UNIVERSAL OFFICE (PTY) LTD PROTECTION OF PERSONAL INFORMATION ACT PRIVACY POLICY

Background to POPIA

POPIA is South Africa’s primary data protection law.

The purpose of POPIA is to promote the protection of Information that is Processed by any Person, by prescribing certain minimum requirements for the Processing of Information.

These minimum requirements must be met, in order for a Person to Process Information and include those requirements set forth in clause 4 of the Policy of 2013.

Purpose of this Policy

This Notice explains how we obtain, use, and disclose our client’s personal information, in accordance with the requirements of the Protection of Personal Information Act (“POPIA”).

At Universal Office Automative Solutions we are committed to protecting your privacy and to ensure that your personal information is collected and used properly, lawfully, and transparently.

In order for Universal Office Automative Solutions to process information in a manner which is consistent with POPIA, Universal Office Automative Solutions must:

Process the Information lawfully and in a reasonable manner that does not infringe the right to privacy of the Person whose Information is being Processed.

Process the Information for a specific, explicitly defined, and lawful purpose related to a function or activity of Universal Office Automative Solutions

Process the Information only if, given the purpose for which it is Processed, it is adequate, relevant, and not excessive and if the Person whose Information will be Processed has consented to its Information being Processed.

It is necessary to Process the Information to carry out actions for the conclusion or performance of a contract to which the Person whose Information will be Processed is a party; or it is necessary to Process the Information to comply with an obligation imposed by law on Universal Office Automative Solutions or to protect a legitimate interest of Universal Office Automative Solutions and/or the Person whose Information will be Processed.

Take reasonable steps to ensure that the Person whose Information will be Processed is aware of the Information that will be Processed, the source from which that Information will be collected and the purpose for which that Information will be Processed.

Take reasonable steps to ensure that the Information that is Processed is complete, accurate, not misleading and updated where necessary.

Take reasonable technical and organisational measures to secure the integrity and confidentiality of Information that is processed to prevent the loss, damage or unauthorised destruction of Information and the unlawful access to or Processing of Information; and

Take reasonable steps to ensure that the Person whose Information will be Processed is aware of his rights in and to his Information.

How we use your information

We will use your personal information only for the purposes for which it was collected and agreed with you. In addition, where necessary your information may be retained for legal or research purposes.

For example:

  • To gather contact information.
  • To confirm and verify your identity or to verify that you are an authorised user for security purposes.
  • For the detection and prevention of fraud, crime, money laundering or other malpractice.
  • To conduct market or customer satisfaction research or for statistical analysis.
  • For audit and record keeping purposes.
  • In connection with legal proceedings.

Awareness and Consent

Universal Office Automative Solutions is required to ensure that its clients are aware of the purpose for which their Information is being Processed, the way it will be Processed and their rights in respect thereof. Universal Office Automative Solutions will do this by:

publishing a copy of this Policy on its website at www.uoas.co.za

Making a copy of this Policy available for inspection at its principal place of business at 102 Sydney Road, Farm Klipfontein, Ravenswood, Boksburg, Gauteng.

Using bona fide endeavours to communicate the existence of this Policy to those of its clients whose Information Universal Office Automative Solutions has processed prior to the date referred to in Section 114(1) of POPIA.

Referring to this Policy in its recruitment and/or job advertisements; and incorporating this Policy by reference into, inter alia, the following documents:

  • employment agreements.
  • standard terms and conditions of trading.
  • offer to purchase contracts.
  • credit applications; and
  • any other contracts or agreements that Universal Office Automative Solutions may enter with its clients.

Universal Office Automative Solutions will, where it is necessary or appropriate to do so, obtain the written consent of its clients to Process their Information in accordance with POPIA, inter alia, by:

  • requesting its clients to consent to the Processing by Universal Office Automative Solutions of their Information; and
  • requiring applicable Clients to sign any one or more of the documents contemplated in clause 7.1.5 of this Policy.
  • Universal Office Automative Solutions will catalogue and store the record of consents that it obtains from its clients.

Disclosure of information

We may disclose your personal information to our service providers who are involved in the delivery of products or services to you. We have agreements in place to ensure that they comply with the privacy requirements as required by the Protection of Personal Information Act.

We may also disclose your information:

  • Where we have a duty or a right to disclose in terms of law or industry codes.
  • Where we believe it is necessary to protect our rights.

