1. INTRODUCTION

Blue Coat IT (Pty) Ltd (“BCI” or “we” or “us” or “our”) respects your privacy, and protection of your personal information is important to us. BCI’s Terms and Conditions, available on our website at www.bluecoat.co.za, at paragraph 23 demonstrate our contractual and statutory obligations to You.

This privacy statement  aims to let you know how BCI will treat any personal information that it may have about you and how you can access such personal information held. Reference made to “POPIA” means the Protection of Personal Information Act 4 of 2013 and reference made to “PAIA” means the Promotion of Access to Information 2 of 2000 as amended.

By visiting our website, communicating electronically with us and using our products and services, you consent to the processing and transfer of your personal information as set out in this privacy statement below. BCI will take all reasonable measures, in accordance with this statement, to protect your personal information and to keep it confidential.

For purposes of this privacy statement, “personal information”, “data subject” and “processing” will have the meanings given to them in the POPIA.

We may collect website usage information using “cookies” which allows us to collect standard internet visitor usage information. Details of all other documents pertaining to terms and conditions of personal information are available on our website.

We reserve the right to amend this privacy statement at any time, without prior notice, by posting the amended statement on our website.

2. APPLICATION OF THE PRIVACY STATEMENT

2.1. Our privacy practices apply to the processing of your personal information collected by us or on our behalf, such as data subjects who use  our website and/or our products and services, and/or who provide us with products and services, customers and any other data subjects who engage with us.

2.2. This privacy statement does not apply to third party websites linked to our website, or websites that link to or advertise on our website.

3. COLLECTION OF PERSONAL INFORMATION

3.1. The personal information may be provided to us by you and/or collected by us when you engage with us and/or on your use of our products and services, and/or when you provide us with your products and services, and/or when you access our website or from third parties (such as regulators).

3.2. The type of personal information we collect will depend on the purpose for which it is collected and used. The specific purpose for which the information is collected will be apparent from the context in which the information is requested including but not limited to when: 

3.2.1. You purchase and/or use our products and services.
3.2.2. You submit enquiries to us or contact us and you may be required to provide your name and surname, identity or passport number, BCI account number, postal or street address, title, contact numbers or email address.
3.2.3. You make use of our website or interact with us on social media, we may collect your non-personal browsing habits and click patterns, email address, IP address, telephone data information, or username and password.
3.2.4. You apply for employment opportunities at BCI, you may be required to provide your name and surname, identity number, employment history and criminal behaviour.
3.2.5. You visit our premises where CCTV cameras are installed.
3.2.6. Where possible, we will inform you of what information is voluntary or mandatory for you to provide to us and the consequences for failing to provide the requested information.
3.2.7. We will only retain your personal information as long as is necessary for the fulfilment of those purposes as have been identified by us and/or as required by law and/or as agreed with you.

4. HOW WE USE YOUR INFORMATION

4.1. Personal information will only be processed for the purposes for which it was collected and/or to comply with legal and regulatory obligations and/or as authorised by law and/or with your consent.

4.2. The purposes for which we process personal information includes, but is not limited to:

4.2.1. Respond to your enquiry.
4.2.2. Provide services or products to you.
4.2.3. Provide access to restricted pages on our website.
4.2.4. Comply with legal requirements or industry codes.
4.2.5. Market or promote our services and products.
4.2.6. Safety and security reasons.
4.2.7. Compile non-personal statistical information about browsing habits, click patterns and access to the BCI website.

5. DISCLOSURE OF INFORMATION

5.1. BCI may disclose your personal information to third parties in certain circumstances, which include, but are not limited to:

5.1.1. Where we have your consent.
5.1.2. Where we are required to do so by law.
5.1.3. To our service providers who are involved in the delivery of products or services to you, where we have agreements in place to ensure that they comply with these privacy terms.

5.2. Third parties who we disclose personal information to include, but are not limited to:

5.2.1. Service providers to BCI.
5.2.2. Accredited debt collection agencies.
5.2.3. Regulators, courts, tribunals and law enforcement agencies.

5.3. We may compile, use and share any information that does not relate to any specific individual and retain all rights to non-personal statistical information collected and compiled by us.

6. TRANSFER OF INFORMATION OUTSIDE SOUTH AFRICA

6.1.We may need to transfer your personal information to another country for processing or storage. We will ensure that anyone to whom we pass your personal information agrees to treat your information with similar protection as provided for in the POPIA.

6.2. We may transfer your information to other countries which do not have similar protection as provided for in the POPIA, with your consent.

 

7. INFORMATION SECURITY

7.1. We take appropriate and reasonable technical and organisational measures to prevent any unauthorised or unlawful access, loss of, damage to or unauthorised destruction of personal information. 

7.2. We have implemented various policies, procedures and standards to safeguard personal information. 

7.3. We regularly verify that the safeguards are effectively implemented and ensure that they are continually updated in line with best practice. 

7.4. BCI has implemented procedures to address actual and suspected data breaches, and undertake to notify you and the relevant regulatory authorities of breaches in instances in which BCI is legally required to do so and within the period in which such notification is necessary. 

