iSparkle (Proprietary) Limited (“we”; “us”), is committed to protecting and respecting your (“you”; “your”; “User”) privacy. We acknowledge that the right to privacy is one that needs to be protected and we will take reasonable measures to protect it, as more fully detailed below.

This Privacy Policy (“policy”) forms part of and is incorporated by reference into iSparkle’s website Terms. The website Terms and this policy must also be read with the Electronic Communications and Transactions Act 25 of 2002 (“ECTA”) and the Protection of Personal Information Act 4 of 2013 (“POPI”).

This policy governs the data which we collect from Users and other third parties in the course of our business and the way in which we protect and process such information.

Please read this policy carefully to understand how we will treat your Personal Information.

iSparkle will:

• comply with both the law and good practice;
• respect individuals’ rights;
• be open and honest with individuals whose data is held; and
• provide training and support for staff who handle Personal Information, so that they can act confidently and consistently.

1. Responsible Party

For the purpose of POPI, the responsible party is iSparkle (Proprietary) Limited (Company Registration Number: 2013/106705/07), having its registered address at 1 Kramer Road, Bedfordview, Johannesburg, 2007 (“Responsible Party”).

1. Information we may collect about you: Access to and Use of Information

The website receives various types of information from Users who access the website, including Personal Information as defined in the Promotion of Access to Information Act 2 of 2000 (“PAIA”), section 1 of ECTA and also in terms of section 1 of POPI.

We voluntarily subscribe to the protection of Personal Information principles contained in ECTA, and comply with the requirements of POPI.

When used in this Privacy Policy, “Personal Information” is any information that identifies or can be used to personally identify you.  This includes, but is not limited to, information such as your name, address, telephone number, and email address (as is more fully set out at “Consent to use your Personal Information” hereinbelow).

We collect Personal Information to provide our services, to conduct our business and to improve our products, services, and customer service.

The type of information we collect will depend on the purpose for which it is collected and used. We will only collect information to the extent that is reasonably necessary for that purpose.

When registering for a new online purchase account with iSparkle, a User is obliged to provide (at least) the following information:

• A chosen username;
• Full name and surname;
• A safe, secure password;
• Their mobile number;
• Their email address;
• Their physical address.

We do not normally collect sensitive information about you such as information relating to your health, religion, political beliefs or race.

We may furthermore collect and process the following data about you: Information you provide when you use our website www.twentyplus.co.za (the “website”) or other media by which you use our services. This includes information provided by you at the time you place an order for any of our products or services. We may also ask you for information if you report a problem with our website.

If you contact us by email, via chat, by telephone or in writing, we may keep a copy of that correspondence or communication. 

This may include details of any transactions you carry out with us through the website or by any other means, including those contained in an order form, and of fulfilment of your orders, and details of your visits to the website and the resources that you access. If you have provided us with the Personal Information of another person, you confirm that he/she consents to the processing of his/her Personal Information and that you have informed him/her of our identity as a Responsible Party and provided him/her with a copy of our Terms and this policy. We also monitor visitors to and content on our message board and blog sites to meet our obligations to ensure that rules as to content are being followed. We will review and, if appropriate, edit content on these sites.

Where possible, we will inform you what information you are required to provide to us and what information is optional.

1. Consent to use of your Personal Information

iSparkle undertakes to comply with Conditions 2 and 8 of POPI in terms of data subject consent.

By using the website and/or submitting Personal Information, the User consents to:

• the collection, collation, processing, and use of its Personal Information which may include but is not limited to contact information (such as full name, postal address, physical address, cellular and/or telephone numbers, email address), age, date of birth and gender;
• payment information (such as your payment card number, expiration date, delivery address);
• the transfer of your Personal Information to countries outside South Africa;
• the disclosure of your Personal Information to entities that are related to iSparkle;
• that your Personal Information may be retained by iSparkle for a defined period, subject to your rights to have the Personal Information deleted and/or removed;
• receiving promotional and/or marketing material and information in any form, which you can opt out of at any time.

You may withdraw any consent you previously provided to us, or object at any time on legitimate grounds, to the processing of your Personal Information. We will apply your preferences going forward within a reasonable amount of time. In some circumstances, withdrawing your consent to our use or disclosure of your Personal Information will mean that you cannot take advantage of some of our products or services.

1. Retention of your information

We take appropriate measures to ensure that any information collected from you is kept only for so long as is necessary for the purpose for which such information is used. For the avoidance of doubt, we will normally keep your data for a period no longer than five (5) years, unless required to hold your data for a longer period for regulatory purposes.

We normally update your Personal Information within seven (7) working days of any new or updated Personal Information being provided to us, to ensure that the Personal Information we hold about you is as accurate as possible.

