Privacy Policy

This Privacy Policy is effective from 1^st Aug 2024.

This Privacy Notice sets out the basis on which any Personal Information collects, uses, shares and otherwise processes. Please read the following carefully to understand TsogaShop’s views and practices regarding Personal Information and how TsogaShop will treat it. This Privacy Statement explains why and how we collect, use and store your personal information. The processing of personal data must be transparent and secure, in conformity with the South African Protection of Personal Information Act (POPI), the European Union General Data Protection Regulation (GDPR) and the privacy legislation of the countries in which TsogaShop operates. By accessing and using TsogaShop Services, including TsogaShop’s interactions with you via our websites, mobile sites and applications (“Sites”), you agree to the transfer, storing and processing of Personal Information as set out in this Privacy Notice.

1. What Is This Notice About?

We want you to understand who you are sharing your information with, what kind of information we collect and how we use the information.

In your day-to-day dealings with TsogaShop, we obtain information about you. We want you to know exactly what that information is and what we do with it. This Privacy Statement describes how we collect, use, process, and disclose your personal information, in conjunction with your access to and use of TsogaShop’s web and app platforms.

2. You are important

At TsogaShop, our most important asset is you and your trust. In this Privacy Policy we cover what and how we collect, use, disclose, transfer, and store your information.

We want to assure you that TsogaShop is committed to maintaining the confidentiality, integrity and security of any Personal Information about our users. This Privacy Policy explains to you what and how we collect, use, disclose, transfer, and store your non-personal and Personal Information shared through our sits or in connection with our Services.

It is not mandatory for you to provide the Personal Information that we have requested, but, if you choose not to do so, unfortunately, we will not be able to provide you with our Services or respond to any queries you may have.

This Privacy Policy forms part of our agreement with you. You should read it along with the terms and conditions that apply. These terms and conditions can be accessed on the specific TsogaShop website or products, and www.Tsogatec.com.

This notice may change from time to time. From time to time we may have to amend this notice to accommodate changes in our business or services or if legal requirements change. It is your responsibility to check that you have read the latest version.

3. Principles of Data Processing

Tsogatec shall apply the following principles when processing your Personal Information:

• Lawfulness, fairness and transparency: All Personal Information will be processed fairly, transparently and in compliance with applicable laws.
• Purpose: Any Personal Information collected will be used for a stated purpose.
• Data Minimization: TsogaShop will collect only the Personal Information that is adequate and relevant to the purposes for which it is collected.
• Accuracy: TsogaShop will keep the Personal Information accurate and, where necessary, kept up to date information.
• Storage Limitation: Personal Information will be stored with TsogaShop for a defined period as per its policy or applicable law.
• Integrity and Confidentiality: TsogaShop will implement appropriate technical, organizational and physical security measures to protect Personal Information.

4. When This Privacy Statement Applies

This Privacy Statement applies:

• when you use any of our products or services;
• when you apply to us for a job;
• when you supply services to us where this involves any personal information;
• as a result of your relationship with our clients; and/or
• to any information collected from or shared with third parties.

This Privacy Statement also applies to our websites, apps and online services as well as any publications or newsletters that you request.

5. What Information do We Collect

Personal information’ is any information that can be used to identify you or that we can link to you. Where you use our services, we will collect personal information directly from you.

We may also collect personal information from third parties such as your employing organisation, regulatory authorities, recruitment agencies, credit reporting agencies, information or service providers, publicly available records, and the third parties described in this Privacy Statement.

6. Information that you voluntarily provide to us.

6.1. How do we use your Personal Information?

TsogaShop uses Personal Information internally in relation to:

1. Conduct its Operations, Risk Management, Transaction Processing, Marketing, development of existing and new Products and for Legal, compliance, regulatory or law enforcement purposes.
2. Online Session Information and Use is Collected to Improve Your Experience

When you use our online services, we may collect the following:

Information you provide by completing forms (this includes information you give us, submitting material, requesting services, registering for any of our online offerings or other services).

