including:
• 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.
Your internet browser generally accepts cookies automatically, but you can often change this setting or delete them manually. However, if you do so, we won’t be able to provide you with access to certain aspects of our website where cookies are necessary. We have no access to or control over any cookies that our business partners use on our website, and they have their own privacy policies that govern them. Many websites use cookies; you can learn more about them at www.allaboutcookies.org.
6.4. Third-party cookies
Some of our business partners use their 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, not by us.
6.5. Web beacons
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 data. We merely use them to compile anonymous information about our website.
6.6. Messages
We may use your identifying information to send you administrative and update messages about the website. We may also sometimes send you promotional messages, but you may opt out of them.
6.7. Targeted content
While logged into the website or application, we may display targeted adverts and other relevant information based on your data. In a completely automated process, computers match personal data to adverts or related information. We never share personal data with any advertiser unless you provide us with your consent. Advertisers receive a record of each advert's total number of impressions and clicks. They do not receive any personal data. 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 data to advertisers using the referring URL. However, once you are on the advertiser’s website, the advertiser can collect your data.
7. Disclosure
7.1. Sharing
We may share your personal information with third parties to fulfil our obligations to you, including with:
• other companies or divisions within our group;
• our contractors who help provide part of our goods or services;
• third parties as required by applicable law.
• 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 (if you utilise the services to receive payments and you meet their criteria); and
7.2. Honour this policy
We will require anyone with whom we share your personal information to honour this policy whenever possible in terms of applicable law.
7.3. Mandatory disclosure
We may disclose personal information to third parties if required for legal reasons, such as to regulators as required by law or governmental audit, law enforcement as required by a subpoena or court order, third parties as required by applicable law, and to protect the safety of the individual or the general public.
7.4. No selling
We will not sell personal data. No personal data will be disclosed to anyone except as provided in this privacy policy.
7.5. Personnel
We may need to disclose personal information to our personnel to do their jobs, but we will not do so unnecessarily and only to enable them to do their jobs. This includes our responsible management, human resources, accounting, audit, compliance, information technology, or other personnel. Any of our employees or personnel who handle your personal data will have signed non-disclosure and confidentiality agreements.
7.6. Change of ownership
If our ownership changes for any reason, we may assign our rights to the personal information we process to our new owners. We will disclose the transfer on our website. If you are concerned about your personal data migrating to a new owner, you may request that we delete it.
8. Security
We take the security of personal data 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 authorise access to personal data only for those employees who require it to fulfil their job responsibilities. We implement disaster recovery procedures where appropriate.
9. Accurate and up to date
We will try to keep the personal data we collect as accurate, complete, and up to date as necessary for the purposes defined in this policy. From time to time, we may request that you update your data on the website. You can review or update any personal data we hold on to you by accessing your account online, emailing us, or phoning us. Please note that we verify your identity before granting you access to your account or correcting your data to protect you better and safeguard your data. You retain the right to rectify incorrect personal data throughout your interaction with us. This does not apply if we process your data as an operator or processor on behalf of a responsible party or data controller. Please keep your data up-to-date by accessing your account, emailing us, or phoning us.
10. Retention
We will only retain your data 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.
During the retention period, we will continue to abide by our non-disclosure obligations and not share or sell your data. We may retain your data in physical or electronic records at our discretion. We will only retain your data for as long as is necessary.
11. Transfer to another country
We may transmit or transfer personal data outside of the country in which it was collected to a foreign country and process it in that country. Personal data may be stored on servers outside the country in which it was collected in a foreign country whose laws protecting personal data may not be as stringent as those in the country in which it was collected. You consent to us processing your data in a foreign country whose laws regarding processing of personal data may be less stringent.
12. Updating or removing
You may correct or update the personal data you have submitted to us, by clicking the relevant menu in any of the pages on our website or the application or contacting us by phone or email. You are entitled to a right to be forgotten. We will delete any personal data you don’t want us
to have. If you do this, we will remove your data from our system, but we may still retain specific personal data as required or allowed by law, including:
• where we can show legitimate grounds for processing your data that override your request or
• where we process your personal data to establish, exercise or defend legal claims.
If you are a data subject of one of our customers (who is the data controller), then you must submit your request to the relevant data controller who will then delete your personal data.
13. Restriction of processing
You may request that we restrict the use of your personal data. When we restrict your personal data we still have the right to store it but not use it. You can ask that we do this verbally or in writing. We will respond to the request within 30 days.
