Privacy Policy

PRIVACY NOTICE AND INFORMED CONSENT NOTICE

CONSENT TO PROCESS PERSONAL INFORMATION IN TERMS OF THE PROTECTION OF
INFORMATION ACT, 4 OF 2013 (POPIA)

The Protection of Personal Information Act, 4 of 2013 (POPIA) gives effect to the constitutional right to data privacy in terms of Section 14 of the Bill of Rights of the Constitution.

The responsible use of the COETZEE & KRUGER INC’S website and related resources in respect of data privacy is important to COETZEE & KRUGER INC.

This Privacy Notice describes how we collect, use, share, or otherwise process Personal Information as a Data Controller in the course of operating our business, including our websites, mobile applications, and digital communications.

“Personal Information” as used in this notice means information that identifies, relates to, describes, or can reasonably be linked, directly or indirectly, to a specific individual. It does not include information that is considered anonymous, de-identified, or aggregated by applicable law.

In our legal representation of a client, we may also process Personal Information. Such processing is performed on behalf of and at the direction of our client, subject to our client agreements and professional responsibilities, and is not covered by this notice.

Whilst COETZEE & KRUGER INC is committed to protecting all persons’ rights to privacy and will in consequence ensure that all person’s Personal Information is used appropriately, transparently and according to applicable law, COETZEE & KRUGER INC also has a duty to ensure that these rights to privacy are balanced with other rights such as needed to comply with our legal obligations, as permitted by applicable law, or as otherwise described in this Notice.

This Policy sets out the responsibilities and obligations of all persons who make use of, or access or receive COETZEE & KRUGER INC’S Information and Communications, including electronic communications via its website or email and how all users of these facilities and resources are to ensure that when using these resources that they respect and process another’s Personal Information lawfully and in accordance with the provisions of POPIA and the Personal Information Processing Principles.

PLEASE READ THE DOCUMENT BEFORE YOU MAKE USE OF THE COETZEE & KRUGER INC’S
ELECTRONIC FACILITIES OR PROVIDE COETZEE & KRUGER INC WITH ANY PERSONAL
INFORMATION. BY PROVIDING COETZEE & KRUGER INC WITH YOUR PERSONAL
INFORMATION, YOU CONSENT TO THE COETZEE & KRUGER INC PROCESSING YOUR PERSONAL INFORMATION, WHICH COETZEE & KRUGER INC UNDERTAKES TO PROCESS STRICTLY IN ACCORDANCE WITH THIS PRIVACY POLICY.

1. INTRODUCTION

1.1 COETZEE & KRUGER INC, in order to carry out its aims and objectives as a legal firm does, and will, on an ongoing basis receive, provide and process Personal Information.

1.2 In terms of a law known as the Protection of Personal Information Act, 4 of 2013 (POPIA) everyone has the right to privacy, including the right to the lawful collection, retention, dissemination and use of one’s Personal Information.

1.3 In order to give effect to this right, COETZEE & KRUGER INC is under a duty to provide any person whose Personal Information is processed by it, known as a “Data Subject”, with a number of details pertaining to the use of and subsequent processing of the Data Subject’s Personal Information, before such Personal Information may be used or processed by COETZEE & KRUGER INC.

1.4 In accordance with this requirement, COETZEE & KRUGER INC sets out below

the reasons why it will have to process a Data Subject’s Personal Information,
the conditions under which it will receive and use a Data Subjects Personal Information,  how COETZEE & KRUGER INC will use and handle this Personal Information, as well as  the conditions under which it will provide its own Personal Information.

2. APPLICATION

2.1 The Privacy Policy of COETZEE & KRUGER INC is applicable to:

2.1.1 all Personal Information collected by COETZEE & KRUGER INC’S, including vai electronic platforms and facilities, such as social media, websites and / or email, whether owned by, established by, used by, hosted by and / or accessed by COETZEE & KRUGER INC, and

2.1.2 all and any Data Subject(s), who may access and make use of the aforementioned COETZEE & KRUGER INC’S electronic platforms and facilities, including, without detracting from the generality thereof, COETZEE & KRUGER INC’S employees and staff, customers, vendors, contractors, service providers and / or other third parties.

2.2.2 all the Personal Information which is owned by COETZEE & KRUGER INC and which is provided to any responsible parties and / or operators as a result of such person accessing or making use of the COETZEE & KRUGER INC’S electronic platforms.

