User Data Handling - Privacy policy

 

1. Who are we?

We are Sesalos (PTY) LTD, a company that develops software and mobile applications. All references in this policy to "Sesalos", "our", "us" or "we" refer to Sesalos (PTY) LTD. All references in this policy to "apps" are to our apps that are available to download on mobile devices from time to time.

2. Our values and the purpose of this policy

We commit to the information of employees, customers, stakeholders and other interested parties with the utmost care and confidentiality.
We value your privacy and in the interests of accountability and fairness, we want to be transparent with you regarding how we collect and use your personal information. We also want you to know your rights in relation to your information.
In this policy, we describe how we gather, store and handle data fairly, transparently and with respect towards individual rights.

3. Who this policy applies to

This policy applies to users of our apps and people who contact our customer support function.

4. Who is covered under the Data Protection Policy?

Employees of our company and its subsidiaries must follow this policy. Contractors, consultants, partners and any other external entity are also covered. Generally, our policy refers to anyone we collaborate with or acts on our behalf and may need occasional access to data.

5. What this policy contains

5.1 How we collect and use your personal information
5.2 Our legal basis for using your personal information
5.3 How and why we share your personal information with others
5.4 How long we store your personal information
5.5 Your Rights
5.6 Children
5.7 Risks and how we keep your personal information secure
5.8 Changes to this privacy policy
5.9 Further Questions and how to make a complaint

In summary:

Our data will be:

• Accurate and kept up-to-date
• Collected fairly and for lawful purposes only
• Processed by the company within its legal and moral boundaries
• Protected against any unauthorized or illegal access by internal or external parties

Our data will not be:

• Communicated informally
• Stored for more than a specified amount of time
• Transferred to organizations, states or countries that do not have adequate data protection policies
• Distributed to any party other than the ones agreed upon by the data's owner (exempting legitimate requests from law enforcement authorities)

To exercise data protection we're committed to:

• Restrict and monitor access to sensitive data
• Develop transparent data collection procedures
• Train employees in online privacy and security measures
• Build secure networks to protect online data from cyberattacks
• Establish clear procedures for reporting privacy breaches or data misuse
• Include contract clauses or communicate statements on how we handle data
• Establish data protection practices (document shredding, secure locks, data encryption, frequent backups, access authorization etc.)

5.1 How we collect and use your personal information

Our apps collect the following personal information about you:

• Your login details consisting of Name, Surname, Username and Email Address
• If you contact our customer support function, we will collect your e-mail address (as well as any other information you include in your correspondence with us), including any updates to any of that information.

Our company collects this information in a transparent way and only with the full cooperation and knowledge of interested parties.
We collect this information to keep track of who is performing which tasks in relation to the software connected to the app. This also ensures that employees access rights are enforced.
Information submitted when engaging with our customer support interface allows us to receive and respond to your queries efficiently.

We also collect your information for internal corporate reporting and business administration purposes in the aid of ensuring the security of company facilities, research and development, and to identify and implement business efficiencies. We may process your personal information for these purposes where it is in our legitimate interests to do so.

Furthermore, we collect your information to comply with any procedures, laws and regulations which apply to us - this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so; and to establish, exercise or defend our legal rights - this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.

We will not use your personal information in any way that is incompatible with the purposes listed above.

5.2 Legal basis for use of your personal information

We consider that the legal bases for using your personal information as set out in this privacy policy are as follows:
(a) our use of your personal information is necessary to perform our obligations under any contract with you (for example, to comply with the terms of service of our apps); or
(b) our use of your personal information is necessary for our legitimate interests or the legitimate interests of others. Our legitimate interests are to:
(i) run, grow and develop our business (as well as the businesses of our group companies);
(ii) and operate, maintain and improve our apps.

5.3 How and why we share your personal information with others

In short, we don't share or sell or rent any of your personal information except as detailed below.
We may share some information with Google, Inc. (trading as Firebase), who provide analytics of bugs and issues with our apps, so that we can fix, stabilise and improve our apps.
We may also be compelled to share your personal information in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity or in order to establish, exercise, enforce, or defend our terms of service or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or to protect the rights, property, or safety of Sesalos, our staff, our customers or other persons.
We may also disclose and use anonymised, aggregated reporting and statistics about users of our apps for the purpose of internal reporting or reporting to our group or other third parties. None of these anonymised, aggregated reports or statistics will enable our users to be personally identified.

5.4 How long we store your personal information

We keep your personal information for no longer than necessary for the purposes for which the personal information is processed. The length of time for which we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.

5.5 Your rights

You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us via the 'Contact Us' page at any time. You have the following rights:

• Right of access. You have a right of access to any personal information we hold about you. You can ask us for a copy of your personal information; confirmation as to whether your personal information is being used by us and details about how and why it is being used.
• Right to update your information. You have a right to request an update to any of your personal information which is out of date or incorrect.
• Right to delete your information. You have a right to ask us to delete any personal information which we are holding about you in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details supplied at the end of the document.
• Right to object. You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person's legitimate interest.

We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims. If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.

5.6 Children

You must be aged 16 or over to use our apps. Our website and services are not directed at children younger than this and we do not knowingly collect any personal information from children younger than this.
If you are aged below the age of 16 and we learn that we have inadvertently obtained personal information from you from our websites, or from any other source, then we will delete that information as soon as possible.
Please contact us via the 'Contact Us' page if you are aware that we may have inadvertently collected personal information from a child below the age of 16.

5.7 Risks and how we keep your personal information secure

The main risk of our processing of your personal information is if it is lost, stolen or misused. This could lead to your personal information being in the hands of someone else who may use it fraudulently or make public, information that you would prefer to keep private.
For this reason, we are committed to protecting your personal information from loss, theft and misuse. We take reasonable precautions to safeguard the confidentiality of your personal information, including through use of appropriate organisational and technical measures. We use industry-standard practices such as encryption, firewalls and password protection systems to safeguard the confidentiality of any personal information that we might collect from you. For example, your email address will be encrypted, which will make it extra hard for someone to discover and use them without our authorisation. We also strive to limit access to your data to employees performing a legitimate business function which requires them to access and use your data in order to supply you with our apps. We review our security procedures periodically to consider appropriate new technology and updated methods to ensure we continue to protect your data.
Although we make every effort to protect the personal information which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to our apps or customer services function and that any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorised access to it.

5.8 Changes to our privacy policy

We may update our privacy policy from time to time. Any changes we make to our privacy policy in the future will be made available to you via the privacy policy, accessible in our app. Please check back frequently to see any updates or changes to our privacy policy.

5.9 Further questions and how to make a complaint

If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please make contact via the 'Contact Us' page. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information.

Your response:

What you need to do and your confirmation to us: Please read this privacy policy carefully to understand how we handle your personal information. By engaging with us in the ways set out in this privacy policy, including downloading and using any of our apps, you confirm that you have read and understood the entirety of this privacy policy, as it applies to you.