Information Security

We are legally obliged to provide adequate protection for the personal information we hold and to stop unauthorized access and use of personal information. We will, on an on-going basis, continue to review our security controls and related processes to ensure that your personal information remains secure.

Our security policies and procedures cover:

  • Physical security.
  • Computer and network security.
  • Access to personal information.
  • Secure communications.
  • Security in contracting out activities or functions.
  • Retention and disposal of information.
  • Acceptable usage of personal information.
  • Governance and regulatory issues.
  • Monitoring access and usage of private information.
  • Investigating and reacting to security incidents.

When we contract with third parties, we impose appropriate security, privacy, and confidentiality obligations on them to ensure that personal information that we remain responsible for, is kept secure.

We will ensure that anyone to whom we pass your personal information agrees to treat your information with the same level of protection as we are obliged to.

Client Participation and Rights in and to its Information

Each Client, after having provided adequate proof of identity to Universal Office Automative Solutions, has the right to:

request that Universal Office Automative Solutions confirms, free of charge, whether it holds Information about that Client.

Request the record of or a description of the Information that Universal Office Automative Solutions holds about that Client.

Request that Universal Office Automative Solutions correct or delete any Information in its possession or under its control about the Client that is inaccurate, irrelevant, excessive, out of date, incomplete or misleading, or to destroy or delete a record of any Information about it that Universal Office Automative Solutions is no longer authorised to retain; and withdraw its consent for Universal Office Automative Solutions to Process its Information at any time, but the withdrawal of consent will not affect:

the Processing of its Information before the withdrawal of consent; nor the processing of any of its Information that is required by Universal Office Automative Solutions to comply with law and/or finalise the performance of any agreement that it has entered into with the Client concerned.

Should any Client wish to exercise any of the rights referred to above, it can do so by contacting the Information Officer who can be contacted in the manner described in clause 13 of this Policy, and the Information Officer will give effect to the Client’s request or withdrawal.

Information Officer

Universal Office Automative Solutions will appoint an Information Officer.

The name and contact details of the Information Officer can be obtained by visiting Universal Office Automative Solutions’ website at www.uoas.co.za or by sending an email to the following email address: sales@uoas.co.za

The Information Officer will be responsible for, inter alia:

Ensuring that Universal Office Automative Solutions Processes the Information of its Clients in a lawful and reasonable manner that does not unreasonably infringe its clients’ right to privacy.

Providing regular training and support to the employees and officers of Universal Office Automative Solutions who have access to or Process Information, so that they can do so lawfully and in terms of this Policy.

Creating awareness about the provisions of this Policy, including by way of the mechanisms contemplated in clause 7 of this Policy; and

ensuring that it applies due diligence in the monitoring of developments in relation to the law pertaining to protection of Information, and in amending and/or updating Universal Office Automative Solutions’ approach to such protection, including by way of updating and/or amending this Policy.

The Information Officer will be trained appropriately to give effect to this Policy and will address any reasonable queries or concerns that any Clients may have regarding this Policy or the Processing of their Information as contemplated in it.

Status of Policy

This Policy has been adopted by and will apply to Universal Office Automative Solutions.

The information we collect.

Collection of Personal Information on our Website:

We collect and process your Personal Information mainly to provide you with access to our services and products, to help us improve our offerings to you and for certain other purposes explained below.

The type of information we collect will depend on the purpose for which it is collected and used.

  • We will only collect information that we need for that purpose.
  • We collect information directly from you where you provide us with your personal details, for example:
  • when you purchase a product or services from us or when you submit enquiries to us or contact us.

Where possible, we will inform you what information you are required to provide to us and what information is optional.

Examples of information we collect from you are:

  • name
  • address
  • email address
  • telephone/cell number
  • user-generated content, posts, and other content you submit to our web site.

We also collect information about you from other sources as explained below.

With your consent, we may also supplement the information that you provide to us with information we receive from other companies in our industry to offer you a more consistent and personalized experience in your interactions with Universal Office Automative Solutions.

Collection of Non-Personal Information

We may automatically collect non-Personal Information about you such as the type of internet browsers you use or the website from which you linked to our website. We may also aggregate details which you have submitted to the site (for example, the products or services you are interested in).

