Privacy & Security Statement

This Privacy and Security Statement applies to this web site which is owned and operated by SP24 Security Services under the domain name www.sp24security.co.za ("SP24 Security Services Web site"). References to this Privacy and Security Statement includes the Schedule.

To address our mutual rights, duties and obligations arising as a result of the implementation of the General Data Protection Regulation 2016/679 (“GDPR") and the Applicable Data Protection Laws (as defined in the Schedule), that come into effect across the EU on May 25 2018, in our provision of our services, the User and you authorise SP24 Security Services to process Personal Data provided to SP24 Security Services or which is made available to it for the purposes set out in Paragraph 4 of the Schedule (“Purposes"). For the purposes of GDPR and/or the Applicable Data Protection Law, you as the User shall be the "Data Controller" and SP24 Security Services shall be the "Data Processor" in respect of any personal data you have provided to us to process for the Purposes. The Schedule defines the Data Subjects, Categories of Personal Data, Processing Operations, and Duration of Processing relevant to the provision of the Services.

We collect and, in some cases, disclose information about you as part of the normal operation of our services. SP24 Security Services understands and values your concerns about your privacy and the confidentiality and security of information we may collect from you online. SP24 Security Services is dedicated to protecting your privacy. This SP24 Security Services Privacy and Security Statement describes how information obtained from you will be treated as you access and interact with the SP24 Security Services Web site.

In addition to the provisions of this Privacy and Security Statement, certain sections of the SP24 Security Services Web site may have specific and additional privacy provisions. Because those specific and additional provisions also protect your privacy, you should read them wherever they are available on the SP24 Security Services Web site. In the event of a conflict between the provisions of this Privacy and Security Statement and those other specific and additional provisions, the latter will take precedence.

1. Acceptance and changes to Privacy and Security Statement

This Privacy and Security Statement is incorporated into and subject to the Terms of Use, which together is intended to constitute a single binding agreement of terms and conditions for your use of the SP24 Security Services Web site ("the Agreement"). This Privacy and Security Statement supplements the Terms of Use, and unless the context indicates or requires otherwise, terms defined therein shall have the same meanings in this Privacy and Security Statement. In the event of a conflict, the provisions of the Terms of Service will take precedence. You acknowledge and accept that by using or accessing the SP24 Security Services Web site, you are indicating your acceptance of the Agreement. The following is the most recent Privacy and Security Statement. It supersedes any previous Privacy and Security Statement for the SP24 Security Services Web site that has been published on the SP24 Security Services Website. SP24 Security Services will continue to strive to provide you with better and more customized services, as well as a more effective web site, as the SP24 Security Services Web site develops and technology evolves. SP24 Security Services reserves the right to change the Privacy and Security Statement at any time by posting the revised Privacy and Security Statement on the SP24 Security Services Web site. You agree that by doing so, SP24 Security Services has given you adequate notice of the changes. SP24 Security Services does, however, encourage you to review the Privacy and Security Statement on a regular basis because it may change from time to time.

2. Information and Personal Data

(a) We collect information from you in order to provide you with a smooth, efficient, and personalized service while using SP24 Security services. Some of this information may be in a form or format that allows you or another person to be identified ("Personal Data").
(b) The more information you provide (and the more accurate it is), the better we can tailor your experience. Please keep in mind that, in accordance with Section 2.03(i) of the Terms of Service, you have warranted the accuracy of any Personal Data or Content that you may Post.

(c) If you visit the SP24 Security Services Web site to read, browse, or download information, our system will log the date and time of your visit, the pages you view, and any information you download.

(d) To use some of the services offered by SP24 Security services, you may be required to fill out various online forms containing Personal Data such as your name and e-mail address.

(e) We make every effort to include a link to this Privacy and Security Statement whenever you provide SP24 Security Services with Personal Data.

(f) You authorize SP24 Security Services to track certain Personal Data about you automatically based on your behaviour on the SP24 Security Services Web site and to use such Personal Data for internal research on user preferences and behaviour in order to better understand and serve our users.
In accordance with this Privacy and Security Statement, such Personal Data are aggregated and cumulatively compiled and analysed.