1. Uses made of your information

We will use your personal information only for the purposes for which it was collected or agreed with you.  For example, we collect, hold, use and disclose Personal Information for the following purposes:

• To ensure the products and services you have chosen are delivered to you in the most effective way, and to assist with the performance of our internal contract, accounting and administrative functions;
• To carry out our obligations arising from any contracts entered into between you and us;
• To report aggregate information to our advertisers. This is statistical data about our Users’ browsing actions and patterns and does not identify any individual;
• To assist us in developing new and improved products as indicated by User practice and preferences, based on our analysis of patterns of site usage;
• To provide you with details of changes to our products or of other product offerings which we believe may be of interest to you from iSparkle (or other third-party providers). We will not share your data with third parties for marketing purposes unless we have procured your express consent to do so.
• To send communications;
• To establish, manage, and maintain our relationships;
• To respond to inquiries and requests;
• To develop, provide, and improve our services, offers and/or promotions;
• To inform you about our services, offers and/or promotions;
• To obtain feedback from you on our services, offers and/or promotions;
• To provide you with a more personalised experience when you interact with us;
• To conduct administrative and business functions;
• To update our records and keep contact details up to date;
• To enable you to subscribe to our website, newsletters and mailing lists;
• To assess the performance of our website and to improve its operation;
• To process and respond to privacy complaints; 
• To comply with any law, rule, regulation, lawful and binding determination, decision or direction of an authorised entity, court/tribunal, other governmental authority; industry codes to which we subscribe or which apply to us, in co-operation with any governmental authority of any country; or as we otherwise believe to be necessary or appropriate under applicable law.

1. Profiling or other automated individual decision making

Automated individual decision making refers to a decision made solely based on automated processing of your Personal Information, without human involvement. For instance, this means processing using an algorithm or a software code. Profiling is defined as automated processing of Personal Information to evaluate certain things about an individual: profiling can be part of an automated decision-making process.

We may conduct automated decision making or profiling to better understand your centre of interests and preferences and adapt our communications to your profile.

1. Disclosure of your information

We may disclose your personal information where applicable to any member of our group, which may mean and include our subsidiaries, our ultimate holding company and its subsidiaries.

We may disclose your personal information to third parties in the following circumstances:

1. If we sell or buy any business or assets, in which case we may disclose your Personal Information to the prospective seller or buyer of such business or assets.
2. If we or substantially all of our assets are acquired by a third party, in which case Personal Information held about our customers will be one of the transferred assets
3. If we are under a duty to disclose or share your Personal Information to comply with any legal obligation.
4. To enforce or apply our Terms and other agreements.
5. If it is required to do so to deliver our services. We sometimes outsource certain functions of our business to service providers: some of these service providers may use cloud-based systems: in that case, your Personal Information would be hosted on their servers, but under our direction and control.
6. To protect the rights, property or safety of iSparkle, our customers or others.
7. Where we have received your permission for us to do so.
8. Any company within the iSparkle Group (including to its employees and sub-contractors) which assists us in providing the services or which otherwise has a need to know such information;
9. Any third party which assists us in providing the services, including (but not limited to) payment processors, providers of marketing services.
10. Any third party which can assist us in verifying the accuracy of your Personal Information, including financial institutions and credit reference agencies (a record of the search may be retained by such third party), identity verification entities.
11. Any contractors or other advisers auditing any of our business processes or who have the need to access such information for the purpose of advising us; and
12. Any law enforcement body (authorised entities, courts/tribunals, other governmental authorities of any country, or other recipients as we believe to be necessary or appropriate under applicable law) which may have any reasonable requirement to access your Personal Information.

We will ensure that we have agreements in place with the above mentioned third parties to ensure adequate and equivalent protection for your personal information and that such parties comply with appropriate security, privacy and confidentiality obligations to ensure that personal information that we remain responsible for, is kept secure.

To the extent permitted by applicable law, we may also disclose your personal information:

• where we have a duty or a right to disclose in terms of laws; and
• where we believe it is necessary to protect our rights.  

If at any time you wish us to stop processing your Personal Information for the above purposes, then you must contact us and we will take the appropriate steps to stop doing so. Please note that this may mean that your Account may be closed. You may contact us by sending an email to info@twentyplus.co.za.

1. Transfers outside the Republic of South Africa (“South Africa”)

We will only transfer your Personal Information to countries which are considered as providing an adequate level of legal protection or where alternative arrangements are in place to protect your rights.

We may transfer your Personal Information outside South Africa in the unlikely event that we receive a legal request from a foreign law enforcement body. All requests for information we receive from these bodies will be carefully checked before Personal Information is transferred.

