Website Usage - GDPR & POPI

Who we are

This is the privacy notice of Halo Media cc (Registration Number: 2006 / 157138 / 23, registered in South Africa - Church Place, Westville, Durban, South Africa, 3610) and The Halo Media Group Ltd. (company number 08700760 registered in United Kingdom - Witherington Road, Salisbury, UK, SP5 3DN) In this document, "we", "our", or "us" refer to both Halo Media cc and The Halo Media Group Ltd.

Our website address is: https://www.halo-media.com.

1. INTRODUCTION

This is a notice to inform you of our policy about all information that we record about you. This Privacy Policy defines how we collect and pross personal information about you; how we use and protect this information, and your rights in relation to this information, in accordance with the requirements of the Protection of Personal Information Act (POPIA) and the General Data Protection Regulation (GDPR).It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.

  • We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website.
  • We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them and will not accidentally fall into the hands of a third party.
  • We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
  • Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
  • The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data. We do this now, by requesting that you read the information provided at knowyourprivacyrights.org
  • Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.

The bases on which we process information about you

The law requires us to determine under which of six defined bases we process different categories of your personal information and to notify you of the basis for each category.

If a basis on which we process your personal information is no longer relevant, then we shall immediately stop processing your data.

If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

2. PERSONAL INFORMATION WE COLLECT

We may collect your personal information from a variety of sources, including personal information we collect from you directly, when you contact us, make a purchase or submit an online request to be contacted by us on our website.

Certain personal information is required because of a contractual relationship we have with you, to allow us to carry out our contractual obligations. Failure to provide this personal information could prevent or cause a delay in the fulfilment of these obligations.

2.1. Information we collect directly from you:

The categories of personal information that we may collect directly from you include the following:

  • personal details (name, age, date of birth, gender, identity number or registration number)
  • contact details (phone number, email address, postal address or mobile number)
  • employment details (job title; employer name, employee number)
  • economic or financial information (When payments are made)

We may use it in order to:

  • verify your identity for security purposes
  • sell products to you
  • provide you with our services
  • provide you with suggestions and advice on products, services and how to obtain the most from using our website

We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.

Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.

We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract

2.2. Information we may collect from other sources:

The following are examples of the categories of personal information we may collect from other sources such as the Companies and Intellectual Property Commission, or third-party service providers include but are not limited to the following:

  • personal details (name, age, date of birth, gender, identity number, registration number)
  • contact details (phone number, email address, postal address or mobile number)
  • employment details (job title; employer name, employee number)
  • economic or financial information (When payments are )

3. HOW WE USE OF PERSONAL INFORMATION

We may use it in order to:

  • verify your identity for security purposes
  • to fulfil our contractual obligations to you
  • sell products to you
  • to ensure that invoices are issued
  • to communicate with you and to carry out instructions and
  • provide you with our services
  • provide you with suggestions and advice on products, services and how to obtain the most from using our website

We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.

Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.

We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

We will only process your personal information for the purpose(s) for which it was collected and agreed to.

Why we use your personal information:

  • To contact you regarding the services we are providing to
  • To keep our records up to date
  • To issue accurate invoices for our
  • comply with legal obligations we need
  • comply with obligations in terms of our mandate from

A list of records that we hold and are legally required to hold is listen in our PAIA manual, should you wish to view this, please contact.

Information Officer:

  • Hayes Cunningham
  • hayes@halo-media.com
  • +44 7444 718580
3.1.  Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including our products and services, you provide your consent to us to process information that may be personal information.

Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.

Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.

Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.

If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.

We continue to process your information on this basis until you withdraw your consent, or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us by email at: hayes@halo-media.com However, if you do so, you may not be able to use our website or our services further.

3.2. Information we process because we have a legal obligation

We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

This may include your personal information.