• Your name and address
• Your delivery address (if different to above)
• Your contact telephone number in case we need to call you
• Your credit or debit card number, expiry date and security code
• Information you provide by your participation in competitions, live chats or message boards
• Information you provide to us if you contact us, for example to report a problem with our online services or raise a query or comment

We may also collect technical and navigational related Personal Information, such as computer browser type, Internet protocol address, pages visited, and average time spent on our Site. This Personal Information may be used, for example, to alert you to software compatibility issues, or it may be analysed to improve our design and functionality of the TsogaShop Sites and the Services.

Where our online services require that you enter a password or other information in order to access certain features, we will collect such credentials when you enter them.

6.2. We Use Cookies and other technologies to improve your Experience

We may use cookies and similar technologies to help us better understand user behaviour, tell us which parts of TsogaShop Sites people have visited, and facilitate and measure the effectiveness of offer and Services and improve them.

We treat the information received from cookies and other technologies as non-personal information. You will have the option to disable cookies. If you choose to do so, unfortunately, certain features of the TsogaShop website and the Services will not be available once cookies are disabled.

Some web browsers may send out ‘do not track’ signals. There is no industry standard currently in place as to what websites and other online services should do upon receipt of such signals. Should such a standard be developed, TsogaShop will re-visit its notice, but currently takes no action upon receipt of such signals.

TsogaShop may offer certain features that are only available through the use of tracking technologies. Temporary cookies are used to enable you to navigate our site and use its features. These are deleted when you close your browser. IP addresses are used in conjunction with cookies for the purpose of “remembering” computers or other devices used to access our Sites.

Analytical or performance cookies collect anonymous information about how visitors use our websites. They allow us to analyse information such as the count of visitors to our websites, what search terms our visitors are using, what pages are viewed, and the last page visited. This information is based on the visitor’s IP address, and we cannot view individual activity tied to a single person.

To the extent that Internet Protocol (IP) addresses (or similar identifiers) are clearly defined to be Personal Information under any local law and where such local law is applicable to TsogaShop Services, TsogaShop will manage such identifiers as Personal Information.

TsogaShop Sites may also contain links to and from third party websites, including those of partner TsogaShop, advertisers and affiliates. Please note that these websites may have their own privacy notices and cookies policies, and TsogaShop does not accept any responsibility or liability for these third party websites. The inclusion of links to third party websites in no way constitutes an endorsement by us of such websites’ content, actions, or policies.

7. Information from other sources

We may collect information from other sources, such as social media platforms that share information about how you interact with our social media content, and any information gathered through these channels will be governed by the privacy settings, policies, and/or procedures of the applicable social media platform, which we strongly encourage you to review. We will handle any unsolicited information in accordance with law, including destroying or de-identifying such information where we are required to do so.

8. We collect information when you contact our Call Centres to respond to your query.

When you contact our customer support services, we collect information that helps us to categorise your query, respond to it and, if applicable, investigate what went wrong. We also use this information to track potential problems and trends to customise our support responses to provide a better service to you. Calls are recorded for quality control and record-keeping purposes.

Our call centres are committed to keeping your personal information safe and secure. Please take care not to provide more information than what we ask for. Please do not provide your bank account details or passwords to our Call Centre Agents. Any unnecessary information you give us will not be retained.

9. We collect information while you use our websites.

Every time you connect to our websites we store web server logs which show your IP address (the unique number which your machine uses when it is connected to the Internet), what you looked at, whether the page request was successful or not, and which browser you used to view the pages. The use of this data is strictly for statistical and personalisation purposes only. This helps us understand which areas of the site are of particular interest and also which pages are not being requested. It also tells us how many hits and page requests we get.

We use cookies to optimise your website experience, but you can opt out.

A cookie is a small piece of information stored by your browser on your device. It may contain some personal details in an encrypted format, which can be recalled when you return to the website. This speeds up our identification, ordering and delivery processes.

