Privacy Policy
Last updated 31 July 2026
This Privacy Policy forms part of, and should be read together with, our Terms of Service.
INTRODUCTION
This Privacy Policy (“Policy”) governs the Processing of Personal Information and/or Personal Data by Agile Africa (“We”, “Us”, “Our”, “Ourselves”) in accordance with Applicable Data Protection Laws and in connection with Our Platform which is located on Our Website. The Data Subject’s (“You”, “Your”, “Yourself/ves”) use of the Platform is subject to this Policy and the Terms of Service which are incorporated by reference into this Policy. In general, by accessing and using the Platform, You signify Your Consent to Us Processing Your Personal Information and/or Personal Data in accordance with this Policy.
We believe that meaningful human connections are built on trust. Protecting Your Personal Information and/or Personal Data is not simply a legal obligation, it is fundamental to the confidence You place in Our Platform. We are committed to maintaining Your trust by handling Your Personal Information and/or Personal Data with integrity, accountability and transparency. We undertake to ensure that all Personal Information and/or Personal Data entrusted to Us is collected, used, disclosed, stored and otherwise Processed lawfully, responsibly and securely, while maintaining its confidentiality, integrity and availability through appropriate technical and organisational safeguards. We remain committed to making thoughtful, privacy-conscious decisions that respect Your rights as a Data Subject, support meaningful engagement, and reflect Our ongoing commitment to responsible data stewardship. Accordingly, We encourage You to read this Policy carefully and contact Us with any questions or concerns in regard to Our privacy practices.
We may amend this Policy at any time. All amended terms shall be effective immediately upon the posting of the revised Policy on the Platform and any subsequent activity in relation to Our Platform shall be governed by such amended terms and conditions.
If You do not agree with any terms in this Policy, please do not use the Platform. Alternatively, please contact our Information Officer and/or Data Protection Officer at legal@agileafricaventrues.com
This Policy was last revised on 31 July 2026.
You are advised to regularly visit Our Key Updates page to review any amendments or updates to this Policy.
For enquiries, contact Our Information Officer and/or Data Protection Officer.
1. APPLICABILITY
We respect Your rights to responsible management of Your Personal Information under the Protection of Personal Information Act 4 of 2013 (“POPIA”) where you are a resident of South Africa, Your Personal Data under the General Data Protection Regulation (“GDPR”) where you are a resident of the European Union, and where applicable, the relevant Applicable Data Protection Law in Your specific jurisdiction. For the purposes of this Policy and interpreting the applicable provisions to you:
• Part A addresses POPIA and is applicable to Users living in the Republic of South Africa or who are South African citizens living outside the Republic of South Africa;
• Part B addresses other Applicable Data Protection Laws and is applicable to Users residing in various jurisdictions worldwide.
• Part C addresses the general clauses applicable to all Users who access Our Platform.
2. GENERAL DEFINITIONS
2.1. “Account” means the personal Profile created by a User which allows him/her to access and use the Platform.
2.2. “Administrator” means any duly authorised person who has been appointed by Agile Africa Ventures (Pty) Ltd to run and manage the day-to-day operations of the Platform and to liaise with the Users who utilise the Platform.
2.3. “Aggregation/Aggregated” shall mean the process of combining, summarizing, or grouping Data or information from multiple Users to create a summarised and anonymised dataset which includes key metrics, trends, themes, insights, or patterns derived from individual User Data without revealing any Personal Information and/or Personal Data. Such dataset shall be used by Us to inform Our research, Platform development and improvement, and to draft progress reports to track Our progress with Our business objectives and goals.
2.4. “Artificial Intelligence (AI)” means any computer-based system, software, model, tool, feature or technology that uses data, algorithms, machine learning, statistical modelling, natural-language processing, computer vision, automated reasoning, predictive analytics or similar techniques to generate, infer, classify, recommend, optimise, identify patterns, create content, support decisions or otherwise produce outputs that may influence a process, service or outcome. For purposes of this Privacy Policy, AI includes both AI developed, operated or deployed by Us as the Platform owners and AI-enabled services, tools or systems provided by approved Third Party service providers that Process Personal Information and/or Personal Data in connection with Our Services.
2.5. “Agile Africa Ventures (We, Us or Our)” means Agile Africa Ventures (Pty) Ltd, a private company registered in terms of the company laws of the Republic of South Africa, situated at 10 Gregory Close, 19 Gregory Avenue, Melrose North, Gauteng, 2196.
2.6. “Cookies” means the small text files that are downloaded onto the User’s device when he/she accesses and uses Our Platform.
2.7. “Content” means including but not limited to any audio, blogs, data, figures, illustrations, images, information, interactive features, text, resources, User testimonials, videos, PDFs in whole or in part housed or contained, displayed, provided, or otherwise made available on or through the Platform by Us.
2.8. “Data” means facts, figures, or any other information that is collected from Users, Processed, and used for Our business objectives.
2.9. “Employees” means any person employed by Us to render the Services and who is entitled to receive remuneration.
2.10. “Electronic Signatures” means data attached to, incorporated in, or logically associated with other Data and which is intended by the User to serve as a signature, as defined in the Electronic Communications and Transactions Act, 2002 ("ECTA") and/or any other applicable law in User’s jurisdiction.
2.11. “Fees” means any transaction-based fees, service fees, or other charges payable by Users to Us for utilising the Platform and associated Services.
2.12. “Mobile Application” means the software application (Platform) made available by Us for installation and download on Your mobile device through Your official application store.
2.13. “Newsletter” means Our periodic communication that is distributed to Our Users electronically via email and/or WhatsApp which contains updates, announcements, news, events, resources and other relevant information related to Our Services.
2.14. “Platform” means the DMC application, which is a digital Content-sharing and communication platform that enables Users to create, upload, share, store, and interact with audio, video, text, and other digital Content within private or group-based environments.
2.15. “Process/Processing” means any operation or set of operations which is performed upon Personal Information and/or Personal Data, whether or not by automatic means, such as collection, recording, organisation, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, blocking, erasure, or destruction of information.
2.16. “Services” means all services, features, and functionalities made available on or through the Platform, including the ability to create, upload, record, share, store, organise, access, and interact with audio, video, text, and other digital Content, as well as any related tools, communications, and support provided to Users.
2.17. “Social Media Pages” means Our official profiles and/or accounts on various social media platforms such as Facebook, Instagram, LinkedIn, TikTok, YouTube and X which We use to engage with Our Users, share Content, promote Our Services and build brand awareness.
2.18. “Subscription” means any enhanced or paid features, functionalities, or Services offered on the Platform for a Fee.
