SHESHA LIFESTYLE PRIVACY POLICY

WHO ARE WE

This privacy policy describes how we, Shesha Lifestyle (Pty) Ltd, a company registered and incorporated in the Republic of South Africa with registration number 2013/230600/07 (“SHESHA”) (“we”, “us” or “our”) collect and otherwise process Personal Information about you when you visit this website located at sheshalifestyle.com. Our website address is: https://tgcsitedemo.com (the “Website”).

PERSONAL INFORMATION WE COLLECT AND OTHERWISE PROCESS

In most circumstances, providing your Personal Information to us is voluntary. Sometimes, it may be mandatory to provide your Personal Information to us. Please note however that, where the provision of your Personal Information is voluntary and if you elect not to provide us with your Personal Information, we may not be able to provide you with the information, products and/or services you have requested or otherwise fulfil the purposes for which we have asked for the Personal Information. Aside from this, your visit to, access and/or use of the Website will remain unaffected.

We only collect and process Personal Information that is reasonably necessary for us to carry out our business functions.

Generally, we may collect and otherwise process the following Personal Information:

• your name, surname, date of birth, contact information and residential/postal address;
• your banking and financial information;
• your personal preferences and tastes in relation to sports teams;
• any other form of Personal Information that we may reasonably require to offer any of our products or services to you, including login details, display name, and order history;
• details of the resources that you access to visit the Website (for example, URL addresses, traffic data etc.);
• records of any contact you have made to us including notes or recordings of a call you make to one of our contact centres, an email or letter you send to us;
• information about the type of device you have used to visit the Website, your device settings, and the cause of any system errors. Your device manufacturer or operating system provider will have further details on what information your device makes available; and
• “cookies” that track your preferences during your visits to the Website which enables us to simplify navigation, by using Google Analytics (which is a web-analysis tool from Google Inc). This allows us to ensure that the content of the Website remain up to date and comprehensive. The information that is used during this process (which includes your IP address) is de-identified and makes personal identification impossible. We own and retain all rights to de-identified statistical information collected and compiled by us. We also make use of first-party and third-party cookies, as well as web beacons and similar technologies to deliver measurement services and targeted advertising to the Website visitors. Cookies may include Google Analytics cookies, a Google Ads cookie, and a Facebook Event Tracking cookie. Cookies help us to provide you with a better online experience, by enabling us to monitor which pages you find useful or not. Please note that we are not responsible for the privacy practices of other parties and advise you to read the privacy statements of each website you visit which collects Personal Information. A cookie does not give us access to your computer or any of your Personal Information, other than that which you choose to share with us. You may at any time decline cookies in your web browser settings, but this may prevent you from using the full functionality of the Website. For more information on the use of Google Analytics, please visit https://policies.google.com/technologies/partner-sites. For detail regarding the information Google collects and how it is used to deliver targeted advertising, please visit http://www.google.com/policies/privacy/ads/“.

We do not collect any special Personal Information about you other than the above listed Personal Information about you through the Website.  If we do, we will only do so with your consent.

HOW WE COLLECT YOUR PERSONAL INFORMATION

Most of the time we will collect Personal Information directly from you and, depending on the type of products/services used by you, it may be collected when you:

• visit the Website, our app or our social media platforms;
• create an online profile on our e-commerce platform(s) or download one of our apps;
• shop with us online;
• purchase any goods online, you will also be prompted to provide necessary Personal Information to process payment. When you pay for goods on the Website, we collect your contact and payment details, including shipping and billing addresses, payment method, bank account number or credit card number, and order history;
• when you leave comments on the Website, we collect the data shown in the comments form including your profile photo and details, and also your IP address and browser user agent string to help spam detection;
• upload any media or images onto the Website or social media platforms. (You should avoid uploading images with embedded location data (EXIF GPS) included, as any visitors to the Website will be able to download and extract any location data from any images / media on the Website.);
• sign up for our any of our rewards or loyalty programmes;
• give us your details for an item request;
• engage with us online, telephonically, on social media, on our apps, by SMS, email or via WhatsApp;
• sign up for our newsletters;
• enter any of our competitions; and
• interact with any online advertising, content or links and any interaction you may have had with such content or advertising (including, but not limited to, mouse hover, mouse clicks and any forms you complete).

We also collect records of your interactions with our online advertising and content, records of advertising and content displayed on pages displayed to you, and any interaction you may have had with such content or advertising (including, but not limited to, mouse hover, mouse clicks and any forms the user completes.