We use cookies to identify the device you use to connect to our website. We use anonymous cookies to collect data about how you use our website, so that we can improve and optimise your website experience. You can opt out of cookies by activating the setting on your web browser which allows your web browser to refuse cookies. However, if you select this setting you may be unable to access certain parts of our website and this may have a detrimental effect on your experience and the web-based services that we can offer you. You may delete the cookies stored on your computer at any time. Other tracking pixels may also be collected as required.

10. Sharing Your Information

Your privacy is important to us, and we undertake to not use or share your personal information unless for business purposes. We will not provide any of your information to entities outside our group so as to permit them to market their goods or services to you.

You agree that we may make your information available to the following people and organisations in order to process your data as set out in this Privacy Statement:

• We only share your personal information with companies that help us to provide our services to you and who have agreed to keep your information secure and to only use it for authorised purposes.
• We use suppliers or service providers who we trust to provide services to us and sometimes that involves sharing your information with them. They operate under strict requirements aimed at keeping your personal information secure and confidential and they will only use it for the purpose for which we have sent it to them. We will engage external service providers with appropriate Non Disclaimer and/or Data Sharing Agreements to protect your data.
• We may share your personal information with banking institutions and the issuers of payment cards you use.
• To governmental, judicial, regulatory and law enforcement bodies and agencies, including any credit regulator.
• Sometimes we have to send your personal information to other countries.

11. How We Use Anonymized Data: Peer Comparisons, Research & Development

TsogaShop may make anonymous or aggregate Personal Information and disclose such data only in a non-personally identifiable manner to:

• advertising, measurement or analytics partners approved by TsogaShop that conduct research into consumer spending;
• deliver products and services to other clients; and
• Users of the Service for purposes of comparison of their financial situation relative to the broader community.

12. With whom does TsogaShop share Personal Information and for what purposes?

Before we share Personal Information, we ensure there are adequate safeguards in place to protect the processing of that data. TsogaShop does not disclose information that could identify you personally to anyone, except as described in this notice, including, but not limited to:

• Any TsogaShop group company;
• Any group company (such as advisers, share plan, payroll and other third party administrators, agents or contractors working on behalf of TsogaShop);
• Financial institution clients;
• Service providers and other third parties under contract who help with our business operations (including, but not limited to, fraud investigations, site analytics and operations);
• Regulatory, legal and judicial authorities;
• Social media sites integrated into web services that we offer;
• Governmental or quasi-governmental organizations; and
• Potential purchasers of TsogaShop.

TsogaShop may disclose Personal Information to third parties for the following purposes:

• Legal or regulatory purposes
• Business purposes
• Suppliers who assist TsogaShop with the provision of its Services

13. Information on cross-border data transfers

TsogaShop, has its headquarters in Pretoria, South Africa. The data TsogaShop collects from you may be transferred, stored and processed in a country different from where the data was collected.

By using our TsogaShop Sites and Services, you are permitting TsogaShop (or its authorized service providers) to process, store and transfer Personal Information to a country which is different from where the data was collected. The transfer of information will often be in furtherance of a contract to which you or your bank/merchant are a party. In other cases, the transfer of information will be consistent with the legitimate interests of conducting TsogaShop Services.

14. Individual’s Privacy Rights (data subject rights)

Certain laws and regulations give individual data subject rights in relation to their Personal Information (for example, the right to access that data, to rectify inaccurate data, or to erase Personal Information). In certain circumstances, data subjects may have such rights in respect of the Personal Information processed by TsogaShop.

In such circumstances, where a request to exercise such a right is received by TsogaShop, it must be forwarded to privacy@Tsogatec.com so that it can be handled in accordance with applicable laws and statutory timeframes.

15. Security

We take your privacy and the security of your personal information seriously.