4. YOUR RIGHTS AS DATA SUBJECTS

4.1  Right to access to information.

You have the right to request, free of charge, what personal information we hold about you. You also have the right to request a copy of the record of personal information or a description of the personal information we hold about you. These requests need to be done in the correct format and manner as prescribed in the PAIA and GDPR act.

4.2. Right to request correction or deletion of personal information.

You have the right to request the correction, updating or deletion of the personal information held by us. You can also request, the destruction or deletion of a record of the information held by us.

4.3. Right to object to the processing of personal information

You have the right to object to the processing of your personal information unless there is a legitimate legal bases, we need to continue to process your information (court order).

4.4. Right to object to automated decision-making.

You have the right to object automated decision making,

4.5. Right to unsubscribe from direct marketing.

You have the right to opt-out of any direct marketing that is sent to you by clicking on the opt-out or unsubscribe link at the bottom of the email.

4.6. Right to withdraw consent.

You have the right to withdraw your consent to us processing your information at any time, these requests need to be sent to Hayes Cunningham hayes@halo-media.com

4.7. Right to lodge a complaint with the information regulator.

You have the right to lodge a complaint with the Information Regulator, in the prescribed manner and form, if you believe that we are not complying with the protection of your personal information. If you reside in South Africa, you can contact the Information Regulator on 010 023 5207 (telephone number) and can lodge a complaint via email inforeg@justice.gov.za. If you reside within the European Union or United Kingdom, you have the right to lodge a complaint with a Data Protection Authority about how we process your personal data at the following websites: for EU residents, https://edpb.europa.eu/about-edpb/board/members_en ; for UK residents, https://ico.org.uk/make-a-complaint/.

If you complain about any of the content on our website, we shall investigate your complaint.

If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.

Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.

If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.

When we receive a complaint, we record all the information you have given to us.

We use that information to resolve your complaint.

If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.

We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

5. INFORMATION SHARING

We do not share your personal information with third parties unless there is a contractual requirement to do so for the completion of services rendered or unless we are legally obligated to do so.

5.1. Information provided on the understanding that it will be shared with a third party

Our website allows you to post information with a view to that information being read, copied, downloaded, or used by other people.

In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it.

We do store it, and we reserve a right to use it in the future in any way we decide.

Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.

Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion, we may agree to your request to delete personal information that you have posted. You can make a request by contacting us at hayes@halo-media.com

5.2. Information relating to your method of payment

Payment information is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it.

At the point of payment, you are transferred to a secure page on the website of PayPal/Stripe/Payfast. That page may be branded to look like a page on our website, but it is not controlled by us.

6. INFORMATION SECURITY

We have implemented generally accepted standards of technology and operational security to protect personal information from loss, misuse, alteration, or destruction.

We require all staff to sign a non-disclosure agreement and all contractors to keep personal information confidential and only authorized personnel has access to this personal information.

We will retain your personal information in accordance with our data retention policy which sets out data retention periods required or permitted by law.

6.1. How we protect your data

We shall review security controls and processes on a regular basis to ensure that personal information is secure. We will take appropriate, reasonable technical and organizational measures to prevent loss or damage or unauthorized destruction of personal information, and unlawful access to or processing of personal information.

This will be achieved by:

  • Identifying internal and external risks
  • Establishing and maintaining appropriate safeguards
  • Regularly verifying these safeguards and their implementation
  • Updating the safeguards
  • Implementing generally accepted information security practices and
  • Have appointed an Information Officer who is responsible for compliance with the conditions of the lawful processing of personal information and other provisions of POPI as well as GDPR compliancy.
6.1.1. Wordfence

We use top WordPress security systems on our website. By using our website you consent to their use. You can view their privacy policy here.

6.1.2. Hosting

Our website is located in Germany on through an extremely secure server with a company called Xneelo. You can read their privacy policy here. All data is stored on the website and do not store any of your data outside of this.

7. HOW WE RETAIN YOUR DATA

7.1. Cookies

Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.

Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.

Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.

Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.

When you first visit our website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose.

If choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our website.