3. ACCOUNTABILITY

3.1 COETZEE & KRUGER INC takes the privacy and protection of a Data Subject’s Personal Information very seriously and will only process a Data Subject’s Personal Information in accordance with POPIA and the terms of this Privacy Policy.

3.2 In turn where COETZEE & KRUGER INC provides any of its Personal Information to a Responsible Party or Operator, then such person will be required as a condition of receiving such information, to process such Personal Information in accordance with POPIA and the terms of this Privacy Policy.

3.3 Accordingly, the relevant data privacy principles relating to the processing of Personal Information, whether that belonging to COETZEE & KRUGER INC or that belonging to a data subject (including, but not limited to, the collection, handling, transfer, sharing, correction, storage, archiving and deletion) will apply without exception, save where POPIA provides for such an exception, to all and any Personal Information provided to another by / received by COETZEE & KRUGER as a result of the use of COETZEE & KRUGER INC’S electronic platforms and / or facilities.

4. AGREEMENT TO BE BOUND AND CONSENT TO PROCESS

4.1 By accessing or using the COETZEE & KRUGER INC’S electronic platforms and facilities including all website and URL’s, any sites housed under its domain names and / or social media platforms, and / or when sending or receiving emails using the COETZEE & KRUGER INC’S email, the Data Subject:

4.1.1 acknowledges that it has read and understood this Privacy Policy and related provisions;
4.1.2 agrees to be bound by this Privacy Policy;
4.1.3 agrees to comply with this Privacy Policy; and
4.1.4 gives COETZEE & KRUGER INC consent to process and further process the required Personal Information for the required purpose, in accordance with this Privacy Policy.

5. RECEIPT, USE AND SHARING OF PERSONAL INFORMATION BY THE COETZEE & KRUGER INC

5.1 COETZEE & KRUGER INC will receive Personal Information pertaining to a Data Subject when the Data Subject submits a query to / or request from COETZEE & KRUGER INC, including via its website, or by way of email, telephone or via social media.

5.2 On receipt of the request or query, COETZEE & KRUGER INC will thereafter use and process the Data Subject’s Personal Information for the purpose of the query and for a variety of related purposes, which will all depend on the query or request, and which without detracting from the generality thereof may include:

for the purposes of identifying and / or verifying the Data Subject’s details;
for the purposes of providing information, products and / or services or details in connection therewith or pertaining thereto, that the Data Subject, may have requested;
to enrol the Data Subject as a vendor;
for employment application purposes;
for the purpose of concluding an employment relationship with an applicant;
for the purposes of managing any information pertaining to the Data Subject;
for further processing or general administration purposes;
for legal or contractual purposes;
to help COETZEE & KRUGER INC improve the quality of their products and services;
to help COETZEE & KRUGER INC detect and prevent fraud and money laundering;
for the purposes of recovering unpaid monies and / or any other amount due to COETZEE & KRUGER INC;
for the purpose of debt collection;
for the purposes of research, analytical and statistical purposes;
for the purpose of carrying out analysis and consumer / customer profiling;
for the purposes of identify other products and services which might be of interest to the Data Subjects;
for the purposes of informing a Data Subject about COETZEE & KRUGER INC products and services.

5.3 In order to correctly handle any request or query, and in order to perform the purposes described above, COETZEE & KRUGER INC may from time to time share a Data Subject’s Personal Information with the following parties:

COETZEE & KRUGER INC’S employees, which will only be done on a need to know basis;
COETZEE & KRUGER INC’S suppliers, which will only be done on a need to know basis;
COETZEE & KRUGER INC ‘S carefully selected business partners who provide products and services which may be of benefit to a Data Subject which will only be done on a need to know basis; and
COETZEE & KRUGER INC ‘S operators such as service providers and agents who perform services on behalf of the COETZEE & KRUGER INC which will only be done on a need to know basis and in terms of a COETZEE & KRUGER INC ‘S operator agreement.

5.4 COETZEE & KRUGER INC does not share a Data Subject’s Personal Information with any third parties who have not been described above, unless:

COETZEE & KRUGER INC is legally obliged to provide such information to another for legal or regulatory purposes;
COETZEE & KRUGER INC is required to do so for purposes of existing or future legal proceedings;
the onward transmission or sharing of Personal Information is necessary for the pursuance or protection of COETZEE & KRUGER INC’S legitimate interests or that of the Data Subject or a third party;
COETZEE & KRUGER INC is involved in the prevention of fraud, loss, bribery or corruption and are using another agent or service provider under a mandate to provide such service, and the agent or service provider needs to process the Data Subject’s Personal Information for the purpose of investigating and or preventing any act of fraud, loss, bribery or corruption,

and under all of the abovementioned circumstances, COETZEE & KRUGER INC will take reasonable measures to ensure that such Personal Information is only provided to the recipient, if such recipient undertakes to keep the Personal Information confidential and secure.

