Effective date: September 12, 2018
Last updated: November 29, 2024

1. Introduction

Any reference below to “the Company” is reference to Jurumani Solutions (Pty) Ltd.
The Protection of Personal Information Act, 2013 (“POPI”) came into complete commencement on 1 July 2021, in this regard the Company has a number of obligations and duties in terms of POPI that Jurumani Solutions must comply with. The protection of your personal information is a high priority for the Company and Jurumani Solutions has taken steps to ensure that your personal information is protected and remains private.
In addition to this document serving as the Company privacy policy, this document will also serve as the Company’s data subject notification as contemplated in section 18 of POPI. In this regard, this document will inform you of what personal information Jurumani Solutions collects, why it was collected, how it used, and what safety measures are in place to protect it.
Where the Company refers to “process”, it means how the Company collects, uses, stores, makes available, destroys, updates, discloses, or otherwise deals with your personal information. As a general rule, the Company will only process your personal information if this is required to deliver or offer a service, provide a product or carry out a transaction.
The Company may combine your personal information and use the combined personal information for any of the purposes stated in this Privacy Policy.
Jurumani Solutions (Pty) Ltd operates the http://www.jurumani.com website (hereinafter referred to as the “Service”).
This page informs you of the Company’s policies regarding the collection, use, and disclosure of personal data when you use the Company’s service and the choices you have associated with that data.
The Company may use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in the Company’s Terms and Conditions, accessible from http://www.jurumani.com.
If you use the Company’s services, goods , and/or products, you agree that the Company may process your personal information as explained under this Privacy Policy.
The Company may change this Privacy Policy from time to time if the law or the Company’s business practices require it.  The version of the Privacy Policy displayed on the Company’s website at the time of your interaction with the Company will be applicable.

2. Definitions

Service	Service is the http://www.jurumani.com website operated by Jurumani Solutions (Pty) Ltd.
Personal Data	Personal Data means data about a living individual who can be identified from those data (or from those and other information either in the Company’s possession or likely to come into the Company’s possession).
Usage Data	Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies	Cookies are small files stored on your device (computer or mobile device).
Data Controller	Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. For the purpose of this Privacy Policy, the Company are a Data Controller of your Personal Data.
Data Processors (or Service Providers)	Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. The Company may use the services of various Service Providers in order to process your data more effectively.
Data Subject (or User)	Data Subject is any living individual who is using the Company’s Service and is the subject of Personal Data.

3. Information Collection and Use

3.1. Personal information defined

Personal information refers to any information that identifies you or specifically relates to you. The company collects several different types of information for various purposes to provide and improve the Company’s Service to you. Personally identifiable information may include, but is not limited to:

· Age	· Language	· Physical address
· Cookies and Usage Data	· Location information	· Pregnancy
· Correspondence	· Marital Status	· Race
· Criminal history	· Mental Health	· Religion
· Correspondence	· Medical History	· Sex
· Disability	· Name	· Ethnic origin
· Education	· National Origin	· Financial history
· E-mail address	· Online identifier	· Gender
· Telephone number	· Sex

The Company may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from the Company by following the ‘unsubscribe’ link or the instructions provided in any email the Company sent.

3.2. Usage Data

The Company may also collect information on how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g., IP address), browser type, browser version, the pages of the Company’s Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

3.3. Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

Session Cookies. We use Session Cookies to operate our Service.
Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
Security Cookies. We use Security Cookies for security purposes.

3.4. What is special personal information?

Special personal information is personal information about the following:

· Biometric information	· Philosophical beliefs
· Criminal behaviour	· Political persuasion
· Ethnic origin	· Race
· Health	· Religious beliefs
· Sex life	· Trade union membership

3.5. Is the supply of personal information voluntary or mandatory?

The supply of certain personal information is mandatory, meaning the Company must collect this personal information from you by law. If you do not supply this information, the Company cannot comply with the Company’s legal obligations. In this regard, if you do not supply this personal information, the Company cannot do business with you. The Company collects personal information as is required by the following legislation:

· Basic Conditions of Employment Act, No 75 of 1997
· Continuing Education and Training Act (previously known as Further Education and Training Colleges Act) 16 of 2006
· Compensation for Occupational Injuries and Diseases Act, No. 130 of 1993
· Credit Agreement Act, No. 75 of 1980
· The Criminal Procedure Act, No. 51 of 1977
· Debt Collectors Act, No. 114 of 1998
· Employment Equity Act, No. 55 of 1998
· Financial Intelligence Centre Act, No. 38 of 2001
· Higher Education Act 101 of 1997
· Income Tax Act 58 of 1962
· Labour Relations Act, No 66 of 1995
· National Credit Act, No. 34 of 2005
· NQF Act No 67 of 2008
· Pension Funds Act, No. 24 of 1956
· Skills Development Act 97 of 1998
· Unemployment Insurance Act, No. 63 of 2001
· Financial Advisory and Intermediary Service Act, No. 37 of 2002
· Occupational Health and Safety Act No. 85 of 1993
· Prevention of Organised Crime Act No. 121 of 1998

In other instances, the supply of personal information is voluntary, which means there is no law imposed on the Company to collect this personal information. Even though there is no law that imposes the collection of personal information, the Company requires the personal information to deliver the products and/or services to you. In this regard, if you do not supply the personal information, the Company cannot do business with you.

