PLACEMENT PLUS (PTY) LTD – PRIVACY POLICY
Last updated October 2022
Placement Plus (Pty) Ltd (“Placement Plus”, “we”, “us” “our”) is committed to protecting and respecting your privacy.
1. DEFINITIONS
1.1 “User” means a person that accesses, browses, crawls, scrapes, or in any way uses the Platform and includes but is not limited to: any person who submits an application for employment in response to a job advert submitted by a prospective employer.
1.2 “Client” means a user registered on the Platform and who has a current Subscription Agreement with Placement Plus for use of the Subscription Services
1.3 “Data Subject” means the person to whom the personal information relates.
1.4 “PAIA” means the Promotion of Access to Information Act, 2000 (Act No. 2 of 2000).
1.5 ‘‘Personal Information’’ means information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person.
1.6 “Platform” means the website, www.placementplus.co.za , and mobile application accessible through this website, www.placementplus.co.za, of which Placement Plus is the registered licensee.
1.7 “POPIA” means the Protection of Personal Information Act, No. 4 of 2013, as amended from time to time;
2. WHAT IS THIS PRIVACY POLICY FOR?
2.1 This Privacy Policy in conjunction with the Terms and Conditions of Use apply to your access and use of the Platform
2.2 This Privacy Policy describes the ways in which any personal information we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and its utilization.
2.3 This policy serves to protect the Company from compliance risks associated with the protection of personal information which includes: breaches of confidentiality, and reputational damage.
2.4 The policy also demonstrates the Company’s commitment to protecting the privacy rights of Data subjects including; the Company’s Board of Directors, all employees, contractors, suppliers, clients, persons acting on behalf of the company and all potential and existing Data subjects.
2.5 At Placement Plus we are committed to protecting your privacy impact and to ensure that your Personal Information is collected and used properly, lawfully, and transparently.
3. USER CONSENT
By using the Platform, you confirm that you agree to the terms of this Privacy Policy and you expressly consent to the collection, use and processing of your personal information by us, our affiliates, subsidiaries, partners, contractors and permitted agents according to this Privacy Policy.
4. INFORMATION WE MAY COLLECT FROM YOU
We will collect and process the following data from you:
4.1 Personal Information: all the information you submit when you create an account on the Platform This includes and not limited to:
4.1.1 Telephone Number (s)
4.1.2 Date of Birth
4.1.3 Email Address
4.1.4 Residential address
4.1.5 Identity/Passport number
4.1.6 Name
4.1.7 Surname
4.1.8 Employment history
4.1.9 Work experience
4.1.10 Qualifications
(Hereafter referred to as “Personal Information”)
4.2 Further information:
4.2.1 The User may visit the Platform without providing any Personal Information. However, the Platform’s servers may still collect technical information from the User regarding the use of the Platform, which is aggregated for analytical purposes, technical maintenance and for improving the content offered on the Platform, including but not limited to:
4.2.1.1 internet protocol (IP) addresses;
4.2.1.2 internet service provider information (ISP);
4.2.1.3 browser information and date and time stamps;
4.2.1.4 a User's location,
4.2.1.5 a User’s usage information.
4.2.2 A User will not be identified from or by the information outlined in 4.2.1 and Placement Plus is entitled to copy, distribute or otherwise use such information without limitation.
4.2.3 If you contact us, we may keep a record of that correspondence and/or ask for further information
4.2.4 We may also ask you to complete surveys to provide extra information, although you are under no obligation to respond to these surveys;
5 HOW WE USE YOUR INFORMATION
5.1 Placement Plus may collect a User's Personal Information and use such information for any lawful purpose relating to a function or activity of Placement Plus's business or in any other lawful manner recorded elsewhere in this Privacy Policy. Such purposes may include the following:
5.1.1 to enter into a contract with a Client;
5.1.2 to perform any obligations under a contract with a Client;
5.1.3 to comply with a legal obligation;
5.1.4 to protect a legitimate interest of a Client (unless the User has specifically objected in writing to all or some of the processing activities on reasonable grounds);
5.1.5 to pursue its own legitimate interests or the legitimate interests of a third party who it is sharing the information with (unless the User has specifically objected in writing to all or some of the processing activities on reasonable grounds);
5.1.6 to process Personal Information for credit, qualifications check and criminal reporting purposes;
5.1.7 to process Personal Information for direct marketing purposes (unless the User has opted out of receiving any direct marketing material);
5.1.8 to present content to the User in the most effective way for them and their viewing device and browser;
5.1.9 to customize and display content including, but not limited to products, articles, listings
5.1.10 to enable the User to voluntarily participate in interactive features on the Platform;
5.1.11 to notify the User about changes to the Platform;
5.1.12 and advertisements to the User in a way that Placement Plus feels may interest the User or be most beneficial to them; and/or
5.1.13 to send content including, but not limited to products, articles, listings and advertisement content to the User via email or other electronic media, where the User has consented to be contacted by Placement Plus with such content.
