Last updated: August 19, 2021
1. As used in this privacy statement, “The Service Provider”, “us”, and “we” refer to the Service Provider’s network and/or one or more of its member firms of companies that may process your personal information. In this regard ‘The Service Provider’ will be FA Cronje & Cronje Inc or any of the other entities in the group of companies or successors in title.
2. You/Your/Yourself means the User of the Website or a client of the Service Provider.
OUR LEGAL GROUNDS FOR PROCESSING YOUR PERSONAL DATA
4. Your local law may require us to set out in this privacy statement the legal grounds on which we rely in order to process your personal information. In such cases, we rely on one or more of the following processing conditions:
· our legitimate interests in the effective delivery of information and services to you and in the effective and lawful operation of our businesses and the legitimate interests of our clients in receiving professional services from us as part of running their organisation (provided these do not interfere with your rights);
· our legitimate interests in developing and improving our businesses, services and offerings and in developing new technologies and offerings (provided these do not interfere with your rights);
· to satisfy any requirement of law, regulation or professional body of which we are a member (for example, for some of our services, we have a legal obligation to provide the service in a certain way);
· to perform our obligations under a contractual arrangement with you; or
· where no other processing condition is available, if you have agreed to us processing your personal information for the relevant purpose.
WHAT KIND OF PERSONAL DATA IS COLLECTED AND TRANSFER OF THAT DATA?
5. If we process your personal information, your personal information may be transferred to and stored outside the country where you are located. This includes countries outside the
European Economic Area (EEA), if you are based in the EEA, and countries that do not have laws that provide specific protection for personal information.
6. Transfer outside the EEA (where applicable) will be only:
· to a recipient located in a country which provides an adequate level of protection for your personal information; and/or
· under an agreement which satisfies EU requirements for the transfer of personal data to data processors or data controllers outside the EEA, such as standard contractual clauses approved by the European Commission.
Other member firms or companies
7. We may share personal data with other member firms or companies where necessary in connection with the purposes described in this privacy statement. For example, when providing professional services to a client we may share personal information with Member Firms or companies in different territories that are involved in providing advice to that client.
Third Party Providers or operators
8. We may transfer or disclose the personal data we collect to third party contractors, subcontractors, and/or their subsidiaries and affiliates. Third parties support the Service Provider’s network in providing its services and help provide, run and manage IT systems as well as assist the Service Provider to provide certain services to the client. Examples of third party contractors we use are providers of identity management, website hosting and management, data hosting and analysis, data backup, security and cloud storage services, payroll and accounting software and marketing. The servers powering and facilitating our IT infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them.
9. The third party providers may use their own third party subcontractors that have access to personal data (sub-processors). It is our policy to use only third party providers that are bound to maintain appropriate levels of security and confidentiality, to process personal information only as instructed by the Service Provider, and to flow those same obligations down to their sub-processors.
WHAT IS THE PURPOSE AND THE LEGAL BASIS OF THE PROCESSING OF THE DATA?
10. Contact Details in relation to Yourself are collected to open a record on Yourself in Our system and the data is processed on the basis of Our legitimate interest (our interest is that to have accurate data on Yourself) as well as a contractual or technical necessity. Contact Details as well as communication data are also processed in order to manage our business relationship with You. Contact Details and due diligence data (including any document You may supply permitting i) to identify You, ii) to establish Your domicile address, iii) to establish Your source of funds, of wealth, Your economical background, iv) to ascertain a fact that must be ascertained in order to know You or comply with anti-money laundering provisions in general) are also processed for the specific requirements that emanate from
the anti-money laundering laws. Thus, in the latter case, data is being collected and processed in order for Us to be compliant with a legal obligation.
11. The purpose for which We collect Your data is varied which include the following:
· In order to fulfil Your order;
· Send You an order confirmation;
· Assess Your needs and that of Your business to determine suitable products;
· Send You the requested product or information;
· Reply to customer service requests;
· Keep an open communication with You;
· Site Optimization and application troubleshooting;
· Invoice and charge you for applicable service fees, including debiting your credit card in accordance with the applicable Terms and Conditions;
· Marketing and communication;
· Conduct Due Diligence on Yourself and Your company; and
· Reply to Your queries and concerns.