7.5. Notwithstanding paragraphs 7.1 to 7.3 above, to the extent permissible by law, we shall not be liable for any loss, claim and/or damage arising from any unauthorised access, disclosure, misuse, loss, alteration or destruction of your personal information.

8. DATA SUBJECT RIGHTS

Subject to the POPIA provisions, you have the right to: 

8.1. Request access to your personal information. 

8.2.Request, where necessary, the correction, destruction or deletion of your personal information. 

8.3. Object to the processing of your personal information. 

8.4. Submit a complaint to the Information Regulator regarding the alleged interference with the protection of the personal information. 

8.5. Institute civil proceedings regarding the alleged interference with the protection of your  personal information.

9. USE OF COOKIES

9.1. BCI may use “cookies” to enhance your experience as a customer (referred to as the “user”). The user’s web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. The user may choose to set their web browser to refuse cookies, or to be notified when cookies are being sent. If the user does so, note that some parts of the website service may not function properly. 

9.2. BCI collects, stores and uses the above mentioned information for the following purposes:

9.2.1. To communicate requested information to the user.
9.2.2. To provide services to the user as requested by the user.
9.2.3. To authenticate the user.
9.2.4. To provide the user with access to restricted pages on this website.
9.2.5. To compile non-personal statistical information about browsing habits, click patterns and access to the BCI website.

9.3. Information detailed above is collected either electronically by using cookies or is provided voluntarily by the User. Users may determine cookie use independently through their browser settings. For purposes of this clause, a cookie means a small computer file created by a web browser to save user information for website.

9.4. Cookies ensure that BCI is able to continually improve its website. We utilise “first party cookies” (originating from us) to simply track the user’s visits between sessions and deliver a more personalised experience. We also utilise “third party cookies” (not originating from us) to provide traffic analysis and tracking. 

19.5. Cookies may be set through our site by our advertising partners. These cookies may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites. They do not store personal information directly, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

10. GOOGLE ANALYTICS’ USE OF COOKIES

10.1. On our website we may use “Google Analytics”, a web analytics service of Google Inc. (“Google”). Google Analytics uses cookies on your device which assists in evaluating the use of our website (more information can be found here: https://policies.google.com/technologies/types). 

10.2. We may use the code “get.anonymizeIP”; “This results in Google shortening your IP address and allowing an anonymised evaluation. The reduction of IP addresses occurs within the EU or the European Economic Area. The IP address submitted by your browser as part of Google Analytics will not be merged with other google data.

10.3. The data collected with the help of cookies is usually transferred to a google server and stored there. Compliance with data protection standards and data rights is ensured by a certification under the EU- US privacy shield. See the Google Privacy statement [https://policies.google.com/privacy] for more information.

10.4. On our behalf, Google uses the data collected through Google Analytics to evaluate the use of our website, to compile reports on the website activities and to provide further information related to the use of the website.

10.5. Data is processed based on your consent by clicking the button on our cookie banner.

10.6. Data is stored for a period of 14 months. You can prevent the storage of the Google Analytics cookies by a corresponding setting in your browser. This may restrict the functionality of our website.

10.7. You may also prevent the collection of data generated by cookies and use of the website (including your IP address) by Google and the processing of such data by Google by clicking the Opt-Out Button located on our cookie banner, this will place an opt-out cookie on your browser. Learn more by clicking on the link below: https://policies.google.com/technologies/managing.  

11. LINKS TO SOCIAL MEDIA PAGES

11.1. BCI has links to their Social Media pages (e.g. Facebook, LinkedIn, Twitter and Youtube, etc). If you visit these websites the Privacy Policy and Terms and Conditions of the specific website apply.

11.2. When you contact us via a contact form, via email or phone we process the personal data you communicate to us, e.g. your name, your email address and your request. The data will be stored in a BCI repository. The data marked as mandatory has to be provided in order to action your request.

11.2.1. We use your data to process and answer your request.
11.2.2. We process data to take steps to action your request.
11.2.3. We store your data if it is necessary to fulfil the purposes mentioned above.

12. DATA SUBJECT RIGHTS

Subject to the POPIA provisions, you have the right to:

12.1. Request access to your personal information.

12.2. Request, where necessary, the correction, destruction or deletion of your personal information.

12.3. Request to BCI to amend incorrect data, or delete your personal data provided the request does not conflict with a statutory or contractual obligation to retain data.

12.4. Object to the processing of your personal information for any reason including direct marketing.

12.5. Submit a complaint to the Information Regulator regarding the alleged interference with the protection of the personal information.

12.6. Institute civil proceedings regarding the alleged interference with the protection of your personal information.

13. CONTACT DETAILS

Privacy enquiries may be submitted to [email protected].

 

14. INFORMATION REGULATOR

You have the right to lodge a complaint with the Information Regulator in writing if you believe that our data processing does not meet the legal requirements, or we did not facilitate the exercise of your rights accordingly as per their website https://inforegulator.org.za/.