Sales Cadence (Pty) Ltd (registration 2022/452270/07), trading as ClearToContact ("ClearToContact", "we", "us"), is committed to the highest standards of guarding your personal information when we process it through your use of this website, our services, or any linked applications or platforms (collectively, "the Website"), or when you share your personal information with us in any other manner. This Privacy Policy explains how we protect your privacy and secure your personal data.
ClearToContact is operated by a private company duly registered and operating in accordance with the laws of South Africa. Terms may also be defined in our Terms of Service.
This Privacy Policy aims to give you information on how ClearToContact collects and processes your personal data through any form of your engagement with us. Please read it, along with any other privacy notice we may provide on specific occasions, so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and is not intended to override them.
This Privacy Policy complies with, and facilitates the obligations required by, the South African Protection of Personal Information Act, No. 4 of 2013 ("POPIA"), as amended. Users from jurisdictions other than South Africa should note that we comply with South African data protection law when processing personal information, as we are a South African entity operating in the South African market. Should foreign law apply to your use of the Website in any way, please contact us and we will engage with you on its application and your rights.
We do not intentionally process special categories of personal data (such as information about health, religion, race or biometric data). Please do not supply us with such information.
ClearToContact acts as the "Responsible Party" for your personal data where we determine the processing operations regarding your personal data. When customers use the ClearToContact platform to process their own contact and suppression data, we act as an "Operator" on behalf of that customer as Responsible Party, and the privacy terms of that customer apply to that data; this Privacy Policy is focused on our processing as a Responsible Party.
We have appointed an Information Officer ("IO") who is responsible for overseeing questions concerning this Privacy Policy. Should you have any questions, including requests to exercise your legal rights, please contact the IO using the details below.
You have the right to lodge a complaint at any time with the Information Regulator (South Africa). We would, however, appreciate the chance to address your concerns before you approach the Regulator, so please contact us in the first instance.
The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share your data. We do not control these third-party websites and are not responsible for their privacy statements. We urge you to read the privacy policy of each third party you interact with.
Personal data means any information about a natural or juristic person from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer ("process") the following kinds of personal data:
We also collect, use and share Aggregated Data, such as statistical or demographic information, for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law, as it does not directly or indirectly reveal your identity. If we combine Aggregated Data with your personal data so that it can identify you, we treat the combined data as personal data under this Privacy Policy.
If we are required to collect personal data by law or under a contract with you, and you do not provide that data when requested, we may be unable to perform the contract we have or are trying to enter into with you. We will notify you if this is the case at the time.
Direct interactions: you may give us your data by filling in forms on the Website, applying for the design partner programme, consulting with us, using our services, providing services to us, requesting information, or corresponding with us.
Automated technologies: as you interact with the Website, we may automatically collect Technical Data and Usage Data through server logs and similar technologies.
Third parties or publicly available sources: we may receive personal data about you from analytics providers, hosting and form providers, providers of technical, financial or payment services, and publicly available sources.
We will use your personal data only when the law permits and for valid reasons. Typically, we will use your personal data in the following circumstances:
Specifically, we use Application Data to assess fit for the design partner programme, respond to your application, and send you the research findings where you have requested them; Client, Transaction and Financial Data to provide and bill for our services; Technical and Usage Data to administer and secure the Website; and Marketing and Communications Data to send you updates you have requested, with an opt-out in every message. Note that we may process your personal data on more than one lawful ground depending on the purpose. Please contact us if you need details about the specific legal ground we rely on.
You will receive communications from us if you have requested them or applied to the design partner programme and have not opted out. If you no longer want to receive marketing from us, unsubscribe using the link in any email or contact us. Opting out of marketing will not affect personal data we process on another lawful basis. We will obtain your express opt-in consent before we share your personal data with any entity outside our group for their marketing purposes.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so. We may process your personal data without your knowledge or consent where this is required or permitted by law.
We may share your personal data with: service providers acting as operators (including hosting, form-handling, IT and system administration providers); professional advisers, including legal practitioners, bankers, auditors and insurers; South African or other national authorities where required by law; and third parties to whom we may sell, transfer or merge parts of our business or assets, in which case the new owners may use your personal data in the manner set out in this Privacy Policy. All third parties are required to uphold the security of your personal data and to process it in compliance with the law and only on our instructions.
Some of our service providers (such as form-handling and hosting providers) may process your data outside of South Africa. Whenever your personal data is transferred out of South Africa, we ensure a similar level of protection by transferring only to countries with appropriate data protection legislation, or by using contracts and clauses that ensure the personal information is processed and secured lawfully.
We have implemented security measures to prevent your personal data from being accidentally lost, misused, accessed without authorisation, altered or disclosed, including encryption where possible and periodic deletion of information we no longer need. We restrict access to your personal data to those employees, agents, contractors and third parties who have a proper business need to know; they process it only on our instructions and are bound by a duty of confidentiality. We have procedures for handling any suspected personal data breach, and will notify you and the Regulator of a breach where legally required.
We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including legal, accounting or reporting requirements. In determining retention periods, we consider the amount, nature and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure, the purposes of processing, and applicable legal requirements. In some instances we may anonymise your personal data for research or statistical purposes, in which case we may use that information indefinitely without further notice to you. You may request deletion of your data as set out below.
This Website does not use advertising or tracking cookies. Our hosting and form providers may collect standard server logs (such as IP address and browser type) for security and uptime purposes. If cookies are introduced in future, this policy will be updated first.
You have rights in relation to your personal data where we are the Responsible Party. You may:
To exercise any of these rights, contact privacy@cleartocontact.co.za. You will not pay a fee to exercise your rights, although we may charge a reasonable fee, or refuse the request, if it is clearly unfounded, repetitive or excessive. We may need to request specific information from you to confirm your identity, as a security measure. We endeavour to respond to all legitimate requests within one month; complex or multiple requests may take longer, in which case we will keep you updated. Note that other South African legislation may require us to continue processing certain data notwithstanding a withdrawal of consent, for example to comply with anti-corruption or crime-fighting legislation.
This Privacy Policy is subject to change and will be effective once the amended version is uploaded to the Website. Your continued use of the Website constitutes acceptance of the amended policy. It is important that the personal data we hold about you is accurate and current; please keep us informed if your personal data changes during your relationship with us.