Introduction
Universal Link Group (Pty) Ltd (Registration number 2016/099708/07) is fully committed to protecting its and all its associated companies (collectively “Universal Link Group”) customers and visitors’ privacy throughout the entire business process. We take the protection of personal information (POPIA) Act 4 of 2013, very seriously. The purpose of this policy is to describe the collection, storage, usage, and protection of Universal Link Group’s information with customers or any of the natural or juristic persons.
- Who does this policy apply and relate to?
- Any visitor of / to the Universal Link Group website
- Any and all customers who has ordered and / or requested goods and /or services from Universal Link Group.
Collection of Personal Information
Personal information includes certain information that is:
Automatically collected by Universal Link Group when visited by the customer through the website and / or collected on Registration on our website or any other form of data collecting process. Collected on submission by the customer including optional information that the customer provides to Universal Link Group voluntarily but with the exclusion of the following:
Information that has been provided anonymously so that it does not identify a specific person/s or permanently de-identified information that does not relate or cannot be traced back to the customer specifically. Non-personal statistical information collected and compiled by Universal Link Group and information that the customer has provided voluntarily in an open, public environment or forum including any blog, chat room, community, classifieds or discussion board (this is because the information has been disclosed in a public forum, it is therefore no longer confidential and does not constitute personal information subject to protection under this policy).
Common examples of the types of personal information which Universal Link Group may collect and process include:
- Identification information – such as the customers’ name, date of birth, or identification number of any kind
- Contact information – such as the customers’ phone numbers and / or email addresses
- Address information – such as the customers’ physical and / or postal address
- Demographic information – such as the customers’ gender and / or marital status.
Sensitive Personal Information
Depending on the goods or services that the customer requires, Universal Link Group may also collect sensitive personal information including the customers’:
- Financial Information – such as the customers’ bank account details
- Sensitive Demographic Information – such as the customers’ race or ethnicity
- Medical Information – such as information about the customers’ physical and/or mental health
- Criminal Information – such as information about the customers’ commission or alleged commission of any offence or about any related legal proceedings
- Employment Information – all information including the customers’ membership of a trade union
Acceptance Required
It is mandatory that the customer accepts all the terms of this policy when the customer requests and / or orders Universal Link Group’s goods and /or services. If the customer does not agree with the current information in this policy, then the customer may not order and /or request Universal Link Group’s goods and /or services.
Legal Capacity
The customer may not access Universal Link Group’s website or order Universal Link Group’s goods or request Universal Link Group’s services if the customer is younger than 18 years old or does not have the legal capacity to conclude legally binding contracts.
Deemed Acceptance
These Terms and Conditions form the entire Contract between You and Universal Link Group in respect of Your access to and use of the Site and the Content and supersedes all prior understandings, purchase orders, agreements, and arrangements. Any unauthorized use of the Site Terminates this Agreement. By accepting this policy in its entirety, the customer is deemed to have read, understood, accepted, and agreed to be bound by all of its terms found herein.
Customers Obligations
The customer may only provide Universal Link Group with his/her/its own personal information or the information of another data subject where the customer has such (third party customer) permission to do so.
Changes
Universal Link Group may change the terms of this policy at any time by updating Universal Link Groups’ web pages. Universal Link Group will notify the customer of any changes by placing a notice in a prominent place on the website or by sending the customer an email detailing the changes that Universal Link Group has made and indicating the date that this policy was last updated. If the customer does not agree with the changes, then the customer must stop using the website and Universal Link Group’s goods and / or services. If the customer continues to use the website or Universal Link Group’s goods and /or services following notification of a change to the terms, the changed terms will apply to the customer and the customer will be deemed to have accepted those updated terms.
- Collections On Registration
- As soon as the customer:
- Registers on Universal Link Group’s website
- Subscribe to a newsletter
- Register on Universal Link Group’s blog and/or any forum
- Submitting the customers’ details via a form/s
the customer will no longer be anonymous to Universal Link Group as some information could include personal information as indicated below:
This personal information will include the customers’:
- Name and Surname
- Email Address
- Telephone Numbers
- Username and Password
- Company Name, Company Registration Number, VAT number
- Postal Address and / or Street Address
Universal Link Group will use this personal information to update the customers’ account, fulfil the customer orders provide additional services/products and information to the customer as Universal Link Group reasonably considers appropriate and for any other purposes set out in this policy.
Orders and/or Requests
When the customer orders Universal Link Group’s goods and/or requests its services, the customer will be asked to provide Universal Link Group with additional information on a voluntary basis (goods and / or services information).