You cannot be identified from this information, and it is only used to assist us in providing an effective service on our websites. We may from time-to-time supply third parties with this non-personal or aggregated data for uses in connection with this website.

How we use your information

We will use your Personal and Non-Personal Information only for the purposes for which it was collected or agreed with you, for example:

  • Analyse the effectiveness of our advertisements, competitions, and promotions.
  • Collect information about the device you are using to view the site, such as your IP address or the
  • type of Internet browser or operating system you are using, and link this to your Personal
  • Information to ensure that the site presents the best web experience for you.
  • Evaluate the use of the site, products, and services.
  • For audit and record keeping purposes
  • For market research purposes
  • For monitoring and auditing site usage

Help speed up your future activities and experience on the site. For example, a site can recognise that you have provided your Personal Information and will not request the same information a second time.

  • In connection with legal proceedings
  • Make the site easier to use and to better tailor the site and our products to your interests and needs 15 POPI Act Policy V1.0
  • Offer you the opportunity to take part in competitions or promotions.
  • Personalise your website experience, as well as to evaluate (anonymously and in the aggregate)
  • statistics on website activity, such as what time you visited it, whether you have visited it before and
  • what site referred you to
  • Suggest products or services (including those of relevant third parties) which we think may be of
  • interest to you
  • To assist with business development
  • To carry out our obligations arising from any contracts entered into between you and us.
  • To conduct market or customer satisfaction research or for statistical analysis
  • To confirm and verify your identity or to verify that you are an authorised customer for security.
  • Purposes
  • To contact you regarding products and services which may be of interest to you, provided you.
  • have given us consent to do so or you have previously requested a product or service from us and
  • the communication is relevant or related to that prior request and made within any timeframes.
  • established by applicable laws.
  • To notify you about changes to our service
  • To respond to your queries or comments
  • We will also use your Personal Information to comply with legal and regulatory requirements or
  • industry codes to which we subscribe, or which apply to us, or when it is otherwise allowed by law.
  • Where we collect Personal Information for a specific purpose, we will not keep it for longer than
  • is necessary to fulfil that purpose unless we must keep it for legitimate business or legal.
  • In order to protect information from accidental or malicious destruction when we delete information from our services, we may not immediately delete residual copies from our servers or remove information from our backup systems.
  • You can opt out of receiving communications from us at any time. Any direct marketing
  • communications that we send to you will provide you with the information and means necessary to opt out.

Disclosure of Personal Information

We may disclose your Personal Information to our business partners who are involved in the delivery of products or services to you. We have agreements in place to ensure that they comply with these privacy terms.

We may share your Personal Information with, and obtain information about you from:

  • Third parties for the purposes listed above.
  • Other companies in our industry when we believe it will enhance the services and products, we
  • can offer to you, but only where you have not objected to such sharing.
  • Other third parties from whom you have chosen to receive marketing information.

Personal Information Security

We are legally obliged to provide adequate protection for the Personal Information we hold and to stop unauthorised access and use of personal information. We will, on an on-going basis, continue to review our security controls and related processes to ensure that your Personal Information is secure.

Our security policies and procedures cover:

  • Acceptable usage of personal information.
  • Access to personal information.
  • Computer and network security.
  • Governance and regulatory issues.
  • Investigating and reacting to security incidents.
  • Monitoring access and usage of personal information.
  • Physical security.
  • Retention and disposal of information.
  • Secure communications.

Access to your Personal Information

You have the right to request a copy of the Personal Information we hold about you. To do this, simply contact us at the numbers/addresses listed on our home page and specify what information you would like. We will take all reasonable steps to confirm your identity before providing details of your personal information.

Please note that any such access request may be subject to a payment of a legally allowable fee, as laid down in our POPI Act Policy.

Correction of your Personal Information

You have the right to ask us to update, correct or delete your personal information. We will take all reasonable steps to confirm your identity before making changes to Personal Information we may hold about you. We would appreciate it if you would take the necessary steps to keep your Personal Information accurate and up to date by notifying us of any changes, we need to be aware of.

Amendments

UOAS may alter or amend this Policy or any part thereof at any time. UOAS will use reasonable endeavours not to change this Policy too often, and to bring to its clients’ attention any material changes to it, but its clients will be required to ensure that they keep up to date with the latest version of the Policy that is available on Universal Office Automative Solutions’ website and at Universal Office Automative Solutions’ principal place of business.