2.19. “Third Party/Parties” means any other natural or juristic person that is not You, the User, or Ourselves.
2.20. “User, You, Yourself/ves” means any natural who uses Our Platform for informational purposes and to receive the Services, and this shall include Children.
2.21. “User-Generated Content” means any content, information or material that is created, uploaded, submitted, transmitted, shared, recorded, published or otherwise made available by or on behalf of a User through the Platform, including text, messages, comments, photographs, images, audio recordings, video recordings, live streams, and any other digital content.
2.22. Website” means the Platform’s website located at www.thedmcapp.com and is owned by Agile Africa (Pty) Ltd and shall serves as the primary online portal where We shall market, promote and provide information about Our Services, the Platform and its related features.
3. WHO ARE WE
3.1. Agile Africa is a private owned company registered and incorporated in terms of the laws of the Republic of South Africa. We are a mobile software development company specialising in the design, development, and deployment of community-centric digital platforms that foster meaningful human connection, collaboration, and engagement through technology. As part of Our product offering, We have developed the DMC application (“Platform”) which is designed to enable Users to build and maintain meaningful relationships through structured and intentional communication. The Platform allows Users to create private groups with selected contacts, within which they can record, upload, share, and access audio and video updates in the form of episodic User-Generated Content, facilitating deeper and more consistent engagement between individuals, families, and communities.
3.2. The Platform is designed to move beyond traditional social media interactions by prioritising authentic connection, ongoing communication, and the preservation of meaningful moments through structured User-Generated Content sharing. Users are able to organise their interactions through group-based environments, access historical User-Generated Content, and engage with other Users through features that support reflection, continuity, and relationship-building. Our Platform is currently available to Users through the Mobile Application.
3.3. The Platform collects and Processes Personal Information and/or Personal Data of its Users. The Processing of all Personal Information and/or Personal Data is conducted in accordance with this Privacy Policy.
3.4. We do not collect Special Personal Information and/or Sensitive Data of Our Users for purposes of providing the Services.
4. PRIVACY BY DESIGN AND BY DEFAULT DECLARATION
4.1. Privacy is a fundamental consideration in the design, development, and ongoing improvements of Our Platform and is embedded in Our Platform features. Where appropriate, We undertake privacy impact assessments and other risk-based reviews before introducing new features, technologies, integrations or material changes to the Platform that may involve the collection, use, disclosure or other Processing of Personal Information and/or Personal Data to ensure that such Personal Information and/or Personal Data is processed lawfully and responsibly, and to determine whether additional technical and organisational measures are required before implementation.
4.2. We regularly review and enhance Our Platform and Services to reflect technological developments, evolving privacy risks, changes in the Applicable Data Protection Laws and regulatory guidance, industry standards, and the reasonable expectations of Our Users. Where appropriate, We shall implement privacy-enhancing technologies and other protective mechanisms designed to reduce privacy risks and promote the responsible stewardship of Personal Information and/or Personal Data throughout its lifecycle.
4.3. Our commitment to ‘Privacy by Design and by Default’ for the Platform extends beyond legal compliance. It reflects our ongoing commitment to developing a Platform that enables Users to build meaningful human connections and engage with confidence, knowing that respect for privacy forms an integral part of how We design, operate and continually improve Our Services.
5. RESPONSIBLE ARTIFICIAL INTELLIGENCE DECLARATION
5.1. Our Platform does not use AI to Process Personal Information and/or Personal Data, make decisions about Users, generate Content, profile individuals, or otherwise provide AI-powered functionalities as part of Our Services. However as Our Platform continues to evolve, We may introduce AI-enabled tools or features to enhance the User experience, improves the efficiency, accessibility or security of Our Services, or supports other legitimate business purposes. In the event that We introduce AI functionalities that involves the Processing of Personal Information and/or Personal Data, We are committed to doing so responsibly, transparently and in accordance with Applicable Data Protection Laws.
5.2. Before deploying any AI-enabled functionality that Processes Personal Information and/or Personal Data, We undertake to conduct the appropriate privacy, security, ethical and governance assessments to evaluate potential AI risks and determine appropriate safeguards to put in place. Where AI features are introduced, We will explain:
5.2.1. the AI functionality being used and the purpose for which it is deployed;
5.2.2. the types of Personal Information and/or Personal Data being Processed by the AI functionality;
5.2.3. whether Personal Information and/or Personal Data is used to develop, improve or train AI models and, where applicable, the legal basis or consent mechanism relied upon;
5.2.4. circumstances in which Personal Information and/or Personal Data will not be used for AI training or model development;
5.2.5. the technical and organisational measures in place to promote security, privacy, fairness, accountability and responsible use of AI; and
5.2.6. the rights available to Users under applicable laws in relation to the AI-enabled functionalities.
5.3. We shall not deploy AI merely because it is technologically available, it will only be made available where it delivers genuine value, is consistent with Our organisational values, and can be supported by appropriate governance, transparency, security, human oversight and responsible data management practices. We will continue to review emerging technologies and evolving regulatory expectations to ensure that any future use of AI remains aligned with our commitment to protecting the privacy, rights and legitimate interests of Our Users.
5.4. We will update this Privacy Policy and any other relevant notices to provide Users with clear and meaningful information regarding the use of AI when they access and use Our Platform.
PART A: THE PROTECTION OF PERSONAL INFORMATION ACT, 2013
Part A is only applicable to Users who are South African citizens or resident in South Africa.
1. POPIA DEFINITIONS
1.1. “Binding Corporate Rules” means the set of internal rules adopted by multinational companies to allow the transfer of Personal Information and/or Personal Data across borders within the organisation to ensure adequate protection of Personal Information and/or Personal Data.
1.2. “Child/Children” means a natural person under the age of 18 years who is not legally competent, without the assistance of a Competent Person, to take any action or decision in respect of any matter concerning him- or herself.
1.3. “Competent Person” means any person who is legally competent to Consent to any action or decision being taken in respect of any matter concerning a Child which may include a parent or legal guardian.
1.4. “Consent” means any voluntary, specific, and informed expression of will in terms of which You give Your permission to Us to Process Your Personal Information in accordance with Our Terms of Service and this Privacy Policy.
1.5. “Data Subject” means the person who owns the Personal Information that is to be Processed by Us when they use Our Platform.
1.6. “De-identify” means to delete any information in a way that prevents all ways that re-identifies the Data Subject; can be used or manipulated by a reasonably foreseeable method to identify the Data Subject; or can be linked by a reasonably foreseeable method to other information that identifies the Data Subject.
