Privacy Policy

Privacy Policy Overview

1. Introduction:

This is an overview of our Full Privacy Policy, created to guide and inform you about how we handle your information.

Our Privacy Policy describes how we collect, use and disclose the Personal and Non-Personal Data we collect from and about you when you access or use our desktop and/or mobile websites, applications, services, and software (collectively, our “Site”).

Our Site covered by this Privacy Policy includes the desktop and/or mobile services, applications, websites, and software of  KoshOnline.co.za

The KoshOnline.co.za mission is to provide modern solutions that can help the community find good businesses, and also to help businesses and organizations to promote their products and services in an extensive, effective and accessible manner. Our core mission is to empower businesses in South Africa via digital sources, with a special focus on small and micro businesses with lesser means.

2. Who is responsible for your information?

The entity responsible for your information will depend on your location and whether we are acting as a data controller or data processor pursuant to Section 1.1 of our Full Privacy Policy, below. Please check the table below to determine the entity responsible.

Location of User	Data Controller
South Africa	KoshOnline.co.za
Outside of South Africa	Pending

3. What information do we collect about you?

• You choose to provide to us, through our Site e.g. business details, contact details, location data;
• through your activity on our Site e.g. information from your device and actions taken on the site, searches you make or business listings you click on;
• when you use assessment questions, or log in from third party sites such as Facebook; and
• where you use chargeable services or are a business providing necessary information, e.g., for verification purposes.

Full details of the types of Personal Data that we collect from you and details of the legal basis for such collection are detailed in section 2 of our full Privacy Policy.

4. Why do we collect this information?

We collect and use your information to help people find businesses, and services and help businesses and organizations to promote their products and services, and to provide and improve our services to you. In summary, we use your Personal Data, where applicable, to:

• Create your account and send you alerts or other promotional materials.
• Give you relevant search results and recommendations.
• Facilitate communication between users and businesses.
• Prevent fraud, spam and other potentially fraudulent or illegal activities.
• Facilitate payment, in connection with chargeable services (though, your sensitive payment details are entered on a independent, secure pages managed by the payment gateway you choose, and not stored on our site).
• Carry out automated processing in order to provide some of our services.
• Enhance and optimize our services to you by data sharing with third parties such Google Analytics.
• Improve our services, maintain product quality and protect users.
• Aggregate and share with third parties content posted on our Sites intended to be publicly available, such as Google SERPS.

Full details of the purposes for which we use your Personal Data are set out in sections 4, 5 and 9 of our Full Privacy Policy.

5. Who is this information shared with?

Your information is shared with:

• Businesses, and Users (e.g., if a user visits or interacts with a business advertiser via a business page/listing on our site);
• third-party service providers that are used for our operations, e.g. data storage, analytics or fraud detection and prevention.

Please see sections 4, 8, 9 and 11 of our full Privacy Policy for more details.

6. How long do we store your information?

We store your Personal Data until it is no longer necessary to provide our services to you, or until you ask us to delete your Personal Data. We may also be required to retain certain information in order to comply with local laws. If you wish to delete your Personal Data, you should submit a delete request to us via our main contact page. Please see section 2 of our Full Privacy Policy for more information on how long we store your data.

7. What are your rights with respect to your Personal Data?

Your privacy is something we take very seriously. We provide GDPR-type rights to all our users globally. This includes the right to access your Personal Data; delete your Personal Data; get your Personal Data in a portable format; and the right to restrict or object to certain processing of your Personal Data. Where our use of your Personal Data is based on your consent, you have the right to withdraw that consent. Please see section 10 of our full Privacy Policy for more information in regards to your rights and how they can be exercised.

You also have the right to complain to your local data protection supervisory authority about our use of your data as detailed in section 12 of our full Privacy Policy. If you are located in the US, you may have specific privacy rights which can be found in section 13 of our full Privacy Policy.

8. Contacting Us:

You may contact KoshOnline.co.za via our contact form at any time

KoshOnline.co.za Full Privacy Policy

1. Introduction:

We are determined to protect the privacy and the trust of our users – community members and business owners alike.

This Privacy Policy describes how we work to protect information.

In particular, this Privacy Policy details how we collect, use and disclose personal and non-personal data provided by you, the user, when you access or use KoshOnline.co.za.

1.1 The Entities Responsible for Your Information:

This section determines which entity acts as the controller or processor of your Personal Data.

*We as the Controller:

For the purposes of this Privacy Policy, “our”, “we” or “us” means: KoshOnline.co.za.

We are the controller of all Personal Data processed pursuant to this Privacy Policy, except as otherwise expressly stated below in this section 1.1.

Please also note that the contracting entity indicated in our terms of service may differ from the data controller indicated in this Privacy Policy.

*We as the Processor:

We offer certain services to businesses where we acts as a data processor, or similarly, under applicable data protection laws, and processes the personal data it collects from and about you only on the business’s behalf, subject to our Terms and Conditions. This applies to our import features/service that allows businesses to manage their processes/business listing. If you have any questions about our processing of your personal data as part of these services, or to exercise any rights you may have with respect to such information, please contact us via our contact page. The remainder of our processing activities covered by this Privacy Policy does not apply to Personal Data that we collect through these services.

1.2 Some Important Definitions:

Personal data (“Personal Data”) refers to any information that relates to an identified or identifiable individual or business, and non-personal data (“Non-Personal Data”) refers to any information that does not identify a specific individual or business. Please note that at all times we will adhere to the applicable statutory definition in determining what is and is not Personal Data for the purposes of this Privacy Policy. Where this Privacy Policy refers to “information” or “your information” this may include both Personal and Non-Personal Data.

The Site is made available for use by individuals searching for, business information, services and products offered by businesses. Where applicable, the Site may also be made available to individuals, entrepreneurs and/or organizations seeking to promote products and services offered by them.

1.3 The Scope of our Privacy Policy:

This Privacy Policy covers only data that we collect through KoshOnline.co.za, and not any other data collection or processing, including, without limitation, any third-party operators of web pages to which the site links, and any information that we collect offline or through any websites, products, or services that do not display a direct link to this Privacy Policy.

Occasionally, we may refer to this Privacy Policy in notices on the Site, including special purpose web pages or mobile applications, including invitations. We may amend this Privacy Policy at any time.