5.5 Where COETZEE & KRUGER INC has to transfer the Data Subject’s Personal Information across the South African borders, it will before it does so, ensure that the recipient thereof agrees to be bound by POPIA under and in terms of a set of binding corporate rules or binding agreements that provide an adequate level of protection and uphold the principles for the reasonable and lawful processing of such Personal Information.

6. RECEIPT, USE AND SHARING OF THE COETZEE & KRUGER INC PERSONAL INFORMATION

COETZEE & KRUGER INC on receipt and in response to a query or request received from a Data Subject, referred to under section 5 above, may transmit via its website, or by way of email, telephone or via social media, its own Personal Information, which Personal Information on receipt by the requesting or receiving party, may only be used for the purpose relating to the initiating of the request or query and for no other purpose. Furthermore, the recipient undertakes that it will not use this Personal Information for any other purpose or share this information with any other party, save where it has been given express permission to do so by COETZEE & KRUGER INC.

7. INFORMATION QUALITY / OPENNESS / DATA SUBJECT PARTICIPATION

7.1 Whilst COETZEE & KRUGER INC will make all effort to ensure the integrity and accuracy of a Data Subject’s Personal Information, this may not at all times be possible. Following this, the Data Subject accepts the responsibility for keeping his / her or its Personal Information up to date, and undertakes to inform COETZEE & KRUGER INC of any changes to his / her and its Personal Information.

7.2 A Data Subject has a right of access to any Personal Information which COETZEE & KRUGER INC may have and where applicable may ask COETZEE & KRUGER INC to correct any inaccuracies in or to any such Personal Information. Any access request must be done by way of a formal COETZEE & KRUGER INC PAIA process, which is available at a request from the liason officer of the entity at [email protected]

8. SECURITY OF PERSONAL DATA

8.1 COETZEE & KRUGER INC makes all reasonable effort and practicable actions to prevent unauthorised access, business disruptions, legal liabilities and abuse of personal information records. However, COETZEE & KRUGER INC advises that it cannot guarantee the security of any information provided to COETZEE & KRUGER INC or by COETZEE & KRUGER INC through the COETZEE & KRUGER INC’S website, e-mail or internet. Following this COETZEE & KRUGER INC cannot be held responsible for any loss or unauthorised use or interception of information transmitted via these social media and electronic platforms or sites, including its Internet, which is beyond the COETZEE & KRUGER INC’S reasonable control.

8.2 COETZEE & KRUGER will ensure that suitable measures are in place to prevent and detect unauthorised access, business disruptions, legal liabilities and abuse of PI records, including:

entry to premises where personal information may be stored.
Protection of computer systems and networks used for storing, processing and transmitting personal information from unauthorised access, modification and disclosure;
Secure method of transit whenever Personal Information ins transferred from one location to another
Training of employees on privacy obligations
Written agreements with Third Parties requiring them to maintain security of all Personal Information in respect of which COETZEE & KRUGER INC is responsible.

9. THIRD PARTY INFORMATION AND THAT BELONGING TO MINORS

9.1 If a Data Subject provides COETZEE & KRUGER INC with Personal Information on behalf of another, COETZEE & KRUGER ING will not be able to process the query or request unless such query or request is accompanied with the required permission and consent from the owner of that Personal Information.

9.2 If a Data Subject is under the age of 18, such person’s Personal Information will only be processed if the minor’s parent or legal guardian gives the required consent or permission to the processing of the provided Personal Information.

10. CONTACT DETAILS

You can contact COETZEE & KRUGER INC in relation to this Privacy Policy by writing to us at [email protected] or by calling our landline at 012 348 1546.

11. REVISION OF POLICIES

COETZEE & KRUGER INC reserves the right to and may from time to time update this Privacy Notice.

Any such revision will be published as an amended version on the COETZEE & KRUGER INC website.

Following this, any change to this Policy will be posted as an updated version and readers are advised to visit and re-read this policy on a regular basis.

Privacy Policy

PRIVACY NOTICE AND INFORMED CONSENT NOTICE
CONSENT TO PROCESS PERSONAL INFORMATION IN TERMS OF THE PROTECTION OF
INFORMATION ACT, 4 OF 2013 (POPIA)