Privacy Policy

TECHNOLOGY SOLUTIONS (PTY) LTD (“2TS”, “TTS”, “WE” OR “US”), REGISTRATION NUMBER 2009/009342/07 AND REGISTERED BUSINESS ADDRESS AT MIDLANDS OFFICE ESTATE WEST, MOUNT QURAY ROAD, MIDSTREAM ESTATE, GAUTENG, 1692, SOUTH AFRICA.

AT 2TS WE ARE COMMITTED TO SAFEGUARDING YOUR PRIVACY. THIS PRIVACY POLICY DESCRIBES HOW WE MAY COLLECT, USE, SHARE AND KEEP PERSONAL INFORMATION ABOUT AND/OR THAT HAS BEEN PROVIDED BY YOU. PLEASE READ THIS DOCUMENT CAREFULLY.

YOU CAN REQUEST YOUR PERSONAL INFORMATION AT ANY TIME BY FILLING OUT AND SUBMITTING THE FOLLOWING FORMS:

• PAIA Form 02 Request for Access to Record
• PAIA Form 03 Outcome of Request and Fees Payable

1. What does our Privacy Policy cover?

This Privacy Policy applies to our public-facing Thuthukani branded website and other online services and will be available by a link on all sites and services which it covers, what type of information about our websites’ users is gathered and tracked, and how the information is used, shared or otherwise processed offline. It also describes how cookies; web beacons and other technologies may be used in our services and software products. Reference to 2TS website, products and services in this Privacy Statement include apps, programs, and devices. Other 2TS websites, apps, or online services may collect and use personal information about you in a different way and so publish a different 2TS Privacy Policy. We encourage you to take a moment to look at the applicable Privacy Policy, available by a link at the bottom of the homepage or as you download the app. We may also ask you to register a 2TSid, in which case you need to provide us with your name, email address, country location and other information if needed for the purpose for which you are asked to register. The 2TSid serves to uniquely identify you when you visit our websites, have a request or order or use a product or service. For ordering of most services and products we require you to have registered a 2TSid. Registration with 2TSid may allow you to customize and control your privacy settings. Certain 2TS products and services may require unique registration specifically for the purpose of providing these products or services. In such cases, registration details provided by you for a product or service will only be used for the specific purpose of providing you with that product or service. In addition, some of our software products and 2TS Subscription services include technologies that allow 2TS to collect certain information about the use of our products and services. We may also use such technologies to determine whether you’ve opened and e-mail or clicked on a link contained in an email. For details regarding the technologies we employ, see Cookies, Web Beacon and Other Technologies below. This Privacy Policy applies to our public-facing Thuthukani branded website and other online services and will be available by a link on all sites and services which it covers, what type of information about our websites’ users is gathered and tracked, and how the information is used, shared or otherwise processed offline. It also describes how cookies; web beacons and other technologies may be used in our services and software products. Reference to 2TS website, products and services in this Privacy Statement include apps, programs, and devices.

2. What is in our Privacy Policy?

•  What personal information do we collect?
•  Do we use cookies?
• How do we use your personal information?
• How long do we keep your personal information?
• How do we share your personal information?
• Where do we keep your personal information?
• What rights do you have in relation to your personal information?
• How do we safeguard your personal information?
• How will we update this, Policy?
• How can you contact us about this Policy?
• Other important Information.

3. What personal information do we collect?

For the purpose of this Privacy Policy, references to ‘personal information’ shall have the meaning ascribed thereto in terms of section 1 of Protection of Personal Information Act No. 4 of 2013 (“POPI”), which includes any information relating to an identified or identifiable individual. Examples of personal information may include, for example: i) your name, ii) your contact details, or iii) your location.
We collect information that you supply to us when you choose to contact us for more information or when you register for one of our websites or online services. You may supply the information directly to us or indirectly by using your credentials from third parties such as LinkedIn or Facebook. This information typically includes your name, professional credentials, email address and other contact data. We may append information from other sources, such as Google Analytics, to supplement what you give us. We do, on occasion, obtain or license contact information from third parties for limited marketing purposes, such as maintaining an accurate marketing database. We shall endeavour to only collect and process personal information relating to you, which is adequate, relevant, and not excessive in terms of POPI and which is required by us to provide you with the required products and services.