1.7. “Information Officer" means in the case of a juristic person: the chief executive officer or equivalent officer of the juristic person or any person duly authorised by that officer; or the person who is acting as the head of the juristic person or any person duly authorised by such acting person.
1.8. “Operator” means the natural or juristic person who Processes Personal Information on behalf of a Responsible Party in terms of a contract or mandate, without coming under the direct authority of the Responsible Party.
1.9. “Personal Information” means information relating to an identifiable, living, natural person and where it is applicable, to an identifiable, existing juristic person, including but not limited to:
1.9.1. information relating to race, gender, sex, pregnancy, marital status, national, ethnic, or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language, and birth of the person;
1.9.2. information relating to the education or the medical, financial, criminal or employment history of the person;
1.9.3. an identifying number, symbol, email address, physical address, telephone number, location information, online identifier, or other particular assignment to the person;
1.9.4. the biometric information of the person;
1.9.5. the personal opinions, views, or preferences of the person;
1.9.6. correspondence sent by the person that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence;
1.9.7. the views or opinions of another individual about the person; and
1.9.8. the name of the person if it appears with other Personal Information relating to the person or if the disclosure of the name itself would reveal information about the person.
1.10. “Record” means recorded information, in any form, including Personal Information in computer systems, created, or received and maintained by the Responsible Party in the course of its official duties and kept as evidence of such activity.
1.11. “Responsible Party” means a public or private body or any other person which alone or in conjunction with others, determines the purpose and means for Processing Personal Information. For the purposes of this Policy, We are the Responsible Party in relation to Personal Information You submit through the Platform.
1.12. “South African Information Regulator” means the independent body established under the Protection of Personal Information Act (POPIA) in South Africa whose mandate is to monitor and enforce compliance with the Protection of Personal Information Act, 2013.
1.13. “Special Personal Information” means special personal information as defined by the Protection of Personal Information Act, 2013.
2. PERSONAL INFORMATION
2.1. The Platform collects and Processes the Personal Information of its Users for the purposes listed in clause 2.4 below.
2.2. It is the duty and responsibility of the Responsible Party (Us) to direct the Users to the terms and conditions of this Privacy Policy.
2.3. Consent For Collection and Processing
2.3.1. By submitting Your Personal Information when accessing or otherwise using the Platform, You agree to the terms and conditions of this Policy. You hereby expressly Consent to the Processing of Your Personal Information in accordance with this Policy.
2.3.2. You understand that Your Consent to the Processing of Your Personal Information by Us relates strictly to the purposes specified below in clause 2.4.
2.3.3. By using Our Platform, You represent and warrant that You are 18 years of age or older. Our Platform is not intended for use by Children. If You are a Child, You undertake to obtain Your Competent Person’s Consent before registering an Account in order to access and use Our Platform.
2.3.4. We encourage Competent Persons to monitor the online activities of their Children at all times, however, if as a Competent Person becomes aware that their Child has provided their Personal Information to Us without the Competent Person’s Consent, the Competent Person is required to contact Our Information Officer in order to exercise any of Your Data Subjects’ rights listed in clause 7 below.
2.3.5. Should We become aware that We have collected and Processed the Personal Information of a Child without the Competent Person’s Consent, We will take reasonable steps to either alert that Child’s Competent Person about such findings or permanently delete that Personal Information which will result in Us de-activating that specific Account.
2.3.6. You warrant that the Personal Information submitted on Our Platform relates to You and not to a Third Party. Where You submit the Personal Information of a Third Party, You warrant that You are legally entitled to do so.
2.3.7. You expressly Consent to Us keeping Your Personal Information once Your relationship with Us has been terminated for Aggregate, statistical or historical purposes. Such Personal Information will be De-identified and cannot be used to identify You personally.
2.3.8. In the event that You wish to revoke Consent pertaining to Your Personal Information and You would like Us to delete Your Personal Information, You are encouraged to contact Our Information Officer whose role and contact details are set out in clause 7 below.
2.4. Purpose For Collection and Processing
2.4.1. We primarily Process Your Personal Information collected or received from You for the following purposes:
2.4.1.1. To inform You about and/or market Our Services and other related activities;
2.4.1.2. To respond to any queries submitted by You either through Our WhatsApp line or sent by You over email;
2.4.1.3. To provide Our Services to You;
2.4.1.4. To enable other Users are able to identify You when You are using the Platform for purposes of ensuring that they are communicating and engaging with the correct individual;
2.4.1.5. On-going User profile management, including but not limited to creating and maintaining Your Account, updating and correcting Your profile information, managing Your Account preferences and privacy setting, preventing impersonation and/or fraudulent activity, and ensuring accurate administration and operation of the Platform;
2.4.1.6. To operate, maintain and improve Our Service offerings through requesting feedback from You and through the information We obtain from Our tracking technologies;
2.4.1.7. To comply with the law, specifically in response to a demand from government authorities where such demand meets the legal requirements; and
2.4.1.8. To achieve other purposes as authorised or required by law (e.g., to prevent a threat to life, health, or safety, or to enforce Our legal rights).
2.5. We expressly acknowledge and undertake that we do not use any Personal Information for any other purposes not described above.
3. WHAT WE COLLECT AND HOW
3.1. We may collect, Process, and retain certain Personal Information from You in connection with Your use of the Platform. We only collect Personal Information in the following ways:
3.1.1. When You visit Our Website for informational purposes;
3.1.2. When You create an Account on Our Platform in order to obtain Our Services;
3.1.3. When You send Us a WhatsApp message;
3.1.4. When You subscribe to our Newsletter;
3.1.5. When You interact with Us on any of Our Social Media Pages; and
3.1.6. When You send an email to Us or call Us.
3.2. We collect the following Personal Information:
3.2.1. When You visit Our Website for information purposes:
3.2.1.1. Your internet protocol (“IP”) address;
3.2.1.2. Your browser type and version;
3.2.1.3. Your operating system name and version;
3.2.1.4. Date of Your visit to Our Website;
3.2.1.5. The type of electronic device You are using;
3.2.1.6. Your location information; and
3.2.1.7. Your online behaviour (e.g., how long You stay on a certain page)
3.2.2. When You create an Account on Our Platform in order to obtain Our Services:
3.2.2.1. Your name;
3.2.2.2. Your surname;
3.2.2.3. Your email address;
3.2.2.4. Your mobile number;
3.2.2.5. Your date of birth;
3.2.2.6. Your profile picture;
3.2.2.7. Your payment and billing information in instances where You use Our Platform under a Subscription basis; and
3.2.2.8. Your User-Generated Content.
3.2.3. When You call Us, send Us a WhatsApp message, communicate with Us via Our Social Media Pages, or send an email to Us:
3.2.3.1. Any Personal Information that may be contained in Your email or other communications with Us.
3.3. We do not knowingly collect or Process Personal Information of Data Subjects under the age of 18 without the respective Data Subject’s Competent Person’s Consent.