Browser
Universal Link Group automatically receives and records Internet usage information on Universal Link Group’s server logs from the customers’ browser, such as the customers’ Internet Protocol address (IP address), browsing habits, clicking patterns, versions of software installed, system types, screen resolutions, colour capabilities, plug-ins, language settings, cookie preferences, search engine keywords, JavaScript enablement, the content and pages that the customer access on the website, and the dates and times that the customer visit the website, paths taken, and time spent on sites and pages within the website (full usage information report). Please note that other websites visited before entering Universal Link Group’s website might place personal information within the customers’ URL during a visit to such other website, and Universal Link Group have no control over such websites and is not accountable for it in this respect. Accordingly, a subsequent website that collects URL information from the customer may log some personal information.
Cookies
Universal Link Group may place small text files called ‘cookies’ on the customers’ device when the customer visits Universal Link Group’s website. These files do not contain personal information but they do contain a personal identifier allowing Universal Link Group to associate the customers’ personal information with a certain device. These files serve several useful purposes for the customer which includes allowing the customer access to restricted and controlled content.
Customising Universal Link Group’s website’s functionality to the customer individuality by enabling Universal Link Group to identify the customers’ preferences which assists Universal Link Group to target deliverable advertising where appropriate in agreement with the applicable laws.
It also greatly enhances Universal Link Group’s website performance and granting third parties’ access to provide goods and / or services to Universal Link Group’s website
The customer’s internet browser generally accepts cookies automatically but the customer can at their discretion change this setting at any time. The customer can also delete cookies manually. However, no longer accepting cookies or deleting them will prevent the customer from accessing certain aspects of Universal Link Group’s website where cookies it is deemed necessary. Most websites use cookies. For more information in this regard go to http://www.allaboutcookies.org.
Third Party Cookies
Universal Link Group’s business partners and associates use their own cookies or widgets on Universal Link Group’s website. Universal Link Group has no permission to access or control over them. Information collected by any of those cookies or widgets is governed by the privacy policy of the organisation by whom it was created and not by Universal Link Group.
What are Single Pixels and Web Beacons?
Universal Link Group’s website may contain electronic image requests (called a single-pixel gif or web beacon request) that allows Universal Link Group to count page views and to access cookies. Any electronic image viewed as part of a web page (including an ad banner) can act as a web beacon. Universal Link Group’s web beacons do not collect, gather, monitor or share any of the customers’ personal information. The purpose is to compile anonymous information about Universal Link Group’s website, for the usage by Universal Link Group.
Optional Details
The customer may also provide additional information to Universal Link Group on a voluntary basis. This includes content that the customer decides to upload to or download from Universal Link Group’s website, or when the customer enters competitions, takes advantage of promotions, responds to surveys, order certain additional goods and / or services, or otherwise use the optional features and functionality of Universal Link Group’s website.
Call Recording
Universal Link Group may monitor and record all telephone calls received by the customer for both quality and clarity purposes and to protect both the company and the customer.
Universal Link Group may use or process any goods and / or services information, including optional/ additional information that the customer provides to Universal Link Group for the purposes that the customer indicates when entering into the agreement. Processing includes gathering the customers’ personal information, recording it, and combining it with other personal information. Universal Link Group generally collects and processes the customers’ personal information for various purposes, including:
For goods and / or services purposes – such as collecting orders or requests for and providing Universal Link Group’s goods and / or services
For Marketing purposes – such as pursuing lawful related marketing activities and services
For Business purposes – such as internal audit, accounting, business planning, joint ventures, disposal of business and / or other proposed and actual and contractual transactions
For Legal purposes – such as handling claims, complying with regulations and / or pursuing good governance.
Universal Link Group may use the customers’ usage information for the purposes described above including the storage of the customers’ information in order that the customer will not have to re-enter it during the customers’ next visit to the website. To measure and monitor website usage such as total number of visitors and pages accessed. Tracking entries, submissions and statuses created by the customer in any promotions or other activities relating to the customers’ usage of the website.
Collection Consent
The customers’ consent will be obtained to collect personal information in accordance with applicable law by Universal Link Group. The customer provides Universal Link Group with any registration information or optional information.
Our Obligations and Commitments
Universal Link Group may use the customers’ personal information to fulfil the company’s (Universal Link Group’s obligations and commitments to the customer. Messaging, Emailing and Updates (automatic or otherwise). Universal Link Group may send administrative messages and email updates to the customer about the website. Universal Link Group may wish to provide the customer with information about new goods or services in which Universal Link Group thinks the customer may be interested. Accordingly, Universal Link Group may also send the customer primarily promotional messages. The customer can choose to opt-out of promotional messages at any time.
