PRIVACY POLICY
Last
updated February 03, 2022
Thank you for choosing to
be part of our community at The CopperClock PTY LTD, doing business
as The Copper Clock (“The Copper Clock,” “we,”
“us,” or “our“). We are committed to
protecting your personal information and your right to privacy. If you have any
questions or concerns about this privacy policy or our practices with regard to
your personal information, please contact us at [email protected].
This privacy policy
describes how we might use your information if you:
● Visit our website at https://www.copperclockwifi.com
● Download and use our mobile
application — Copper Clock Wifi
● Engage with us in other
related ways ― including any sales, marketing, or events
In this privacy policy, if
we refer to:
● “Website,”
we are referring to any website of ours that references or links to this policy
● “App,” we
are referring to any application of ours that references or links to this
policy, including any listed above
● “Services,”
we are referring to our Website, App, and other related services, including any
sales, marketing, or events
The purpose of this privacy
policy is to explain to you in the clearest way possible what information we
collect, how we use it, and what rights you have in relation to it. If there
are any terms in this privacy policy that you do not agree with, please
discontinue use of our Services immediately.
Please read this privacy
policy carefully, as it will help you understand what we do with the
information that we collect.
This Policy explains how we
obtain, use and disclose your personal information, in accordance with the
requirements of the Protection of Personal Information Act (“POPIA”).
At The Copper Clock (and
including this website, POPIAct-Compliance) we are committed to protecting
your privacy and ensuring that your personal information is collected and used
properly, lawfully and transparently.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE
COLLECT?
2. HOW DO WE USE YOUR
INFORMATION?
3. WILL YOUR INFORMATION BE
SHARED WITH ANYONE?
4. WHO WILL YOUR INFORMATION BE
SHARED WITH?
5. DO WE USE COOKIES AND OTHER
TRACKING TECHNOLOGIES?
6. HOW DO WE HANDLE YOUR SOCIAL
LOGINS?
7. IS YOUR INFORMATION
TRANSFERRED INTERNATIONALLY?
8. WHAT IS OUR STANCE ON
THIRD-PARTY WEBSITES?
9. HOW LONG DO WE KEEP YOUR
INFORMATION?
10. HOW DO WE KEEP YOUR
INFORMATION SAFE?
11. DO WE COLLECT INFORMATION
FROM MINORS?
12. WHAT ARE YOUR PRIVACY
RIGHTS?
13. CONTROLS FOR DO-NOT-TRACK
FEATURES
14. DO CALIFORNIA RESIDENTS HAVE
SPECIFIC PRIVACY RIGHTS?
15. DO WE MAKE UPDATES TO THIS
NOTICE?
16. HOW CAN YOU CONTACT US ABOUT
THIS NOTICE?
17. HOW CAN YOU REVIEW, UPDATE,
OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT
INFORMATION DO WE COLLECT?
Personal information you
disclose to us
In Short: We collect personal
information that you provide to us.
We collect personal
information that you voluntarily provide to us when you register on the
Services, express an interest in obtaining information about us or our products
and services when you participate in activities on the Services or otherwise
when you contact us.
The personal information
that we collect depends on the context of your interactions with us and the
Services, the choices you make and the products and features you use. The
personal information we collect may include the following:
Personal Information
Provided by You. We collect names; phone numbers; email addresses; contact or
authentication data; date of birth; and other similar information.
Social Media Login
Data. We may provide you with the option to register with us using your
existing social media account details, like your Facebook, Twitter or other
social media account. If you choose to register in this way, we will collect
the information described in the section called “HOW DO WE HANDLE YOUR SOCIAL
LOGINS?” below.
All personal information
that you provide to us must be true, complete and accurate, and you must notify
us of any changes to such personal information.
Information automatically
collected
In Short: Some information — such as
your Internet Protocol (IP) address and/or browser and device characteristics —
is collected automatically when you visit our Services.