3. Third Party Web sites

(a) The SP24 Security Services Web site also contains links to the websites of third-party providers of goods and services, as well as the websites of SP24 Security Services Affiliates (collectively referred to as "Third Party Web sites"), from which Personal Data about you may be obtained. If you access Third Party Web sites via the SP24 Security Services Web site and those third parties receive information about you, SP24 Security Services may receive or have access to that information as part of our arrangements with those third parties.

(b) Third-party websites should have their own privacy policies. Third-party Web sites are not covered by this Privacy and Security Statement or any other provisions of the Agreement, and you must inform yourself about their own privacy practices.

4. Third Party Hosting Service

You authorize SP24 Security Services to enter into a data processing agreement with one or more third parties to maintain and host the SP24 Security Services Web site. The Third Party Host that we use must have adequate technical and organizational data protection measures in place. As a result, you authorize us to place and store any information you submit, including Personal Data, on a third-party computer server. Your use of the SP24 Security Services Web site, as well as any provision of information, Content, or Data to the SP24 Security Services Web site, constitutes your acknowledgement, authorization, and instructions that such information, Content, or Data may pass through and be stored in servers beyond the control of SP24 Security Services, and that such information, Content, or Data may be accessed by the administrator of such site and others who gain access to SP24 Security Services server or stored files. When you provide Personal Data directly to the Third Party Host without going through SP24 Security Services, the Third Party Host is the data processor acting on your instructions as the data controller under the GDPR. You agree that SP24 Security Services is not liable or responsible for any authorized or unauthorized disclosure that results from or arises from such pass through or storage.

5. Cookies

(a) SP24 Security Services employs "cookies" as an essential component of our interaction with your Internet browser. The goal is to provide you with a better, more personalized service as well as a more effective website.

(b) A "cookie" is a small text file that our web server places on your computer. Our web servers can later retrieve a cookie. The majority of cookies are "session cookies," which means they are automatically deleted at the end of a session.

(c) Cookies are used in the majority of areas of the SP24 Security Services website. As a result, accepting cookies is required if you want to fully utilize the SP24 Security Services Web site. If your browser is set to reject all cookies, you may be unable to use certain services on the SP24 Security Services Web site that rely on cookies to function.

(d) You can always refuse SP24 Security Services cookies if your browser allows, but you may be unable to use certain parts of the SP24 Security Services Web site that require cookies to participate.

(e) You authorize and consent to SP24 Security Services processing any Personal Data contained in cookies to monitor your traffic patterns and website usage in order to assist us in developing and improving our websites or other business tools for the Service. When you login to the SP24 Security Services Web site, you must confirm your authorization and consent by clicking the tick box in the pop-up window.

(f) Advertising networks that serve advertisements on the SP24 Security Services Web site may use their own cookies as well.

6. Processing of Personal Data

(a) Information provided by you that is not Personal Data may be used or shared as SP24 Security Services deems appropriate in its sole discretion. Personal Data provided by you will generally be used or disclosed to third parties in ways that you have authorized and instructed as outlined in this Privacy and Security Statement. You expressly consent to the use, disclosure, and processing of the information you provide to SP24 Security Services for the Purposes by using or accessing the SP24 Security Services Web site.

(b) SP24 Security Services uses the Personal Data:

• to remind us of your identity and to access your account information (stored on our computers) in order to provide you with better and more personalized service.
• to estimate our audience size and to statistically analyse the usage.
• to identify pages you have accessed and Third Party Web sites you have accessed.
• to improve our marketing and promotional efforts.
• to measure certain traffic patterns, which areas of the SP24 Security Services Web site you have visited, and your visiting patterns in the aggregate.

This research is used to understand how our users' habits are similar or different from one another, so that we can improve each new experience on the SP24 Security Services Web site. This information may be used by SP24 Security Services to better personalize the content, banners, and promotions that you and other users see on the SP24 Security Services Web site.

• to improve our service.
• to provide the service you require.
• for administrative and security purposes.

(c) SP24 Security Services may also use:

(1) Personal Data is used to provide you with information that is tailored to your interests in some cases.

(2) your email address, mailing address, and phone number so that we can contact you about administrative notices, new features, and communications related to your use of the SP24 Security Services Web site.

(3) information in the file that SP24 Security Services keeps about you, as well as other information obtained from your current and past activities on the SP24 Security Services Web site, to resolve disputes, troubleshoot problems, and enforce the Agreement; unless you have indicated in accordance with Section 8 of this Privacy and Security Statement that you do not wish to receive such information.