1.4 Changes to the Privacy Policy:

Any changes to this Privacy Policy will become effective on the “Last Updated” date indicated at the bottom of this privacy policy page. By using the Site or providing information to us following such changes, you will have accepted the latest amended Privacy Policy. If we are going to use Personal Data collected through the Site in a manner that is materially different from that stated at the time of collection, then we will notify users via email and/or by posting a notice on the Site for 30 days prior to such use or by other means as required by law.

2. Information Collected:

When using KoshOnline.co.za, you provide different types of information in order for us to provide you with our Sites’ services, products.

2.1 Information You Provide to us:

*From Your Account:

We collect data from you when you create an account, request information, subscribe for a service, participate in a survey, post a rating, review or comment, post a question or answer, upload media, complete an assessment, update your information, upload content, or otherwise actively send us data on our Site. This may include, but is not limited to, your user name, business name, business hours, password, first and last name, email address, telephone number (including mobile phone number and whatsapp and similar contact aps), street address, gender, occupation, interests, achievements, career goals, professional certification or license numbers, messages you send to users, and any other data included in your account profile, including but not limited to application materials, answers to questions submitted to us or to businesses through us, and answers you give to any questionnaires on our Site or sent to you. All of this information may be associated with your profile.

You may provide (by yourself) your specific location data when we help you find more relevant services and business information. We seek your consent at the time of such provision, and such processing will only be performed where consent is secured.

If you create an account, we may also create and assign to your device an identifier that is similar to an account number. We may collect the name you have associated with your device, device type, telephone number, country, and any other information you choose to provide, such as username, email address, or zip code. For example, while using a mobile device to access our site, we may provide a user with relevant business Listings or Business Information that are located within the same location as where this activity is taking place.

*Through Your Activity on the Site:

In addition, as part of the standard and necessary operation of our Site, we may collect, analyze, process, store, and record in real-time and analyze any and all of your activity on, interaction with, and communications on or through the Site, including, but not limited to, by collecting, analyzing, processing, storing, and recording the areas and when and for how long each such activity occurred. This also may include collecting, analyzing, processing, storing, and recording information from and about your computer or mobile device and your actions taken on the Site, including, but not limited to, your business profile, your searches, the information you search, click on or apply to, where those businesses are located, session activity, browser type, operating system, type of device, mobile device advertising identifier, MAC address, IP address, and any of your other behavior or actions on, interaction with, or communications with or through the Site. The Site cannot work as we intended it to work unless we undertake such activities. If you do not want your actions to be collected, processed, analyzed, or recorded this way, do not use the Site.

*When Providing Business Information:

As a Business Owner/Listing Author, we may request that you provide certain information in order to verify your account. This information may include, but may not be limited to, your Federal Employer Identification Number (EIN), Identity Number, Business Registration information, or a utility bill, the name and email address of a business representative. This information will be used for internal purposes, subject to any request by law enforcement or a court order.

*When Using Chargeable Services:

During checkout, your sensitive info is not entered or stored onto our Site. Instead, you are redirected to a page owned and maintained by a third party financial institution, either PayFast or Paystack, 2 Checkout, which is a much safer process in itselffd.

In connection with chargeable services, we will also collect payment information. This information may include, but may not be limited to, financial institution, account number, card number, branch code and related verification information. Please note that we do not store card security codes.

*When Voluntarily Providing Demographic Information:

In certain markets users can, entirely at their own choice, provide their demographic information including age, race ethnicity, gender, disability, LGBTQ+ Community Membership to us for specific purpose(s) such as evaluating ‘fairness’ in our offerings which includes testing for unfair bias. We are committed to fairness in all processes. The provision of this information is entirely voluntary. The data you provide is based on your consent at the time the information is taken. If you choose to provide your demographic information, you can complete as many of the data fields as you like when presented with an input form (you can choose ‘prefer not to say’ for any of the fields that you don’t want to complete). You can easily view the demographic data we hold in your profile and you can ask for this information to be removed at any time by deleting your demographic information.

*When Updating Information Provided to us:

When you share information with us, or update information previously provided to us, including preferences you may set in your profile, it may take us a few days to reflect these changes on the Site. From the time you make these changes to the time we reflect them on our Site, new data may not appear and previously provided data may continue to show. As a result, information you choose to share publicly on our Site may continue to be visible in our search pages and elsewhere on our Site to businesses and other users.

2.2 Information Collected When You Access us from Some Third-Party Websites:

– When You Log In or Use us from Some Third-Party Sites

You may also create an account or log in to your liostingo.co.za account using third-party websites including, but not limited to, Facebook or Google. If you do not already have an account but log in to KoshOnline.co.za using your Facebook or Google account, this creates an account using the same email address used in your Facebook or Google account. If you agree to provide this information to us, Facebook or Google will authenticate you and redirect you to us. Please note, when you log in to KoshOnline.co.za using your Facebook or Google account, Facebook or Google will cookie you in order to authenticate you as a Facebook or Google user.

By accessing us through your Facebook or Google account, you understand that Facebook or Google will share certain data detailed in the above paragraph for the purposes of authentication to permit you to access our Site in a secure manner. You may stop this at any point from your Facebook or Google account. This information will be considered account information for the purposes of your use of our Site.

You have the ability to disable the connection between your Facebook or Google account and our account at any time by accessing your privacy settings on your Facebook or Google account. Facebook or Google may also ask for your permission to share certain other details with us, including but not limited to your name, profile picture, public profile information, and email address. Once you give this permission, the requested information will be shared with us. This information will be used to provide services to you, including populating your profile. The shared information will remain associated with your profile until you modify or delete it.

NOTE THAT YOUR RELATIONSHIP WITH FACEBOOK OR GOOGLE OR ANY OTHER THIRD-PARTY WEBSITE IS GOVERNED SOLELY BY YOUR AGREEMENT WITH SUCH THIRD-PARTY WEBSITE.

2.3 Any Other Personal Data we May Receive from Third Parties:

Any Personal Data that we may obtain from other third-party sources, including data from sponsored advertisements that we have on third party sites, will be processed by us in accordance with this Privacy Policy and all applicable laws.