We have implemented reasonable security safeguards to protect the personal information that you give us. For example sensitive data (such as your credit card information) is protected by SSL encryption when it is exchanged between your web browser and our website.

You can play a role in protecting your information by never sharing your username, PIN or password with anyone or submitting it to a website you don’t recognise. Always log off after a web session and change your password regularly.

We regularly monitor our systems for possible vulnerabilities and attacks. No system is perfect so we cannot guarantee that information may not be accessed, disclosed, altered or destroyed by breach of any of our physical, technical or managerial safeguards.

Please note that any email you send to us is not encrypted and may be monitored by us. Please do not send us sensitive or confidential personal information by email.

16. We Are Committed To Keeping Your Personal Information Secure

The security of your Personal Information is important to us. As discussed below, we utilize physical, electronic and procedural security measures to protect against loss, misuse, and alteration of Personal Information under our control. We adhere to industry standard practices and security measures and our practices are independently validated annually enabling us to comply with ISO 27001 (where applicable) and PCI-DSS standards to safeguard and secure the information we collect.

No method of transmission over the Internet, or method of electronic storage, is completely secure. Therefore, we cannot guarantee its absolute security. Any transmission is at your own risk.

We use a combination of firewall barriers, encryption techniques and authentication procedures, among others, to maintain the security of your online in-app session and to protect TsogaShop accounts and systems from unauthorized access. Our servers are in a secure facility. Access requires multiple levels of authentication. Security personnel monitor the system 7 days a week, 24 hours a day.

17. Our Service Ensures Secure Communications with Encryption

From the time you submit your login ID and password so that communications between your device and TsogaShop are encrypted. This enables client and server applications to communicate in a way that is designed to prevent eavesdropping, tampering and message forgery.

You are responsible for keeping your login ID, password, mobile device, and email account safe and confidential.

You also agree that you control and limit access to the email account and mobile device. If your email address or your mobile device changes, you are responsible for informing us of that change.

We are not responsible if someone else accesses your account through Registration Information they have obtained from you or through a violation by you of this Privacy Notice or the Terms of Use.

18. Restrictions and Monitoring of Our Partners and third parties

Any partners we work with have been selected in accordance with our security and risk management policies and practices and are bound by contractual obligations which includes compliance with TsogaShop policies and requirements relating to confidentiality, privacy and security. They may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

We may also use third party vendors or service providers to help us provide the Service to you, such as sending e-mail messages on our behalf or hosting and operating a particular feature or functionality of the Service. We require such third parties to maintain the confidentiality of the Personal Information we provide to them.

19. How long does TsogaShop store and retain Personal Information?

TsogaShop will store Personal Information only for the greater of as long as necessary to achieve the purposes for which it was collected and applicable law. Retention periods for transaction and other data categories may vary, depending on our obligations. For example, legal and regulatory compliance with anti-money laundering (AML) and KYC requirements, operational demands, business requirements or dates we assigned based on contracts will also need to be taken into account, and may require retention for a period of up to 7 years after the data was collected or after the merchant or other customer relationship has ended.

20. What happens in case of a data breach?

In case TsogaShop is faced with a breach of Personal Information, TsogaShop shall inform the relevant authorities and the data subjects/data controller where required by applicable law and shall take necessary steps to mitigate the impact of such breach.

21. Changes and updates to the privacy notice

TsogaShop may, from time to time, make changes to this Privacy Notice. If any material changes are made as to how TsogaShop treat Personal Information, you will be notified through this notice on TsogaShop’s Sites.

This notice is global in scope, but is not intended to override any legal rights in any territory where such rights prevail. In such event, the rights and obligations set out in this Privacy Policy will apply, subject only to amendment under any applicable local law having precedence.

22. We will inform you if your privacy is ever compromised.

Although we cannot prevent all security threats, we have measures in place to minimise the threat to your privacy. Should there be a data breach where your personal information is directly affected, we will follow the guidelines provided by data privacy legislation in order to inform you.