Privacy policy

01 INTRODUCTION

This Privacy Policy explains Our views and practices regarding the collection, processing, use, disclosure and transfer of Your information by Us, both in respect of: (i) Use of Our Site; and (ii) the processing of information as part of Our business separately from use of Our Site.

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02 INFORMATION WE MAY COLLECT FROM YOU

We receive and store information, including personal information, about You and Your use of Our Site. This information is gathered in a number of ways, as further set out below. In this Privacy Policy, the term “personal information” has the same meaning as the meaning given to it in the Protection of Personal Information Act, 4 of 2013 (when it comes into full force and effect) (the POPI Act), as amended from time to time, and means, inter alia, information that can be used to uniquely identify or contact You. Any other information (non-personal information) is information that does not permit direct association with You. We may collect, process, use, disclose and transfer non-personal information for any purpose. You can choose not to provide personal information that We may request of You. You acknowledge that Your choice not to provide Us with personal information may affect Our ability to interact with You, for example, if collection of the personal information from You is required by Applicable Law.

We may collect and process the following personal information about You:

information related to You and Your use of Our Site where You have provided Us with Your personal information, including but not limited to: Your online activity, correspondence and information provided through Our grievance submission mechanism (such as Your name, contact details, country, eligibility criteria and description of Your grievance);

Your name and contact information that You have provided to Us so that We may contact You, including by way of Our newsletter (if You have consented to receiving Our newsletter);

a record of correspondence if You contact Us;

information that You provide when Your report a problem with Our Site;

information obtained from surveys that We may ask You to voluntarily complete from time to time, which We use for research purposes;

information posted by You pursuant to reviews of Our Site; and

any other information that may be necessary: (i) to carry out actions for the conclusion or performance of a contract to which You are a party, whether as a customer or a service provider; (ii) for You to provide to Us as part of the “Know Your Client” (KYC) procedures We are required to comply with internally and in terms of Applicable Law); (iii) to comply with an obligation imposed on Us by Applicable Law; (iv) to protect Your legitimate interest; (iv) to pursue a legitimate interest of Ours or of a third party to whom the information is supplied.

Consent in respect of Special Personal Information.

Where We collect information from You and We are required, as part of Our obligations under Our KYC processes and/or Applicable Law, to undertake background and or criminal searches and to process other forms of special personal information, We will notify You of this and, by providing such personal information, You consent to Our performing such checks and processing the results of such searches to the extent required in order for Us to meet Our obligations (and to Our using third party service providers to do so if necessary).

 

03 INTERNET PROTOCOL ADDRESSES

We may collect information about Your device, including (where available) Your internet protocol address, operating system and browser type, for system administration, and to report aggregate information to Our advertisers and/or service providers. This is statistical information about Your browsing actions and patterns, and You cannot be identified by this information.

04 WHERE WE STORE YOUR PERSONAL INFORMATION

The information that We collect from You may be transferred to, and stored at, a destination outside of South Africa. It may also be processed by staff members operating outside of South Africa who work for Us or for one of Our service providers (including but not limited to payment processors, cloud service or other IT providers, and other companies that provide services to Us). Such staff members may be engaged in, among other things, the provision of the service or the provision of maintenance and support services. Most of the information that We collect from You is stored on DropBox (which We understand has its servers located across the United States), Mimecast (which We understand has its servers located in and outside of the European Economic Area) and on Our email servers (located in South Africa). Our service providers are subject to provisions materially similar to those set out in clause 13. By submitting Your personal information, You agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that Your information is treated securely, in accordance with this Privacy Policy and in accordance with the terms of the POPI Act and all Applicable Law, as amended from time to time.

05 SECURITY

We take information security seriously and use reasonable administrative, technical, physical and managerial measures to protect Your personal information from unauthorised access.

Unfortunately, no security system can be guaranteed to be completely secure. Accordingly, although We will do Our best to protect Your personal information, We cannot guarantee the security of Your information transmitted to or through Our Site or otherwise provided to Us by You, and any transmission is at Your own risk. By using Our Site, You agree that We can communicate with You electronically regarding security, privacy, and administrative issues relating to Your use of Our Site.

We will not be liable for any access to Your personal information that is obtained by any third party through Your failing to adequately restrict access to Your device or Your personal information.