14. Data portability
If you should wish to transfer your data from us to another data controller that we will facilitate this transfer. We will pass on all of our personal data to the data controller. If you are a data subject of one of our customers (who is the data controller), then you must submit your request for your personal data to the relevant data controller, who will then export your personal data as a Microsoft Excel or CSV file.
15. Data breaches
We will notify our customers of any confirmed data breaches that has occurred. It is our customers’ responsibility to notify relevant supervisory authority and any affected data subjects of the data breach.
16. 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.
17. Enquiries
Please contact us if you have any questions about this privacy policy or how we handle your personal information.
We respect your privacy and take it very seriously. We are Jula Media (Pty) Ltd (Registration number 2021/858783/07), and this is our plan of action to protect your personal information. The purpose of this policy is to describe how we collect, store, use, and protect data that can
be associated with you or another specific natural or juristic person (like a company) and can be used to identify you or that person (personal data).
2. Application
This policy applies to you when you:
• sign a contract with us;
• visit our website;
• and filled out the ‘contact us’ form or
• request our services as a customer (i.e. when we run a campaign for you).
3. Personal information
Personal data includes:
• certain information that we collect automatically when you visit our website or use our application;
• 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, social media platform, 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).
3.1. Common examples
Common examples of the types of personal data 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.
3.2. Sensitive personal data
Depending on the goods or services that you require, we may also collect sensitive personal data 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 in a trade union and
• beliefs – including your political or religious beliefs.
4. Acceptance and changes
4.1. Acceptance required
You must accept all the terms of this policy when you order any of our goods, register for, or use the website, application or any of our services. If you disagree with this policy, you may not order any of our goods or order, register for, or use the website, application or any of our
services. You may not order any of our goods or order, register for, or use the website, application or services if you do not accept this policy.
4.2. Legal capacity
You may not access our website or application or order our goods or services if you are younger than 18 years old or do not have the legal capacity to conclude legally binding contracts.
4.3. Deemed acceptance
By accepting this policy, you are deemed to have read, understood, accepted, and agreed to be bound by all its terms.
4.4. Changes
We may change the terms of this policy at any time by updating this web page. We will notify you of any changes by placing a notice prominently on the website or the application or by email detailing the changes we have made and indicating the date they were last updated. If you disagree with the changes, you must stop using the website, the application and our goods and services. If you continue to use the website, the application 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.
5. Collection
5.1. Automatic
When you visit our website, we automatically collect your Internet usage information, including your IP address, browser details, and usage information. We may use this information to display our website correctly, track your activities, or for other necessary purposes.
5.2. On submission
We ask you to provide specific identifying information when you submit information through our ‘Contact Us’ form. We will use this personal data to fulfil your account and provide additional services and information as we reasonably think appropriate and for any other purposes in this policy.
This personal data 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.
5.3. Through a request
We ask you to provide us with certain service information when you request our services.
5.4. Voluntarily
We may ask you to provide us with certain optional information on a voluntary basis. This includes content or products that you decide to upload or download from our website or application or when you enter competitions, take advantage of promotions, respond to surveys, order certain additional goods or services, or otherwise use our website or application's optional features and functionality.
5.5. Consent to collection
When you provide us with your personal information, we will obtain your consent to collect it in accordance with applicable law.
5.6. Purpose for collection
We may process your information for the purposes that you indicated when you provided it to us. We generally collect and process your personal information for various purposes, including:
• services purposes – such as collecting requests for our services and supplying you with those services; and
• business purposes –proposed and actual transactions;
Processing includes gathering your personal information, disclosing it, and combining it with other personal information.
6. Use
6.1. Information from browser
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, paths taken, and time spent on sites and pages within the website (usage information). Please note that other websites visited before entering our website might place personal data within your URL during a visit, and we have no control over such websites. Accordingly, a subsequent website that collects URL information may log some personal data.
6.2. Processing
We may process your personal information to fulfil our obligations to you.
6.3. Cookies
We may place small text files called ‘cookies’ on your device when you visit our website or use our application. These files do not contain personal data, but they do contain a personal identifier allowing us to associate your data with a particular device. These files serve several functional purposes for you, including:
• 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.
Your internet browser generally accepts cookies automatically, but you can often change this setting or delete them manually. However, if you do so, we won’t be able to provide you with access to certain aspects of our website where cookies are necessary. We have no access to or control over any cookies that our business partners use on our website, and they have their own privacy policies that govern them. Many websites use cookies; you can learn more about them at www.allaboutcookies.org.
6.4. Third-party cookies
Some of our business partners use their 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, not by us.
6.5. Web beacons
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 data. We merely use them to compile anonymous information about our website.