(d) SP24 Security Services will disclose Personal Data provided by you only when: (1) you have authorized SP24 Security Services to do so (including as set forth below); and (2) SP24 Security Services believes that such disclosure is reasonably necessary to enforce the Agreement, respond to claims of violation of third-party rights, or protect the rights, property, or personal safety of SP24 Security Services, its Affiliates (as defined in Section 1.06 of the Terms of Use), Web site users, and the public.

(3) SP24 Security Services believes that the use or disclosure is reasonably necessary to assist a law enforcement agency or a national security agency in carrying out their functions; or

(4) SP24 Security Services is authorized, required, or permitted to disclose the information by law, governmental, or quasi-governmental agencies.

(5) One exception is when you use the SP24 Security Services Web site to access Third Party Web sites.

In that case, information generated by cookies, as well as information about your preferences or other information about yourself that you provide, may be shared between that third party, the person hosting the Third Party Web sites, SP24 Security Services and/or its Affiliates.
The information is used by SP24 Security Services to provide you with information about products and services that may be of interest to you.
It may also be used to enhance the services offered by the SP24 Security Services website and third-party websites.

(e) You hereby authorize and consent that SP24 Security Services may disclose Personal Data to the following entities, organizations, and individuals for as long as you have not notified SP24 Security Services otherwise in writing, or SP24 Security Services may otherwise be authorized to share such personally identifiable information pursuant to the immediately preceding subsections 6(d)(1) through (5) (including by subsequent consent):

• SP24 Security Services and its affiliates, employees, agents, delegates, sub-processors, who use the Personal Data for the same purposes as SP24 Security Services
• outsourced hosting service providers who manage the services we provide to you (if any);
• your representatives (e.g. your authorised representatives or legal advisers);
• credit-reporting and fraud-checking agencies;
• our professional advisers, including our accountants, auditors and lawyers;
• government and regulatory authorities and other organisations, as required or authorised by law;
• telecommunication and information service providers;
• third party licensors

(g) Except as expressly stated otherwise, this Privacy and Security Statement only addresses the use and disclosure of information provided by you in the first instance.

Personal Data about you provided by another party will be deemed to be Personal Data collected from such other party, not you, for the purposes of this Privacy and Security Statement, regardless of whether such other party obtained the information from you or another source.

7. How we handle E-mails

We may keep the content of any email you send us.
Any Personal Data in your e-mail, including your e-mail address, will be used or disclosed in accordance with the terms of this Privacy and Security Statement.
Employees and/or agents of SP24 Security Services may monitor the content of your e-mail messages for troubleshooting and maintenance purposes, or where e-mail abuse is suspected.

8. Choice/Opt-out

SP24 Security Services will keep or process your Personal Data for as long as it is necessary to provide the Service, conduct investigations related to the Service, fulfill the Purposes, or as required and/or justified by applicable laws. You have the right to request that SP24 Security Services delete, cease using, or retain Personal Data provided by you. SP24 Security Services shall, at your option, destroy or return the Personal Data upon termination of the Agreement. However, in some circumstances, such as to comply with any legal obligations or regulatory requirements, resolve disputes, troubleshoot problems, and/or enforce the Agreement, we may need to retain some of the Personal Data you have requested to be removed from our files.
Furthermore, due to technical constraints and the fact that we back up our systems, such prior information is never completely removed from our databases.
As a result, you should not expect us to remove all of your Personal Data from our databases in response to your requests.

9. Reviewing and Changing Your Personal Data

• You can review and change the information you submitted including but not limited to the following:
o Your email address.
o Your address, city, state, zip code, country, phone number and fax number.
• You must promptly update us of any changes to your information.

10. Security of Information

SP24 Security Services takes reasonable technical and organizational measures to protect against unauthorized or unlawful processing, accidental loss or destruction of, or damage to cookies and Personal Data, and to ensure that all persons who have access to process Personal Data have agreed to appropriate confidentiality obligations in accordance with the GDPR and this Privacy and Security Statement.
SP24 Security Services will use standard industry efforts, such as firewalls and secure socket layers, to protect the confidentiality of your Personal Data. You acknowledge that, despite SP24 Security Services efforts to ensure security, there can be no guarantee of security on the Internet, and that the risk of interception and tampering with any communication related to the SP24 Security Services Web site is solely your responsibility.