4. ACCURACY
4.1. You agree that any and all Personal Information that You provide to Us is accurate, full and up to date. In the event that Your Personal Information contains any errors or inaccuracies, You agree to indemnify and hold Us, Our officers, directors, employees, agents, members, and service providers harmless from and against any claims, damages, actions, and liabilities, including without limitation: loss of profits, direct, indirect, incidental, special, consequential, or punitive damages arising out of Our reliance on such Personal Information.
4.2. You agree to let Us know immediately if You become aware that Your Personal Information has been provided to Us by a Third Party without Your Consent or if You did not obtain Consent before providing a Third Party's Personal Information to Us.
5. PROCESSING OF PERSONAL INFORMATION
5.1. We will only Process Your Personal Information where:
5.1.1. You have Consented to such Processing (which Consent may be withdrawn at any time by sending an email to Our Information Officer. Kindly refer to clause 7 below);
5.1.2. The Processing is necessary to provide the Platform and related Services to You;
5.1.3. The Processing is necessary for the conclusion or performance of a contract between Us and You;
5.1.4. The Processing is necessary for compliance with Our legal obligations; and/or
5.1.5. The Processing is necessary to protect Your legitimate interests or to pursue Our legitimate interests or those of any Third Party recipients that may receive Your Personal Information.
6. DISCLOSURE OF PERSONAL INFORMATION
6.1. We may disclose Your Personal Information to:
6.1.1. Our Employees who fulfil requests by You, and/or otherwise provide information or technical support as and when requested in the event of You encountering any troubleshooting problems related to operating the Platform;
6.1.2. Our Administrator who manages Our Platform;
6.1.3. Our Third Party service providers including without limitation, internet service providers and payment gateways to assist You when you have troubleshooting problems related to operating the Platform; and
6.1.4. Any organisation for any authorised purpose with Your express Consent.
6.2. We may share De-identified Personal Information with Third Parties for research, statistical analysis, Service improvement, product development, innovation, performance optimisation, business intelligence, strategic planning and other legitimate business purposes.
6.3. We may further disclose Your Personal Information under the following circumstances:
6.3.1. To comply with the law or with legal process;
6.3.2. To protect and defend Our rights, equipment, facilities, and other property; and
6.3.3. To protect Us against misuse or unauthorised use of the Platform;
6.4. We will not disclose Your Personal Information to any Third Parties other than Our Operators who are authorised to Process Your Personal Information on Our behalf. Any other disclosure of the Personal Information that You Provide to Us may only be done in accordance with Applicable Data Protection Laws.
7. OUR INFORMATION OFFICER AND YOUR RIGHTS
7.1. The Protection of Personal Information Act places a duty on Us to appoint an Information Officer whose contact details are as follows:
Email Address: legal@agileafricaventures.com
Contact Number: +27 10 203 9052
7.2. The Information Officer’s duties under the Applicable Data Protection Laws are:
7.2.2. Liaising with You when You have a question about Your Personal Information;
7.2.3. Assisting You with any requests and enforcing Your rights in respect of Your Personal Information;
7.2.4. Making sure that We are compliant with the Applicable Data Protection Laws and that We Process Your Personal Information in accordance with this Policy.
7.3. You may choose when You wish to provide Your Personal Information to Us. You also have the right to withdraw Your Consent at any time. However, if You choose not to provide certain details, or if You withdraw Your Consent, Your experience with some, or all of the Platform features and/or Our Services, may be affected.
7.4. To the extent provided for in law, You have certain rights in respect of Your Personal Information, in particular:
7.4.1. Withdrawal of Consent: You may withdraw Your Consent at any time by sending a written request to Our Information Officer. Upon receiving notice that You have revoked Your Consent, We will stop using Your Personal Information within a reasonable time, which will vary depending on what information We have collected and for what purpose. We will send You a confirmation email stating same.
7.4.2. Access or Obtain a Copy of Your Personal Information: You have the right to examine any of Your Personal Information that We collect. Should You wish to examine the Personal Information We hold about You, or obtain a copy thereof, please send a written request to Our Information Officer. As per the Promotion of Access to Information Act, 2000, We may charge a nominal fee should You request any physical copies or Records.
7.4.3. Update, Modify, Rectify, Erase: You may request Us to update, modify, rectify, or erase the Personal Information that We hold on You, by emailing Our Information Officer; and
7.4.4. Object: You have the right to object to the Processing of Your Personal Information or restrict Us from using any of the Personal Information which We hold on You, including by withdrawing any Consent You have previously given to the Processing of such information. In this regard You may email Our Information Officer. We will send You a confirmation email stating that We have ceased Processing Your Personal Information.
7.5. These rights are not absolute, and We therefore reserve the right to refuse any requests in terms of the above-mentioned rights, for any reason permitted under the Applicable Data Protection Laws.
7.6. Furthermore, You also have the right to lodge a complaint with the South African Information Regulator.
8. SECURITY OF PERSONAL INFORMATION
8.1. We are committed to and will implement and maintain reasonable and appropriate technical and organisational measures to safeguard any Personal Information provided to Us from accidental or unlawful destruction, loss, or alteration, as well as the unauthorised disclosure of, or access to, Personal Information transmitted, stored, or otherwise Processed.
8.2. We review Our information security programme regularly, having regard to recognised industry standards and security best practices, to ensure that all evolving threats, technological developments and operational risks are addressed and improved when required.
8.3. We use reputable Third Party service providers whose infrastructure and/or services are designed and operated in accordance with recognised information security standards and certifications appropriate to the services they provide
8.4. To make sure Your Personal Information is secure, We communicate Our privacy and security guidelines to Our Employees and strictly enforce privacy safeguards within the company.
8.5. NOTWITHSTANDING THE ABOVE, IT IS EMPHASISED THAT EVEN THOUGH WE HAVE TAKEN SIGNIFICANT STEPS TO PROTECT YOUR PERSONAL INFORMATION, YOU ACKNOWLEDGE AND UNDERSTAND THAT NO COMPANY, INCLUDING OURSELVES, CAN FULLY PROTECT AGAINST SECURITY RISKS ASSOCIATED WITH THE PROCESSING OF PERSONAL INFORMATION ONLINE.
