FlexConnect (Pty) Ltd Privacy Notification to Data Subject (Clients) when Collecting Personal Information

Security of Information

Your privacy is important to us. To better protect your privacy, we provide this notice explaining our information practices and the choices you can make about the way your information is collected and used at this Organisation.

Confidentiality affects everyone: We collect, store and uses large amounts of personal information every day, which may be paper-based or held on a computer.

We take precautions to keep the personal information disclosed to us secure, and we will not intentionally disclose such information to third parties for commercial purposes. To prevent unauthorised access, maintain personal information accuracy, and to ensure the appropriate use of information, we have put in place electronic safeguards, as well as internal organisational procedures to safeguard and secure the information that you provide.

Collection, Use and Disclosure of Personal Information

What personal information do we collect?

We collect and hold information such as (but not limited to) names, addresses, contact information, occupations, dates of birth, information pertaining to the issue with which you are communicating with us. and any other information which assists us in conducting our business and complying with our legal obligations. We collect personal information when you contact us directly, when you access information about our services, ask about our activities, telephone conversations, emails, responding to surveys or marketing communications, registering, make a donation to us, engage with our social media channels and transacting on our website and from third parties. We may collect and hold information from former, current and prospective clients, our suppliers and their employees, as well as contractors and others.

There are some reasons we might be required by law to process your personal information, for instance, report any suspected abuse. Any analysis of personal information required by statute does not require your consent. In limited circumstances, we will share this information with third parties, who will process this personal information on our behalf, under our direction. This will only be done with your consent or legitimate interest and where we are satisfied that the other party is compliant with the POPI Act and all other data regulations.

It is essential that we have accurate and up to date information about you so that we can give you the best possible care. Please check that your personal details are correct whenever you visit us and inform us of any changes. This minimises the risk of you not receiving important correspondence.

Purpose for which the information is being collected

We use this information to provide you with service support, to respond to inquiries, and to monitor and improve the quality and types of services and client, product, and service support we provide to our clients. We process this information because of our legitimate interest in providing quality services and client, product and service support, and ensuring client satisfaction.

Further to the above, we may Process your Personal Information, for among other things, the following:

● to conduct market research;

● to compile statistical and/or data analyses;

● to give effect to any communication received from you, which may include instructions, requests, queries, complaints, and questions;

● to update our records and/or your contact details;

● for the administrative, marketing (including direct marketing), planning, product or service development, quality control, survey and research purposes of us, its related bodies corporate, contractors, real estate agents and employees or service provider; and

● generally to render our Services.

For the avoidance of doubt, the Personal Information shall be exclusively collected for the specific, explicitly defined and lawful purpose of conducting our business.

The Organisation may also disclose your personal information for law enforcement and other legitimate reasons although we shall do our best to assure its continued confidentiality to the extent possible.

Is the supply of the information voluntary or mandatory?

Supplying of certain types of information is mandatory.

● If you, ○ ○

○ refuse to provide your personal information which we request; do not consent to us handling your personal information in accordance with this Privacy Notice; or revoke any consent regarding the handling of your personal information by us which you have previously given, then such refusal or revocation of previously given consent might prevent us from performing our services, and this might in turn, depending on your circumstances, adversely affect you.

Transfer the information to a third country We may transfer your information to a Cloud database outside your country of domicile, potentially including countries which may not require an adequate level of protection for your Personal Information compared with that provided in your country.

Limits on collection

We collect only the information that is required to provide service, administrate the service that is provided, and communicate with you. We do not collect any other information, or allow information to be used for other purposes, without your express (i.e., verbal or written) consent except where authorised to do so by law.

When and to whom do we disclose personal information?

Disclosure to our agents and sub-contractors

Your personal information may be shared with our agents and sub-contractors and selected third parties who process the information on our behalf.

Disclosure to third parties

We may also disclose your personal information to third parties under certain circumstances. If you do not wish us to disclose this information to third parties, please contact us at the contact details set out above. We may, however, not be able to provide products or services to you if such disclosure is necessary.

Disclosures authorised by law:

There are limited situations where we are legally required to disclose your personal information without your consent. These situations include (but are not limited to) reporting abuse, infectious diseases and fitness to drive, or by court order.

Disclosures to all other parties:

Your express consent is required before we will disclose your information to third parties for any purpose other than to provide you with care or unless we are authorized to do so by law. Examples of disclosures to other parties requiring your express consent include (but are not limited to) third party medical examinations, enrolment in clinical (research) trials.

Can you withdraw consent?

You can withdraw your consent to have your information shared with other third parties at any time, except where the disclosure is authorized by law.

Client Rights

How do you access the personal information held by this office?

You have the right to access your record in a timely manner. If you request a copy of your record, one will be provided to you at a reasonable cost. If you wish to view the original record, one of our staff must be present to maintain the integrity of the record, and a reasonable fee may be charged for this access. Client requests for access to their record can be made in writing to our Information Officer in terms of our Promotion of Access to Information Act, Section 51 Manual (see office address at top of Policy).

Limitations on access

In extremely limited circumstances you may be denied access to your records, but only if providing access would create a significant risk to you or to another person.

What if you feel your record is not accurate?

We make every effort to ensure that all of your information is recorded accurately. If an inaccuracy is identified, you can request that a note be made to reflect this on your file.

Deletion of records

You do have a right, in the prescribed manner, to request us to –

1. correct or delete personal information in our possession or under our control that is

inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained

unlawfully; or

2. destroy or delete a record of personal information about you that we are no longer

authorised to retain in terms of section 14 of the POPI Act.

Office Safeguards

How secure is your information?

Safeguards are in place to protect the security of your information. These safeguards include a combination of physical, technological and administrative security measures that are appropriate to the sensitivity of the information. These safeguards are aimed at protecting personal information against loss or theft, as well as unauthorised access, disclosure, copying, use or modification.

What is our communications policy?

We protect personal information regardless of the format. Specific procedures are in place for communicating by phone, email, fax, and post/courier.

How long do we keep information?

We retain records as required by law, professional guidelines as defined in our Document Retention and Destruction Policy.

How do we dispose of information when it is no longer required? When information is no longer required, it is destroyed in a secure manner, according to set procedures that govern the storage and destruction of personal information.

Complaints process

If you believe that this office has not replied to your access request or has not handled your personal information in a reasonable manner, please address your concerns first with our Information Officer. You may also choose to make a complaint to the Information Regulator.

Information Officer Name: Ettiene Grobler
Tel No: 010 001 4278

Email: info@FlexConnect.co.za Information Regulator

Address: 33 Hoofd Street; Forum III, 3rd Floor Braampark

Tel No: +27 (0) 10 023 5200
Email: complaints.IR@justice.gov.za

Web Address: https://www.justice.gov.za/inforeg/contact.html