PRIVACY POLICY

We, Blue Code Africa (hereinafter also referred to as “we” or “us”), thank you for your interest in BLUE CODE and want to ensure that you feel safe when using the BLUE CODE website (“BLUE CODE”). We take the protection of your personal information very seriously. It goes without saying that we observe the applicable data protection regulations, in particular South Africa’s Protection of Personal Information Act (“POPIA”).

1. PURPOSE
This policy explains how we process your personal information.

2. PERSONAL INFORMATION
We collect personal information on submission when you contact us via the website at the following e-mail address: info@bluecodeafrica.com

3. ACCEPTANCE
You must accept this policy before contacting us.

4. COLLECTED ON SUBMISSION
We collect your name, contact details, and communication data when you contact us.
Communication data may include both the content of communications and communications metadata (e.g. when communications were made and to whom), depending on your cookies preferences. See clause 6 for more details.
We may ask you to provide us with various personal information as we are required by law to verify the identity of our clients.

5. COLLECTED AUTOMATICALLY
We collect your internet usage information when you visit this website.
Each time a user accesses the BLUE CODE website, BLUE CODE automatically logs the following information:

• Date and time of access
• Name of the accessed page
• Transferred information volume
• Access status (file transferred, file not found etc.)
• Identification information of the operating system used and the user’s terminal device
• Name of the provider of the user’s Internet access

This information will be collected, processed, and used for the purpose of enabling the use of BLUE CODE, system security, and technical administration of the network infrastructure. In these purposes lies our legitimate interest in information processing. A comparison with other information sets or a transfer to third parties, even in excerpts, does not take place. It is not possible to identify a user individually. The logs are deleted at regular intervals. A longer storage only takes place if this is necessary to investigate detected attacks on our website or to pursue legal claims. Concerning the collection of information for the provision of the website and the storage of the information in log files, the user has no right to object, as these are absolutely necessary for the operation of the website.

6. COOKIES
We use cookies and similar technologies to improve your browsing experience on our website, understand how you interact with us and, in some cases, so we can show you ads based on your browsing habits.
The cookies collect data that relates to your general internet usage to customise your experience on our website. This data includes your IP address, browser versions, number of visits and other data relating to your navigation of the internet and our site. Cookies do not collect sensitive information like financial information or passwords.
We hold any personal information you submit in our own secure databases and to some extent for marketing purposes in the databases of third parties engaged by us (subject to obligations regarding privacy and confidentiality) to conduct electronic direct marketing subject to all legislative requirements. User ID tracking for AdWords is also set up, which
allows better understanding of repeat customers.
You can refuse to accept cookies by activating the settings on your internet browser, however, this can affect your overall browsing experience.

7. PURPOSE FOR COLLECTION
We may use your personal information that you provide to us for the purposes that you indicated when you agreed to provide it to us.

8. USE
We may use your personal information:
to verify your identity;

• to fulfil our obligations to you;
• to enable the use of BLUE CODE, system security, and technical administration of the network infrastructure
• to improve our services to you;
• to provide you with our marketing material (including electronic communications) related to our services. You can at any time unsubscribe from receiving marketing material.

9. LEGAL BASIS FOR PROCESSING
Necessary for the performance of contract:

• to fulfill our obligations to you

Consent:

• to provide our marketing material.

Legitimate Interest:

• to enable the use of BLUE CODE, system security, and technical administration of the network infrastructure;
  to assist and improve our services to you (customer support or customised marketing).

Permitted by law:

• to verify your identity.

When your consultation is related to the exercise of your rights

10. SHARING

We may also share your information with selected third parties Specifically, these are the following categories of recipients:

• Companies of the BLUE CODE Group: We may share your personal information with other companies of the BLUE CODE Group. This takes place insofar as there is an administrative interest in the exchange of information.
• Subcontractors: We may transfer your personal information to subcontractors and other third parties involved in the provision of services to fulfill contractual obligations with you or for other purposes described in this Privacy Statement. All parties we share information with are contractually bound to keep the shared information confidential and may only keep information for as long as is necessary. We make sure they are aware of their obligations and that they take them seriously.

We hereby clarify that we do not sell personal information to third parties for advertising purposes.

11. DISCLOSURE
We may disclose personal information to third parties:
when such disclosure is necessary to protect the legitimate interests (safety, property or other rights) of Blue Code Africa, the director or any other person, or where required or permitted by law;
if we are under a duty to disclose your personal information in order to comply with any legal obligation.

12. AUTOMATED DECISION-MAKING

Automated decisions mean that a decision that affects you is made automatically based on a computer determination (using software algorithms) without our human review. No automated decision making takes place in connection with the BLUE CODE system.

13. SECURITY
We take all reasonable and appropriate technical and organizational security measures to keep your personal information secure. We regularly backup all your personal information. Our website is hosted on a secure server and uses security measures to prevent interference by intruders, but we cannot guarantee the absolute security of it.
In the case of the collection and processing of personal information, the information is transmitted in encrypted form to prevent misuse of the information by third parties. Our security measures are continuously revised in line with technological developments.

14. REFERENCING — LINKS TO OTHER WEBSITES
Our website contains links to other websites for referencing purposes. If you access these links, the operators of such websites may collect information from you which will be used by them in accordance with their own privacy policies and may differ from ours. We are not responsible for their privacy practices. Nevertheless, we try to protect the integrity of our website and we welcome any feedback.

15. TRANSFER
We may transfer your personal information outside South Africa to a foreign country for website hosting purposes.
In cases where any other service providers are located in territories outside South Africa that do not offer a level of data protection that are substantially similar to the conditions for lawful processing of personal information of South Africa, we will ensure that we transfer your data with appropriate safeguards in place to ensure keeping your data secure.

16. RETENTION
We will only keep your personal information for as long as is necessary to achieve the purpose for which we collected it, unless there is a lawful basis or legal requirement for us to keep your personal information for a longer period.
As a matter of principle, we keep your e-mail address, cell phone number and other contact information (in case we need to contact you) for the duration of our business relationship with you. In addition, we are subject to a variety of retention obligations which require us to retain your personal information beyond termination or after completion of our business relationship with you.

17. YOUR RIGHTS
We must notify you when any of your personal information is being processed by us, or a third party, or when your personal information has been accessed or taken by an unauthorised person.
You may access, update, rectify, or remove the personal information you have submitted to us by contacting us.
In certain cases, you may also:

• object to us processing and using your data, or to transferring your data.
• request the identity of all third parties, or categories of third parties, who have, or have had access to your personal information.
• submit a complaint to the Regulator or institute civil proceedings regarding alleged interference with the protection of your personal information.

18. CONTACT INFORMATION
If you have any questions about our processing of your personal information in terms of this policy, please email us on info@bluecodeafrica.com

LAST UPDATED: 17/11/2020