9. SECURITY INCIDENTS
9.1. We take the security of Your Personal Information seriously and maintain internal processes designed to identify, assess, manage and respond to actual or suspected unauthorised access to, disclosure of, loss of, destruction of, alteration of, or compromise of Personal Information.
9.2. Where We become aware of a security compromise and/or data breach involving Your Personal Information, We will take reasonable steps to investigate the incident, contain and mitigate any potential harm, assess the nature and scope of the affected information, and determine whether notification is required under POPIA. Where required, We will notify the South African Information Regulator and affected Users and/or Data Subjects as soon as reasonably practicable. Any notification provided to affected Users may include, where appropriate and available, a description of the incident, the categories of Personal Information affected, the possible consequences of the breach, the measures taken or proposed to address the breach, steps Users may take to protect themselves, and contact details for further information.
9.3. We may provide such notification by email, in-app notice, public communication, or any other appropriate method, having regard to the nature of the breach, the information affected, the urgency of the circumstances and applicable legal requirements.
9.4. Where a Third Party service provider notifies Us of a security compromise affecting Personal Information processed on Our behalf, We will take reasonable steps to assess the incident, coordinate an appropriate response with the Third Party service provider, and provide any notifications required under POPIA.
9.5. We will also take reasonable steps to review the circumstances of the incident and, where appropriate, improve Our technical, organisational and governance safeguards to reduce the risk of similar incidents occurring in future.
10. RETENTION OF PERSONAL INFORMATION
10.1. We retain Your Personal Information for the period necessary to fulfil the purposes outlined in this Policy which may include without limitation, maintaining the performance of Our Platform and the related Services, making data-driven business decisions in respect of additional features We may display on Our Platform and any other legitimate business purpose.
10.2. For purposes of this Privacy Policy, all User-Generated Content will generally only be retained by Us for 1 (one) year from the date it was created and all deactivated accounts with all Personal Information including recordings are deleted after 60 (sixty) days, unless a longer retention period is required or permitted by applicable laws, necessary to establish, exercise or defend legal claims, resolve disputes, enforce Our rights and/or that of Third Parties, investigate misuse of the Platform, or otherwise protect Our legitimate interests.
10.3. When retention of the Personal Information is no longer necessary, the information will either be permanently deleted or Aggregated for analytics purposes. We will De-identify Your Personal Information once We no longer require it for the purposes mentioned herein, or as required by law.
11. STORAGE AND TRANS-BORDER FLOW OF PERSONAL INFORMATION
11.1. Your Personal Information is stored on servers inside of South Africa. You hereby provide Us with Your Consent to store Your Personal Information inside of South Africa.
11.2. As an organisation that operates and provides the Services in the Republic of South Africa, when a User chooses to access and use the Services from locations outside the Republic of South Africa, You Consent to the collection, transmission, use, storage and Processing of Your Personal Information in accordance with the local laws in Our jurisdiction.
11.3. We are committed to ensuring the protection of Your Personal Information collected from You. As Our Services cater to Data Subjects across the globe, Your Personal Information, User-Generated Content and other electronic communications may be transmitted to, accessed from, or otherwise processed in countries outside the jurisdiction in which they were originally collected and Processed. We do not, by default, transfer Your Personal Information beyond the borders of South Africa without Your express Consent.
11.4. Where Personal Information is transferred across borders, We will take reasonable steps to ensure that such transfers are carried out in accordance with POPIA and are subject to appropriate contractual, technical and organisational safeguards designed to protect Your Personal Information. To facilitate lawful trans-border flows of Your Personal Information, We employ various mechanisms such as:
11.4.1. Binding Corporate Rules where applicable, to facilitate intra-group transfers.
11.4.2. Concluding data processing agreements with Third Party service providers who assist Us with Our Services worldwide in order to ensure compliance with the Applicable Data Protection Laws.
11.4.3. Implementation of robust technical and organisational measures to protect Your Personal Information during international transfers, including end-to-end encryption, and regular security assessments to prevent unauthorised access, disclosure , alteration or destruction of Your Personal Information.
PART B: APPLICABLE DATA PROTECTION LAWS
Part B is applicable to Users who are citizens or resident in other jurisdictions worldwide.
Part B describes how We collect, Process, store and delete Personal Data via the Platform in accordance with Applicable Data Protection Laws in the jurisdictions where We have Data Subjects accessing and using Our Platform. Where local data protection laws provide additional Data Subject rights or impose stricter requirements, We will comply with those requirements to the extent applicable.
1. APPLICABLE DATA PROTECTION LAWS DEFINITIONS
1.1. “Adequacy Decision Making” means the determination made by the European Commission regarding whether a non- European Economic Area country provides an adequate level of Data protection.
1.2. “Anonymized” means the procedure of Processing Personal Data in such a way that it can no longer be attributed to a specific Data Subject without additional information in accordance with the provisions of Applicable Data Protection Laws so that there is no risk of re-identification. The term “Anonymized” as used in this Terms shall be the specific term used and shall hold the meaning ascribed to it in the Applicable Data Protection Laws, in the event of any conflict between such definitions, the definition most favourable to the protection of the Data Subject shall apply.
1.3. “Applicable Data Protection Laws” means all legislation, regulations or guidance notes in the applicable country, whether promulgated or in draft form, protecting the fundamental rights and freedoms of individuals or juristic persons in respect of their right to privacy and the Processing of Personal Data.
1.4. “Applicable Data Protection Authority” means the regulatory body or bodies responsible for overseeing and enforcing the Applicable Data Protection Laws and safeguarding individuals’ privacy rights in various jurisdictions where Our Users reside or are citizens of.
1.5. “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data; where the purposes and means of such Processing are determined by Union or Member State law, the Controller or the specific criteria for its nomination may be provided for by Union or Member State law. The term “Controller” as used in this Terms shall be the specific term used and shall hold the meaning ascribed to it in the Applicable Data Protection Laws, in the event of any conflict between such definitions, the definition most favourable to the protection of the Data Subject shall apply. Agile Africa is the Controller in this instance.
1.6. “Child/Children” means a natural person under the age of 16 years, or such lower age, below the age of 13 at which he/she may lawfully Consent to the Processing of their Personal Data under the GDPR and applicable Member State law. The term “Child/Children” used in this Terms shall be the specific term used and shall hold the meaning ascribed to it in the Applicable Data Protection Laws, in the event of any conflict between such definitions, the definition most favourable to the protection of the Data Subject shall apply.
1.7. “Consent” means any freely given, specific, informed and unambiguous indication of the Data Subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the Processing of Personal Data relating to him or her. The term “Consent” as used in this Terms shall hold the meaning ascribed to it in the Applicable Data Protection Laws, in the event of any conflict between such definitions, the definition most favourable to the protection of the Data Subject shall apply.