2.4 Storage of Your Information:

We store your Personal Data until it is no longer necessary to provide our services to you, or until you ask us to delete your Personal Data. As one example, if a business deletes information in their dashboard, we may delete information associated with that listing. As another example, after communication has been delivered to a business, we may retain a copy of that application for a limited time and then delete the copy. We are also required to retain certain information in order to comply with local laws.

We may also store the information detailed in this section 2 of the Privacy Policy on its equipment or the equipment of third parties that we have a relationship with. Such storage services will be governed by appropriate protections, as required by applicable rules.

2.5 What Personal Data is Required:

It will be indicated to you at the point of provision as to whether or not particular Personal Data provided by you is required in order to provide particular services or features to you. Where Personal Data that is required is not provided by you then the particular feature or service may not be available to you.

2.6 The Legal Basis On Which We Collect Personal Data:

We collect and processes your Personal Data on the basis of different legal grounds, depending on the nature of the Personal Data being provided and the type of processing involved.

– Performance of a Contract:

Some of the Personal Data processed by us is performed on the basis that it is necessary for the performance of our agreement with you, or in order to take steps at the request of the user prior to entering such an agreement.

– Legitimate Interest:

A second ground relied upon by us for other types of processing of your Personal Data is that it is necessary for the purposes of legitimate interests pursued by us or a business. Examples of such legitimate interests will include where we send you marketing about our products and services, where we believe you have a reasonable expectation that we will perform a particular type of processing on your behalf, where such processing is strictly necessary for fraud detection and prevention, and analytics. We will only rely on such a ground where an assessment has been performed balancing the interests and rights involved and the necessity of the processing in order to provide our services, products and features to you.

– Compliance with a Legal Obligation:

A third ground relied upon for certain types of processing is that it is necessary in order to allow us to comply with a legal obligation. An example of this would be where it is required to retain business records for fixed periods of time in order to comply with local legal requirements.

– Consent:

Finally, in certain limited situations, we rely on your consent in order to process your Personal Data. Where we require your consent, we seek it at the time of provision, and the processing will only be performed where consent is secured. For example, your consent will be sought in certain instances where you initiate a marketing message. Alert (detailed in section 4 of this Privacy Policy). You can withdraw your consent, as detailed in section 10 of this Privacy Policy where applicable, or by sending an email to [email protected].

3. Limitations of Use:

3.1 Where a User Wants to Close an Account:

When a user closes an account, the user will no longer have access to any of the data we make available under that account, including but not limited to, search history, and any other data associated with the account. If the user uses the same email address to set up a new account, the data from a previous account will not become available to the user again. Please also note that closing your account may result in you losing access to some of our products and the ability to utilize the “log in” feature. Accounts can be closed by clicking on the close account inside your user dashboard.

We reserve the right to keep any materials in a closed account as necessary to preserve and protect our rights to the extent permitted by law (for example, to preserve records of a dispute) or to comply with our obligations under local law (for example, if requested to retain by law enforcement). A closed account does not mean that all of the data is expunged from our systems, although it will not be readily available under the original account. When the user presses the close account button on the dashboard, we will begin to process within 24 hours and will have completed the operation within 30 days.

If a user wishes to access or delete their Personal Data held by us, they should follow the steps listed in section 10 of this Privacy Policy.

3.2 Where a Business Wants to Close an Account:

Businesses may close an account at any time from their dashboard. Please also note that closing your account may result in you losing access to some of our products and services.

We reserve the right to keep any materials in a closed account as necessary to preserve and protect our rights to the extent permitted by law (for example, to preserve records of a dispute) or to comply with our obligations under local law (for example, if requested to retain by law enforcement). A closed account does not mean that all of the data is expunged from our systems, although it will not be readily available under the original account. When the user presses the close account button on the dashboard, we will begin to process within 24 hours and will have completed the operation within 30 days.

If a user wishes to access or delete their Personal Data held by us, they should follow the steps listed in section 10 of this Privacy Policy

3.4 Where the Business Contact Details Provided to us Are Incorrect:

We depend on the business or their agents to provide us with the correct destination for all communications. In the event that the electronic destination provided to us is incorrect, your materials will not be sent to the intended recipient. We have no liability for such applications.

3.5 Email Addresses:

When communicating through our message relay system, you will see an email address with an @keyhashone.com end. You understand that you retain no ownership rights in these email addresses and they are owned by us. However, our relay system will show the name associated with your account in the “To:” or “From:” field. Please note that emails which include an email address ending in @keyhashone.com will be stored on our systems.

Please also note that since these message proxy and relay services depend on the functionality of third-party providers, there may be technical delays on the part of those email service providers, out of our control.

3.6 Minimum Age of our Users:

KoshOnline.co.za are not for use by anyone under the age of 16. However if local laws provide for an alternative minimum age for the provision of the Sites’ services to you, then that shall apply as the applicable minimum age. In all jurisdictions outside the European Union, if you are under the age of 18 or the age of majority in your jurisdiction, you must use the Site under the supervision of your parent, legal guardian or responsible adult.

We adopt a range of measures to try to ensure that we do not accept individuals who do not meet the minimum age and any other applicable age requirements. If you do not satisfy these age requirements, please don’t use the site.

4. Purposes, Uses and Disclosures of Information:

We may use any information collected pursuant to this Privacy Policy, including Personal Data, for the purposes set forth in sections 4, 5 and 9 of this Privacy Policy, to the extent applicable. We associate Personal Data with your profile in order to perform the activities described in this Privacy Policy. We use such information to help users find services and business information, and to help businesses find customers and promote their products and services. In order to do this we use your Personal Data to:

1. Provide our services, products and features to you, to help users find services and business information, and businesses to find customers and promote their products;
2. to measure and improve those services, products and features; and
3. to protect our user’s privacy and provide them with customer support.

More detail on these purposes, uses and disclosures of your information is set out below.

4.1 Creating an Account, Sending You Alerts and Other Promotional Materials:

If and to the extent permitted by applicable law, we may use the information you provide to us, such as your contact information and information about your activity on our Site, to (i) Create an account for you; (ii) Send you alerts; (iii) Send you information about the Site and (v) Send you monthly verification alerts, including by displaying our promotional materials to you on third-party platforms. We may use third-party partners to perform these activities on our behalf.