Most of the time, we collect Personal Information from you when you interact with us.  However, we sometimes collect Personal Information about you from third party sources where this information is publicly or commercially available.  There are also instances where we collect information from trusted external sources. These sources may include our commercial partners to whom you have given consent to share your information.

We sometimes collect Personal Information through embedded content from other websites. Articles or other content on the Website may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if you have visited the other website. These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and is logged in to that website. These third party websites are not controlled by us and we are not responsible for the content of, or the services offered by these sites.  The hyperlinks are provided solely for your convenience and should not be construed as an express or implied endorsement by us or the third party websites or the products or services provided therein or any association with their operators. You access the third-party websites and use their products and services solely at your own risk.

It is the nature of the Internet and websites that we, by default, record your information on our server traffic reports from the browser which you are using to view the Website, including an IP address and which web pages were visited.

COOKIES

We use cookie technology. Cookie technology consists of trace elements of data, in the form of an alphanumeric identifier, that is transferred to and stored on your computer’s hard drive and which contains information about you, so that next time you visit the Website, the cookie recognises your prior visit. Cookies may also be used to compile aggregate information about areas of the Website that are visited most frequently. You can disable use of cookies by configuring their browser settings accordingly.

Cookie technology also generates and saves your user and session ID’s to your internet browser and computer to track and analyse your Website usage. We do this to identify any technical problems with the Website, so that any such problems can be corrected and create a better online experience for you.

Depending on how you use and access the Website, the cookies collect data in the following ways:

• If you leave a comment on the Website you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment.
• If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data.
• When you login, we will also set up several cookies to save your login information and your screen display choices.
• If you select “Remember Me”, your login will persist for a limited duration. If you log out of your account, the login cookies may be removed.
• If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited.

WHY WE USE AND PROCESS YOUR PERSONAL INFORMATION

Users of the Website understand and agree that, to offer certain services or functions, we must collect and process Personal Information about users.

We use the information we collect and receive for the following general purposes:

• to provide you with information, products or services you request from us;
• in order to refer you to an appropriate third-party service provider;
• to communicate with you; and
• to provide you with support.

WHO WE SHARE YOUR PERSONAL INFORMATION WITH

We may share your Personal Information with:

• our Affiliates;
• our employees and third-party service providers (other than those whom we refer you to);
• our business partners;
• any authorized official if required to do so by law or if it is required to protect the safety of other Website users or the public, to prevent fraud or abuse, misuse or unauthorised use of our services, or if we believe that such action is necessary to protect and defend our rights or properties;
• other parties in response to legal process or when necessary to conduct or protect our legal rights;
• companies that provide services to us (note that companies that provide services to us or act on our behalf may have access to information about you. We adopt appropriate contractual and security measures to limit the ability of such companies to use information they receive in the course of providing services to us or you); and
• third parties where you provide consent in the form of an explicit opt-in. Before we ask you to opt in, we will endeavour to provide you with a clear description of what data would be shared with the third party.  Remember that once you have opted in to allow us to send your information to the third party, we cannot control what they do with your data; therefore, be sure to investigate their privacy policies before providing permission for us to share your information.

HOW WE SECURE YOUR PERSONAL INFORMATION

Protecting and securing your information is very important to us and we will take all reasonable and practicable steps to ensure that your Personal Information is secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.  However, we do employ a number of safeguards to mitigate the security risks.

• Personal Information collected by us is stored in a secure operating environment that is not available to the public.
• We use all reasonable endeavours to put in place and maintain electronic procedures and systems to ensure safety of and eliminate risks of unauthorised access to, and loss, misuse or wrongful alteration of, Personal Information with reference to accepted technological standards.

It is your responsibility to maintain the confidentiality and security of your password and to alert us or reset your password if you suspect any compromise of security.

WILL YOUR PERSONAL INFORMATION BE SENT OUT OF THE COUNTRY?

Your Personal Information may be collected and processed outside of your country of residence. Your Personal Information may be transferred to and maintained on servers located outside of your country of residence, where the data privacy laws, regulations and standards, may not be equivalent to the laws in your country of residence.

We may transfer your Personal Information to places outside of South Africa and store it there, where us, our Affiliates and/or our service providers might process it.  If that happens, your Personal Information will only be transferred to and stored in a country that has equivalent, or better, data protection legislation than South Africa or subject to appropriate measures requiring compliance with data protection requirements equivalent or better than those applicable in South Africa.

