Posted: 30 September 2020
Effective: 30 September 2020

Introduction

This privacy policy has been compiled to better serve those who are concerned with how their "personal information" is being used online. Where we refer to "us", "we", "our" and "VoxCroft", we mean the VoxCroft group of companies. Where we refer to "personal information" or "information" in this policy, we mean personal information as defined in the South African Protection of Personal Information Act, No. 4 of 2013 ("POPI"), and "personal data" as per the General Data Protection Regulation 2016/679 ("GDPR"). This privacy policy applies to individuals as well as juristic entities. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your personal information in accordance with our website.

When does this Policy apply?

You agree that this policy will apply if you access or use our website at https://www.voxcroft.ai/. When visiting, signing up for any communications and making any enquiries on our site, as appropriate, you may be asked to enter your name, email address or other details to help you with your experience. This policy will apply to you, and will create a legally binding contract between us, whenever you use or access our website.

Our commitment

This policy is important to us. We are committed to taking steps to protect your privacy when you use our website and implementing business practices that comply with all relevant legislation, including POPI, GDPR and the South African Electronic Communications and Transactions Act 25 of 2002. In this policy, we explain how we will use and protect your personal information.

What information is collected

We generally store and use the following information: personal details (such as your name, email address or telephone number), IP address or cookie information, geo-location information, any other legally required information and information which we reasonably need to perform our obligations when you use our services.

How we collect your information

We can collect your information directly from you when you use our website or any of our services or if we request it from you. In very limited instances, we may collect personal information from third parties where such information is publicly available or for legitimate business purposes.

How we use your information

We use your information to provide our website and services to you and generally for purposes of our relationship. We may process the information we collect from you when you visit, sign up for any communications, make any enquiries on our site, respond to a survey or marketing communication, view the website, or use certain other site features. We may use your information for other purposes but only if the law allows for it, or if you consent to it, or if it is in the public interest.

Purposes for processing information

• We will only process adequate and relevant information to:
• provide you with our services;
• respond to your requests for services or information;
• identify, develop or improve products that may interest you;
• carry out market research, business and statistical analysis;
• ask for ratings and reviews of services or products, and carry out audits;
• follow up with you after correspondence (live chat, email or phone enquiries);
• perform other administrative and operational tasks like testing our processes and systems;
• sending you information (in the form of our newsletter) and inviting you to events; and
• comply with our regulatory or other obligations.

Cross-border flow of information

We may transfer your information to foreign countries mainly for retention purposes or if our service providers are cross border (such as website hosting servers) or use systems cross border. If you continue to use our website, you expressly agree that we may transfer the information cross border for these purposes. We will only share information cross border to recipients who have similar laws like POPI or GDPR that apply to them, or who entered into an agreement with us to include the relevant POPI principles. To the extent required by applicable law, when we transfer your information to recipients in other countries, we will take all reasonable measures to protect that information.

Children's information and special personal information

We do not intentionally collect or use information of persons under the age of 18 years unless with consent of a competent person (someone like the parent or legal guardian), or if the law otherwise allows or requires us to process such information.

Sharing of personal information

In general, we may share your information within the VoxCroft group of companies, with our affiliates, third party service providers, regulatory and governmental authorities or tax authorities (if we are requested by them to do so), and any other third party if the law requires from us to share it. We will keep your personal information confidential and only share it with others in terms of this policy, or if you consent to it, or if the law requires from us to share it. We have trusted relationships with carefully selected third parties who perform services for us. All these service providers have a contract with us in terms of which they have a legal obligation to secure your personal information and to use it only in a way that we permit.

How do we protect your information

We maintain administrative, technical and physical safeguards consistent with legal requirements where the personal information was obtained, designed to protect against unauthorized or unlawful destruction, loss, alteration, use or disclosure of, or access to, personal information that you have provided to us.

Right to object

You may on reasonable grounds object to us using your information. If you object, we will stop using your information, except if the law allows its use.