An alert is an email or push message that you sign up for containing information in response to a search query you have run. A company alert is one type of alert which contains Listings information and other information you have requested regarding a company. Alerts may also include Listings that are recommended for you, Targeted Ads, companies you may be interested in following, or other actions you may want to take on the Site. The frequency of alerts may be adjusted.

As part of how we display our promotional materials to you, we may also use your information to show you targeted advertisements, and other content that has been customized for you, on third-party platforms, such as other online, print, or televised media. Such advertisements will only relate to the Site’s services, products, and features, all of which focuses on helping users find services and business information and businesses to find customers and promote their products. If you wish to opt out of receiving any marketing messages from the Site, please see section 10.3 of this Privacy Policy.

– Business Accounts:

In the business account settings, we offer users the ability to Depending on the roles assigned to a particular linked user, this may include, but not be limited to, contact information, communications between users and businesses, any action taken by you regarding the account and when you took certain actions, including billing information within the account.

4.2 Giving You Relevant Search Results:

In order to optimize our services, products and features for your – and our visitors’ benefit, we may use your previous search and browsing history on our Site, or application materials and answers to questions, to identify you, determine relevant search results and reach out to you about offers, such as services and products you may be interested in. We may also use profile data to tailor your experience on the Site and to display content according to your preferences. We may return different results for the same search query and have full discretion with respect to the results we present in response to any particular search.

4.3 Your Contact Information:

When you provide your contact information to KoshOnline.co.za, such as your name and email address, and other forms of Personal and Non-Personal Data, you agree that we may utilize that information for the purposes outlined in sections 4, 5 and 9, to the extent applicable. In particular, you agree that we may, as part of our services to you, communicate with you, or initiate communication with you on behalf of a third party, through your account or through other means such as email, push messages, telephone (including mobile phone), text message or postal mail. This includes communication through the use of contact information that you may provide to us or that we may otherwise obtain from third-party resources. We may also analyze our users’ contact information in the aggregate to better understand our users and improve our products and services.

4.4 Your Business or Organization Information:

Your business information, including any other Personal Data that you may include in it, are placed on KoshOnline.co.za when you create, upload, or edit a business listing profile, which becomes part of your user profile.

Your profile may be available to anyone accessing KoshOnline.co.za. This includes users of our search service, businesses whose company page you may be following, and anyone with access to a URL associated with your profile, such as search engines and other third parties that may crawl our Site. We offer you this visibility to help you find customers and to promote your products and services to users.

When you create a business profile on KoshOnline.co.za, you authorize us to share the contents of your business profile, including any other Personal Data that you may include in it, publicly on the Site, and to allow users to see if you were recently active on the Site and your available contact methods. For example, users using our search service are able to search for businesses based upon the information in your business profile. If you do not want to share certain information with users, you can remove it from your profile.

We restrict scraping of our Site to ONLY reputable search engines, although some third parties may use our Site in violation of these terms to obtain your information.

We may also provide browser extensions and other tools to help users better interact with business information, including tools that allow users to download your information. Users are solely responsible for complying with all applicable laws that relate to the use of information obtained from us, including any obligations users may have to restrict how others interact with your information downloaded from our Site.

4.8 Sending Messages:

We provide a two-way message proxy and relay services to the users of our services (“Relay Service”), including, but not limited to: business listings, posts, chat, onboarding, private calling, and other electronic communication services whether in the form of phone, text, video or audio. By utilizing any Relay Service, you acknowledge that you are asking us to send these messages on your behalf. This includes your cover letters, applications, messages, questionnaire answers, responses, offer letters and other materials. We may provide read receipts to the sender of a message through a Relay Service indicating that the recipient has viewed the message. We may also separately inform the sender and recipient of a message through a Relay Service whether the sender or recipient recently has been active on the Site.

We process, monitor, review, store and analyze such content, which may include Personal Data, including via automated means, for data analysis, quality control, enforcement of the Sites’ rules and other policies, content moderation, and to improve the Sites or any other product or service. Examples of such improvements would be improving the open rate of messages by optimizing their delivery, optimizing our search results, improving Business Listings, permitting applicants to manage their applications after transmitting them, ensuring you are provided with personally relevant product features and communications, and preventing fraud and spam. Some of this activity is performed on our behalf by service providers, as described in the section of this Privacy Policy titled ‘Transfers of Information to Service Providers’. As a result of this activity, or due to technical malfunction, in certain circumstances such content may be delayed or may not be delivered to the intended recipient. We may (but is not obligated to) notify you in such an event. By using a Relay Service or otherwise providing User Content through the Site, you agree to this activity and acknowledge that this activity is necessary for maintaining the quality of our Site and for providing the Relay Service.

4.9 Sending You Text Messages About Appointments

We may offer you the opportunity to receive a text message from us when a business has scheduled any interaction or event with you, when a business seeks to contact you based on your public info, or has responded to you via an email relay. In such an event you will enter your phone number on the consent form. By entering your phone number you are representing and confirming it is your number and you have the right to accept text messages at the number. We will only send you a text message reminder for your relevant queries or messages through our email relay, and you agree to accept such text messages on your cell phone including messages sent by automated telephone dialing system. To unsubscribe at any time, reply to the text with STOP. Replying STOP in response to an SMS alert will unsubscribe you. In order to unsubscribe from other products, you must respond STOP within the specific text flows of those products, such as email.

4.10 Facilitating telephone relay system between users and businesses (Pending):

Where applicable, we may offer users and businesses the option to use a telephone relay system to facilitate contact for the purpose of submitting queries, networking or other communication. Such a system uses masked or proxy telephone numbers to protect users, and is only available to users who select it on the Site. No recording of conversations or messages is performed through this relay system, although data relating to whether a call was answered and call duration may be gathered. Such functionality is provided to by third party service providers, such as Twilio.

