Privacy notice

The Protection of Personal Information Act (POPIA) enacted in 2013, which came into effect on 1 July 2021, includes a series of data protection rights which you should be aware of while using our site and services. These rights are captured in principles or articles which for the purposes of this data privacy policy constitute data subject (your) rights. The following sections of our policy outline your rights in the context of POPIA.

1. Data Privacy & Protection Principles

We are committed to processing your data in accordance with principles outlined in the POPIA. These principles aver that we must take due care with your data and limit our use to what’s necessary for collection and retention.

Data we collect must be processed lawfully, fairly and in a transparent manner in relation to individuals and organisations (legal entities);
Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the POPIA in order to safeguard the rights and freedoms of individuals; and processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”

2. General provisions

This policy applies to all personal information (PI) held by us and on our behalf by Data Processors.
Our Information Officer shall take responsibility for our ongoing compliance with this policy.
This policy shall be reviewed at least annually.
We are registered with the Information Regulator (IR) as an organisation that processes personal data.

Facebook and Instagram

As a visitor to our page, you agree that you will not violate any laws and regulations, including copyright, intellectual property right laws and other, regarding any content that you send or receive. You also agree you will not transmit any material in any manner that is unlawful, disruptive, threatening, profane, abusive, harassing, embarrassing, tortuous, defamatory, obscene, libelous, or is an invasion of another person’s privacy, is hateful or racially, ethnically or otherwise objectionable as solely determined by the Carmién staff; impersonate any person or entity or falsely state or otherwise misrepresent your affiliation with a person or entity; transmit unsolicited or unauthorized advertising, promotional materials or any other form of solicitation, transmit any material that contains software viruses.

Cookies

This website stores cookies on your computer. These cookies are used to collect information about how you interact with our website and allow us to remember you. We use this information in order to improve and customize your browsing experience and for analytics and metrics about our visitors both on this website and other media. To find out more about the cookies we use, see our Data Privacy Policy (link included in the website).

If you decline, your information won’t be tracked when you visit this website. A single cookie will be used in your browser to remember your preference not to be tracked.

Cookies (alternate)

The Website and Services use “cookies” to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you.

We may use cookies to collect, store, and track information for statistical purposes to operate the Website and Services. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the features of the Website and Services. To learn more about cookies and how to manage them, visit www.internetcookies.org or www.learn-about-cookies.com

For browser settings you can visit https://support.mozilla.org/ or https://support.microsoft.com/en-us/windows/

Email marketing (newsletters)

We offer electronic newsletters to which you may voluntarily subscribe at any time. We are committed to keeping your e-mail address confidential and will not disclose your email address to any third parties except as allowed in the information use and processing section or for the purposes of utilizing a third-party provider to send such emails. We will maintain the information sent via e-mail in accordance with applicable laws and regulations.

3. Lawful, fair and transparent processing

To ensure processing of your data is lawful, fair and transparent, we maintain a “Roadmap of Processing Activities” (ROPA).
The ROPA shall be maintained and reviewed at least annually.
Individuals have the right to access their personal data free of charge in an accessible electronic format.
Such requests, known as Data Subject Requests (DSR) made to us shall be provided within 28 days of receipt. (*exceptions may apply)

4. Lawful purposes

As required by POPIA, all data processed by us is conducted on lawful basis. This basis includes the following four categories; Consent, Contract, Legal Obligation & Legitimate Interest.
This lawful basis is recorded in our record of processing activities.
Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent will be clearly available and systems will be in place to ensure such revocation is reflected accurately on our systems.

5. Data minimisation

We shall ensure that personal data processing safeguards are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
Data minimisation techniques such as anonymisation will be used where possible. This is in line with our Privacy by Design and Default approach to data privacy in our data privacy policy.

6. Accuracy

We shall take reasonable steps to ensure personal data is accurate.
Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

7. Archiving / Removal

To ensure that personal data is kept for no longer than necessary, we shall put in place an archiving provision in our company data privacy policy for each area in which personal data is processed and review this process annually.
The archiving policy shall consider what data should/must be retained, for how long, and why.

8. Security

We shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
When personal data is deleted this will be done safely such that the data is irrecoverable. (e.g. compliant with electronic security protocols)
Strong authentication (Multi Factor Authentication) will be used for administrators of personal data on our systems.
Personal data stored and transmitted on our systems will be encrypted using the latest encryption standards.
Appropriate back-up and disaster recovery solutions shall be in place.

9. Data Breach

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, we shall promptly assess the risk to your data and if appropriate report this breach to the Information Regulator.
Where a breach is likely to result in a high risk to your personally, we will inform you within 72 hours as required by the breach notification rules.