Lodging a complaint

If you believe we are using your information unlawfully, first attempt to resolve any concerns with Voxcroft, and if you are not satisfied with such process you may lodge a complaint to the South African Information Regulator with the following contact details:

The Information Regulator (South Africa) SALU Building 316 Thabo Sehume Street Pretoria Tel: +27(0)12 406 4818 Email: inforeg@justice.gov.za Website: https://www.justice.gov.za/inforeg/index.html

If you are located in the United Kingdom, European Union or the United States, the relevant regulatory authority's details are as follows:

GDPR EU Commission Online complaint procedure: https://ec.europa.eu/info/about-european-commission/contact/problems-and-complaints/how-make-complaint-eu-level/submit-complaint_en European Commission, Secretary-General B-1049 Brussels, BELGIUM Fax: 3222964335

The independent Data Protection Authority ("DPA") per member state Website listing all DPA's per member state: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm Data Protection Act, 1998 (UK) The Information Commissioner's Office Website: https://ico.org.uk/global/contact-us/ Tel: 0303 123 1113

US Consumer Protection Federal Trade Commission (FTC) Online complaint procedure: https://www.ftccomplaintassistant.gov/#crnt Bureau for Consumer Protection Bureau of Consumer Protection Federeal Trade Commission 600 Pennsylvania Avenue, NW Washington, DC 20580

Our website is scanned on a regular basis for security holes and known vulnerabilities

Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible. We are committed to implementing appropriate technical and other security measures to protect the integrity and confidentiality of your information. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential. In addition, all sensitive information you supply is encrypted via Transport Layer Security (TLS).

Security breach

We will report any security breach to the Information Regulator and to the individuals or companies involved. If you want to report any concerns about our privacy practices or if you suspect any breach regarding your information, kindly notify us by sending an email to info@voxcroft.com.

Integrity and access to your information

We want to ensure that your information is accurate and up to date. You may ask us to correct or remove any information that you think is inaccurate, by sending us an email to info@voxcroft.com. You have the right to request us to provide you with information that we hold about you. You must contact us directly to do so or send an email to info@voxcroft.com.

Retention of information

We retain information in accordance with the required retention periods in law or for legitimate business purposes. We will only retain your information for the purposes explicitly set out in this policy. We may keep information indefinitely in a de-identified format for statistical purposes. This policy also applies when we retain your information.

Use of Cookies

We may receive and record information on our server logs from your browser that may include your location, IP address, and the page you requested. This information does not identify any individual.

Cookies enable us to improve our service to you, store information about your preferences and recognize when you return to our website.

Disabling cookies

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since each browser is a little different, look at your browser's Help Menu to learn the correct way to modify your cookies.

You can set your web browser to refuse cookies, but if you do this some of the features may not function properly, you may not be able to enjoy the full use of our website and you may not be able to take advantage of certain of our services.

Can you opt-out of communications?

You can opt-out of receiving communications from us at any time. Simply click on the "unsubscribe" link at the bottom of any email received from us.

Disclosure

We do not sell, trade, or otherwise transfer to outside parties your personal information.

Links on our website

Our website may include links to other applications or third party websites which do not fall under our control. We cannot accept any responsibility for your privacy or the content of these applications, but we display these links in order to make it easier for our visitors to find information about specific subjects.

How does our site handle Do Not Track signals?

We honour Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place.

Are there other applicable terms too?

Yes, please visit our website's terms of use. Additional terms may also apply for specific products or services or subscriptions available through our website – these terms are included in our website terms of use. If there is a conflict between these terms and the specific terms, the specific terms will apply.

Changes to this policy

If you do not agree with any terms of this policy, you must stop using our website.

Unless notice is required in terms of the law, we may change the terms of this policy from time to time in line with any changes that the law or our internal business operations require, without prior notice. The current version of this policy that applies at the time you visit and/or use our website will regulate our relationship. It is your responsibility to consider the policy each time you use our website.

Contacting us

If there are any questions regarding this privacy policy, you may contact us using the information below.

E-mail: info@voxcroft.com