By selecting the Opt-in box to disclose Personal Information, you acknowledge that this Personal Information may be transmitted to other countries, including the United States, in the approved form and manner.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We keep your Personal Information for as long as any contractual and legal requirements, credit risk, fraud detection and customer service periods require, as well as to comply with regulatory requirements, and the resolution of disputes or fraud prevention.

MINORS

By using our Website, we assume that you are at least 18 years old, or that someone (like a parent or legal guardian) has assisted you to consent to our terms (including this Privacy Policy) and visit and transact with us on the Website.

YOUR RIGHTS

Your consent

By providing us with your Personal Information, either directly, using our site, our products and services and/or communicating electronically and/or using non-electronic means of communication with us, you agree to this Privacy Policy and consent to the processing and transfer of your Personal Information as set out in this Privacy Policy, and authorise us and other third parties to process your Personal Information for the purposes stated in this Privacy Policy.

Right to access to your Personal Information

Under the Promotion of Access to Information Act, 2000 (“PAIA”), you have the right to, at any time, request confirmation that we hold your Personal Information, access to your Personal Information and confirmation regarding the identities or categories of third parties to whom we have disclosed your Personal Information. You may be asked to pay a fee to access the information. Fees to obtain a copy or a description of Personal Information held about you are prescribed in terms of PAIA. Confirmation of whether or not we hold Personal Information about you may be requested free of charge. If you would like to obtain a copy of your Personal Information held by us, please review our PAIA Manual located at www.sheshalifestyle.com/paia-manual/. 

Right to correction of your Personal Information

You can request that we correct any Personal Information that is incomplete, misleading, inaccurate, excessive or out of date (although please first try changing your Personal Information through your user profile and if this does not work, please contact us to help you).

Right to erasure of your Personal Information

You can request that we erase any Personal Information that we hold about you. This does not include any data we are obliged to keep for statutory, administrative, legal, or security purposes, or data we deem necessary to retain for the pursuit of legitimate business purposes. Where we cannot delete your Personal Information, we will take all reasonable steps to make it anonymous.

Right to object to the processing of your Personal Information

You also have the right to object to your Personal Information being used by us. This includes the right to object to the transfer of Personal Information that you have made available to us and to withdraw consent to the use of your Personal Information. Please be aware that, should you object to the transfer of Personal Information or withdraw your consent to the use of your Personal Information, we may no longer be able to provide you with the Information, products and/or services that you have requested or otherwise fulfil the purposes for which we have asked for the Personal Information.

Any updates or removals will reflect in our active database, but we may retain data in backup files and archives or to prevent a user from being accidentally re-added to the database after they have expressly unsubscribed.

Please be advised however that your rights as set out above may in certain circumstances be limited if we have legal grounds to process your Personal Information.

Our contact details for any requests can be sent to kathleen@tgcsitedemo.com.

If you have any questions, concerns or complaints regarding our processing of your Personal Information in terms of this Privacy Policy, please contact our Information Officer at:

Designated Information Officer:	Kathleen Merrifield Powell
Email address of Information Officer:	kathleen@tgcsitedemo.com
Postal address:	Building 3, Fernridge Office Park 5 Hunter Street, Blairgowrie, Randburg, 2194
Street address:	Building 3, Fernridge Office Park 5 Hunter Street, Blairgowrie, Randburg, 2194
Phone number:	(+27) 010 492 3741

If you are unsatisfied with our response to your complaint or believe that we have used your Personal Information contrary to law or this Privacy Policy, you have the right to lodge a complaint with the Information Regulator.

You can contact the Information Regulator with your complaint/query at:

Physical address:        JD House

27 Stiemens Street

Braamfontein Johannesburg

Post address:              P.O. Box 31533

Braamfontein

Johannesburg 2001

Email address:            POPIAComplaints@inforegulator.org.za

Email address:            PAIAComplaints@inforegulator.org

You can visit the Information Regulator’s website for more details, which can be accessed at: https://inforegulator.org.za

AMENDMENTS TO THIS PRIVACY POLICY

We may amend this Privacy Policy at any time, but we will always ensure that the latest version is available on our Website and apps.

By using the Website, you signify your acceptance of our Privacy Policy and its changes from time to time.

If you do not agree to this Privacy Policy, please do not continue to access or use our Website or submit any Personal Information to us.

CONTACT US

If you have any questions about this Privacy Policy, please contact us on kathleen@tgcsitedemo.com.