1.8. “Data Protection Officer (DPO)” means the natural person designated by an organisation, where required or voluntarily appointed to advise on, and monitor compliance with Applicable Data Protection Laws, provide guidance on data protection obligations, oversee data protection governance, cooperate with Applicable Data Protection Authorities, and serve as the primary point of contact for Data Subjects on matters relating to the Processing of Personal Data.
1.9. “Data Subject” means the person who is the subject of Personal Data that is being processed by Us in order to provide Our Services.
1.10. “Personal Data” means any information that relates to an identified or identifiable person, whether natural or juristic as the case may be, which includes without limitation names, identification numbers, location data, online identifiers, and factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person as defined in the Applicable Data Protect Law in a specific jurisdiction.
1.11. “Processor” means a natural or legal person, public authority, agency, or other body which Processes Personal Data on behalf of the Controller. The term “Processor” as used in this Terms shall be the specific term used and shall hold the meaning ascribed to it in the Applicable Data Protection Laws, in the event of any conflict between such definitions, the definition most favourable to the protection of the Data Subject shall apply.
1.12. “Sensitive Data” means the category of Data that requires extra protection and handling due to tits nature and the potential harm that may result from its unauthorised access or disclosure including without limitation, biometric Data, health information, religious and/or philosophical beliefs, political opinions, sexual orientation, financial information and Data concerning criminal convictions and offenses. The term “Sensitive Data” as used in these Terms shall be the specific term and hold the meaning ascribed to it in the Applicable Data Protection Laws, in the event of any conflict between such definitions, the definition most favourable to the protection of the Data Subject shall apply.
1.13. “Standard Contractual Clauses” means the established legal tools used to facilitate the transfer of Personal Information and/or Personal Data from the European Economic Areas (EEA) to countries outside the EEA that do not have an adequate level of data protection.
2. PERSONAL DATA
2.1. The Platform collects and Processes the Personal Data of the Users for the purposes listed in clause 2.4 of Part A of this Policy below in accordance with this Privacy Policy.
2.2. It is the duty and responsibility of the Controller to direct the Users to the terms and conditions of this Privacy Policy.
2.3. Consent for Collection and Processing
2.3.1. By accessing, visiting, or otherwise using Our Platform, You agree to the terms and conditions of this Privacy Policy. You expressly Consent to the Processing of Your Personal Data in accordance with this Privacy Policy and the Applicable Data Protection Laws.
2.3.2. You understand that Your Consent to the Processing of Your Personal Databy Us relates strictly to the purposes specified below in clause 2.4 of Part A of this Policy.
2.3.3. By using Our Platform, You represent and warrant that You are 18 years of age or older. Our Platform is not intended for use by Children. If You are a Child, You undertake to obtain Your parent’s and/or legal guardian’s Consent before registering an Account in order to access and use Our Platform.
2.3.4. We encourage parents and/or legal guardians to monitor the online activities of their Children at all times, however, if as a parent and/or legal guardian becomes aware that their Child has provided their Personal Data to Us without their Consent, they are required to contact Our Data Protection Officer in order to exercise any of Your Data Subjects’ rights listed in clause 7 below.
2.3.5. Should We become aware that We have collected and Processed the Personal Data of a Child without the Competent Person’s Consent, We will take reasonable steps to either alert that Child’s Competent Person about such findings or permanently delete that Personal Data which will result in Us de-activating that specific Account.
2.3.6. You warrant that the Personal Data submitted on Our Platform relates to You and not to a Third Party. Where You submit the Personal Data of a Third Party, You warrant that You are legally entitled to do so.
2.3.7. You expressly agree and Consent to Us keeping Your Personal Data once Your relationship with Us has been terminated for Aggregate, statistical or historical purposes. Such Personal Information will be Anonymized and cannot be used to identify You personally.
2.3.8. In the event that You wish to revoke Consent pertaining to Your Personal Data and You would like Us to delete Your Personal Data, You are encouraged to contact Our Data Protection Officer whose role and contact details are set out in clause 12 below.
2.4. Purpose for Collection
2.4.1. We use the Personal Data We collect from You for the reasons listed in clause 2.4 under Part A of this Privacy Policy.
3. WHAT WE COLLECT AND HOW
3.1. We may collect, Process, and retain certain Personal Data from You in connection with Your use of the Platform through the methods listed under clause 3 in Part A of this Privacy Policy in order to provide You with Our Services.
3.2. We do not knowingly collect or Process Personal Data of Data Subjects under the age of 18 without the respective Data Subject’s parent or legal guardian’s Consent.
4. ACCURACY
4.1. You agree that all Personal Data provided to Us is accurate. If any errors or inaccuracies are found, You agree to indemnify and hold Us harmless from any resulting claims or damages arising out of Our reliance on such Personal Data.
4.2. You also agree to inform Us immediately in writing if your Personal Data is shared without Your Consent or if You share a Third Party’s Personal Data without proper Consent.
5. PROCESSING OF PERSONAL DATA
5.1. We will only Process Your Personal Data on the following basis:
5.1.1. Consent - You have provided Us with clear consent to process Your Personal Data by clicking “I Accept” or any other similar wording that signify Your Consent when presented with this Policy and the Terms of Use. Please note that such Consent may be withdrawn at any time by sending an email to Our Information Officer. Kindly refer to clause 11 below);
5.1.2. Contract - The Processing of Your Personal Data is necessary to provide the Platform and Our related Services to You;
5.1.3. Legal obligations – Processing of Your Personal Data is necessary to comply with Our legal obligations under the applicable legislation in Your jurisdiction; and
5.1.4. Legitimate Interest - Processing of Your Personal Data is necessary for the protection of Our and/or Your legitimate interests which includes without limitation responding to Your queries or providing You with the Services.
6. DISCLOSURE OF PERSONAL DATA
6.1. We may disclose your Personal Data to the following natural and/or juristic persons:
6.1.1. Our Employees who fulfil requests by You, or otherwise provide information or technical support to You as and when requested in the event that You encounter any troubleshooting problems related to operating the Platform;
6.1.2. Our Administrator who manages the Our Platform;
6.1.3. Our Third Party service providers including without limitation, internet service providers and payment gateways to assist You when you have troubleshooting problems related to operating the Platform; and
6.1.4. Any organisation for any authorised purpose with Your express Consent.
6.2. We may share Anonymised Personal Data with Third Parties for research, statistical analysis, Service improvement, product development, innovation, performance optimisation, business intelligence, strategic planning and other legitimate business purposes.