5.2 If Placement Plus intends to process a User's Personal Information for any other purpose not listed in Clause 5.1 or elsewhere in this Privacy Policy, or which is otherwise not automatically permitted by law, it shall ensure that it obtains the User's written consent to do so.
5.3 Placement Plus shall only sell a User's Personal Information to a third party with the prior written consent of the User and only to the extent permitted by law.
6. DIRECT MARKETING
6.1 You hereby consent to the processing of your Personal Information for the purpose of direct marketing by means of electronic communications including automatic calling machines, SMS's or electronic mail.
6.2 The User can opt out of receiving further marketing communications by un-checking certain boxes on the forms used on the Platform to collect their personal information, or by contacting Placement Plus at info@placementplus.co.za
7. USE OF COOKIES
7.1 This Platform uses cookies to better the users experience while visiting the Platform. Where applicable, this Platform uses a cookie control system allowing the user on their first visit to the Platform to allow or disallow the use of cookies on their computer / device.
7.2 Cookies are small files saved to the user's computer hard drive that track, save and store information about the user's interactions and usage of the Platform. This allows the Platform, through its server to provide the users with a tailored experience within this Platform.
7.3 Users are advised that if they wish to deny the use and saving of cookies from this Platform on to their computers hard drive they should take necessary steps within their web browsers security settings to block all cookies from this Platform and its external serving vendors.
7.4 This Platform uses tracking software to monitor its visitors to better understand how they use it. This software is provided by Google Analytics which uses cookies to track visitor usage. The software will save a cookie to your computer’s hard drive, to track and monitor your engagement and usage of the Platform, but will not store, save or collect Personal Information. You can read Google's privacy policy here for further information [ http://www.google.com/privacy.html ].
7.5 Other cookies may be stored to your computer’s hard drive by external vendors when this Platform uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No personal information is stored, saved or collected.
8. RISKS ASSOCIATED WITH USING THE PLATFORM
8.1 All information you provide to us is stored on our secure servers. However, the transmission and storage of information using the internet and servers is not completely secure. Although we will do our best to protect your personal data, and will employ strict secure processes and security features, we cannot guarantee the security of data transmitted or stored using our Platform; any transmission or submission of data while using the Platform is therefore at your own risk.
8.2 Information wirelessly sent to and from your device may be captured by someone else with a wireless device. Please keep this in mind when sending or accessing personal or business information.
8.3 When accessing the Platform, anti-virus, security and privacy of information is the responsibility of the Device owner.
8.4 If you reside outside the Republic of South Africa, you understand that your personally identifiable information will be processed in the Republic of South Africa, where laws regarding processing of personal information may be less stringent than the laws in your own country.
8.5 When we contract with third parties, we impose appropriate security, privacy and confidentiality obligations on them to ensure that Personal Information that we remain responsible for, is kept secure.
8.6 We will ensure that anyone to whom we pass your Personal Information in the ordinary course of our business agrees to treat your information with the same level of protection as we are obliged to.
9. PLATFORM SECURITY
9.1 Placement Plus is committed to protecting the Personal Information in its custody against any loss of, damage to or unauthorized destruction of that information, and to prevent any unauthorized parties from accessing that information. Placement Plus shall take reasonable steps in this regard but to the maximum extent permitted by law shall not be liable for any loss arising as a result of a failure of its systems.
9.2 Users must maintain the secrecy of any passwords used to gain access to this Platform and should change such passwords regularly.
10. PROTECTION OF YOUR DATA
10.1 Placement Plus shall maintain appropriate administrative, physical, and technical safeguards for the protection of data, confidentiality and integrity of Client and user data. All data is stored and maintained in South Africa.
10.2 We shall not (a) modify client/user Data, (b) disclose client/user data except as compelled by law or as expressly permitted in writing by a user/client, or (c) access client Data except to provide the services or prevent or address service or technical problems, or at a client’s request in connection with customer support matters. However, clients should note that a User may request Placement Plus to delete their complaint related material.
11. RETENTION OF DATA
Due to security and privacy concerns, Placement Plus does not allow migration of any data from Placement Plus’s database. Accordingly, after the termination or expiration of the Agreement for any reason, Placement Plus shall retain all data for a period of three (3) years (“Retention Period”). During the Retention Period, a Client shall have a limited right to access and view data at no additional charge. This limited right does not include the right to further use the Placement Plus services in any other manner. After the Retention Period has expired, Placement Plus shall have the right to permanently destroy data or a Client may contact Placement Plus to inquire whether Placement Plus has fee-based retention alternatives.
