PRIVACY POLICY

The privacy of SACCESS users is taken into great consideration by Vodacom and its appointed service providers. We hereby provide  inform you about what kind of personal data that might be collected from you when you use the SACCESS News App (the “App Service”), the SACCESS Web Service (the “Web Service”) or SACCESS News Feed (the “News Feed Service”) (together the “Services”), what this information is used for, these pieces of information are used for, the situations in which the information you provide us will be shared with other parties and the rights you have in relation to our processing of your data.

In this document you will find the following information:

  1. WHO WE ARE AND LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA?
  2. TYPES OF INFORMATION COLLECTED AND FOR WHAT PURPOSE
  3. USE OF GATHERED INFORMATION
  4. DISCLOSURE OF INFORMATION TO THIRD PARTIES
  5. TRANSFER OF PERSONAL DATA
  6. SECURITY OF INFORMATION
  7. DATA RETENTION
  8. NOTE ABOUT CHILDREN
  9. OUR USE OF COOKIES
  10. CHANGES TO THE PRIVACY POLICY
  11. CONTACT AND QUESTIONS
  1. WHO WE ARE AND LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

The Services was  developed by our appointed service provider Njuice AB (SQUID), a Swedish company with company registration number 556801-9201, (“Njuice”) that is based in Stockholm. Njuice is the controller and therefore responsible for the processing of personal data that occurs when you use the Services. The legal basis for processing your personal data is the following.

    1. Contract:

We process your data to the extent necessary as a part of our contractual obligation to provide you with the Services. For example, providing you with news within your selected topics of interest.

    1. Legitimate interests:

We process some of your data \to fulfil our legitimate interests of analyzing user behavior to improve and optimize the Services and communicating with you regarding feedback that you have left us using any of our feedback functions ("Feedback”). Where this is the case, we have analyzed the impact using your data may have on you and limited our use to the data to what is necessary. For example, we have made efforts to minimize the collection and storage of any information derived from your usage of the Services. Vodacom and its appointed service providers do not track the activities taken of a device with a certain IP-address. Instead, each user is assigned a pseudonymized ID which is used to deliver the Services.

    1. Consent:

To the extent that you have provided your consent for the use and storage of your personal data, we rely on your consent for such use and storage of your personal data

    1. Legal obligation:

We may process your data if it is necessary for us to comply with a legal obligation, for example complying with a court order to disclose certain information.

  1. TYPES OF INFORMATION COLLECTED AND FOR WHAT PURPOSE
    1. Purpose of the processing

In order for the Services to work effectively and to constantly improve, we will be collecting different kinds of information from you. Such as information that will enable us to: (a) administer the Services, (b) help us understand how to improve and optimize the Services in future updates, (c) customize the Services to your interests and needs, (d) reply to you if you contact us with Feedback, comments or concerns, (e) provide maintenance and technical support and (f) provide advertising based on your preferred news topics, (g) provide you with more information if we think it necessary.

The data collected is where appropriate, used in an aggregated form to identify usage patterns and trends, analyze problems and requests, and eventually optimize the Services for our users. This aggregated data may be disclosed to third parties.

    1. Information we collect directly from you

We collect the following information from you:

      • Your preferred settings in the Services, such as information concerning the type of news feeds you selected and subsequent amendments. This information is stored dynamically, so as soon as you adjust any settings, the information stored is changed.
      • Any personal data, such as your name, e-mail address, phone number etc. that you provide to us by using the Services’ Feedback functions.
    1. Information collected via technology

Some information is provided to us by your device when you use the Services. We also collect information on how you interact with the Services.