4. Use and processing of Personal Information

For the purpose of this Privacy Policy, references to ‘processing’ shall mean any operation or activity or any set of operations, whether or not by automatic means, (i) concerning personal information, including the collection receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use (ii) dissemination by means of transmission, distribution or making available in any other form; and (iii) merging, linking as well as restriction, degradation, erasure or destruction of information..

We shall only process your personal information if the processing is:

• necessary to carry out our obligations to you;
• consented to by you;
• required for us to comply with our obligations imposed by law, including under the Financial Intelligence Centre Act No. 38 of 2001;
• necessary to protect a legitimate interest of yours; and
• necessary to pursue our legitimate interests or that of a third party to whom the information is supplied.

5. Do we use cookies?

We use cookies and other commonly used data collection technologies on our website and in our newsletters and emails to collect information on both an aggregate and individual basis. Please see our Cookies Policy for more details on how we use cookies and how to control cookies or their use for targeted advertising or marketing.
As mentioned above, we collect information from your visits to our website and your use of our software products to help us gather statistics about usage and effectiveness, personalize your experience, tailor our interactions with you, and improve our products and services. We do so through the use of various technologies, including scripts, tags, Local Shared Objects (Flash cookies), Local Storage (HTML5) beacons, and “cookies”.

6. How do we use your personal information?

We may use personal information we collect to:

• provide and administer our services;
• understand our audience and improve how our websites work;
• contact you and answer your questions;
• market and advertise our products and services to you;
• allow you to publish comments and participate in professional web-based forums;
• keep our systems, users, employees and services safe; and
• provide you with the information or support you requested.

7. How long do we keep your personal information?

We keep your personal information for so long as is necessary in light of the purpose for which it was originally collected or lawfully further processed. The criteria we use to determine the period of time for which your personal information may be kept include:

• the nature and type of personal information that you provide to us;
• the purpose for which you provide your personal information to us; and
• necessary business and operational requirements to continue to supply you with the services or functionality you have requested.
  We may retain your information for a longer time period if we are required to do so by law.

8. How do we share your personal information?

We may disclose personal information about you to third parties, including:

• to other members of the 2TS group of companies;
• to vendors that work on our behalf;
• to law enforcement when we have a good-faith belief that it is necessary to comply with a court order, ongoing judicial proceeding, or other legal process served on us;
• to exercise our legal rights or defend against legal claims; and
• to protect human safety or our networks or property, or as part of a sale or merger of our company or business assets.
• Fulfilling your Transaction Request: If you request something from 2TS, for example, a product or service, or a callback, or specific marketing materials, we will use the personal information you provide to fulfill your request. To help us do this, we may share information with others, for instance, 2TS’ partners, financial institutions, shipping companies, postal or government authorities, such as customs authorities, involved in fulfillment.
• Providing Support: We may use your personal information to support products or services you have obtained from us, such as notifying you of a product update or fix. We may combine your information from other interactions with you to provide you with more valuable suggestions in relation to product support. In the course of providing technical support to you, we may sometimes have incidental access to data that you have provided to us or data that is located on your system. This data may contain information about you, your organization’s employees, customers, partners or suppliers. This Privacy Statement does not apply to our access to or handling of this information; the conditions regarding the handling and processing of this date is covered in the applicable Terms of Use or other agreements between you and 2TS, such as the Terms of Use for Exchanging Diagnostics Data. Some 2TS sites and software products may also use web beacons or other technologies to better tailor those sites to provide better customer service. These technologies may be in use on a number of pages across 2TS’ website. When a visitor accesses these pages, a non-identifiable notice of that visit is generated which may be processed by us or by our suppliers. These web beacons usually work in conjunction with cookies. If you don’t want your cookie information to be associated with your visits to these pages or use of these products, you can set your browser to turn off cookies or turn off cookies in the product itself, respectively. If you turn off cookies, web beacons and other technologies will still detect visits to these pages; however, they will not be associated with information otherwise stored in cookies.
• We undertake to ensure that any affiliates or third-party service providers to which personal information is disclosed, complies with the necessary confidentiality, processing and privacy standards set out by POPI and this Privacy Policy.
• For more information about the technologies employed by our services and software products, including how to turn them off, please consult the user guide for the particular software product or 2TS services you are using.