06 USE MADE OF THE INFORMATION

We use information and personal information held about You and other Users in the following ways and any other ways expressly agreed with You in writing:

to ensure that Content on Our Site is presented in the most effective manner for You, and for Your computer or other device;

to communicate with You as set out in these Inspired Evolution Terms;

to provide You with industry news and information that You request from Us or which We feel may interest You (such as newsletters and press releases about new investments closed by Us), where You have expressly consented to be contacted for such purposes;

to determine Your general geographic location, to enforce the terms of this Privacy Policy and the Inspired Evolution Terms;

to carry out Our obligations required to enter into contracts with You or arising from any contracts entered into between You and Us, if any, including the Inspired Evolution Terms;

to allow You to participate in interactive features of Our Site (if any), when You choose to do so; and

to notify You about changes to Our Site, or to the Inspired Evolution Terms.

If You do not want Us to use Your information in this way, or to pass Your details on to Our service providers or third parties, please let Us know when concluding an agreement with us, tick the relevant box situated on the form on which We collect Your information or by responding to the emails We send You in this regard. You can also exercise this right at a later time by contacting Us at info@inspiredevolution.co.za.

In addition, We may use other companies, agents or contractors to perform services on Our behalf or to assist Us with the provision of access to Our Site to You and for the implementation of contracts We have concluded with You. For example, we engage services providers to provide services required to provide Our services to You, communications, infrastructure and IT services, personalise and optimise Our Site, analyse and enhance data, and process consumer surveys. In the course of providing such services, these service providers may have access to Your personal information. We do not authorise these service providers to use or disclose Your personal information except in connection with providing the services We request of them. Our service providers provide services to Us subject to the provisions materially similar to those set out in clause 13.

07 DISCLOSURE OF YOUR INFORMATION

We may disclose Your personal information if We reasonably believe that access, use, preservation or disclosure of such information is reasonably necessary to: (a) satisfy any Applicable Law, legal process, or governmental request; (b) enforce these Inspired Evolution Terms and other applicable terms of use and agreements with You, including investigation of potential violations thereof; (c) detect, prevent, or otherwise address illegal or suspected illegal activities, security or technical issues; or (d) protect against harm to the rights, property or safety of Us, Our Users or the public as required or permitted by Applicable Law. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. In connection with any reorganisation, restructuring, merger or sale, or other transferring of assets We reserve the right to transfer information, including personal information, provided that the receiving party agrees to respect Your personal information in a manner that is consistent with this Privacy Policy.

08 YOUR RIGHTS

You have the right to ask Us not to process Your personal information for marketing purposes. We will usually inform You (before collecting Your information) if We intend to use Your information for such purposes or if We intend to disclose Your information to any third party for such purposes, and where required under Applicable Law We will request that You provide Your express consent to such use or disclosure. You can exercise Your right to prevent such processing by letting Us know when We conclude a contract with You, or by checking certain boxes on the form on which We collect Your information or by responding to the emails We send You in this regard. You can also exercise this right at a later time by contacting Us at info@inspiredevolution.co.za.

09 YOUR RIGHTS

Where You provide us with personal information of any third party, You are the responsible party and We are the operator in respect of that personal information (as such terms have been defined in the POPI Act) and, acting as the operator, We will comply with Our obligations under the POPI Act when they come into full force and effect, including, but not limited to the following:

We shall process such personal information only with Your knowledge or authorisation and treat such personal information as confidential and will not disclose it, unless required by Applicable Law or in the course of the proper performance of Our duties;

We hereby agree with You that We shall establish and maintain security measures to secure the integrity and confidentiality of any personal information that We process for You, and will follow the requirements in section 19 of the POPI Act (when they come into full force and effect) and shall not provide or give access to such personal information to any third party without Your prior, written consent; and

We undertake to as soon as reasonably possible notify You where there are reasonable grounds to believe that the third-party personal information processed by Us has been accessed or acquired by any unauthorised person.

10 ACCESS TO INFORMATION

The POPI Act (when it comes into full force and effect) gives You the right to access personal information held about You. Your right of access can be exercised in the manner set out in section 25 of the POPIA read with sections 18 and 53 of the Promotion of Access to Information Act 2 of 2000, by submitting an access request to Our information officer at info@inspiredevolution.co.za. Any access request may be subject to a fee for meeting Our costs in providing You with details of the personal information We hold about You. If You have a question regarding Our privacy practices or want to exercise Your rights regarding Your personal information, please contact Us at info@inspiredevolution.co.za

11 CONTACT US

If You have questions concerning the Inspired Evolution Terms, including the Privacy Policy in this clause 12, including the treatment of Your personal information and/or Our use of Cookies and other technologies, please contact Us via email at the addresses specified in clause 19.

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