Information we collect from your device is information such as:

      • Date and time that you downloaded the Services
      • Type of device that you are using and the operating system of that device (i.e., what Android or IOS version you are using)
      • Country and language settings on your device
      • Network type used (including information on network provider or wifi)
      • Application type, i.e., what service you are using, such as browser or widget.
      • What articles you read, save, and share.
      • Time spent when visiting our services and reading articles.
      • When you access our Services for the first time, we use the IP-address or other type of identifiers assigned to your device to create an anonymous ID. This ID is used for communication with the Services and tracking of your usage of the Services, which includes what news topics you are interested in.
  1. DISCLOSURE OF INFORMATION TO THIRD PARTIES

For the purposes of providing the Services and for optimizing the Services, we may disclose information under these circumstances:

    1. Service providers

Your personal information may be shared with third party service providers we use to: (a) provide you with the services we offer through the Services, (b) conduct quality surveys, (c) facilitate the user experience and (d) provide maintenance or technical support and (f) provide advertisements in the Services. These service providers are bound not to use your personal data for any other purpose than that to provide the services requested.

At present we share the data with:

Advertisers: We use personalised advertising in our Services. Vodacom provides advertising via programmatic partners. Those partners include cookies and tracking devices such as google analytics as part of the advertising. This allows us to deliver more relevant advertising. We do not collect or use any direct identifying information such as your name, email address, postal address, or phone number for personalised online advertising. We may also provide third party advertisers with aggregated statistical data about our users. This aggregated information might include information, such as preferred news topics of our users, type of device used to access the Services and how the advertisements are performing. The information is used to provide contextual advertising, i.e., relevant on the basis on what type of news you are reading. When providing programmatic advertising, the advertisers may include cookies as part of the advertising. If you do not want this, you need to block cookies in your web-browser.

For advertisements we use the following third-party service providers:

Vodacom SA (PTY) LTD or VodaMedia is a company based in South Africa as a network provider as well as a media house to facility premium and programmatic advertising.  For more information about how they process your data please see: https://www.vodacom.co.za/vodacom/terms/privacy-policy

Analytics

We use third party service providers to help us understand how our Services are used. This implies how the users interact with news and how users behave while using the Services.

      • Google Analytics and Firebase (provided by Google LLC) are integrated into the Services to capture information on how they are being used, including statistics on number of visits and what activities the visitor has carried out. The information collected is used by Google Analytics and Firebase to provide us with detailed reports on what the user has read and visited when using the Services. This is done by using a Google ID or placing a cookie. This helps us to identify how the Services can be improved. The information is transferred to Google in United States. Google may share this information with its partners. You can find more information on Google’s processing in its privacy policy: https://policies.google.com/privacy?hl=en-US.
      • Facebook (provided by Facebook Inc) provides an analytics tool used by Njuice. Therefore, a Special Development Kit (SDK) has been implemented from Facebook. For more information on Facebook Plugins, please go to https://developers.facebook.com/docs/plugins.
      • Adjust (provided by Adjust GmbH Inc) is an analytical tool to monitor user attribution and analytics. For more information on Adjust privacy policy, please go to https://www.adjust.com/terms/privacy-policy/.
    1. Social Network Services (“SNS”)

Some of the features the Services offers require the connection to SNSs (e.g., Facebook, Twitter, etc.). If you decide to use these features and share an article on any of the SNS connected to the Services, we will provide the requested article to the selected third party. When this is done, the SNS twill save the details of the users SACCESS setting including the article being shared. Please note that when you share an article on an SNS, terms of use of that particular SNS apply.

    1. Fulfil legal obligations and manage legal claims

Regardless of any choice you may make regarding your personal information disclosure, Vodacom and its appointed service provider may need to disclose your personal information if it deems it necessary in good faith, in the following circumstances: (a) in connection with legal investigations, (b) to comply with relevant statutory law, (c) to protect copyright, trademark or other property rights of the Services or third parties, or (d) to assist or prevent potential violation of the law.

    1. Other circumstances

We may also share your personal information in the following instances: (a) negotiation of merger, (b) financing, (c) acquisition, (d) dissolution, (e) sale, (f) transfer, (g) insolvency, (h) bankruptcy. In case another company acquires the Services or some of its assets, the personal information we collected will be transferred to that company and it will assume the rights and obligations regarding your personal information described in the Terms and this Privacy Policy.