4.11 Preventing Fraud and Spam:

We may also use information collected pursuant to this Privacy Policy to help diagnose problems with the Site and our products and services, to prevent potentially fraudulent or illegal activities, and to protect individuals from other activities that may be detrimental to you or others. We may investigate and disclose information from or about you or your use of us if we have a good faith belief that such investigation or disclosure (a) is reasonably necessary to comply with legal process (including subpoenas, search warrants, court orders) and law enforcement instructions and orders; (b) is helpful to prevent, investigate, or identify possible wrongdoing in connection with the use of KoshOnline.co.za; or (c) may protect our rights, reputation, property, safety, or that of the public; or (d) as necessary to meet national security requirements.

We may use a variety of methods to detect and address anomalous activity and screen content to prevent abuse such as spam or fraud. However, such detection methods are not perfect and false positives may occur. These efforts may, on occasion, result in a temporary or permanent suspension or termination of some functions for some users.

– Preventing Fraud and Spam in Messages:

We reserve the right to block messages from our relay system that we determine do not adhere to the Sites’ rules or any of the terms of our terms of service. We further reserve the right to conduct investigations to determine whether you are perpetrating a scam, spamming us or our users, or otherwise conducting fraudulent activity on the Site by various means. We also reserve the right to turn over any information gathered via such investigations to the police or other third parties if we have a good faith belief that you are using the Site in violation of this Privacy Policy or the applicable terms of service.

We reserve the right to verify and confirm the identity of any party associated with an email relay. This includes but is not limited to verifying the identity of the sender of an email with the business agents associated with that email address on the relevant listing.

4.12 Facilitating Payment:

If you provide credit, debit or other payment card and related details to us in order to make a payment, we will use such information only for the purpose of processing the payment. Any credit, debit, or other payment card and related billing and payment information that you provide to us may be shared by us with companies who work on our behalf, such as payment processors and/or credit agencies, solely for the purposes of checking credit, effecting payment and servicing your account. We don’t store your sensitive banking information on our Site, as you are redirected to a third party checkout page that are secured by the specific third party selected, for example, Payfast and Pasystack, 2 checkout.

4.13 Automated Processing of Your Personal Data:

In order to optimize the performance of the Site, we perform automated processing of Personal Data evaluating certain specific aspects relating to a user. In particular we use automated processing to analyze or predict a user’s personal preferences or interests. Where it occurs, such processing is carried out if it is necessary for the performance of our agreement with our users, to allow us to provide our services to users and businesses.

For example, in certain cases such processing allows us to match users with businesses effectively, to provide users with Alerts, recommended listings, to display search results, or to perform certain spam and fraud detection activities to protect our users. Such processing is subject to the safeguards detailed in this Privacy Policy to protect the privacy of our users.

– Improved Services

Data sharing with third parties such as Google AdSense provides users with more personalized and improved content, performance, features and services. For example, we might use your previous search and browsing history, IP address, or profile information, to determine relevant search results, alerts, display and moderate business insights. Such sharing is also performed to facilitate improved data analysis, testing, research, and service improvement.

This sharing also allows businesses to have better insight into the performance of their listings. For example, we may share data related to user clicks on their listings which in turn allows businesses to understand the extent to which they are attracting customers. By providing businesses with the information they need to better utilize our platform, they can provide stronger listings and better business sollutions.

– Increased Businesses and Users:

Such data sharing allows users to access an even broader database of listings and businesses, and for businesses to gains access to more users.

– Better Security for Users

Such data sharing allows us and our affiliates to process your Personal Data for the purpose of improving user security and internal operations, troubleshooting, and detecting and preventing fraud and spam.

4.15 Transfers of Information to Businesses:

Business account holders agree to comply with all their responsibilities under applicable data protection rules with respect to the collection, processing and storage of Personal Data, as well as providing adequate protection of all data subject rights provided for under all applicable data protection rules.

4.16 Transfers of Information to Users:

We send certain business-related information to users. This includes company profiles and information on the Site and publishing listings on third-party websites, such as Google. We may also provide information to users about a business’s activity and responsiveness on the Site in order to help users evaluate opportunities. This may include the business representative’s name, the business’s city/state location, whether the business has taken an action with regard to the user communication as opening, viewing, responding to or making a decision in regard to it, whether the business has engaged with other users or viewed other users profile, and whether the business has taken an action in regard to a listing such as pausing or closing it. As a business, when you use the Site (for example by posting a Listing or contacting a user through the Site) you agree that we may provide this information to users.

4.17 Transfers of Information to Service Providers:

We may use third party service providers to perform services in connection with our operations, to improve the Site and our services, products, and features, to protect our users and better understand their needs, and to optimize the services and the users’ experiences. By using our Site, you acknowledge and agree to us making use of such third-party service providers, including, but not limited to, for the purpose of collecting, processing, analyzing, and recording your activity on, interaction with, and communications with or through our Site, as further described in section 2 of this Privacy Policy.

These service providers may have access to Personal Data in the course of providing these services, which may involve transfers of such Personal Data to other countries. Such transfers are made for the purposes set forth in sections 4, 5 and 9 of this Privacy Policy.

– Improving our Services:

These third parties may provide data points including how much time you spend on specific pages, which links you choose to click, and data that helps determine user preferences. This information enables us to build and maintain our services with user feedback. These third parties, such as Google, may use cookies and other technologies to collect data on your behavior and devices such as the device type, browser information, and preferred language.

– Maintaining Quality and Protecting Users:

We may transfer your Personal Data in limited situations to certain third-party vendors that assist us with protecting our users and maintaining the quality of our services, products and features provided to those users. An example would be vendors we use for fraud detection purposes. Another example would be vendors we use in order to prevent accounts being created using account credentials that have been publicly disclosed. An example of such a vendor is: SpyCloud.

– Facilitating Payments:

We may also share any credit, debit, or other payment card and related billing and payment information that you provide to us with companies who work on our behalf, such as payment processors and/or credit agencies, solely for the purposes of checking credit, effecting payment to us and servicing your account.

– Installing or Using our Apps:

In order to provide you with certain services and support ad attribution, limited user data may be shared with certain service providers when you install, download or use our Apps. This may include your IP address or other unique identifier, and event data related to the installation of our Apps.

This may be done for a variety of purposes, including facilitating user log-in through third party accounts. It may also assist us to understand and optimize our users’ complete customer journey by helping us: (i) understand how users arrive at the Site; (ii) better measure the performance of our ads; and (iii) understand where a user has accessed the Site through different devices.