We may use remote website server hosts to provide and maintain some aspects of our service and website, which may be based outside South Africa (in “the cloud”). Your Personal Information may also be processed by staff operating outside South Africa or one of our service providers located in a country outside of South Africa. Transfers to service providers outside of South Africa will be protected by contractual commitments and, where appropriate, further assurances, such as certification schemes. In all cases we will take steps with the aim of ensuring that your privacy rights continue to be protected, as outlined in this privacy policy and in accordance with POPI and other applicable laws.

We provide adequate protection for your Personal Information in our possession including appropriate and reasonable technical, physical and organisational measures and precautions to protect Personal Information from misuse, loss, unauthorised access, modification or disclosure using a combination of physical, administrative and technical safeguards.  We will, on an ongoing basis, continue to review our security controls and related processes to ensure that your Personal Information in our possession is secure.

Access to your Personal Information will be limited to individuals who have a legitimate business need to access your Personal Information.

iSparkle’s website is linked to the internet, and as the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online.  Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.  Accordingly, any Personal Information or other information which you transmit to us online is transmitted at your own risk.

You have the right to ask for more information about the safeguards we have put in place as mentioned above.

1. Direct Marketing

To the extent permitted by applicable law, we may send you direct marketing communications and information about our services, offers and/or promotions that we consider may be of interest to you.  We may send communications in various forms, including mail, SMS, fax and email, in accordance with applicable laws.

If you do not wish to receive direct marketing communications from iSparkle, you may opt-out of receiving them by using the opt-out mechanisms provided in those communications.  

We will try to comply with your request(s) as soon as reasonably practicable.  Please also note that if you do opt-out of receiving marketing-related communications from us, we may still send you important administrative messages, and you cannot opt-out from receiving such administrative messages.

1. 10.How you can access and correct your Personal Information

You have a right to ask us to update, correct or delete your Personal Information.  If you wish to access, correct, update, suppress, or delete your Personal Information that has been previously provided to us, please send a written request using the contact details set out below:

Email: info@twentyplus.co.za 

We would appreciate it if you would keep your Personal Information accurate. Please update your information whenever your details change.

1. 11.Using our website(s)

When you access our website, we may send a “cookie” (which is a small summary file containing a unique ID number) to your computer, mobile device or other device from which you access the website.  This enables us to distinguish you from other users of our website and recognise your computer or mobile device. This helps us to provide you with a better experience when you browse our website.  We also use cookies to measure traffic patterns and to determine which areas of our website have been visited.  The information collected may also include your domain name and IP address, details of your computer, operating system and browser, the website you visited prior to visiting our website and unique number identifiers that are automatically generated by our systems when you visit our website.  This will include details of the choices you make on our website indicating whether you wish to receive information on other products and services.  Some of this information is retained in “cookie” files on your computer.  These files retain useful information that can speed your navigation through frequently visited sites.  They can also retain records that track site usage, preferences and passwords.

If you do not wish to receive cookies, you can set your browser so that your computer does not accept them, however, note that our website requires cookies to operate effectively.  If you continue using our website, you accept the use of cookies.  We do not use cookies to track your internet activity before or after you leave the iSparkle environment.

Please note that our advertisers may also use cookies, over which we have no control.

Any activity you participate in on our website may be monitored.  We may log IP addresses (that is, the electronic addresses of computers connected to the internet) to analyse trends, administer the website, track users movements, and gather broad demographic information.

1. 12.Links to other websites

Our website offers links to many thirdparty websites. We are not responsible for the accuracy or efficacy of the information or data policies or procedures of these third parties. If you access these sites using the links provided on our website, you should satisfy yourself as to the relevant data policies in effect on these sites.

1. 13.Changes to our privacy policy

Any changes we may make to our Privacy Policy in the future will be posted on this page and on our website. Please check this page regularly to ensure you are happy with any changes.

If you have any questions about our privacy policy, or if you want to request information about our privacy policy, please contact us at info@twentyplus.co.za or in writing at the address set out on the Contact Us page of the website.

1. 14.Contacting us

If any of your Personal Information changes, or if you have any questions, comments or requests regarding the protection of your Personal Information or this policy, please contact us by email at info@twentyplus.co.za or in writing at the address set out on the Contact Us page of the website.

1. 15.Information Officer

iSparkle (Proprietary) Limited has appointed an Information Officer (“IO”) who is responsible for matters relating to privacy and data protection.

iSparkle’s IO can be reached by:

sending an email to IO@twentyplus.co.za, or writing to:

For attention: The Information Officer

iSparkle (Pty) Ltd

1 Kramer Road

Bedfordview

Johannesburg

2007