  1. TRANSFER OF PERSONAL DATA

Our processing of data is primarily carried out through Amazon Web Services with servers based on Ireland so any processing of your personal information will take place within the EU/EEA.

Njuice sometimes shares your personal data with third parties with operations outside of EU/EEA. If such transfer is necessary, we will ensure that a similar degree of protection is afforded to it and made in accordance data protection legislation. Unless there is another legitimate basis, our transfer of personal data is based on the EU Commission’s standard contractual clauses or where applicable US Privacy Shield or other applicable safeguards used to fulfil applicable data protections legislation

  1. YOUR RIGHTS

Vodacom and its appointed service provider will respect your legal rights to your data. If you would like to exercise these rights feel free to direct requests, or other questions and comments regarding this Privacy Policy to contact@saccess.co.za

 

Below are the rights that you have under law:

    1. Right of access

You have a right to access your personal data that we store.

    1. Right to erase

You have the right in certain circumstances to request the deletion or removal of personal data, for example if the data collected is no longer needed.

    1. Right to rectification

You have the right to ask us to rectify the data we hold if it contains inaccuracies or is incomplete.

    1. Withdraw consent

If we rely on your consent to the use of your personal data you have the right to, at any time, withdraw your consent.

    1. Right to restriction of processing

In certain circumstances, you have the right to “block” or suppress the processing of your personal data.

    1. Right to data portability

In certain situations, you have the right to request a copy of your personal data, in a structured and machine-readable format, enabling you to store and re-use it for further personal use or to transfer it to a third party.

    1. Right to object

You have the right to know if your personal data is used for direct marketing and you have the right to object to this kind of processing at any time.

    1. Right to complain

Certain use of your personal data is based on our or others legitimate interest. You have the right to object to the use of your personal data based on a legitimate interest for reasons which concerns your situation. Moreover, you have the right to at any time object to our use of your personal data for direct marketing purposes.

  1. SECURITY OF INFORMATION

Security plays a crucial role for us. We are extremely committed to protecting your personal information. We have implemented commercially reasonable technical and organizational measures to protect your personal data against abuse and loss. Nevertheless, as no electronic method of data transmission and storage is totally secure, Vodacom and its service providers, despite its reasonable efforts to protect the security of your personal information, cannot guarantee its absolute efficacy.

  1. DATA RETENTION

We will not retain personal data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable law or regulations. Information which has been anonymized may be stored for a longer time. Yet, some information in non-personally identifiable form may still be available for the Services in the archives.

Personal data that you provide to us by using the Services Feedback function will be erased following a period after the matter has been completed.

  1. NOTE ABOUT CHILDREN

It is not our intention to collect personal information from users who are under the age of 13. However, if personal information of a child under 13 is collected in our Services and we learn about it, we will attempt to delete all information about the child as soon and effectively as possible. Accordingly, if you believe that we might be in possession of personal information from a child under 13, please contact us at: contact@saccess.co.za

 

 

  1. OUR USE OF COOKIES

When you use the Services, we, and some of our third-party service providers use cookies and similar tracking technologies (together “cookies”) to learn how the Services are used and to improve both your experience and the functionality of the Services

Advertising platforms and analytical services such as Google and Facebook use cookies and IDs to deliver targeted ads and to provide Vodacom and its appointed service provider with analytical statistics. For more info on these cookies and below see the links to the respective websites listed above.

You can change your cookie settings at any time, e.g., manage if and how cookies may be stored and erase cookies from your device. However, please note that the Services may not work as intended if you change your cookie settings.

  1. CHANGES TO THE PRIVACY POLICY

Our Privacy Policy may undergo amendments and updates from time to time. If we make significant changes to this Privacy Policy or changes concerning how we process your information, we will notify you before such a change becomes applicable. The current version of the Privacy Policy was issued in April 2021.

 CONTACT AND QUESTIONS

If you have any questions, concern or complaint concerning our Privacy Policy, data collection, storage, and processing practices, or if you want to report a violation of your privacy or need a translation of the privacy policy in your local language, please contact us at: contact@saccess.co.za