We automatically collect
certain information when you visit, use or navigate the Services. This
information does not reveal your specific identity (like your name or contact
information) but may include device and usage information, such as your IP
address, browser and device characteristics, operating system, language
preferences, referring URLs, device name, country, location, information about
how and when you use our Services and other technical information. This
information is primarily needed to maintain the security and operation of our
Services, and for our internal analytics and reporting purposes.
Like many businesses, we
also collect information through cookies and similar technologies.
The information we collect
includes
● Log and Usage Data. Log and usage data
are service-related, diagnostic, usage and performance information our servers
automatically collect when you access or use our Services and which we record
in log files. Depending on how you interact with us, this log data may include
your IP address, device information, browser type and settings and information
about your activity in the Services (such as the date/time stamps associated
with your usage, pages and files viewed, searches and other actions you take
such as which features you use), device event information (such as system
activity, error reports (sometimes called ‘crash dumps’) and hardware
settings).
● Device Data. We collect device
data such as information about your computer, phone, tablet or other devices
you use to access the Services. Depending on the device used, this device data
may include information such as your IP address (or proxy server), device and
application identification numbers, location, browser type, hardware model
Internet service provider and/or mobile carrier, operating system and system
configuration information.
● Location Data. We collect location
data such as information about your device’s location, which can be either
precise or imprecise. How much information we collect depends on the type and
settings of the device you use to access the Services. For example, we may use
GPS and other technologies to collect geolocation data that tells us your
current location (based on your IP address). You can opt-out of allowing us to
collect this information either by refusing access to the information or by
disabling your Location setting on your device. Note, however, if you choose to
opt-out, you may not be able to use certain aspects of the Services.
Information collected
through our App
In Short: We collect information
regarding your geolocation, mobile device when you use our App.
If you use our App, we also
collect the following information:
● Geolocation Information. We may request access
or permission to track location-based information from your mobile device,
either continuously or while you are using our App, to provide certain
location-based services. If you wish to change our access or permissions, you
may do so in your device’s settings.
● Mobile Device Access. We may request access
or permission to certain features from your mobile device, including your
mobile device’s camera, and other features. If you wish to change our access or
permissions, you may do so in your device’s settings.
● Mobile Device Data. We automatically collect
device information (such as your mobile device ID, model and manufacturer),
operating system, version information and system configuration information,
device and application identification numbers, browser type and version,
hardware model, Internet service provider and/or mobile carrier, and Internet
Protocol (IP) address (or proxy server). If you are using our App, we may also
collect information about the phone network associated with your mobile device,
your mobile device’s operating system or platform, the type of mobile device
you use, your mobile device’s unique device ID and information about the
features of our App you accessed.
This information is
primarily needed to maintain the security and operation of our App, for
troubleshooting and for our internal analytics and reporting purposes.
2. HOW
DO WE USE YOUR INFORMATION?
In Short: We process your information
for purposes based on legitimate business interests, the fulfilment of our
contract with you, compliance with our legal obligations, and/or your consent.
We use personal information
collected via our Services for a variety of business purposes described below.
We process your personal information for these purposes in reliance on our
legitimate business interests, in order to enter into or perform a contract
with you, with your consent, and/or for compliance with our legal obligations.
We indicate the specific processing grounds we rely on next to each purpose
listed below.
We use the information we
collect or receive:
● To facilitate account
creation and logon process. If you choose to link your account with us to a third-party
account (such as your Google or Facebook account), we use the information you
allowed us to collect from those third parties to facilitate account creation
and logon process for the performance of the contract. See the section below
headed “HOW DO WE HANDLE YOUR SOCIAL
LOGINS?” for further information.
● To post testimonials. We post testimonials
on our Services that may contain personal information. Prior to posting a
testimonial, we will obtain your consent to use your name and the content of
the testimonial. If you wish to update or delete your testimonial, please
contact us at [email protected] and
be sure to include your name, testimonial location, and contact information.
● Request feedback. We may use your information
to request feedback and to contact you about your use of our Services.
● To manage user
accounts. We may use your information for the purposes of managing our account and
keeping it in working order.
3. WILL
YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share
information with your consent, to comply with laws, to provide you with
services, to protect your rights, or to fulfil business obligations.
