1. Introduction
This Privacy Policy for SIMVIDA Proprietary Limited (Registration number 2020/784560/07) (“Company,” “we,” “us,” or “our“), describes how and why we might collect, store, use, and/or share (“Process“) your (“your”, “you” or the “User”) Personal Information when you use our services including our website at www.simvida.com (the “Website”), download and use our application(s), such as our mobile application or any other application of ours that links to this Privacy Policy (the “Services“).
The Company is a private company incorporated in accordance with the laws of the Republic of South Africa, and this Privacy Policy has been prepared (where applicable) based on South African laws and regulations.
For purposes of this Privacy Policy, “Personal Information” has the meaning given to it in the Protection of Personal Information Act 4 of 2013, as amended (“the Act”) and includes your name, e-mail address, online identifier and the like.
2. Questions or concerns
Reading this Privacy Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not proceed or use our Services but contact us first using the information provided at the end of this document.
3. What information do we collect?
Personal Information you disclose to us
We collect Personal Information that you voluntarily provide to us when you register for the Services, express an interest in obtaining information about us or our Services, when you use the Services, or otherwise when you contact us. The Personal Information that we collect furthermore depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. Should you sign a subscription agreement with us to access the Company’s platform, this agreement will contain further information regarding the Personal Information that is processed by the Company.
The Personal Information we collect may include the following:
Your name and surname
Your email address
Your telephone or mobile number
The Personal Information we collect may include Special Personal Information such as biometric information, but this will only be done with your consent and in accordance with the Act.
We do not knowingly collect Personal Information from children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. We may process a child’s Personal Information as part of the Services but only when you provide this to us as the child’s parent or guardian.
Application Data
If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:
Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s bluetooth, calendar, camera, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server).
Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device’s settings.
This Personal Information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.
Personal Information automatically collected
Some information such as your Internet Protocol (IP) address and/or browser and device characteristics are collected automatically when you visit our Website and may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Controls for do-not-track features
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.
4. Why do we process your information?
We Process your Personal Information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your Personal Information for other purposes with your consent including where you sign a subscription agreement with us for use of the Company’s platform.
5. What legal basis do we rely on to process your information?
We only Process your Personal Information when we believe that it is necessary and we have a valid reason to do so, and then this will be done reasonably and in accordance with applicable law.
6. When and with whom do we share your personal information?
We may collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your Personal Information, but this data does not directly or indirectly reveal your identity.
We may share Personal Information in specific circumstances for example with our service providers or if required to do so in law. For more information on who we may share your Personal Information with, please see our Promotion of Access to Information Manual (“PAIA Manual”) which may be accessed by using the following link simvida.com/paia-manual
Our application(s) may include links to third party websites and a third-party hosted “offer wall.” Such an offer wall allows third-party advertisers to offer their services to Users in return for the acceptance and completion of an offer document. Such an offer wall may appear in our application(s) and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will be brought to an external website belonging to other persons and will leave our application(s). A unique identifier, such as your user ID, will be shared with the offer wall provider.
We also may need to share your Personal Information in the following situations:
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honour this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
With Your consent: We may disclose your Personal Information for any other purpose with your consent.
7. Do we use cookies and other tracking technologies?
When and where are cookies used?
Cookies are allocated during the registration process for Services. These cookies will hold information collected during your registration and will allow the Company to recognise the User as a customer and provide the User with the Services that the User requires.
How can a User refuse or opt out of cookies?
You will be prompted when accessing the Website as to whether you consent to such cookies or whether you choose not to receive cookies other than cookies necessary for the proper functioning of the Website. if you do not accept cookies, you may not be able to use some parts of our Service..
8. Is your information transferred internationally?
Please be advised that the Website is hosted in the cloud by Amazon Web Services (AWS). The Company may furthermore outsource the Processing of Personal Information to third party operators from time to time and in so doing transfer Personal Information outside the borders of South Africa. For more information in this regard, please see our PAIA Manual which may be accessed by using the following link simvida.com/paia-manual
9. How long do we keep your information?
We keep your Personal Information for as long as is necessary for the purpose outlined in this Privacy Policy, but for a minimum period of at least 5 (five) years, unless otherwise required by law.
10. How do we keep your information safe?
We protect your Personal Information through a system of organisational and technical security measures. Although absolute security cannot be guaranteed on the internet, we have in place reasonable technical and organisational security measures to protect your Personal Information. Although we will do our best to protect your Personal Information, transmission of Personal Information to and from our Services is at your own risk. You should only access the Services within a secure environment.
For more information in this regard, please see our PAIA Manual which may be accessed by using the following link simvida.com/paia-manual
11. Data accuracy
It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us.
12. Your rights with respect to your personal information
You have the right to request us to confirm which of your Personal Information we hold. You may also request for your Personal Information to be corrected, destroyed or deleted. For more information on this and how to exercise these rights, please see our PAIA Manual which may be accessed by using the following link simvida.com/paia-manual
13. Consent and withdrawal of consent
Reading this Privacy Policy will help you understand your privacy rights and choices. By continuing to use the Services you agree to the terms of this Privacy Policy and consent to us Processing your Personal Information.
We rely on your consent to Process your Personal Information. You may object to the Processing of your Personal Information and withdraw your consent at any time by contacting us by using the contact details provided below. Please note that this will not affect the lawfulness of the Processing of your Personal Information before its withdrawal, nor when applicable law allows, will it affect the Processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
The prescribed forms for exercising these rights are attached to our PAIA Manual available on our website at simvida.com/paia-manual.
14. Updates to this privacy notice
We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.
15. Contact information
Should you wish to contact us regarding this Privacy Policy or your Personal Information please email us at contact@simvida.com or see our PAIA Manual at simvida.com/paia-manual.
Simvida Proprietary Limited · Registration number 2020/784560/07
35 Ballyclare Drive, Ballyoaks Office Park, Lacey Oak House, Bryanston, 2021
Directors: E Maree