When you download or install an App, you acknowledge and accept that your Personal Data may be transferred to these service providers. You also agree to our Cookie Policy, Privacy Policy and the applicable terms of service, and are informed that you may avail of your rights at any time, as detailed in section 10 of this Privacy Policy, including the right to object to the legitimate interest use of your Personal Data for marketing purposes.

Examples of the types of technologies that may support this behavior include pixels, javascript snippets, or cookies.

– Storage:

We may also use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be non-negotiable. These service providers have informed us or the general public that they apply security measures they consider adequate for the protection of information within their system, or they have a general reputation for applying such measures. However, we will not be liable (to the fullest extent permitted by law) for any damages that may result from the misuse of any information, including Personal Data, by these companies.

– Verifying Professional Certifications and Licenses:

We may also share certain professional certification or license numbers that you provide to us with the issuing entity or organization in order to verify if the certification or license is valid.

4.18 Transfers of Publicly Available Information:

When users post content on the Site in a manner that is intended to make that content publicly available and searchable by individuals, we reserve the right to aggregate and share that information with third parties. For example, if a business posts a listing, we may share that Job Listing or information contained within that Listing with third parties, at our discretion and subject to agreement with such third parties. We also reserve the right to share information aggregated from public sources in this capacity.

4.19 Third-Party Sites You Link to from us:

You may also use certain third-party websites or services that you link to from the Site. In such cases, all information you provide to a third party is provided to that third party and not to us, and is subject to the third-party’s privacy policy and terms of service. See section 8 of this Privacy Policy titled Links to Third-Party Websites for more information

5. Additional Uses and Disclosures of Non-Personal Data:

This policy also applies to our use of Non-Personal Data. We may use and disclose Non-Personal Data for any purpose, except where we are required to do otherwise under applicable law. If we combine any Non-Personal Data with Personal Data, then we will only use and disclose such combined information for the purposes described in sections 4 and 9 of this Privacy Policy while it is so combined.

6. Security:

We use reasonable security measures to help protect against the loss, misuse and alteration of the Personal Data under our control. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. In addition, please note that emails, messages sent via your web browser, and other similar means of communication with other users, are not encrypted. Therefore, while we strive to protect your information, we cannot guarantee its security.

Please also be aware that we may use third-party cloud service providers as detailed by Section 4.17 of this policy.

7. Cookies:

“Cookies” are small pieces of information that are stored by your browser on your computer’s hard drive. The below info and description is intended to inform and educate about what cookies are and how we use them. Please see our Official Cookie Policy for further information regarding our use of Cookies.

7.1. Introduction: What is a cookie?

This Cookie Policy helps to explain the occasions when and why cookies may be sent to visitors from the Site. Cookies are text-only pieces of information that a website transfers to an individual’s hard drive or other website-browsing equipment for record-keeping purposes. Cookies allow the Site to remember important information that will make your (the user) use of the Site more convenient. A cookie will typically contain the name of the domain from which the cookie has come, the “lifetime” of the cookie, and a randomly generated unique number or other value. Certain cookies will be used on the Site regardless of whether you are logged in to your account or not. 

Session cookies are temporary cookies that remain in the cookie file of your browser until you leave the Site. Persistent Cookies remain in the cookie file of your browser for much longer (though how long will depend on the lifetime of the specific cookie). We use session cookies to track the total number of visitors to our Site. We may also employ cookies so that our Site remembers your computer when it is used to return to the Site to help customize your experience. We may associate Personal Data with a cookie file in those instances.

7.2. How We Use Cookies:

We use cookies, web beacons, and other similar technologies, including those from third-party partners such as Google and Facebook, for measurement services, more relevant advertisements, and for marketing purposes. This takes place from the Site, when you download or install our Apps, and in some of our advertisements on third party websites. These cookies, web beacons, and other similar technologies allow us to display promotional material to you on other Sites you visit across the Internet and connect you with more Businesses. We may also share information about your behavior on the Site with third parties (including operators of third-party websites and/or social networking sites) in order to show you targeted advertisements and other content that has been customized for you. 

We also use these cookies, web beacons, and other similar technologies to facilitate our Targeted Ads Program and other advertisements to help us to determine which advertisements users have seen, how many times users have seen a particular advertisement, and on which sites a particular advertisement appeared. We may also allow businesses who participate in our Targeted Ads Program to place cookies, web beacons, and other similar technologies in advertisements we serve on our Site and on third party websites to help these businesses understand how individuals interact with our advertisements.

We may also use these cookies, web beacons, and other similar technologies on the Site to understand and inform a business about which users saw a particular Business Listing, Company Page, Hiring Event, or other advertisement in which the business is identified.

How We Use Cookies for Analytical Purposes:

We use cookies to analyze user activity in order to improve the Site. For example, we can use cookies to look at aggregate patterns like the average number of searches that users perform. We can use such analysis to gain insights about how to improve the functionality and user experience of the Site.

Your Preferences & User Experience:

We use cookies to gather certain information about users, such as browser type, server, language preference, and country setting, in order to store user preferences on our Site to make your user experience more consistent and convenient. For example, we may store the recent searches you have performed on our Site, in a cookie so that we can allow you to easily repeat those searches when you return to our Site.

In addition, we use cookies to maintain your “logged in” state when you visit our Site repeatedly. We may also use your IP address to determine your geographic location at city or postal code level in order to provide you with the most relevant search results.

Provide Measurement Services and Better Targeted Ads, & Marketing:

We use cookies, web beacons, and other similar technologies from third-party partners such as Google for measurement services, better targeting advertisements, and for marketing purposes. This takes place when you visit our Site and when you download or install our Apps. These cookies, web beacons, and other similar technologies allow us to display our promotional material (which may include a particular Job Listing or Company Page available on the Site) to you on other sites you visit across the Internet. 

Our third-party advertising partners may also use these technologies to identify your browsing interests over time and across different websites to deliver targeted advertisements and other content that has been customized for you. 

We may also share information about your behavior on the Site with third parties (including operators of third-party websites) in order to show you targeted advertisements and other content that has been customized for you. We also use cookies to facilitate the our Targeted Ads Program. In connection with this Program and other advertisements, we use cookies, web beacons and other similar technologies, including from third party partners, to determine which advertisements users have seen, how many times users have seen a particular advertisement, and on which sites a particular advertisement appeared. 