6.6. Messages
We may use your identifying information to send you administrative and update messages about the website. We may also sometimes send you promotional messages, but you may opt out of them.
6.7. Targeted content
While logged into the website or application, we may display targeted adverts and other relevant information based on your data. In a completely automated process, computers match personal data to adverts or related information. We never share personal data with any advertiser unless you provide us with your consent. Advertisers receive a record of each advert's total number of impressions and clicks. They do not receive any personal data. 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 data to advertisers using the referring URL. However, once you are on the advertiser’s website, the advertiser can collect your data.
7. Disclosure
7.1. Sharing
We may share your personal information with third parties to fulfil our obligations to you, including with:
• other companies or divisions within our group;
• our contractors who help provide part of our goods or services;
• third parties as required by applicable law.
• 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 (if you utilise the services to receive payments and you meet their criteria); and
7.2. Honour this policy
We will require anyone with whom we share your personal information to honour this policy whenever possible in terms of applicable law.
7.3. Mandatory disclosure
We may disclose personal information to third parties if required for legal reasons, such as to regulators as required by law or governmental audit, law enforcement as required by a subpoena or court order, third parties as required by applicable law, and to protect the safety of the individual or the general public.
7.4. No selling
We will not sell personal data. No personal data will be disclosed to anyone except as provided in this privacy policy.
7.5. Personnel
We may need to disclose personal information to our personnel to do their jobs, but we will not do so unnecessarily and only to enable them to do their jobs. This includes our responsible management, human resources, accounting, audit, compliance, information technology, or other personnel. Any of our employees or personnel who handle your personal data will have signed non-disclosure and confidentiality agreements.
7.6. Change of ownership
If our ownership changes for any reason, we may assign our rights to the personal information we process to our new owners. We will disclose the transfer on our website. If you are concerned about your personal data migrating to a new owner, you may request that we delete it.
8. Security
We take the security of personal data 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 authorise access to personal data only for those employees who require it to fulfil their job responsibilities. We implement disaster recovery procedures where appropriate.
9. Accurate and up to date
We will try to keep the personal data we collect as accurate, complete, and up to date as necessary for the purposes defined in this policy. From time to time, we may request that you update your data on the website. You can review or update any personal data we hold on to you by accessing your account online, emailing us, or phoning us. Please note that we verify your identity before granting you access to your account or correcting your data to protect you better and safeguard your data. You retain the right to rectify incorrect personal data throughout your interaction with us. This does not apply if we process your data as an operator or processor on behalf of a responsible party or data controller. Please keep your data up-to-date by accessing your account, emailing us, or phoning us.
10. Retention
We will only retain your data 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.
During the retention period, we will continue to abide by our non-disclosure obligations and not share or sell your data. We may retain your data in physical or electronic records at our discretion. We will only retain your data for as long as is necessary.
11. Transfer to another country
We may transmit or transfer personal data outside of the country in which it was collected to a foreign country and process it in that country. Personal data may be stored on servers outside the country in which it was collected in a foreign country whose laws protecting personal data may not be as stringent as those in the country in which it was collected. You consent to us processing your data in a foreign country whose laws regarding processing of personal data may be less stringent.
12. Updating or removing
You may correct or update the personal data you have submitted to us, by clicking the relevant menu in any of the pages on our website or the application or contacting us by phone or email. You are entitled to a right to be forgotten. We will delete any personal data you don’t want us
to have. If you do this, we will remove your data from our system, but we may still retain specific personal data as required or allowed by law, including:
• where we can show legitimate grounds for processing your data that override your request or
• where we process your personal data to establish, exercise or defend legal claims.
If you are a data subject of one of our customers (who is the data controller), then you must submit your request to the relevant data controller who will then delete your personal data.
13. Restriction of processing
You may request that we restrict the use of your personal data. When we restrict your personal data we still have the right to store it but not use it. You can ask that we do this verbally or in writing. We will respond to the request within 30 days.
14. Data portability
If you should wish to transfer your data from us to another data controller that we will facilitate this transfer. We will pass on all of our personal data to the data controller. If you are a data subject of one of our customers (who is the data controller), then you must submit your request for your personal data to the relevant data controller, who will then export your personal data as a Microsoft Excel or CSV file.
15. Data breaches
We will notify our customers of any confirmed data breaches that has occurred. It is our customers’ responsibility to notify relevant supervisory authority and any affected data subjects of the data breach.
16. 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.
17. Enquiries
Please contact us if you have any questions about this privacy policy or how we handle your personal information.