We may process or share
your data that we hold based on the following legal basis:
● Consent: We may process your
data if you have given us specific consent to use your personal information for
a specific purpose.
● Legitimate Interests: We may process your
data when it is reasonably necessary to achieve our legitimate business
interests.
● Performance of a Contract: Where we have entered
into a contract with you, we may process your personal information to fulfil
the terms of our contract.
● Legal Obligations: We may disclose your
information where we are legally required to do so in order to comply with
applicable law, governmental requests, a judicial proceeding, court order, or
legal processes, such as in response to a court order or a subpoena (including
in response to public authorities to meet national security or law enforcement
requirements).
● Vital Interests: We may disclose your
information where we believe it is necessary to investigate, prevent, or take
action regarding potential violations of our policies, suspected fraud,
situations involving potential threats to the safety of any person and illegal
activities, or as evidence in litigation in which we are involved.
More specifically, we may
need to process your data or share your personal information in the following
situations:
● Business Transfers. We may share or
transfer your information in connection with, or during negotiations of, any
merger, sale of company assets, financing, or acquisition of all or a portion
of our business to another company.
● Vendors, Consultants and
Other Third-Party Service Providers. We may share your
data with third-party vendors, service providers, contractors or agents who
perform services for us or on our behalf and require access to such information
to do that work. Examples include data analysis, email delivery, hosting
services, customer service and marketing efforts. We may allow selected third
parties to use tracking technology on the Services, which will enable them to
collect data on our behalf about how you interact with our Services over time.
This information may be used to, among other things, analyze and
track data, determine the popularity of certain content, pages or features, and
better understand online activity. Unless described in this notice, we do not
share, sell, rent or trade any of your information with third parties for their
promotional purposes. We have contracts in place with our data processors,
which are designed to help safeguard your personal information. This means that
they cannot do anything with your personal information unless we have
instructed them to do it. They will also not share your personal information
with any organization apart from us. They also commit to protecting the data
they hold on our behalf and to retaining it for the period we instruct.
● Third-Party Advertisers. We may use
third-party advertising companies to serve ads when you visit or use the
Services. These companies may use information about your visits to our Website(s)
and other websites that are contained in web cookies and other tracking
technologies in order to provide advertisements about goods and services of
interest to you.
● Affiliates. We may share your
information with our affiliates, in which case we will require those affiliates
to honour this privacy policy. Affiliates include our parent company and any
subsidiaries, joint venture partners or other companies that we control or that
are under common control with us.
● Business Partners. We may share your
information with our business partners to offer you certain products, services
or promotions.
4. WHO
WILL YOUR INFORMATION BE SHARED WITH?
In Short: We only share
information with the following categories of third parties.
We only share and disclose
your information with the following categories of third parties. If we have
processed your data based on your consent and you wish to revoke your consent,
please contact us using the contact details provided in the section below titled
“HOW CAN YOU CONTACT US ABOUT
THIS NOTICE?“.
● Cloud Computing Services
● Data Analytics Services
● Social Networks
● Website Hosting Service
Providers
● Testing Tools
5. DO WE
USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies
and other tracking technologies to collect and store your information.
We may use cookies and
similar tracking technologies (like web beacons and pixels) to access or store
information. Specific information about how we use such technologies and how
you can refuse certain cookies is set out in our Cookie Policy.
6. HOW
DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to register
or log in to our services using a social media account, we may have access to
certain information about you.
Our Services offers you the
ability to register and log in using your third-party social media account
details (like your Facebook or Google logins). Where you choose to do this, we
will receive certain profile information about you from your social media
provider. The profile information we receive may vary depending on the social
media provider concerned, but will often include your name, email address,
friends list, profile picture as well as other information you choose to make
public on such social media platform.
We will use the information
we receive only for the purposes that are described in this privacy policy or
that are otherwise made clear to you on the relevant Services. Please note that
we do not control, and are not responsible for, other uses of your personal
information by your third-party social media provider. We recommend that you
review their privacy policy to understand how they collect, use and share your
personal information, and how you can set your privacy preferences on their
sites and apps.
