(Last updated: January 2009. The policy applies to Emotion Technology Services (Pty) Limited and its subsidiaries, and is effective as of April 1, 2004. All employees are required to abide by this policy. )
In the course of conducting our business, Emotion collects and processes personally identifiable information of our clients, shareholders, employees, suppliers, business partners, web site visitors and other persons (Personal Data). Personal Data is information that can be used directly or indirectly to identify a living individual and includes, but is not limited to the Client's name, surname, address, e-mail address, telephone number, cell phone number, ID number, physical address, company name, contact ID number, credit card or banking details. Personal Data may include sensitive categories of information, such as information that reveals political opinions, religious beliefs, trade union membership, health or sexual orientation (Sensitive Personal Data). Maintaining the integrity and confidentiality of Personal Data and handling it correctly is central to the way we conduct our business activities. This policy describes how we handle all Personal Data.
Protecting Client privacy is of utmost importance to Emotion and this Privacy Policy aims at safeguarding our Client's personal information and to protect the confidentiality thereof in terms of the provisions of the Constitution of the Republic of South Africa Act, 108 of 1996, the Electronic Communications Act, 25 of 2002; the Protection of Personal Information Bill of 2006; and the common law so as to ensure compliance with all relevant statutory requirements and best practice under South African law.
By accepting the Emotion services and packages terms, the Client consents to Emotion's collection of personal information on an ongoing basis for the continued duration of the Client's relationship with Emotion, subject to the limitations set out in this Privacy Policy.
We will observe the privacy principles described below of Notice, Choice/Fair Processing, Access, Security/Integrity and Enforcement/Compliance in processing Personal Data.
When we collect and process Personal Data about individuals, we will make certain information available to those individuals on a reasonable and timely basis. This information will include what Personal Data is being collected, who is collecting it, how and for what purposes it is being collected, how it is being used and to whom it will be disclosed.
We will process Personal Data only with consent or when such processing is permitted by applicable law. If we need to process Sensitive Personal Data, we will obtain explicit consent for such processing, unless such processing is permitted by applicable law.
We will not process Personal Data in a manner incompatible with the purposes for which it was originally collected unless later authorized by the affected individuals or allowed by law; we will take reasonable steps to ensure that such data is accurate, adequate, relevant and not excessive in relation to such purposes; and we will not keep such data longer than is necessary for such purposes.
We will enable individuals to choose whether their Personal Data can be disclosed to a third party for direct marketing purposes.
We will allow individuals reasonable access to their Personal Data to verify, correct or delete their data, where inaccurate. We will also provide a means for individuals to exercise all other legal rights that they may have in relation to their Personal Data.
Personal Data will be accessible and processed only by (i) Emotion employees, suppliers, business partners and others who require access for the performance of their obligations to Emotion; (ii) any person granted access by the individual to whom Personal Data pertains; and (iii)those otherwise authorized by law or court order.
We will take reasonable security procedures through appropriate technical and organizational measures to protect against unauthorized or unlawful access or processing, disclosure, alteration, destruction or accidental loss of Personal Data. We will utilize reasonable means to keep Personal Data accurate, complete and current in order to protect the quality and integrity of Personal Data, however, we rely on the Clients to provide all relevant information and to advise us of any changes to their Personal Data to ensure that it remains accurate, complete and current. When we transfer Personal Data within Emotion or to third parties (including our suppliers and business partners), we will observe the privacy principles of Notice and Choice (described above), and we will require all the recipients of such data to provide at least the same level of protection for such data as specified by the standards stated in this policy.
We will follow internal processes for handling complaints regarding our management of Personal Data. We will demonstrate our compliance with this policy by publishing this policy conspicuously so that it is accessible to all interested persons, implementing procedures to execute this policy in the conduct of our business, including training our employees in the use of such procedures and disciplining employees for failure to comply with this policy and its procedures and at least annually, reviewing this policy to ensure that it continues to comply with prevailing privacy standards, current applicable law and regulations and existing agreements.
While Emotion will do all things reasonably necessary to protect the Client's rights of privacy whilst on the Emotion website, Emotion cannot accept any liability whatsoever for unauthorised or unlawful disclosure of the Client's personal and confidential information made by third parties who are not subject to Emotion's control.
In addition to all other Personal Data handled by Emotion, this policy applies to Personal Data collected through Emotion Web sites. As a convenience to our web site visitors, we sometimes provide links to other web sites. These linked sites are not under the control of Emotion, and as such, we are not responsible for their content and/or actions.
If you have any questions or comments about this policy or our privacy practices, please contact us.