12. We will not use the information provided for any other commercial purpose other than the one You requested.
13. It is also important to highlight that if certain data is not provided to Us, then We are unable to provide You with the service You require.
14. Kindly be aware that the Service Provider may intercept some mail and e-mails addressed to individuals within the company. This is so, in order for the Service Provider to protect its employees. Indeed, We might intercept mail in order to detect and prevent any crime, to identify the correct recipients or to make sure mail is dealt with whilst staff is away from the office, or after a resignation of a staff member. In the case of e-mails, We may reject, delay or remove content from e-mails which have a nature, content or attachments which may disrupt Our systems or because they may pose security issues such as viruses. We may also filter out e-mails which contain certain content on the basis that content is offensive or the e-mail is unwanted or considered spam. In certain circumstances this may unfortunately result in “innocent” e-mails being affected but we do try and reduce such occurrences.
15. Most e-mail messages sent from the Service Provider have been automatically scanned for viruses and as such should be free from any virus, malicious code, script or other executable attachment. However, the accuracy of scanning products is not guaranteed. The recipient(s) should therefore carry out any checks that they deem to be appropriate in this respect. We cannot be held responsible for loss of or damage to data or other damages, resulting from such actions out of Our control, howsoever incurred. All e-mail messages from Us are sent in good faith. We cannot be held responsible for any modification that happens by any virus, or other third party after they have been sent. All messages are intended for the recipient only. If You are not the intended recipient specifically identified as the addressee on the email then You should delete the message and all its attachments and You are prohibited from using, reading, disclosing to any person or otherwise acting on the information contained in it and/or its contents in any way and should also notify Us as soon as possible of this fact.
16. Also, it is important to understand that data that is sent through electronic means such as the Internet, could be transmitted across international borders even where the sender and the receiver are located in the same country. The Service Provider shall not accept any responsibility or liability for the security of Your data whilst in transit through the internet.
17. We may also disclose personal information under the following circumstances:
· with professional advisers, for example, law firms, as necessary to establish, exercise or defend our legal rights and obtain advice in connection with the running of our business. Personal data may be shared with these advisers as necessary in connection with the services they have been engaged to provide;
· when explicitly requested by you;
· when required to deliver publications or reference materials requested by you;
· when required to facilitate conferences or events hosted by a third party;
· to law enforcement, regulatory and other government agencies and to professional bodies, as required by and/or in accordance with applicable law or regulation. The Service Provider may also review and use your personal information to determine whether disclosure is required or permitted;
· to protect and defend Our rights and property or that of users of Our Website;
· to protect against abuse, misuse or unauthorised use of Our Website;
· for any purpose that may be necessary for the management, maintenance, upkeep of Our Website and the management, maintenance, upkeep of marketing initiatives such as the management of email marketing as well as communications via email;
18. Personal data shall be shared with adequate and authorised personnel of the Service Provider and with any of Our service providers who would facilitate the usage of the Website whereby they would assist Us with Our business activities such as the processing of Your order or payment, the registration of Your business or any customer service. Personal data would only be shared in order for Us to provide You with the requested service or else because We have a lawful reason to share the data which does not necessarily require Your consent.
OUR PROCESSING ACTIVITIES
19. Personal data related to any information that identifies You as an individual or else that relates to an identifiable individual. The Service provider collects personal data through various ways, such as the following:
· From the Website itself – when a query is sent through the contact form;
· from Yourself either through digital mediums such as email correspondence or else through non-digital mediums such as when documents are provided;
· From the order Form found on Our website;
· From other sources such as social media platforms, publicly accessible data and any other third parties;
· Analytics data collected by third parties.
20. The Service Provider requires to receive Your contact details such as Your name, surname and email address when you contact Us through the Contact Form found on Our website in order to reply back to Your message.
21. The Service Provider shall also collect personal data when You fill in Our Order Form on Our website. We may collect Your contact details such as Your name, surname, email address, mailing address and phone number; Your billing information such as Your credit card data and billing address; and information about Your business such as Your company name, registered address and the business type. Kindly be aware that We may collect the personal data on third parties when You list down on Our Order Form the names of the shareholders of a company should these be natural persons and of the beneficiaries as well. This information is collected in order to process and register Your order for certain products or services.