7. IS
YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and
process your information in countries other than your own.
Our servers are located in
the United Kingdom. If you are accessing our Services from outside the United
Kingdom, please be aware that your information may be transferred to, stored,
and processed by us in our facilities and by those third parties with whom we
may share your personal information (see “WILL YOUR INFORMATION BE SHARED
WITH ANYONE?” above), in South Africa, and other countries.
Some of the persons to whom
we disclose your personal information may be situated outside of the Republic
of South Africa (RSA) in jurisdictions that may not have similar data
protection laws to the RSA. In this regard, we may send your personal information
to service providers outside of the RSA for storage or processing on The Copper
Clock’s behalf. However, we will not send your information to a country that
does not have information protection legislation similar to that of the RSA,
unless we have ensured that the recipient agrees to effectively adhere to the
principles for processing of information in accordance with POPIA.
8. WHAT
IS OUR STANCE ON THIRD-PARTY WEBSITES?
In Short: We are not
responsible for the safety of any information that you share with third-party
providers who advertise, but are not affiliated with, our Website.
The Services may contain
advertisements from third parties that are not affiliated with us and which may
link to other websites, online services or mobile applications. We cannot
guarantee the safety and privacy of data you provide to any third parties. Any
data collected by third parties is not covered by this privacy policy. We are
not responsible for the content or privacy and security practices and policies of
any third parties, including other websites, services or applications that may
be linked to or from the Services. You should review the policies of such third
parties and contact them directly to respond to your questions.
9. HOW
LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your
information for as long as necessary to fulfil the purposes outlined in this
privacy policy unless otherwise required by law.
We will only keep your
personal information for as long as it is necessary for the purposes set out in
this privacy policy unless a longer retention period is required or permitted
by law (such as tax, accounting or other legal requirements). No purpose in
this notice will require us to keep your personal information for longer than
the period of time in which users have an account with us.
When we have no ongoing
legitimate business need to process your personal information, we will either
delete or anonymize such information or, if this is not possible (for example,
because your personal information has been stored in backup archives), then we
will securely store your personal information and isolate it from any further
processing until deletion is possible.
10. HOW
DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect
your personal information through a system of organizational and technical
security measures.
We have implemented
appropriate technical and organizational security measures designed to protect
the security of any personal information we process. However, despite our
safeguards and efforts to secure your information, no electronic transmission
over the Internet or information storage technology can be guaranteed to be 100%
secure, so we cannot promise or guarantee that hackers, cybercriminals, or
other unauthorized third parties will not be able to defeat our security, and
improperly collect, access, steal, or modify your information. Although we will
do our best to protect your personal information, the transmission of personal
information to and from our Services is at your own risk. You should only
access the Services within a secure environment.
11. DO
WE COLLECT INFORMATION FROM MINORS?
In Short: We do not
knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit
data from or market to children under 18 years of age. By using the Services,
you represent that you are at least 18 or that you are the parent or guardian
of such a minor and consent to such minor dependent’s use of the Services. If
we learn that personal information from users less than 18 years of age has
been collected, we will deactivate the account and take reasonable measures to
promptly delete such data from our records. If you become aware of any data we
may have collected from children under age 18, please contact us at [email protected].
12. WHAT
ARE YOUR PRIVACY RIGHTS?
In Short: If you are a
resident of South Africa, the European Economic Area (EEA) and the United
Kingdom (UK), you have rights that allow you greater access to and control over
your personal information. You may review, change, or terminate your account at
any time.
POPIA read with the
relevant provisions of the Promotion of Access to Information Act, No. 2 of
2000 (“PAIA”) confers certain access rights on Data Subjects. These
rights include
A right of access: a Data Subject having
provided adequate proof of identity has the right to (i) request a Responsible
Party to confirm whether any Personal Information is held about the Data
Subject; and/or (ii) request from a Responsible Party a description of the
Personal Information held by the Responsible Party including information about
Third Parties who have or have had access to the Personal Information. A Data
Subject may request:
The Copper Clock to
confirm, free of charge, whether it holds any Personal Information about
him/her/it, and to obtain from The Copper Clock the record or description of
Personal Information concerning him/her/it and any information regarding the
recipients or categories of recipients who have or had access to the Personal
Information. Such record or description is to be provided: (a) within a
reasonable time; and (b) in a reasonable manner and format and in a form that
is generally understandable.