11. Important Reminders

(a) This is to remind you that you have provided SP24 Security Services with all necessary consents, licenses, permits, and authorizations required by any applicable law or otherwise (including all privacy and other data protection regulations and legislation) for the transfer of personal data to SP24 Security Services, its Affiliates, and/or third parties wherever they may be located, and for the use and processing of such data by SP24 Security Services. You acknowledge and agree that SP24 Security Services may transfer personal data to its Affiliates, employees, agents, delegates, sub-processors, or competent authorities, as well as to a country outside of the South African Economic Area and Africa, in accordance with the Framework and/or other available data transfer solutions.

(b) When SP24 Security Services receives data from you, we take reasonable technical and organizational steps to ensure the information's security in our own systems. We remind you that various methods exist and are being developed for deployment in the context of the Internet to help you improve the security of your data. As a result, as the data controller, we encourage you to use all available means to protect your data and communications, such as access codes to your own personal computer.

(c) Remember to close your browser window once you've completed your work. This is done to prevent others from accessing your personally identifiable information and correspondence if you share a computer with someone else or use a computer in a public place.

(d) We also remind you that you, as the data controller, may be legally liable for data processing, for example, if you illegally upload or download data, and that everything can be traced back to you, even if you use a pseudonym.

13. Contacting Us

Should you have any questions about this Privacy and Security Statement, the practice of the SP24 Security Services Web site, or your dealings with the SP24 Security Services Web site, you can contact:

SP24 Security Services

Phone : (+27) 012 111 8874
Email: info@sp24security.co.za
Address: 420 Jeugd Rd, Christiaanville AH, Pretoria, 0151

SCHEDULE

This Schedule describes the categories of Personal Data, Data Subjects and the Processing operations to be carried out by SP24 Security Services as the Data Processor.

1. Data Subjects

SP24 Security Services Personal Data concerns, but is not limited to, the following categories of Data Subjects:

(1) SP24 Security Services website users ("Users");
(2) all of the Users' employees, representatives, contractors, affiliates, and agents.

2. Categories of Personal Data

The Personal Data to be Processed by SP24 Security Services includes but are not limited to:
• Name
• Business Card
• Identity card number or Passport number
• Department
• Role/Job title
• Contact number/Fax number
• Mail address
• Signature
• Email (office or private)
• Address
• Source of Funds
• Identity details of instant messaging or social networking applications
• Social media profile

3. Categories of Sensitive Personal Data

The Categories of Sensitive Personal Data are:

• Sex
• Age
• Date of Birth
• Images of identity cards, passports or other personal identification documents
• Bank account number
• Nationality
• Legal domicile
• Place of birth
• Photograph
• Marital status
• Family member's name (spouse, minors, etc)
• Sanction screening and adverse media searches

4. Processing Operations

Personal Data will be Processed for purposes including, but not limited to:

• Provision of service
• Communications
• Observance of legal and regulatory obligations
• Hosting
• Software
• Business development
• Relationship improvement and development
• Service improvement and development
• System testing and troubleshooting
• Audit and compliance activities pertaining to the foregoing

5. Duration

SP24 Security Services may process personal data for as long as it is necessary to provide the Service, conduct investigation in relation to the Service, fulfill the Purposes, or as required and/or justified by applicable laws.

“Applicable Data Protection Law(s)" means

(i) All applicable national laws, regulations, and other legal requirements relating to (a) privacy, data security, consumer protection, marketing, promotion, and text messaging, email, and other communications; and (b) the use, collection, retention, storage, security, disclosure, transfer, disposal, and other processing of any Personal Information to which SP24 Security Services or its Affiliate is subject or otherwise applicable;
(ii) For the purposes of European Union law, the Data Protection Acts of 1988 and 2003 (as amended), the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications Regulations 2011 and the Regulation (as defined below) (as amended or replaced from time to time), and any other EU regulations, directives, guidance, directions, determinations, codes of practice, circulars, orders, notices, or demands issued by any Supervisory Author are all applicable.
(iii) any applicable national, international, regional, municipal, or other data privacy authority, or other data protection laws or regulations in any other territory to which SP24 Security Services or its Affiliate is subject or otherwise applicable.