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. About the 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 differently 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 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 to provide 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 an 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. About the 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 about 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 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 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 using 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 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 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;</li