A right to request
correction or deletion: a Data Subject may also request The Copper Clock to correct or
delete Personal Information about the Data Subject in its possession or under
its control that is inaccurate, irrelevant, excessive, out of date, incomplete,
misleading or obtained unlawfully; or destroy or delete a record of Personal
Information about the Data Subject that The Copper Clock is no longer authorised
to retain records in terms of POPIA’s retention and restriction of records
provisions.
On receipt of such a
request, The Copper Clock is required to, as soon as is reasonably practicable
– correct the information; delete or destroy the information; provide the Data
Subject with evidence in support of the information; or
where the Data Subject and
Responsible Party cannot reach agreement on the request and if the Data Subject
requests this, The Copper Clock will take reasonable steps to attach to the information
an indication that correction has been requested but has not been made;
A right to withdraw consent
and to object to processing: a Data Subject that has previously
consented to the Processing of his/her/its Personal Information has the right
to withdraw such consent and may do so by providing The Copper Clock with
notice to such effect at the address set out in paragraph 16. Further, a Data
Subject may object, on reasonable grounds, to the Processing of Personal
Information relating to him/her/it.
For EEA and UK Citizens
In some regions (like the
EEA and UK), you have certain rights under applicable data protection laws.
These may include the right (i) to request access and obtain a copy of your
personal information, (ii) to request rectification or erasure; (iii) to
restrict the processing of your personal information; and (iv) if applicable,
to data portability. In certain circumstances, you may also have the right to
object to the processing of your personal information. To make such a request,
please use the contact details provided
below. We will consider and act upon any request in accordance with applicable
data protection laws.
If we are relying on your
consent to process your personal information, you have the right to withdraw
your consent at any time. Please note however that this will not affect the
lawfulness of the processing before its withdrawal, nor will it affect the
processing of your personal information conducted in reliance on lawful
processing grounds other than consent.
If you are a resident in
the EEA or UK and you believe we are unlawfully processing your personal
information, you also have the right to complain to your local data protection
supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are a resident in
Switzerland, the contact details for the data protection authorities are
available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
If you have questions or
comments about your privacy rights, you may email us at [email protected].
Account Information
If you would at any time
like to review or change the information in your account or terminate your
account, you can:
● Contact us using the
contact information provided.
Upon your request to
terminate your account, we will deactivate or delete your account and
information from our active databases. However, we may retain some information
in our files to prevent fraud, troubleshoot problems, assist with any
investigations, enforce our Terms of Use and/or comply with applicable legal
requirements.
Cookies and similar
technologies: Most Web browsers are set to accept cookies by default. If you
prefer, you can usually choose to set your browser to remove cookies and to
reject cookies. If you choose to remove cookies or reject cookies, this could
affect certain features or services of our Services. To opt-out of
interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/.
Opting out of email
marketing: You can unsubscribe from our marketing email list at any time by
clicking on the unsubscribe link in the emails that we send or by contacting us
using the details provided below. You will then be removed from the marketing
email list — however, we may still communicate with you, for example, to send
you service-related emails that are necessary for the administration and use of
your account, to respond to service requests, or for other non-marketing
purposes. To otherwise opt-out, you may:
● Contact us using the
contact information provided.
13.
CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some
mobile operating systems and mobile applications include a Do-Not-Track
(“DNT”) feature or setting you can activate to signal your privacy
preference not to have data about your online browsing activities monitored and
collected. At this stage, no uniform technology standard for recognizing and
implementing DNT signals has been finalized. As such, we do not currently
respond to DNT browser signals or any other mechanism that automatically
communicates your choice not to be tracked online. If a standard for online
tracking is adopted that we must follow in the future, we will inform you about
that practise in a revised version of this privacy policy.