6.3. We may disclose Your Personal Data under the following circumstances:
6.3.1. To comply with the law and associated legal processes;
6.3.2. To protect and defend Our rights, equipment, facilities, and other property; and
6.3.3. To protect Us against misuse or unauthorised use of the Website.
6.4. We will not disclose Your Personal Data to any Third Parties other than Our Processors who are authorised to Process Your Personal Data on Our behalf. Any other disclosure of the Personal Data that You Provide to Us, may be done only in accordance with Applicable Data Protection Laws.
7. YOUR RIGHTS
7.1. The Applicable Data Protection Law may afford you the following rights in respect of Your Personal Data:
7.1.1. Access - You may request Us to access Your Personal Data held by Us;
7.1.2. Erasure - You may request Us to delete Your Personal Data that is under Our control;
7.1.3. Inform – You may request Us to inform You how Your Personal Data under Our control is being Processed, including the purposes for Processing, the categories of Personal Data being processed, and any Third Parties with whom the Personal Data may be shared with;
7.1.4. Object - You may object to Us processing Your Personal Data;
7.1.5. Rectify: You may request Us to rectify any errors in Your Personal Data under Our control;
7.1.6. Restrict: You may request Us to restrict the use of Your Personal Data under Our control; and
7.1.7. Portability: You may request Us to transfer Your Personal Data;
7.2. Please note that these rights are not guaranteed or absolute as data protection legislation vary from country to country worldwide, resulting in some countries may have specific requirements or additional rights for Data Subjects. We therefore reserve the right to refuse any requests in terms of the above-mentioned rights, for any reason permitted under the Applicable Data Protection Laws.
7.3. In the event that You wish to enforce any of the above rights, You can request this by emailing Our Data Protection Officer.
7.4. Furthermore, You also have the right to lodge a complaint with the Applicable Data Protection Authority in Your specific jurisdiction. For more information, please directly contact Your local Data Protection Authority.
8. SECURITY OF YOUR PERSONAL DATA
8.1. We implement reasonable technical and organisational measures to protect Your Personal Data from unauthorized access, disclosure, alteration, or destruction in accordance with clause 8 of Part A of this Policy.
9. SECURITY INCIDENTS
9.1. We take the security of Your Personal Data seriously and maintain internal processes designed to identify, assess, manage and respond to actual or suspected unauthorised access to, disclosure of, loss of, destruction of, alteration of, or compromise of Personal Data.
9.2. Where We become aware of a security compromise and/or data involving Your Personal Information, We will take reasonable steps to investigate the incident, contain and mitigate any potential harm, assess the nature and scope of the affected information, and determine whether notification is required under the relevant Applicable Data Protection Law. Where required, We will notify the Applicable Data Protection Authority and affected Users as soon as reasonably practicable, or within such timeframe as may be prescribed by the Applicable Data Protection Laws. Any notification provided to affected Users may include, where appropriate and available, a description of the incident, the categories of Personal Data affected, the possible consequences of the breach, the measures taken or proposed to address the breach, steps Users may take to protect themselves, and contact details for further information.
9.3. We may provide such notification by email, in-app notice, public communication, or any other appropriate method, having regard to the nature of the breach, the information affected, the urgency of the circumstances and applicable legal requirements.
9.4. Where a Third Party service provider notifies Us of a security compromise affecting Personal Data processed on Our behalf, We will take reasonable steps to assess the incident, coordinate an appropriate response with the Third Party service provider, and provide any notifications required under the Applicable Data Protection Law.
9.5. We will also take reasonable steps to review the circumstances of the incident and, where appropriate, improve Our technical, organisational and governance safeguards to reduce the risk of similar incidents occurring in future.
10. RETENTION OF YOUR PERSONAL DATA
10.1. We will retain Your Personal Data only for as long as necessary to fulfill the purposes for which it was collected or as required by law in accordance with clause 10 of Part A of this Policy.
11. STORAGE AND TRANSBORDER FLOW OF YOUR PERSONAL DATA
11.1. Your Personal Data may be stored on servers inside of South Africa. You hereby provide Us with Your Consent to store Your Personal Data inside of South Africa.
11.2. As an organisation that operates and provides the Services in and from the Republic of South Africa, when a User chooses to access and use the Services from locations outside the Republic of South Africa, You Consent to the collection, transmission, use, storage and Processing of Your Personal Data in accordance with the local laws in Our jurisdiction unless if the relevant Applicable Data protection Law has extraterritorial application.
11.3. We are committed to ensuring the protection of Your Personal Data collected from You. As Our Services cater to Data Subjects across the globe, Your Personal Data, User-Generated Content and other electronic communications may be transmitted to, accessed from, or otherwise processed in countries outside the jurisdiction in which they were originally collected and Processed. We do not, by default, transfer Your Personal Data beyond the borders of Your jurisdiction without Your express Consent. As a citizen or a permanent resident of the European Region, the General Data Protection Regulation (GDPR) will apply in terms of how We handle and Process the Personal Data You provide to Us .
11.4. Where Personal Data is transferred across borders, We will take reasonable steps to ensure that such transfers are carried out in accordance with the Applicable Data Protection Laws and are subject to appropriate contractual, technical and organisational safeguards designed to protect Your Personal Data. To facilitate lawful trans-border flows of Your Personal Data, We employ various mechanisms such as:
11.4.2. Standard Contractual Clauses as approved by the relevant authorities in Your jurisdiction to ensure adequate protection for Your Personal Data;
11.4.3. Adequacy Decision Making where We recognise jurisdiction deemed by the relevant authorities to provide adequate protection for Your Personal Data;
11.4.4. Conducting transfer impact assessments; and
11.4.5. The mechanisms mentioned in clauses 11.4.1 – 11.4.3 in Part A of this Policy.
12. FURTHER INFORMATION
12.1. For further information on Our privacy practices and Your rights under the Applicable Data Protection Laws, please contact Our Data Protection Officer who can be reached at legal@agileafricaventures.com.
12.2. We shall endeavour to acknowledge receipt of Your email correspondence within 48 (forty-eight) to 72 (seventy-two) hours of receiving it. Following receipt, We shall take reasonable steps to verify Your identity and, where applicable, Your authority to make the request before taking any action in respect of Your Personal Data.
12.3. We will consider and respond to Your request as soon as reasonably practicable and, where applicable, within the timeframes prescribed by the Applicable Data Protection Laws. Where additional time is reasonably required due to the complexity of the request or the number of requests received, We will notify You accordingly.