You have a right to object to the legitimate interest use of your Personal Data for the purposes of marketing. To opt out of the collection and use of information for ad targeting, or to exercise any other rights, please feel free to follow the steps detailed in section 10 of our Privacy Policy.

Security Purposes:

We use cookies to limit certain types of cyber attacks.

Testing, Usability and Performance Improvement Purposes:

We use cookies to ensure users receive a consistent user experience while we conduct A/B testing on certain aspects of our Site in order to improve our product offerings. We also use cookies to improve the performance and reliability of our Site.

Fraud/Spam prevention:

We use cookies during fraud reviews and investigations. Some of our cookie/device tracking happens via 3rd party vendors, other times we use our own indexes to identify activity related to specific cookies.

Compliance:

We may use cookies to anonymize traffic and activity data we collect about the use of our Site.

7. 3. What Cookies Do We Use:

We use first-party and third-party cookies differently on our Site to provide our many products and services to you.

We may allow third-parties to use cookies on our Site to help deliver and improve our services, and provide them to you. Our use of these cookies may differ by site and market. If your use of our Sites is not captured in the table above, please review your browser settings for a list of all cookies stored on your device. The list below identifies all of our third-party cookie provider partners in use as of the effective date of this Cookie Policy. Please visit their websites for more information on their privacy practices: Third-Party Cookie Provider Third-Party Website

Google https://www.google.com/

Facebookhttps://www.facebook.com/

7. 4. Your Control over Our Use of Cookies:

– Browser and Device Specific Controls:

Your browser may provide you with the option of blocking cookies, such as third-party cookies. Some browsers also give you the ability to review and manage cookies individually. We encourage you to review your browser’s settings and documentation for additional information on any controls your browser may offer and how they work, more information is available at aboutcookies.org. Please note, if you delete any cookie from your device or browser, but do not set your browser or device to block third-party cookies, we may install the same cookie during a later visit. Some third-party cookies are also integral to the services we provide on our Site. By blocking third-party cookies, you may not be able to take advantage of all of the features available on our Site.

– Targeted Advertising Opt-outs:

You can also opt out of targeted advertising that we do through our third-party advertising partners, such as Google, by visiting resources they provide (such as Google’s How Google Uses Information from Sites or Apps that Use Our Services), or by interacting with them through digital advertising self-regulatory initiatives available in the European Union (Your Online Choices), United States (Your Ad Choices), and Canada (Your Ad Choices). We may update this list from time to time as similar initiatives become available in other markets. We encourage you to visit all of these websites for additional information about each organization’s approach to targeted advertising, lists of participating companies, and the options available to web users. Please note, any third-party opt-outs may require use of a third-party cookie to reflect your choice and clearing third-party cookies from your browser or device may affect or remove your choice.

7. 5. Changes To Our Cookie Policy:

Please review the “Last Updated” at the top of the Cookie Policy to determine when it was last amended. Any changes will become effective on the “Last Updated” date indicated. By using the Site or providing information to us following such changes, you will have accepted the amended Cookie Policy. If we are going to use Personal Data collected through the Site in a manner materially different from that stated at the time of collection, then we will notify users via email and/or by posting a notice on the applicable Site for 30 days prior to such use or by other means to the extent required by law.

– Do Not Track Requests

We do not respond to the browser “Do Not Track” (DNT) signal if enabled by the user in their web browser. When we set or read cookies on non-affiliated sites that have integrated our search and display features, we do so, for example, to provide a personalized search experience to users on those sites. We do not share any information about your use of our Site with those third parties. When third parties that we have integrated into the Site (as described in our Cookie Policy) set or read their own third-party cookies, they may or may not respond to the DNT signal.

8. Links to Third-Party Sites:

The Site may make links available to other third-party websites. When you click on such links, you may leave our Site. Your web browser may also disclose to the third-party website the URL of the Site page you clicked from, and this URL may include search terms and filters you used on the Site. The Site may also make available Company Profiles, which may contain information provided by third-party businesses.

WE ARE NOT RESPONSIBLE FOR THE INFORMATION COLLECTION, USE, DISCLOSURE OR OTHER PRIVACY PRACTICES OF ANY THIRD PARTY, INCLUDING OUR AFFILIATES, THIRD-PARTY SERVICE PROVIDERS, ANY BUSINESSES (INCLUDING ANY BUSINESS THAT PROVIDES A COMPANY PROFILE), ANY THIRD-PARTY SOCIAL MEDIA PLATFORM, ANY THIRD PARTY MAKING AVAILABLE THE DEVICES OR OPERATING SYSTEMS FOR WHICH THE SITES IS AVAILABLE, AND ANY THIRD PARTY OPERATING ANY WEBSITE TO WHICH THE SITES CONTAIN A LINK. YOU MAY HAVE RIGHTS DIRECTLY ENFORCEABLE AGAINST THESE THIRD PARTIES SO YOU SHOULD CONSIDER THEIR PRIVACY POLICIES TO LEARN MORE.

9. Acquisitions and Other Reorganizations:

Information collected pursuant to this Privacy Policy, including Personal Data, may be disclosed to one or more third parties in connection with any change of ownership or control in our business (whether by merger, sale, or otherwise), or any other reorganization or joint venture, or assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceeding), and any such information may be used by such third party in accordance with this Privacy Policy. Equally, information collected pursuant to this Privacy Policy, including Personal Data, may be disclosed to one or more third parties in connection with any acquisition or merger carried out by us of such third parties.

10. Exercising Rights With Respect to Personal Data:

As a user of the Site, you may exercise the rights explained below. Please note, we may attempt to verify your identity through the email address or telephone number associated with your use of our Site prior to fulfilling any such request and reserve the right to deny a request where we are unable to satisfactorily complete this process. If you authorize someone to make a request on your behalf, we may also deny your request if we are unable to verify with you that the individual making the request is authorized to act on your behalf.

10.1 The Right to Rectify Your Personal Data:

Users of the Site are able to edit and update most of their Personal Data held by the Site, and if you have any queries or complaints we encourage you to contact us.