22. We will collect supporting documents such as copies of identity documents, proof of domicile, or client data forms you may fill in and return to us, from which we will extract identification information such as your date of birth, your ID document number, your citizenship or your current domicile address.
23. We would also collect personal data automatically through the Website itself. The Order Form found on Our website would record the information pertaining to Your browsing session as well as Your IP address and the time of Your ordering. This is better explained within our Cookies Policy which is found further hereunder.
24. When You provide Us with personal data in relation to another person rather than Yourself, We would be of the understanding that You have the necessary authority from the said person to provide Us with his/her personal data.
25. When you become a client or as part of Our website, You have the opportunity to subscribe to Our newsletter . In order to subscribe to Our newsletter, You shall provide Us with Your name and email address so as to send You non-transactional, promotional emails from time to time. If You displayed interest in The Service Providers services and have submitted Your name and email address to the Service Provider, You may also be eligible to non-transactional, promotional emails. You can unsubscribe from this service whenever You want by clicking the ‘unsubscribe’ button found in these emails.
26. We shall do Our best efforts to keep the data on Yourself as accurate and up to data as possible.
27. IP addresses are collected in order to monitor the usage and traffic on Our Website, and this would be based on a legitimate interest of Ours to do so.
28. Collection of personal data in relation to recruitment activities. Most of the personal date we collect as part of the recruitment process is provided by you such as:
· Contact details (name, email, telephone number);
· Areas of interest;
· Username and password to apply for a role;
· CV, experience, education, academic and professional qualifications;
· Information provided as part of interviews and assessments;
· Diversity and equal opportunities data;
· Pre-employment screening information if your application is successful;
· Information about your and your immediate family’s financial relationships if your application is successful; and
· Bank account details if your application is successful.
We obtain personal data from third party sources such as:
· References from your named referees;
· Information from your referrer (where applicable);
· Results of screening checks (depending on the role applied for);
· Verification of information provided during the recruitment process by contacting relevant third parties (for example, previous employers, education and qualification providers) or using publicly available sources (for example, to verify your experience, education and qualifications); and
· Information from social media sites that you are a member of about your engagement with our recruitment campaigns.
29. Visitors to our offices are monitored either by way of visitors logs, guest wifi or potentially CCTV cameras. All records are securely kept and only used for legitimate purposes.
30. We have implemented generally accepted standards of technology and operational security in order to protect personal information from loss, misuse, alteration or destruction. Only authorised persons are provided access to personal information; such individuals have agreed to maintain the confidentiality of this information.
31. Although we use appropriate security measures once we have received your personal data, the transmission of data over the internet (including by e-mail) is never completely secure. We endeavor to protect personal data, but we cannot guarantee the security of data transmitted to or by us.
LINKS TO THIRD PARTY WEBSITES
32. At times, Our Website may contain links that direct You to either local or international third party Websites. Kindly be aware that We do not endorse any information or services that are portrayed in the said Websites. To this end, We are not responsible for the
33. Our Website also uses a technology called “cookies.” A “cookie” is a temporary storage file, which may be created by Your computer and which can be stored on Your system. Cookies enable us to collect information about how our Website and services are being used and to manage them more efficiently. These cookies are created for each session when You visit our website.
34. The information so gathered through cookies may include:
· the date and time when You access our Website;
· the Website pages that You view and any download that You may make through such pages;
· whether or not such viewing or download is successful;
· the Internet address of the Website or the domain name of the computer from which You access our Website;
· the operating system of the machine running Your Web browser; and the type and version of Your Web browser.
35. You may reject all or certain cookies that are used by our Website and You may also modify Your Web browser preferences to do so. Nevertheless, if You reject all cookies, then You might be unable to use some of the services available on our Website. You may also set Your browser in a certain way in order to be notified when You receive a cookie so that You have the option to choose whether to accept the cookie or not. In this regard, You should note that if You do so, this may materially distort the quality of service and data You receive. Thus, You would be doing this at Your own risk.