PART C – GENERAL INFORMATION
1. USER ANALYTICS AND TRACKING
1.1. We use Google Analytics as a tracking technology to collect information for the purpose of tracking traffic to understand User interaction with Our Website. The information collected is kept confidential. You can find more information on Google Analytics’ privacy policy here.
1.2. Google Analytics may use various Cookies to collect information and report site usage statistics in order for Us to improve Your experience with Our Website through various ways such as recognising Your electronic device when You use Our Platform and related Services, for security purposes, and analysing statistical information about Your use of the Platform in order for Us to continually improve Our Website’s design and functionality. Most browsers allow You to reject Cookies or any other tracking technologies by actively managing the settings on Your electronic device. However, please note that if You choose not to allow certain Cookies through blocking or deleting them, or if You withdraw Your Consent, Your experience with some, or all of Our Website’s features may be affected.
1.3. We collect and use the information as mentioned in this clause for the purposes of administering and improving Our Website and related Services. This information may be shared with Our Administrator to such an extent as it is necessary for them to administer and improve Our Website.
2. THIRD PARTY ACCESS - OUR SOCIAL MEDIA PAGES
2.1. If You choose to engage and/or interact with Us on any of Our official Social Media Pages, channels or accounts hosted on Third Party platforms, You agree and understand that such interactions are also subject to the applicable terms of use, privacy policies and privacy settings of the relevant social media platform. Accordingly, You acknowledge and agree that:
2.1.1. the Personal Information and/Personal Data You voluntarily submit by and through Our Social Media Pages can be read, collected and/or used by other users of these Third Party websites in accordance with Your privacy settings and functionality of the applicable Social Media platform;
2.1.2. the information You voluntarily make available on Our Social Media Page may be collected, copied, shared, reproduced or otherwise used by other Users or Third Parties without Our knowledge or control, and We cannot be held responsible for the actions or privacy practices of such Third Parties; and
2.1.3. where We respond to, acknowledge or otherwise engage with Your posts, comments or messages on Our Social Media Pages, Your social media profile name, username, handle, profile picture or other publicly available account information may be visible to any and all of Our members which constitute Our social media presence and to other users of the relevant social media platform.
2.2. We encourage You not to publish or disclose sensitive Personal Information through public posts or comments on Our Social Media Pages and, where appropriate, to contact Us through private or secure communication channels for matters involving confidential Data.
2.3. You agree that We shall not be held responsible for the Personal Information and/or Personal Data that You choose to submit on Our Social Media Pages. You hereby expressly state that You understand that the social media websites are independently operated and that We are not responsible for such social media websites’ interfaces, privacy or security practices. We encourage You to review the privacy practices and settings of the Social Media Pages with which We may interact with You from time to time to help You understand their applicable privacy notices or policies.
3. MARKETING OUR SERVICES
3.1. Direct Marketing Communications - We may use Your Personal Information and/or Personal Data to provide You with direct marketing communications about Our Services, promotions, and events that may be of interest to You. These communications may be sent via:
a) WhatsApp;
b) Our Social Media Pages, and
c) Email.
3.2. As a User, You have the right to request Us to stop sending You Our marketing communications at any time. This right can be exercised by objecting and/or choosing to opt-out of receiving direct marketing communications from Us by emailing Us Your objection and/or following the instructions provided by Us of how to unsubscribe or opt-out from Our direct marketing communications.
PLEASE NOTE THAT OBJECTING AND/OR OPTING OUT OF DIRECT MARKETING COMMUNICATIONS WITH US WILL NOT AFFECT OTHER COMMUNICATIONS RELATED TO YOUR ACCOUNT OR THE PROVISION OF OUR SERVICES.
3.3. Newsletters - We may use Your Personal Information and/or Personal Data to email You Our Newsletter which We use to regularly provide You with information about Our latest offers. In this instance, You will be required to subscribe to the Newsletter in order to receive such communications from Us.
3.4. Comments, Feedback and Survey Responses - With Your Consent, We may use Your comments, feedback and survey responses to create Content for Our Platform to showcase, market and promote Our Services and the Platform.
4. TARGETED ADVERTISING
4.1. Where a User makes use the free version of the Platform, We may display targeted or personalised advertising to You in order to support the continued availability and operation of the free Services. Targeted advertising allows Us to show You advertisements that may be more relevant to Your Account, interests or use of the Platform.
4.2. For purposes of targeted advertising, We will only rely on the Personal Information and/or Personal Data that You provide to Us when creating an Account on the Platform and any other Personal Information and/or Personal Data that You choose to make available as part of Your profile. We will not use the content of Your private messages, calls, voice notes, video communications or other private communications between Users for targeted advertising purposes.
4.3. We may use such Personal Information and/or Personal Data to group Users into general advertising categories or segments and to display advertisements that are reasonably aligned with those categories. We may work with Third Party service providers such as advertising partners and We hereby undertake to take reasonable steps to ensure that any sharing or Processing of Personal Information and/or Personal Data for targeted advertising purposes is limited, lawful, secure and subject to appropriate contractual and technical safeguards.
4.4. Users accessing and using the Platform on a Subscription basis will not be subject to targeted advertising unless We expressly notify them otherwise and obtain any Consent required under the Applicable Data Protection Law. Such Users shall be provided with appropriate choices, controls or opt-out mechanisms in relation to targeted advertising.
4.5. We do not sell Your Personal Information and/or Personal Data. Our use of Personal Information and/or Personal Data for targeted advertising is intended to support the free version of the Platform while respecting Your privacy, protecting private communications and limiting advertising-related Processing to the bio details You choose to provide.
5. OBJECTIONS, COMPLAINTS AND QUERIES
5.1. Should You feel that You would like to object to the collection, use or otherwise Processing of Your Personal Information and/or Personal Data, kindly complete FORM 1 and email it to Our Information Officer and/or Data Protection Officer.
5.2. Should You require a correction to be made to Your Personal Information and/or Personal Data that We keep on record, or You would like us to delete Your Personal Information and/or Personal Data, kindly complete FORM 2 and email it to Our Information Officer and/or Data Protection Officer.
5.3. We will endeavour to make any correction, provide any Record (We reserve the right to charge a small fee if You require a physical copy), cease the Processing of Your Personal Information and/or Personal Data or delete Your Personal Information and/or Personal Data in accordance with Your request. We will treat Your requests or complaints confidentially.
6. CHANGES TO THIS POLICY
6.1. We may change this Policy at any time, in which case any amended Terms shall be effective immediately upon the posting of the revised Policy and any subsequent activity in relation to the Platform shall be governed by such amended Terms. Where We make changes, We will provide such notice so that You get an opportunity to review the changes.