14. DO
CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a
resident of California, you are granted specific rights regarding access to
your personal information.
California Civil Code
Section 1798.83, also known as the “Shine The Light” law,
permits our users who are California residents to request and obtain from us,
once a year and free of charge, information about categories of personal
information (if any) we disclosed to third parties for direct marketing
purposes and the names and addresses of all third parties with which we shared
personal information in the immediately preceding calendar year. If you are a
California resident and would like to make such a request, please submit your
request in writing to us using the contact information provided below.
If you are under 18 years
of age, reside in California, and have a registered account with a Service, you
have the right to request the removal of unwanted data that you publicly post
on the Services. To request the removal of such data, please contact us using
the contact information provided below, and include the email address
associated with your account and a statement that you reside in California. We
will make sure the data is not publicly displayed on the Services, but please
be aware that the data may not be completely or comprehensively removed from
all our systems (e.g. backups, etc.).
CCPA Privacy Notice
The California Code of
Regulations defines a “resident” as:
(1) every individual who is
in the State of California for other than a temporary or transitory purpose and
(2) every individual who is
domiciled in the State of California who is outside the State of California for
a temporary or transitory purpose
All other individuals are
defined as “non-residents.”
If this definition of
“resident” applies to you, we must adhere to certain rights and
obligations regarding your personal information.
What categories of personal
information do we collect?
We have collected the
following categories of personal information in the past twelve (12) months:
Category |
Examples |
Collected |
A.
Identifiers |
Contact
details, such as real name, alias, postal address, telephone or mobile
contact number, unique personal identifier, online identifier, Internet
Protocol address, email address and account name |
YES |
B.
Personal information categories listed in the California Customer Records
statute |
Name,
contact information, education, employment, employment history and financial
information |
YES |
C.
Protected classification characteristics under California or federal law |
Gender
and date of birth |
YES |
D.
Commercial information |
Transaction
information, purchase history, financial details and payment information |
YES |
E.
Biometric information |
Fingerprints
and voiceprints |
NO |
F.
Internet or other similar network activity |
Browsing
history, search history, online behavior, interest data, and
interactions with our and other websites, applications, systems and
advertisements |
NO |
G.
Geolocation data |
Device
location |
YES |
H.
Audio, electronic, visual, thermal, olfactory, or similar information |
Images
and audio, video or call recordings created in connection with our business
activities |
NO |
I.
Professional or employment-related information |
Business
contact details in order to provide you our services at a business level, job
title as well as work history and professional qualifications if you apply
for a job with us |
NO |
J.
Education Information |
Student
records and directory information |
NO |
K.
Inferences drawn from other personal information |
Inferences
drawn from any of the collected personal information listed above to create a
profile or summary about, for example, an individual’s preferences and
characteristics |
NO |
We may also collect other
personal information outside of these categories instances where you interact
with us in-person, online, or by phone or mail in the context of:
● Receiving help through our
customer support channels;
● Participation in customer
surveys or contests; and
● Facilitation in the
delivery of our Services and to respond to your inquiries.
How do we use and share
your personal information?
More information about our
data collection and sharing practices can be found in this privacy policy.
You may contact us by email
at [email protected], or by
referring to the contact details at the bottom of this document.
If you are using an
authorized agent to exercise your right to opt out we may deny a
request if the authorized agent does not submit proof that they have been
validly authorized to act on your behalf.
Will your information be
shared with anyone else?
We may disclose your
personal information with our service providers pursuant to a written contract
between us and each service provider. Each service provider is a for-profit
entity that processes the information on our behalf.
We may use your personal information
for our own business purposes, such as for undertaking internal research for
technological development and demonstration. This is not considered to be the
“selling” of your personal data.
The CopperClock PTY
LTD has disclosed the following categories of personal information to third
parties for a business or commercial purpose in the preceding twelve (12)
months:
● Category B. Personal
information, as defined in the California Customer Records law, such as your
name, contact information, education, employment, employment history and
financial information.