Alternatively, if you do not wish to do this you may make a formal request to have us rectify any inaccurate Personal Data on your behalf by sending an email to [email protected].

10.2 The Right to Object to or Restrict the Processing of Your Personal Data:

If you have any queries or complaints about how we process your Personal Data we encourage you to contact us.

10.3 Opting Out of Marketing Messages and Withdrawing Consent:

If you wish to opt out of a particular marketing email, you may do so by clicking “unsubscribe” (or an equivalent action) where applicable. Please note that this will only opt you out of that particular marketing message.

In addition, you may opt out of all marketing messages by sending an email to [email protected]. We will comply with your request as soon as reasonably practicable, and in accordance with applicable laws.

Please note that we may still send other messages to you, such as verification and administrative messages.

10.4 The Rights of Access to and Portability of Your Personal Data:

Users of the Site are able to access most of their Personal Data provided, and if you have any queries or complaints we encourage you to contact us. Alternatively, if you do not wish to do this you may make a formal request to access your Personal Data held by us. We will provide your Personal Data to you in a portable format.

10.5 The Right to Delete Your Personal Data:

Users of the Site are able to edit and update most of the Personal Data held by the Site, and if you have any queries or complaints we encourage you to contact us.

Alternatively, you may make a formal request to delete your Personal Data provided. In order to do so, send an email to [email protected]. Once your request has been confirmed, we will initiate the necessary steps to fulfill your request, including the deletion of any applicable Site account. Where the deletion request relates to Personal Data that you previously requested be made public, we will make reasonable efforts to inform any other controllers of this request. If you have interacted with the Site in question using more than one email address, please submit a subsequent request with the additional email addresses so that we may delete this personal data as well.

PLEASE NOTE: by requesting the deletion of your Personal Data, you will no longer be able to use the same email address on the Site in question. This may include, but is not limited to, your ability to create an account. If you simply wish to close your account, please click the “close my account” button in your account Dashboard. If you take any action on or otherwise interact with our Site after submitting a deletion request, you may not receive certain communications associated with those actions from the Site affiliated with your deletion request or from other users of that Site. Additionally, by making a personal data deletion request, you acknowledge that you will be removed from consideration for all active sweepstakes, contests, prize draws, and other promotions. Deleting your Personal Data held by us does not affect messages we process on behalf of others in connection with their use of our message Relay Service and they may continue to have access to all messages sent to or received from you.

10.6 Withdrawing Consent:

There are certain activities where we ask for your consent to use your Personal Data. You have the right to withdraw this consent at any time. Where you are providing location information via a mobile app, you may turn off your location services on your device at any time. For other services that rely on your consent, you can withdraw your consent via the workflow for that given service. Please note that any processing that we have carried out before the withdrawal of your consent remains lawful.

10.7 Some Limitations

Such rights of rectification, objection, restriction, access, portability and deletion are subject to certain limitations, as provided for by applicable laws. Individual requests will be completed within the time allotted by relevant regulations, which starts to run from the point of us confirming your request. Where permitted, please note there may be a charge for subsequent requests from the same individual, which will be determined by us and only imposed to the extent permitted by applicable law.

11. Personal Data from Individuals in the EEA and Switzerland

11.1 GDPR Protections

Where appropriate, transfers of Personal Data of individuals in the EEA and Switzerland to jurisdictions outside the EEA and Switzerland are performed based on the European Commission’s standard contractual clauses. These agreements also incorporate the protections and requirements provided for under Chapter V (and Article 28, where appropriate) of the GDPR.

12. General Inquiries and Complaints:

12.1 Contacting Us:

You may contact us via our contact form at any time. Response may take up to 48 hours during high volume tickets.

12.2 Complaints:

If you believe your data protection rights have been infringed by us, you have the right to complain to the appropriate data protection supervisory authority. For further information regarding the complaints process, please visit the website of the Information Regulator, or you may contact the Information Regulator for further assistance: Physical address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
Postal address: P.O Box 31533, Braamfontein, Johannesburg, 2017
Email: [email protected]
URL Address: https://www.justice.gov.za/inforeg/index.html

13. California Privacy Rights

By exercising the rights afforded in this section of our Privacy Policy, you are declaring that you are a California resident.

All users may make a verified request to us regarding their Personal Data. This process is detailed in Section 10 of our Privacy Policy, which also describes the designated address information for making requests to us regarding your Personal Data.

13.1 The Right to Know Your Personal Data

You have the right to request that we disclose the Personal Data we collect, use, disclose and “sell” (we explain this term further in Section 13.2, below) about you. For more information on how to exercise this right, please see Section 10 of our Privacy Policy.

The following sections of our Summary of our Privacy Policy explain the categories of Personal Data we collected over the past twenty four (24) months (section 3), why we collected this information (section 4), and the categories of third parties with which we shared it (section 5). We also cover these topics more expansively in our Full Privacy Policy: section 2 of our Privacy Policy explain the categories of Personal Data we collect; sections 4, 5, and 9 of our Privacy Policy explain the purposes for which we use your Personal Data; and sections 4, 8, 9 and 11 of our Privacy Policy explain our disclosure of your Personal Data to third parties.

13.2 The Right to Opt-out of the Sale of Your Personal Data

To learn more about our approach to California’s “Do not sell my personal information” requirement, why it applies to your use of our Sites, and how you can exercise this right, please visit our Opt-Out page. There, we explain how California has defined “sales” under the California Consumer Protection Act (the “CCPA”) and how certain transfers of Personal Data that are integral to the products and services we offer to our users may be captured by this definition.

Under California’s “Shine the Light” law (Civil Code section 1798.83), California residents have certain rights regarding the disclosure of their Personal Data to third parties for their own direct marketing purposes. Our policy is not to disclose your Personal Data to third parties for the third parties’ direct marketing purposes if you have exercised your option to prevent that information from being disclosed to third parties for those purposes. If you wish to not have your personal information shared for those purposes, you may request that we delete your Personal Data by following the steps outlined in Section 10 of this Privacy Policy.

13.3 The Right to Non-Discrimination for Exercising Your Privacy Rights

We will not discriminate against you for exercising any of your rights under the CCPA.