PROTECTION OF PERSONAL INFORMATION (“POPI”), PRIVACY POLICY AND PRINCIPLES
1. Introduction
1.1. Vox respects its customers’ privacy and will take the measures set out herein to protect it.
1.2. Vox may require the customer to provide Vox with personal information which include company names and registration numbers, name and surname, email address, physical address, gender, mobile number, and date of birth.
1.3. Should the customer’s personal information change, please inform Vox and provide Vox with the updates within 7 days to enable Vox to update the customer’s personal information.
1.4. Customer may choose to provide additional personal information to Vox, in which event customer agree to provide accurate and current information, and not to impersonate or misrepresent any person/entity or falsely state or otherwise misrepresent the customer’s affiliation with anyone or anything.
1.5. Vox asks each of its customers to abide by all applicable laws, rules and regulations, as Vox will do so ourselves.
1.6. The “Products” and “Services” and related services are described on the Vox website at www.vox.co.za and in the customer contract.
2. Customer’s Consent
2.1. By using Vox and its Products and/or Services, the customers consent to the processing of the customer’s personal data. Subject to the below, Vox will not, without the customer’s consent, use the customer’s personal information for any purpose other than as set out hereunder:
2.2. Vox uses customers’ personal information for several purposes:
2.2.1. to register the customer for inclusion in our Service to fulfil the customer’s request;
2.2.2. to contact customers if Vox needs to obtain or provide additional information;
2.2.3. to verify the accuracy of our records;
2.2.4. to contact customers regarding customer satisfaction surveys in relation to the ordering, sale, delivery, performance and quality of Products and Services;
2.2.5. to contact customers regarding current or new Products or Services or any other Products offered by Vox (unless customers have opted out from receiving marketing material from Vox);
2.2.6. to inform customers of new features, special offers and promotional competitions offered by Vox (unless customers have opted out from receiving marketing material from Vox);
2.2.7. to improve our Products, Services and customers selection and the customer’s experience on our Products and/or Services by, for example, monitoring the customer’s browsing habits, or tracking the customer’s sales on the Products and/or Services;
2.2.8. to collect certain technical information, such as the browser version and operating system;
2.3. Vox shall not disclose the customer’s personal information to any third party other than as set out below:
2.3.1. to our employees and/or third-party Service providers that need to know the customer’s personal information in order to assist Vox to communicate with customers properly and efficiently.
2.3.2. to law enforcement, government officials, fraud detection agencies or other third parties when Vox believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of the Privacy Policy;
2.3.3. to our Service providers (under contract with Vox) who help with parts of our business operations (fraud prevention, networks, platforms, licenses, marketing, technology Services etc.). However, our contracts dictate that these Service providers may only use the customer’s information in connection with the Services they perform for Vox and not for their own benefit;
2.3.4. to our suppliers in order for them to liaise directly with customers in the event of customers submitting a warranty claim regarding any Products or Services customers have purchased which requires their involvement.
2.4. From time-to-time Vox may also administer random “interactive pop-up” surveys to some customers. These surveys request additional demographic, non-personally identifiable information. The customers’ participation in a survey is always voluntary, and customers therefore have a choice whether to provide the requested survey information. Vox uses the information collected in the survey, in conjunction with information gathered through cookies and code, in order to provide customers with an even more detailed understanding of its target market;
2.5. Some voluntarily provided personally identifiable information may be captured; for example, when an email address or telephone number is incorporated into a survey for the potential awarding of a prize draw, or when the respondent has opted-in to possible follow up research. This information may be shared with entities or other customers who in turn have agreed to adhere to this Privacy Policy;
2.6. Vox is entitled to use or disclose the customer’s personal information if such use or disclosure is required in order to comply with any applicable law, subpoena, order of court or legal process served on Vox, or to protect and defend our rights or property;
2.7. Vox will ensure that all our employees, third party Service providers, suppliers, divisions and partners (including their employees and third-party Service providers) having access to the customer’s personal information are bound by appropriate and legally binding confidentiality obligations in relation to the customer’s personal information.
3. Personal Information
3.1. Vox will:
3.1.1. treat the customer’s personal information as strictly confidential, save where Vox is entitled to share it as set out in this Policy;
3.1.2. take appropriate technical and organisational measures to ensure that the customer’s personal information is kept secure and is protected against unauthorised or unlawful processing, accidental loss, destruction or damage, alteration, disclosure or access;
3.1.3. provide customers with access to the customer’s personal information to view and/or update personal details;
3.1.4. promptly notify customers if Vox becomes aware of any unauthorised use, disclosure or processing of the customer’s personal information;
3.1.5. provide customers with reasonable evidence of our compliance with our obligations under this Policy on reasonable notice and request;
3.1.6. upon the customer’s request, promptly return or destroy any and all of the customer’s personal information in our possession or control, save for that which Vox is legally obliged to retain;
3.2. Vox undertakes never to sell or make the customer’s personal information available to any third party other than as provided for in this Policy.