We use cookies in the following ways:

  • to track how you use our website
  • to record whether you have seen specific messages we display on our website
  • to keep you signed in our site
  • to record your answers to surveys and questionnaires on our site while you complete them
  • to record the conversation thread during a live chat with our support team

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select "Remember Me", your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

7.2. What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

7.3. Where we send your data

Visitor comments may be checked through an automated spam detection service.

7.4. Google Analytics

We use google analytics on this website to ensure we are able to deliver better services and products and experience as our contractual obligation to you. We also use this to market our website to potential clients. You can read their privacy policy here. Should you not wish to continue you have the right not to use our website.

8. PERSONAL IDENTIFIERS FROM YOUR BROWSING ACTIVITY

Requests by your web browser to our servers for web pages and other content on our website are recorded.

We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.

If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.

9. OUR USE OF RE-MARKETING

Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.

We may use a third party to provide us with re-marketing services from time to time. If so, then if you have consented to our use of cookies, you may see advertisements for our products and services on other websites.

Disclosure and sharing of your information.

10. INFORMATION WE OBTAIN FROM THIRD PARTIES

Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.

No such information is personally identifiable to you.

11. CREDIT REFERENCE

To assist in combating fraud, we share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.

12. DATA MAY BE PROCESSED OUTSIDE THE EUROPEAN UNION

We may use outsourced services in countries outside the European Union from time to time in other aspects of our business.

Accordingly data obtained within the UK or any other country could be processed outside the European Union.

For example, some of the software our website uses may have been developed in the United States of America, South Africa, Germany or in Australia.

13. ACCESS TO YOUR PERSONAL INFORMATION

  • At any time you may review or update personally identifiable information that we hold about you, by signing in to your account on our website.
  • To obtain a copy of any information that is not provided on our website you may send us a request at hayes@halo-media.com
  • After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

14. REMOVAL OF YOUR INFORMATION

If you wish us to remove personally identifiable information from our website, you may contact us at hayes@halo-media.com

This may limit the service we can provide to you.

15. VERIFICATION OF YOUR INFORMATION

When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

16. ENCRYPTION OF DATA SENT BETWEEN US

We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.

Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

17. WHAT ARE OUR DATA BREACH PROCEDURES

Should we detect a security breach on any of our systems that contain personal information, we shall take the required steps to assess the nature and extent of the breach in order to ascertain if any information has been compromised.

We shall notify the affected parties should we have reason to believe that their information has been compromised. Such notification shall only be made where the organization can identify the data subject to which the information relates. Where it is not possible it may be necessary to consider website publication and any other measure the Information Regulator prescribes.

Notification will be provided in writing by means of either:

  • email
  • registered mail
  • the organization’s website

The notification shall provide the following information where possible:

  • Description of possible consequences of the
  • Measures taken to address the
  • Recommendations to be taken by the data subject to mitigate adverse
  • The identity of the party responsible for the breach if it is
  • In addition to the above, Halo Media CC shall notify the Regulator of any breach and/or compromise to personal information in its possession and work closely with and comply with any recommendations issued by the Regulator.

The following will apply in this regard:

  • The Information Officer will be responsible for overseeing the
  • The Information Officer will be responsible for reporting to the Information Regulator within 72hrs of becoming aware of the breach/compromise to personal information.
  • The Information Officer will be responsible for reporting to the Data Subject(s) within 72hrs, as far as is reasonable and practicable, of a breach/compromise to personal information.
  • The timeframes above are guidelines and depending on the merits of the situation may require earlier or later

18. HOW YOU COMPLAIN

  • If you are not happy with our privacy policy or if have any complaint then you should tell us by email. Our address is hayes@halo-media.com
  • If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
  • If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner's Office. This can be done at https://ico.org.uk/concerns/

19.  CHANGES TO THE PRIVACY STATEMENT

Changes or amendments to this privacy policy will be done in accordance with any legislative requirements that may be issues from time to time.