36. If the product You are using has digital certificates/certificate signatures then Your name and related details may be displayed as part of any certificate issued to You. It will be seen by those to whom Your certificate or signature is presented or who rely on it. Your details may also need to be entered into a related status directory of certificates issued.
38. Apart from cookies, other technologies that are used are beacons, tags and scripts which are used by the Service Provider as well as Our partners such as marketing partners, analytics or service providers like Our website-based chat service provider. These technologies are used in analysing trends, administering the site, tracking user’s movements around the site and also to gather demographic information about Our user base as a whole.
We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
THIRD PARTY COOKIES
39. Some features on the website are also using third party cookies that are not under the Service Providers control. You need to specifically reject third party cookies through your browser cookies settings if You do not want to receive third party cookies. If you reject third party cookies, Your ability to use the related features may also be limited.
ANALYTICS / LOG FILES
40. The Service Provider gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
41. We may combine this automatically collected log information with other information We collect about you. We do this to improve services We offer you, to improve marketing, analytics, or site functionality.
BEHAVIORAL TARGETING / RE-TARGETING
42. We partner with a third party to either display advertising on Our website or to manage Our advertising on other sites. Our third-party partner may use technologies such as cookies to gather information about Your activities on this site and other sites in order to provide You advertising based upon your browsing activities and interests.
43. We may display personal testimonials of satisfied customers on our site in addition to other endorsements. These testimonials are pulled from a third-party service provider, which may ask for Your personal information, including Your name and email address, though we do not post the personally identifiable information to our site.
YOUR LEGAL RIGHTS IN RELATION TO PERSONAL DATA
You may have certain rights under your local law in relation to the personal information we hold about you. In particular, you may have a legal right to:
44. Obtain confirmation as to whether we process personal data about you, receive a copy of your personal data and obtain certain other information about how and why we process your personal data.
45. The right to request for your personal data to be amended or rectified where it is inaccurate (for example, if you change your address) and to have incomplete personal data completed.
46. The right to delete your personal data in the following cases:
· the personal data is no longer necessary in relation to the purposes for which they were collected and processed;
· our legal ground for processing is consent, you withdraw consent and we have no other lawful basis for the processing;
· our legal ground for processing is that the processing is necessary for legitimate interests pursued by us or a third party, you object to the processing and we do not have overriding legitimate grounds;
· you object to processing for direct marketing purposes;
· your personal data has been unlawfully processed; or
· your personal data must be erased to comply with a legal obligation to which we are subject.
47. The right to restrict personal data processing in the following cases:
· for a period enabling us to verify the accuracy of personal data where you contested the accuracy of the personal data;
· your personal data have been unlawfully processed and you request restriction of processing instead of deletion;
· your personal data are no longer necessary in relation to the purposes for which they were collected and processed but the personal data is required by you to establish, exercise or defend legal claims; or
· for a period enabling us to verify whether the legitimate grounds relied on by us override your interests where you have objected to processing based on it being necessary for the pursuit of a legitimate interest identified by us.
48. The right to object to the processing of your personal data in the following cases:
· our legal ground for processing is that the processing is necessary for a legitimate interest pursued by us or a third party; or
· our processing is for direct marketing purposes.
49. The right to data portability
· The right to receive your personal data provided by you to us and the right to send the data to another organisation (or ask us to do so if technically feasible) where our lawful basis for processing the personal data is consent or necessity for the performance of our contract with you and the processing is carried out by automated means.
- By email: firstname.lastname@example.org
Last updated: 26 March 2021
What are cookies? Cookies are small pieces of text sent by your web browser by a website you visit. A cookie file is stored in your web browser and allows the Service or a third-party to recognize you and make your next visit easier and the Service more useful to you.
Cookies can be “persistent” or “session” cookies.
- When you use and access the service, we may place a number of cookies files in your web browser.
- We use both session and persistent cookies on the Service and we use different types of cookies to run the Service:
- Essential cookies. We may use essential cookies to authenticate users and prevent fraudulent use of user accounts.
In addition to our own cookies, we may also use various third-parties cookies to report usage statistics of the Service, deliver advertisements on and through the Service, and so on.
What are your choices regarding cookies
Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.