9. Where do we keep your personal information?

We collect, store, and process information on servers around the world and may access that information globally. If you are located in the European Union, please note that your personal information may be transferred out of, or stored outside, the European Economic Area. The privacy protections in these jurisdictions may not be equivalent to those in Europe. We will take steps to ensure that your personal information continues to be protected through adequate safeguards, copies of which are available from us on request at the email address below.

10. What rights do you have in relation to your personal information?

European law gives individuals a number of rights in relation to their personal information. These include the right to access, and in some circumstances to amend, delete, or restrict the continued processing of, personal information. Please note that deleting your information or restricting the continued processing of your information may limit our ability to continue to provide our websites, applications, and online services to you. You also have a choice about:

• Whether to receive email marketing messages from us. You may opt out of our email marketing lists by following the opt-out directions at the bottom of our promotional emails. Please note that we have a number of brands and products that allow you to opt out selectively. To remove a specific email address from all 2TS email marketing, send a request to: info@2ts.co.za
• Whether to share information about yourself and your use of our sites with third parties including social media sites.
  or If you join one of our online communities, your comments as well as certain information about you may be visible to other members of the community. Please take a moment to understand how each forum works and what choices you have.
  or If you use credentials from third party, like Facebook, to register, then that third party will also record the fact that you have registered for our sites and may use that information consistent with its own privacy statements and practices. If you use Share, Like or similar social media buttons, those actions may be posted elsewhere (such as on the relevant social media sites).
  or Whether to allow certain uses of cookies and other data collection technologies. Please see our Cookies Policy.
  If you have any questions about your rights, please email us at info@2ts.co.za. You can also contact your local Data Protection Authority.

11. How do we safeguard your personal information?

We use a range of security measures to protect your personal information. Please be aware, however, that 2TS cannot guarantee that third parties will safeguard your personal information in a similar manner. Unencrypted information – including information sent via email – may also be able to be read by third parties. As a user of our services, you are responsible for protecting the information you provide, including user name and passwords, for misuse, by encryption or other means.

12. How will we update this Policy?

We are constantly working to develop new services. We may also change our practices over time as our business and technology evolve, and this may involve changes to the ways in which we collect, process and use your information. As a result, we may amend this Privacy Policy from time to time. If we materially change our Privacy Policy, we will take steps to inform you of the change. We may do this through email. SMS, notices on our websites or other means (or a combination of these means). If you continue to use our sites, applications, and online services after the date any revised Privacy Policy comes into effect, you will be deemed to have read and agreed to the revised Privacy Policy.
The “Effective Date” of this Privacy Policy shows when it was last updated.

13. Information Officer

Our information officer is Mr. Dehan Trumpie. The information officer is responsible for our compliance with POPI and ensuring the lawful processing of your personal information. The details of the information officer are as follows:
Information Officer:
Name: Mr. Dehan Trumpie
Telephone Number: +27 (0)12 021 0103
E-mail: info@2ts.co.za
Physical address: Midlands, Office Park West, Mount Quray Road, Midstream Estate, Gauteng, 1692, South Africa

14. Applicable Laws

This Privacy Policy will be governed by and construed and interpreted in accordance with the laws of the Republic of South Africa.

15. Other important information

Our sites contain links to other websites not owned by 2TS. We do not control the privacy practices of those sites.
Our website and offerings are directed to people in their business and professional capacities. They are not intended for children under 13 years of age. We do not knowingly solicit information online from, or market online to, children under 13 years of age.
By consenting to our terms and conditions when you register on any of our platforms and by browsing and/or making use of any of our platforms, you expressly consent to this Privacy Policy governing your use of the platform; (i) our collection, processing and disclosure of your personal information as set out in this Privacy Policy; (ii) and the use of cookies on the platforms, if and when applicable. You have the right to withdraw consent at any time, but this will not affect any prior processing of your personal information.