Effective Date: June 2018
What is personal information?
Personal information is information or an opinion, in any form and whether true or not, about an individual whose identity is apparent or can reasonably be ascertained from the information or opinion. Examples include an individual's name, address, contact number and email address.
Special provisions apply to the collection of personal information which is sensitive information. This includes health information and information about a persons' race, ethnic origin, political opinions, membership of political, professional or trade associations, religious or philosophical beliefs, sexual preferences and criminal history.
Collection of personal information by Clubshop
To the extent required by the Protection of Personal Information Act:
- Clubshop will not collect personal information about you unless that information is necessary for one or more of our functions or activities.
- Clubshop will collect personal information only by lawful and fair means and not in an unreasonably intrusive manner.
- Clubshop will collect your personal information directly from you where it is reasonable and practicable to do so. Where Clubshop collects information about you from a third party, we will still take reasonable steps to ensure that you are made aware of the details set out above.
Use and disclosure of personal information by Clubshop
If Clubshop uses or discloses your personal information for a purpose (secondary purpose) other the main reason for which it was originally collected (primary purpose), to the extent required by the Protection of Personal Information Act, we will ensure that:
- the secondary purpose is related to the primary purpose of collection (and directly related in the case of sensitive information), and you would reasonably expect that Clubshop would use or disclose your information in that way;
- you have consented to the use or disclosure of your personal information for the secondary purpose;
- the use or disclosure is required or authorised by or under law; or
- the use or disclosure is otherwise permitted by the Protection of Personal Information Act (for example, as a necessary part of an investigation of suspected unlawful activity).
How might we contact you?
We may contact you in a variety of ways, including by post, email, SMS, telephone call or facsimile.
We will not send you any commercial electronic messages such as SMSs or emails unless this is permitted by the Electronic Communications and Transactions Act (for example, if we have your express or inferred consent to do so). Any commercial electronic message that we send will identify Clubshop as the sender and will include our contact details. The message will also provide an unsubscribe facility. If you do not wish to receive commercial electronic messages from us, please let us know (our contact details are provided at the end of this policy).
Data quality and security
To the extent required by the Protection of Personal Information Act, Clubshop will take reasonable steps to:
- make sure that the personal information that we collect, use and disclose is accurate, complete and up to date;
- protect the personal information that we hold from misuse and loss and from unauthorised access, modification or disclosure; and
- destroy or permanently de-identify personal information that is no longer needed for any purpose that is permitted by the Protection of Personal Information Act.
Clubshop will generally provide individuals with the option of not identifying themselves when entering into transactions when it is lawful and practicable to do so.
Transfer of personal information overseas
If Clubshop transfers your personal information outside South Africa, we will comply with requirements of the Protection of Personal Information Act that relate to transborder data flows.
Access and correction of your personal information
Please contact Clubshop if you would like to access or correct the personal information that we hold about you. Clubshop will generally provide you with access to your personal information (although a fee may be imposed), and will take reasonable steps to amend any personal information that is incorrect. In some circumstances, Clubshop may not permit access to your personal information, or may refuse to correct your personal information, in which case we will provide you with reasons for this decision.
Please contact us if you have any queries about the personal information that Clubshop holds about you or the way we handle that personal information. Our contact details for privacy queries are set out below.
ERICAN 717-27 (Pty) Ltd
165 Upper Canterbury
Email : firstname.lastname@example.org
Please contact the Clubshop Privacy Officer using the above details if you have any concerns or complaints about the manner in which your personal information has been collected or handled by Clubshop.
What personal information does Clubshop collect?
Personal information is information or an opinion, in any form and whether true or not, about an individual whose identity is apparent or can reasonably be ascertained from the information or opinion. Examples include an individual's name, address, contact number, date of birth and email address.
The type of personal information we collect about you will depend on how you use this website. For example, personal information is collected when you:
- register on this website to become a member
- post a comment in one of our forums
- submit an article, video or product review to be uploaded to this website
- send a message to another Member using the direct messaging function
- respond to one of our product surveys
- enter a competition or participate in a promotion or
- register or subscribe for, or contribute content to, any other services available through this website from time to time.
We may also keep records of any other interactions you have with us (for example, emails or other correspondence you send via this website), together with any other information that you choose to provide to us.
In some circumstances, we may collect sensitive information about you (for example, if you post a comment in a forum about your health). We will not do this unless you have consented to the collection, or if we are otherwise required or authorised to do so by or under law. Sensitive information includes (for example) health information and information about a person's racial or ethnic origin, political opinions, religious beliefs, professional or trade association membership, sexual preferences and criminal record.
If you do not provide us with the personal information that we request, we may not be able to provide you with some of our products and services (except in cases where we have indicated that the provision of that information is optional). For example, if you do not register as a Member, you will not be able to access pages of this website or other services that are reserved for Members only.
Providing us with personal information about others
How do we collect personal information?
We will generally collect personal information directly from you, through this website. We may also collect personal information:
- from you over the telephone, or through written correspondence (such as letters and emails) and
Collection of information other than personal information
Some of the information that is collected about your visit to this website is not personal information, because it does not reveal your identity. For example, we may record your server address, the date and time of your visit, the pages you viewed, any documents you downloaded and the type of browser and operating system you used.
