RATTLEHUB DIGITAL (“Rattlehub”) PRIVACY AND ACCESS TO PERSONAL INFORMATION POLICY
Privacy of personal information is important to Rattlehub and is dealt with in terms of this Rattlehub Policy. This privacy statement sets out the practices applicable to the protection of personal information as well as access to personal information held by Rattlehub.
Rattlehub is totally committed to protecting their clients’ privacy and ensuring that personal information as defined by the Protection of Personal Act, 4 of 2013 (“the Act”) is collected and used properly and lawfully, with the required confidentiality and transparency.
This Policy sets out how Rattlehub, in cooperation with its business partners, obtains, uses and disseminates personal information of any users of this website.
You are fully entitled to all rights, afforded in terms of law (including, without limitation, the Act). We encourage you to refer directly to the Act, should you require more information on these rights. The Regulator issues Codes of Conduct for various industries from time to time and we will adhere to all codes that as they may apply to us. This Policy is therefore subject to the Act and any other laws regulating privacy of personal data, as well as any applicable Codes of Conduct as issued by the Regulator, from time to time.
The following undertakings are, however, important for us to state:
• We value the trust that you place in us when providing your personal information to us, directly or indirectly. We will always use your personal information in a way that is worthy of that trust.
• We will use your personal information to enhance your experience and the service that Rattlehub and its business partners provide to you and to communicate with you, unless expressly directed by you not to do so.
• We will always be transparent about the information we collect, what we do with it, and with whom we share it.
• We will work with you to resolve any query or concern about how we use your information.
• We will take all reasonable steps to protect your information from misuse and keep it secure.
• We will comply with all applicable data protection laws and regulations and we will co-operate with data protection authorities. In the absence of data protection legislation, we will act in accordance with generally accepted principles governing data protection.
Rattlehub is the developer and owner of a Technology Platform, including certain product offerings, which allows for the end user thereof to, inter alia, capture personal and financial data for the purpose of facilitating life and estate planning.
Rattlehub, has contracted with business partners, including Financial Advisers to provide them and their registered clients with access to our Platform and product offerings.
Our aim is to move people from chaos to order and prepare them to become digital citizens.
COLLECTION OF PERSONAL INFORMATION
We collect and process your personal information mainly to provide you with access to our products and services, and to help us improve the product offering and experience to you.
We will only collect information that we need in order to provide you with the products and services you have selected, directly or indirectly which may include collecting information about you from other sources as explained below.
Website usage information is collected using “cookies” which allow us to collect standard Internet visitor usage information.
Further note that you may withdraw your consent with respect to any personal information processed or further processed by us at any stage and that you hold the right to:
1. object to our processing your personal information; and
2. lodge a complaint to the Information Regulator, whose details appear below.
YOUR PERSONAL INFORMATION
Insofar as Rattlehub processes your personal information, we will process or use your personal information only for the following purposes:
• to provide our products or services to you, directly or indirectly through business partners
• to execute the transactions you requested
• to maintain the relationship with our business partners and indirectly with their clients
• to confirm and verify your identity or to verify that you are an authorised user for security purposes
• for the detection and prevention of fraud, crime, money laundering or other malpractice
• to conduct market or customer satisfaction research or for statistical analysis
• for audit and record keeping purposes
• for legal proceedings
Rattlehub will also, directly or indirectly use your personal information to comply with legal and regulatory requirements or industry codes.
The processing of your personal information will always be done lawfully, within the requirements of the Act, and not in a manner infringing on your privacy.
DISCLOSURE AND SHARING OF INFORMATION
Rattlehub will not sell, rent, or trade your personal information to any third party. Rattlehub may share aggregated information (for example, demographic data) with its stakeholders and business partners, but it will not disclose your personal information to third parties save with your consent or as provided in this policy statement. By using this website and/or the software platform, you hereby provide your express consent to having your aggregated data shared by Rattlehub to its stakeholders and business partners.
Rattlehub may also disclose your information:
• where we have a duty or a right to do so in terms of law or industry codes
• where we believe it is necessary to protect our rights
• we are compelled by law or a court order to do so
To the extent that Rattlehub uses third party providers to assist us in making the services on this site available to you, we may disclose your personal information to such third parties (and you consent to such disclosure) if you have elected to receive one of those services, which they assist in providing.
INFORMATION SECURITY AND QUALITY
Rattlehub shall protect the quality and integrity of your personal information. We are legally obliged to provide reasonable and adequate protection for the personal information we hold and to prevent unauthorised access and use of your personal information.