Sharing Information Disclosure
Universal Link Group may share the customers’ personal information with or for the following reasons. Divisions or associated companies within Universal Link Group so as to provide joint content and services like registration, for transactions and customer support, to help detect and prevent potentially illegal acts and violations of Universal Link Group’s policies, and to guide decisions about Universal Link Group’s products, services and communications (Universal Link Group will only use this information to send the customer marketing communications if the customer requested their goods or services. In terms of an affiliate, in which case Universal Link Group will seek to require the affiliates to comply with this privacy policy. Universal Link Group’s goods and / or service providers under contract who assists, supports with providing certain goods and / or services or assists and supports with parts of Universal Link Group’s business operations, including fraud prevention, bill collection, marketing, technology services Universal Link Group’s contracts dictate that these goods and / or service providers only use the customers’ information relating to the goods and / or services which they supply or services they perform for Universal Link Group and not for their own benefit
Credit Bureaus to report account information, as permitted by law. Banking partners or associates as required by credit card association rules for inclusion on their list of terminated merchants (if the customer utilises the services to receive payments and the customer meet their criteria). Additional third parties who provide Universal Link Group with relevant services where appropriate.
Disclosure to Regulators
Universal Link Group may disclose the customers’ personal information as required by law or for the purposes of governmental audits.
Law Enforcement
Universal Link Group may disclose personal information if required if served with a subpoena or court order and to comply with any law. To protect the safety of any individual and / or the public and to avoid the violation of Universal Link Group’s customer relationship terms.
Selling of Data
Universal Link Group will not sell personal information. No personal information will be disclosed to anyone except as provided in this privacy policy. In terms of marketing, Universal Link Group may disclose aggregate statistics (information in general terms) about the personal information to advertisers or business partners. Employees of Universal Link Group may need to disclose the customers’ personal information to Universal Link Group’s employees that require such personal information to execute their jobs. These employees include Universal Link Group’s management, human resources, accounting, audit, compliance, information technology or any third party other personnel.
What happens when the Ownership Changes?
Should Universal Link Group undergo a change in its ownership, a merger with, an acquisition by, or the sale of assets to, another entity, Universal Link Group may assign Universal Link Group’s rights to the personal information that Universal Link Group processes to a successor, purchaser, or separate entity. Universal Link Group may disclose the transfer on the website should it deem appropriate.
Security
The security of personal information is of paramount importance to Universal Link Group and will always endeavour to do our best to comply with the applicable data protection laws. Universal Link Group’s hosting company will host the website in a secure environment that uses a firewall and other advanced security measures on its servers to prevent intrusion or access from outside intruders. Universal Link Group authorises access to personal information only for those employees who require it to fulfil their job responsibilities. Universal Link Group will implement disaster recovery procedures where appropriate.
Accuracy, Updates, and Retention of Data
Universal Link Group will endeavour to keep the customer’s personal information as accurate, complete, and up to date as is necessary for the purposes defined in this policy. Universal Link Group will from time to time request the customer to update his/her/its personal information on the website. The customer can review or update his/her/its personal information that Universal Link Group holds by accessing the customers’ account online, emailing Universal Link Group, or phoning Universal Link Group. Similarly, Universal Link Group may choose to correct or update his/her/its personal information previously submitted to Universal Link Group, by clicking the relevant menu in any of the pages on Universal Link Group’s website or by contacting Universal Link Group by phone or email. Please note that to better protect the customer and safeguard the customers’ personal information, Universal Link Group takes measures to verify the customers’ identity before granting the customer access to his/her/its account or making any corrections to his/her/its personal information. Universal Link Group will only retain the customers’ personal information for as long as it is necessary to fulfill the purposes explicitly set out in this policy except if retention of records is required or authorized by law or the customer has given consent to the retention of records.
During the period of retention, Universal Link Group will continue to abide by Universal Link Group’s non-disclosure obligations and will not share or sell the customers’ personal information. Universal Link Group may retain the customers’ personal information in physical or electronic records at Universal Link Group’s discretion.
Transferring data to another Country
Universal Link Group may transmit or transfer personal information from the country in which it was collected to a foreign country and process it in that country. Personal information may be stored on servers located outside of the country in which it was collected and that in a foreign country’s laws protecting personal information may not be as stringent/specific as the laws of the country in which it was collected. The customers’ consents to Universal Link Group processing his /her/its personal information in a foreign country whose laws regarding processing of personal information may be less stringent.
Limitations
Universal Link Group are not responsible for, provides no warranties or guarantees, nor makes any representations in respect of the privacy policies or practices of linked or any third-party websites.
Enquiries
Should customers have any questions or concerns arising from this privacy policy or the way in which Universal Link Group handles personal information, please contact Universal Link Group at info@universalmail.co.za.