If collected, this information will be used and disclosed by Clubshop in anonymous, aggregated form only, for purposes including statistical analysis and web site development. You are not individually identified, however Clubshop reserves its right to use or disclose this information to try to locate an individual where we reasonably believe that the individual may have engaged in any unlawful or inappropriate activity in connection with our website, or where we are otherwise required or authorised by law to do so.
We may also allow third parties that publish advertisements on our website to place and access cookies on your computer and use the information from those cookies to tailor the advertisements that you see while browsing online with your interests.
Most internet browsers are set to accept cookies. If you prefer not to receive them, you can adjust your internet browser to reject cookies, or to notify you when they are being used. There are also software products available that can manage cookies for you. If you disable cookies, we may be not be able to optimise your visit to this website and certain features may not be available.
Why does Clubshop collect personal information?
Clubshop uses the personal information it collects through this website for the purposes for which it was provided and for any other purposes explained at the time of collection or in any additional terms and conditions applicable to the particular feature of the website, including:
- to operate this website, including through the publication of forums, articles, videos and reviews
- to conduct competitions and promotions
- to provide customer support for Members
- to respond to questions and requests
- to tailor the advertising that is presented to you on this website and the product and service information that we may send you (see below), for example, by providing you with product information relevant to the preferences or opinions that you
- have expressed in your responses to our surveys
- to conduct research and development
- Where applicable, to investigate an Adverse Event (AE), which is any untoward medical occurrence in person administered a product and which does not necessarily have to have a causal relationship with this treatment.
- for other purposes required or authorised by or under law, including purposes for which you have provided your express or implied consent.
Public Material posted by Members
Some of the services offered through this website allow Members to submit, upload, post or transmit content or material such as text, photos, images, audio and video (including links to content or material) that may be accessed and viewed by the general public on the internet (Public Material). Members acknowledge that anything they post onto this website may appear elsewhere on the internet and may remain on the internet after their membership has ended, and accept that Clubshop cannot guarantee that the Public Material will not appear elsewhere, be copied, downloaded or used otherwise. If Members have any concerns about their personal information being published in this way, they are advised to remove any personal information from the Public Material they post, or not to use these services.
Product and service offers
If you are a Member, we may (unless you opt out of receiving any or all of these communications in your member profile page) use your personal information to:
- send you news, product information and promotional offers from Clubshop and selected third party businesses whose products or services we think may be of interest to you (Promotional Partners)
- invite you to participate in product surveys and promotions and
- send you product samples and ask for your feedback.
We may send this information to you in a number of ways, including by post, email, SMS and MMS. You can let us know at any time if you no longer wish to receive these communications by updating the relevant details in your member profile page. When sending product and service offers to you, we will also let you know how you may opt out of receiving such communications in future. Your consent to receiving these communications will remain current until you advise us otherwise.
We will not send you any commercial electronic messages such as SMSes or emails unless this is permitted by the Electronic Communications and Transactions Act. Similarly, we will not call you on a number listed on the Do Not Call Register unless this is permitted under the Do Not Call Register Act and related instruments.
When do we disclose personal information to third parties?
We may disclose your personal information:
- for the purpose for which that personal information was collected and
- for the purposes set out under heading 3 above.
Personal information may be disclosed (and may be transferred overseas) for these purposes to:
- the general public (both in South Africa and overseas), by publication of this website on the internet
- companies and organisations within Clubshop’s group of companies
- to our Promotional Partners (for example, to enable them to send product samples or material requested by Members on this website directly to those Members or for reporting of Adverse Events)
- Clubshop’s contracted service providers, which may include:
◦ website development, information technology and security providers
◦ database management and data processing analysts
◦ creative, promotional and market research agencies
◦ mailing houses, freight and courier service providers and
◦ external business advisors (such as accountants, auditors, recruiters and lawyers).
Disclosure of information other than personal information
Some of the information that we disclose to third parties is not personal information, although it may have been compiled (in part) from information that you have provided to us. For example:
- if you have participated in one of our product surveys, we may disclose the results of that survey to our Promotional Partners, but only in aggregated, anonymised form, which does not reveal the identity of particular respondents
Links to third party websites
Links to other websites are provided for your convenience. We are not responsible for the privacy practices of those sites, and you should review their privacy policies before supplying any personal information to them.
Quality and security of personal information
We rely on the personal information we hold in conducting our business. We take reasonable steps to ensure that the personal information we collect, use and disclose is accurate, complete and up to date. You can help us, by letting us know about any changes to your personal information, such as email address or phone number. Our contact details are provided under the heading “contacting us”.
With the exception of personal information contained in Public Material, Clubshop strives to protect the personal information and privacy of website users. However, we cannot guarantee the security of any information that you disclose online and you disclose that information at your own risk. If you are concerned about sending your information over the internet, you can contact Clubshop by telephone or e-mail (our details are provided under “contacting us”.
You can also help to protect the privacy of your personal information by keeping passwords secret and by ensuring that you log out of the site when you have finished using it. In addition, if you suspect any security breach, please let us know immediately.
Access and correction
Please contact us if you would like to access or correct the personal information that we hold about you. We will generally provide access or make corrections, subject to some exceptions permitted by law. We may charge a fee to cover our costs of providing access to you.
If you have any questions about your privacy, or if you would like to access or correct the personal information that we hold about you, please email us at email@example.com .
Updated June 2018