Rattlehub will, on an ongoing basis, review our security controls and related processes to ensure that your personal information is secure and only used in line with this policy. Our security policies and procedures include:
• physical security
• computer and network security
• access to personal information
• secure communications, including the use of encryption where appropriate
• security when contracting out activities or functions
• retention and disposal of information
• acceptable use of personal information
• governance and regulatory issues
• monitoring access and use of private information
• investigating and reacting to security incidents
Where Rattlehub shares personal information with third parties, we remain responsible for that information and will take reasonable steps to ensure it remains secure. This includes requiring appropriate security, privacy and confidentiality measures from such third parties.
Rattlehub may need to transfer your personal information cross border for processing or storage, for example cloud storage. We will take reasonable steps to ensure that anyone to whom we pass your personal information agrees to treat your information with the same level of protection that we do and that they operate within a jurisdiction subject to privacy legislation providing an “adequate level of protection” as defined in the Act. Insofar as your personal information needs to be transferred cross-border for the purposes specified above, you consent to the transfer of your personal information by Rattlehub.
Rattlehub cannot guarantee the security of any information you transmit to us online and you do so at your own risk.
COLLECTION OF INFORMATION BY THIRD PARTIES
Owners or information system administrators of third party websites that have links to the Rattlehub website may collect personal information about you when you use these links. Ratttlehub does not control the collection or use of personal information by third parties and this privacy statement does not apply to third parties and we accept no liability for collection of your personal information by such third parties.
WEBSITE CLICKSTREAM DATA
Rattlehub may collect anonymous information from visitors to its websites to help it provide better customer service. For example, Rattlehub keeps track of the domains from which people visit our website and also measures visitor activity on our website. In doing so Rattlehub ensures the information cannot be used to identify you. Rattlehub or its analytic partners may use this data to analyse trends and statistics and to help it provide better customer service. If you do not wish your personal information to be used in this way, please notify us.
Rattlehub engages third parties that help it deliver banner advertisements and other online communications. The third parties may collect and use information about Rattlehub customers to help us understand the offers, promotions, and types of advertising that are most appealing to our customers. The personal information they collect is aggregated and cannot be linked to a person. If you do not wish your personal information to be used in this way, please notify us.
While none of Rattlehub’s websites are directed towards children, Rattlehub is committed to comply with all applicable laws aimed at the protection of children and in particular the protection of their personal information.
CORRECTION OF INFORMATION
You have the right to ask us to update, correct or delete your personal information. You may do this by contacting us via the e-mail address provided on our website.
Your request is subject to the legal requirements we must comply with and we will take all reasonable steps to confirm your identity before making changes to the personal information we hold about you. Rattlehub will make reasonable efforts to respond to your requests to correct inaccuracies in your personal information in a timely manner.
Keeping your personal information up-to-date and accurate remains your sole responsibility.
ACCESS TO INFORMATION
You have the right, in terms of The Promotion of Access to Information Act, no 2 of 2000, to request a copy of the personal information, which we have on record for you. To do this, simply contact our designated information officer via the e-mail address provided on our website and specify what information you would like access to. Rattlehub will take all reasonable steps to confirm your identity before providing details of your personal information.
Any such access request may be subject to the payment of a fee, as legally allowed.
RETENTION OF YOUR PERSONAL INFORMATION
Rattlehub will retain your personal information for as long as required by law or to allow you a reasonable opportunity to request access to it at any time during or after your relationship with Rattlehub, whichever is longer.
Rattlehub will retain your information for longer periods for historical, statistical and research purposes, as defined in the Act. We have established appropriate safeguards against your records being used for any other purposes.
You may at any time after our contractual relationship terminates, contact us to request that your personal information be de-identified. We will however retain the de-identified information for historical, statistical and research purposes as set out above.
You can contact us if you have any questions, comments or concerns about how we deal with your personal information as well as access by yourself to your personal information, again via the e-mail address provided on our website.
INFORMATION OFFICER CONTACT DETAILS:
INFORMATION REGULATOR DETAILS:
The Information Regulator (South Africa)
316 Thabo Sehume Street,
Ms Mmamoroke Mphelo
Tel: 012 406 4818
Fax: 086 500 3351
RESPONSIBLE PARTY DETAILS:
Rattlehub Digital (Pty) Ltd
Southdowns Office Park, Block D Suite 4 Ground Floor
22 Karee Road
Tel: 27(0) 87 550 3077
© Rattlehub Digital 2018