The categories of third
parties to whom we disclosed personal information for a business or commercial
purpose can be found under “WHO WILL YOUR INFORMATION BE
SHARED WITH?“.
The CopperClock PTY
LTD has not sold any personal information to third parties for a business or
commercial purpose in the preceding twelve (12) months. The CopperClock PTY
LTD will not sell personal information in the future belonging to website
visitors, users and other consumers.
Your rights with respect to
your personal data
Right to request deletion
of the data – Request to delete
You can ask for the deletion
of your personal information. If you ask us to delete your personal
information, we will respect your request and delete your personal information,
subject to certain exceptions provided by law, such as (but not limited to) the
exercise by another consumer of his or her right to free speech, our compliance
requirements resulting from a legal obligation or any processing that may be
required to protect against illegal activities.
Right to be informed –
Request to know
Depending on the
circumstances, you have a right to know:
● whether we collect and use
your personal information;
● the categories of personal
information that we collect;
● the purposes for which the
collected personal information is used;
● whether we sell your
personal information to third parties;
● the categories of personal
information that we sold or disclosed for a business purpose;
● the categories of third
parties to whom the personal information was sold or disclosed for a business
purpose; and
● the business or commercial
purpose for collecting or selling personal information.
In accordance with
applicable law, we are not obligated to provide or delete consumer information
that is de-identified in response to a consumer request or to re-identify
individual data to verify a consumer request.
Right to Non-Discrimination
for the Exercise of a Consumer’s Privacy Rights
We will not discriminate
against you if you exercise your privacy rights.
Verification process
Upon receiving your
request, we will need to verify your identity to determine you are the same
person about whom we have the information in our system. These verification
efforts require us to ask you to provide information so that we can match it
with the information you have previously provided us. For instance, depending
on the type of request you submit, we may ask you to provide certain
information so that we can match the information you provide with the
information we already have on file, or we may contact you through a
communication method (e.g. phone or email) that you have previously
provided to us. We may also use other verification methods as the circumstances
dictate.
We will only use the
personal information provided in your request to verify your identity or
authority to make the request. To the extent possible, we will avoid requesting
additional information from you for the purposes of verification. If, however,
we cannot verify your identity from the information already maintained by us,
we may request that you provide additional information for the purposes of
verifying your identity, and for security or fraud prevention purposes. We will
delete such additionally provided information as soon as we finish verifying
you.
Other privacy rights
● you may object to the
processing of your personal data.
● you may request correction
of your personal data if it is incorrect or no longer relevant, or ask to
restrict the processing of the data.
● you can designate an
authorized agent to make a request under the CCPA on your behalf. We may deny a
request from an authorized agent that does not submit proof that they have been
validly authorized to act on your behalf in accordance with the CCPA.
● you may request to opt-out
from future selling of your personal information to third parties. Upon receiving
a request to opt-out, we will act upon the request as soon as feasibly
possible, but no later than 15 days from the date of the request submission.
To exercise these rights,
you can contact us by email at [email protected],
or by referring to the contact details at the bottom of this document. If you
have a complaint about how we handle your data, we would like to hear from
you.
15. DO
WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update
this notice as necessary to stay compliant with relevant laws.
We may update this privacy
policy from time to time. The updated version will be indicated by an updated
“Revised” date and the updated version will be effective as soon as
it is accessible. If we make material changes to this privacy policy, we may
notify you either by prominently posting a notice of such changes or by
directly sending you a notification. We encourage you to review this privacy
policy frequently to be informed of how we are protecting your information.
16. HOW
CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or
comments about this notice, you may email us at [email protected] or by post to:
The CopperClock PTY
LTD
6 Casa Toscana
Willow Avenue, Craigavon,
Fourways
Sandton, Gauteng 2191
South Africa
17. HOW
CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM
YOU?
Based on the applicable
laws of your country, you may have the right to request access to the personal
information we collect from you, change that information, or delete it in some
circumstances. To request to review, update, or delete your personal information,
please email us at: [email protected].