12 HOW WE USE YOUR INFORMATION
12.1 We will use your Personal Information only for the purposes for which it was collected and agreed with you. In addition, where necessary your information may be retained for legal or research purposes. For example:
12.1.1 To gather contact information;
12.1.2 To use or permit selected third parties to use your data, to provide you with information about those goods and services that may be of interest to you;
12.1.3 To provide aggregate information about our users to our advertisers or selected third parties for consumer analysis and marketing.
12.1.4 To confirm and verify your identity or to verify that you are an authorized user for security purposes;
12.1.5 For the detection and prevention of fraud, crime, money laundering or other malpractice;
12.1.6 To conduct market or customer satisfaction research or for statistical analysis;
12.1.7 For audit and record keeping purposes; and/or
12.1.8 In connection with legal proceedings.
12.2 We will only contact you by electronic means (e-mail or SMS) with information about goods and services
12.3 Where we permit selected third parties to use your data, we (or they) will only contact you by electronic means.
12.4 Placement Plus shall comply with all applicable laws, contracts or regulations when it processes a User's Personal Information.
13. DISCLOSURE OF YOUR INFORMATION
13.1 We may disclose your Personal Information to third party service providers who are involved in the delivery of our services. Third party service providers include but are not limited to:
13.1.1 Payment Gateway Provider (User's full names, credit card details);
13.1.2 Bulk email delivery providers (User's email addresses);
13.1.3 Potential providers of goods and services to you if you utilize certain of the functionality on the Platform including applying for a vacancy which may lead to an offer for employment and as such will require that we conduct verification checks of your personal data, such as criminal record, qualifications check, work history.
13.2 Placement Plus may also share aggregated information about Users of this Platform and their usage patterns. Placement Plus may also use such aggregated information to help advertisers target specific audiences. Such aggregated information will be de-identified and the User's personal information will not be disclosed.
13.3 Other than as stated in Clauses 13.1 and 13.2, Placement Plus shall not share a User's Personal Information with any third parties unless:
13.3.1 it has the User's express consent to do so
13.3.2 If we are under obligation to disclose or share your personal data in order to comply with any legal or regulatory obligation or request; and/or
13.3.3 In order to: enforce or apply this Privacy Policy, the Terms of Use, or to investigate potential breaches; or protect the rights, property or safety of us, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
14. CONSENT
14.1 The User hereby consents to the processing of their personal information in terms of the provisions of this Privacy Notice.
14.2 The User acknowledges and agrees that such consent has been given voluntarily after the User has read and understood the provisions of this Privacy Notice, in particular, regarding the following:
14.2.1 the types of personal information to be processed;
14.2.2 the specific processing activities to be undertaken;
14.2.3 the specific purpose/s for such processing; and
14.2.4 the possible consequences for the User that may arise from such processing.
15. Access to your Personal Information
You have the right to request a copy of the Personal Information we hold about you. To do this, simply contact us at the numbers/addresses listed on our home page and specify what information you require. We will take all reasonable steps to confirm your identity before providing details of your personal information. / We will need a copy of your ID document to confirm your identity before providing details of your personal information.
Please note that any such access request may be subject to a payment of a legally allowable fee, as laid down in our POPIA Policy.
16. Correction of your Personal Information
You have the right to ask us to update, correct or delete your personal information. We will take all reasonable steps to confirm your identity before making changes to Personal Information we may hold about you. We would appreciate it if you would take the necessary steps to keep your Personal Information accurate and up to date by notifying us of any changes we need to be aware of.
Contact Us If you have any questions about this Privacy Policy, please contact us.
17. APPLICABLE LAWS
This Privacy Policy and the interpretation and enforcement thereof, will be governed by the laws of the Republic of South Africa, included but not limited to PAIA and POPIA.
18. UPDATES TO OUR PRIVACY POLICY
Any changes we may make to this Privacy Policy in the future will be posted on this page and, where appropriate, you will be notified by SMS or by e-mail. You may also be notified when you log onto the Service, and it may be necessary for you to accept the amended policy before you can continue to use the Services.
Contact Us If you have any questions about this Privacy Policy, please contact us.
19. Resources & Further Information
In terms of the POPI Act (POPIA) section 18. (h) (v) you have the right to lodge a complaint to the Information Regulator (South Africa) (IRSA). The IRSA contact details are:
https://www.justice.gov.za/inforeg/contact.html
JD House, 27 Stiemens Street
Braamfontein, Johannesburg, 2001
P.O Box 31533
Braamfontein, Johannesburg, 2017
Complaints email: complaints.IR@justice.gov.za
The details of our Information Officer are as below:
Name: Evadne Johnson
Telephone number: +27 11 469 0124
Physical and Postal Address: Unit 8 Mulberry Hill Office Park, Broadacres Drive, Dainfern, 2191 Johannesburg South Africa
E-Mail Address: info@placementplus.co.za