3.3. Whilst Vox will do all things reasonably necessary to protect the customer’s rights of Privacy, Vox cannot guarantee or accept any liability whatsoever for unauthorised or unlawful disclosures of the customer’s personal information, whilst in our possession, made by third parties who are not subject to our control.
3.4. If customers disclose the customer’s personal information to an unrelated third party, such as an entity which operates products and/or services linked to Vox supplied Products and/or Services, Vox WILL NOT BE LIABLE FOR ANY LOSS OR DAMAGE, HOWSOEVER ARISING, SUFFERED BY YOU AS A RESULT OF THE DISCLOSURE OF SUCH INFORMATION TO THE THIRD PARTY. This is because Vox does not regulate or control how that third party uses the customer’s personal information. The customer should always ensure that they read the Privacy Policy of any third party;
3.5. Retention Period. Vox will retain the customer’s personal information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law;
3.6. Cross-Border Transfer for customers: The personal information from customers may be stored and processed in any country where Vox has facilities or where the Products or Services originate, and by using Product or Services the customer’s consent to the transfer of information to countries outside of the customer’s country of residence, which have different data protection rules than in the customer’s country;
3.7. Children and Privacy. The Vox Products and/or Services do not offer information intended to attract children. Vox does not knowingly solicit personal information from children under the age of 18;
3.8. Your right to access information. Customers have the right to request a copy of the personal information we hold about the customer. To do so, simply email Vox on our contact details below and send a request to review the personal information or contact us at the numbers/addresses listed below and specify what information is required. Vox will take all reasonable steps to confirm the customer and/or customer’s identity before providing details of its personal information. Please note that any such access request may be subject to a payment of a legally allowable fee;
3.9. Correction of information. Customers have the right to ask Vox to update, correct or delete personal information. Customers may do this by completing the Form 2 on the Vox website. Vox will take all reasonable steps to confirm the customer’s identity before making changes to personal information held about the customer.
3.10. Vox’s POPI contacts. Please refer to Vox’s PAIA manual for more detail.
4. Vox Vobi application
4.1. The Vox Vobi application will only collect and use your contacts information stored on your mobile device on which Vobi is installed if customer allows this option in the application and configures its mobile device to allow the Vobi Application to access the mobile device’s contact list.
4.2. Should you allow the Vobi App access to the contacts list on your mobile, the following personal information from your address book will be viewable in the Vobi App:
4.2.1. Contacts’ names
4.2.2. Contacts’ email
4.2.3. Contacts’ telephone numbers
4.2.4. Contacts’ organization
4.3. Vox will use this information to populate your contacts data in the Vobi App.
4.4. The Vobi App only uses your Contacts information to make your contact information conveniently available in the Vobi App.
4.5. You can choose at any time to erase the collected contact data by denying access to your contacts in your device settings or you can uninstall the “Vobi” application at any time.
5. Security
5.1. Vox uses reasonable organisational, technical and administrative measures to protect personal information under its control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. PLEASE ALSO READ OUR DATA PROCESSING ADDENDUM.
5.2. If customers have reason to believe that the customer’s interaction with Vox is no longer secure (for example, if customers feel that the security of any account customers might have with Vox has been compromised), please immediately notify Vox of the problem.
6. Digital Marketing – Cookies – Website and/or App
6.1. Our Website and/or App makes use of “cookies” to automatically collect information and data through the standard operation of the Internet servers. “Cookies” are small text files a Website and/or App can use (and which Vox may use) to recognise repeat customers, facilitate the customer’s on-going access to and use of a Website and/or App and allow a Website and/or App to track usage behaviour and compile aggregate data that will allow the Website and/or App operator to improve the functionality of the Website and/or App and its content.
6.2. The type of information collected by cookies is not used to personally identify customers. If customers do not want information collected using cookies, there is a simple procedure in most browsers that allows customers to deny or accept the cookie feature.
6.3. Please note that cookies may be necessary to provide customers with certain features available on our Digital Marketing Services, and thus if customers disable the cookies on the customer’s browser, customers may not be able to use those features, and the customer’s access to our Digital Marketing Services will therefore be limited. If customers do not disable “cookies”, customers are deemed to consent to our use of any personal information collected using those cookies.
7. Changes to the Privacy Policy
7.1. Vox may, in its sole discretion, change any of the terms and conditions of this Privacy Policy at any time. It is the customer’s responsibility to regularly check the Privacy Policy and make sure that customers are satisfied with the changes. Should a customer not be satisfied, customers must not place any further orders on, or in any other way use, the Products and/or Services.
7.2. Any such change will only apply to the customer’s use of these Products and/or Services after the change is displayed on the Products and/or Services. If customers use the Products and/or Services after such amended Privacy Policy, customers will be deemed to have accepted such changes.
8. Electronic Communications
8.1. When customers visit the Products and/or Services or send emails to Vox, customers consent to receiving communications from Vox electronically in accordance with our Privacy Policy.
9. Governing Law and Jurisdiction
9.1. This Privacy Policy, our relationship and/or any dispute arising from or in connection with
the Privacy Policy will be governed and interpreted in accordance with the laws of the Republic of South Africa.
