1. Introduction

We respect your privacy and take it very seriously. We are DVV International trading as MOJA, and this is our plan of action for the protection of your personal information. It describes how we collect, use, disclose, and store your personal information.

We will take all reasonable measures, in accordance with the Protection of Personal Information Act 4 of 2013 ("POPIA”) and any other relevant legislation, to protect your personal information (as defined in POPIA) and to keep it confidential, even when you are no longer our customer or a user of our website or services.

2. Application

This policy applies to you when you visit our website, use our application, or order our goods or services as a customer.

3. Personal information

3.1 Scope. Your personal information includes information we collect:

• automatically when you visit our website;
• on your registration or submission;
• telephonically;
• when you apply for and use certain services;
• through an order, booking or purchase; or
• when you provide it voluntarily

It excludes anonymous, de-identified and, statistical information., and public information.

3.2 Common examples. Common examples of the types of personal data which we may collect, and process include your:

• identifying information – such as your name, date of birth, or identification number of any kind;
• contact information – such as your phone number or email address;
• address information – such as your physical or postal address; or
• demographic information – such as your gender or marital status.

3.3 Examples of sensitive personal information we may collect. Depending on the services you use, we may also collect sensitive personal information, including your:

• financial information – such as your bank account details;
• sensitive demographic information – such as your race or ethnicity; or
• children’s information – such as your child’s first name and date of birth.

3.4 Your obligations. You may only send us:

• your own personal information if you are 18 years or over;
• someone else’s personal information if they are older than 18 and you have their permission to do so; or
• a child’s personal information provided you are regarded as a competent person under POPIA

3.5 Legal capacity. You may not use our services if you are younger than 18 years old or do not have legal capacity to conclude legally binding contracts.

4. Acceptance and changes

4.1 Acceptance. You may not use our website, any services we provide, or order any of our goods if you do not accept this policy or any changes to it.

4.2 Changes. We may change this policy at any time and will notify you of the changes on our website, through our application, or by email. The changed policy applies to you if you continue using our website, our application, or our goods or services following the notification.

5. Collection

5.1 Automatically through website. When you visit our website, we automatically collect your Internet usage information (including your IP address, browser details and usage information) through your browser, which we may use to display our website correctly, track your activities on it, or for other necessary purposes.

5.2 On registration or submission. We may ask you to provide us with certain identifying information (including your first name, surname and email address) when you register on or otherwise submit information through our website for the first time.

5.3 Through an order. When you order our goods or services, we ask you to provide us with certain information.

5.4 Voluntarily. We may ask you to provide us certain optional information on a voluntary basis.

5.5 Consent to collection. When we need explicit consent, we will get your consent to collect your personal information in accordance with applicable law when you provide us with it. You have the right to withdraw your consent at any time. This will not affect the validity of the processing prior to the withdrawal of your consent.

5.6 Purpose for collection. We may process your information that you provide to us for the purposes that you indicated when you agreed to provide it to us. Processing includes gathering your personal information, disclosing it, and combining it with other personal information.

6. Use

6.1 Processing. We may process your personal information to fulfil our obligations to you. We will only process your personal information:

• with your explicit consent;
• where it is necessary to carry out actions for the conclusion or performance of a contract with you;
• where it is necessary for us to comply with a legal obligation; or
• where we can show legitimate grounds for processing your personal information.

6.2 Cookies. For more information on our use of cookies please refer to our Cookie Policy.

6.3 Messages. We may use your identifying information to send you administrative messages or updates about our website.

6.4 Promotional messages. We may also sometimes send you promotional messages, but you may choose to opt-out of them.

6.5 Targeted content. We may use your personal information to provide you with targeted content through our website in a completely automated process.

7. Disclosure

7.1 Sharing. We may share your personal information with third parties for the purposes of fulfilling our obligations to you, including with:

• other companies or divisions within our group;
• our contractors who help us meet our obligations to you, including those that help us understand your personal information; or
• third parties or regulators as required by applicable law.

7.2 Honour this policy. We will require anyone that we share your personal information with to honour this policy whenever possible in terms of applicable law.

7.3 Mandatory disclosure. We may disclose personal information, in accordance with POPIA, to third parties if required for legal reasons, such as if required by the relevant authorities or a court order.

7.4 Marketing purposes. We may disclose aggregate statistical information that we derive from your and other people’s personal information to our advertisers or business partners.

7.5 Personnel. We may need to disclose personal information to our personnel to do their jobs, but will not do so unnecessarily.

7.6 Change of ownership. We may assign our rights to the personal information we process to our new owners if our ownership changes for any reason.

8. Storage

8.1 Access. You may ask us to provide you with a description of the personal information that we hold on you, correct or update it or delete it (provided that we do not need it to fulfil our obligations to you or applicable law does not require us to keep it). We will take all reasonable steps to verify your identity before doing so. We may charge a fee to recoup our costs associated with this request if there is a cost to us associated with it and provided that applicable law allows us to do so. Please contact us with your name and any other information needed to identify you correctly if you want access to information or want us to correct, update or delete it.

8.2 Accuracy. We will do our best to keep your personal information that we collect accurate, complete, and up to date.

8.3 Participation. We may ask you to update your personal information from time to time, and we will take steps to verify your identity to prevent unauthorised access when doing so.

8.4 Retention. We will only keep your personal information for as long as is necessary to fulfil our obligations to you, unless you have given us permission to keep it longer or we are otherwise legally allowed to do so. We retain the copyright in our databases of personal information.

8.5 Notification of breach. Where we have reasonable grounds to believe that an unauthorised third party has accessed your personal information and if required by law, we will notify the relevant Regulator and you of the breach. If the law requires us to notify you, we will provide you with sufficient information to allow you to take protective measures against the potential consequences of the breach.

8.6 Transfer. We may transfer your personal information outside of the country in which it was collected to a foreign country. Personal information may be stored on servers located outside the country in which it was collected in a foreign country whose laws protecting personal information may not be as stringent as the laws in the country in which it was collected. You consent to us processing your personal information in a foreign country with less stringent data protection laws than the country in which it was collected.

8.7 Security. Our website is hosted on a secure server and uses security measures to prevent interference by intruders. We authorise access to personal information only for those employees who require it to fulfil their job responsibilities. We implement disaster recover procedures where appropriate.

9. General

9.1 Updating or removing. You may update or remove your personal information:

• through our website; or
• by contacting us.

9.2 Limitation. We are not responsible for anyone else’s privacy policies or practices. We are not responsible for any personal information you provide to third parties linked to our site.

9.3 Enquiries. Please contact us by email (info@mojaafrica.de) if you have any questions about this privacy policy or how we handle your personal information.