3.6. When will the Company process your personal information?

The Company will only process your personal information for lawful purposes relating to the Company’s business if the following applies:

if you have consented thereto.
if a person legally authorised by you, the law, or a court, has consented thereto.
if it is necessary to conclude or perform under a contract, the Company have with you.
if the law requires or permits it.
if it is required to protect or pursue your, the Company’s or a third party’s legitimate interest.

3.7. When will the Company process your special personal information?

The Company may process your special personal information in the following circumstances:

if you have consented to the processing.
if the information is being used for any Human resource or payroll requirement.
if the processing is needed to create, use, or protect a right or obligation in law.
if the processing is for statistical or research purposes and all legal conditions are met.
if the special personal information was made public by you.
if the processing is required by law.
if racial information is processed, and the processing is required to identify you; and/or if health information is processed, and the processing is to determine your insurance risk, or to comply with an insurance policy, or to enforce an insurance right or obligation.

3.8. When and from where did the Company obtain personal information about you?

The Company may collect personal information about you from the following sources:

The Company may collect personal information directly from you.
The Company may collect personal information from a public record.
The Company may collect personal information from an area where you have deliberately made it public.
The Company may collect information about you based on your use of our products, services, or service channels.
The Company may collect information about you based on how you engage or interact with us such as via the Company’s support desk, emails, letters, telephone calls, and surveys.
The Company may collect personal information from a third party.

The Company may collect personal information from another source if you give the Company consent to do so.

If the law requires us to do so, the Company will ask for your consent before collecting personal information about you from third parties.

4. Use of Data

4.1. For what does the Company use your data?

Jurumani Solutions (Pty) Ltd uses the collected data for various purposes:

To provide and maintain the Company’s Service.
To notify you about changes to the Company’s Service.
To allow you to participate in interactive features of the Company’s Service when you choose to do so.
To provide customer support.
To gather analysis or valuable information so that the Company can improve the Company’s Service.
To monitor the usage of the Company’s Service.
To detect, prevent and address technical issues.
To provide you with news, special offers, and general information about other goods, services, and events which the Company offer that is similar to those that you have already purchased or enquired about unless you have opted not to receive such information.

4.2. When how and with whom the Company shares your data? 

In general, the Company will only share your personal information if any one or more of the following apply:

if you have consented to this;
if it is necessary to conclude or perform under a contract, the Company has with you;
if the law requires it; and/or
if it’s necessary to protect or pursue your, the Company’s, or a third party’s legitimate interest.

5. Transfer of Data

Your information, including Personal Data, may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside South Africa and choose to provide information to the Company, please note that the Company transfers the data, including Personal Data, to South Africa and processes it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

The Company will only transfer your personal information to third parties in another country in any one or more of the following circumstances:

where your personal information will be adequately protected under the other country’s laws or an agreement with the third-party recipient.
where the transfer is necessary to enter into or perform under a contract with you, or a contract with a third party that is in your interest.
where you have consented to the transfer; and/or
where it is not reasonably practical to obtain your consent, the transfer is in your interest.

This transfer will happen within the requirements and safeguards of the law. Jurumani Solutions (Pty) Ltd will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

6. Security of Data

The security of your data is important to the Company but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While the Company strives to use commercially acceptable means to protect your Personal Data, the Company cannot guarantee its absolute security. The Company shall strive to take appropriate and reasonable technical and organisational steps to protect your personal information according to industry best practices. Our security measures (including physical, technological, and procedural safeguards) will be appropriate and reasonable. This includes the following:

keeping the Company’s systems secure (like monitoring access and usage).
storing the Company’s records securely.
controlling the access to the Company’s buildings, systems, and/or records; and
safely destroying or deleting records.
Ensure compliance with best practice standards.

7. Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), Jurumani Solutions (Pty) Ltd.’s legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data the Company collects and the specific context in which the Company collects it.

Jurumani Solutions (Pty) Ltd may process your Personal Data because:

We need to perform a contract with you.
You have given us permission to do so.
The processing is in our legitimate interests and it is not overridden by your rights.
To comply with the law.

8. Retention of Data

Jurumani Solutions (Pty) Ltd will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. The Company will retain and use your Personal Data to the extent necessary to comply with the Company’s legal obligations such as:

the law requires the Company to keep it.
a contract between you and the Company requires the Company to keep it.
you have consented to the Company keeping it.
the Company is required to keep it to achieve the purposes listed in this Privacy Policy.
the Company requires it for statistical or research purposes.
a code of conduct requires the Company to keep it; and/or
the Company requires it for the Company’s lawful business purposes.

Jurumani Solutions (Pty) Ltd will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of the Company’s Service, or the Company is legally obligated to retain this data for longer periods.

Take note: The Company may keep your personal information even if you no longer have a relationship with the Company, for the historical data that may be required by your employer or employee.

9. Your Data Protection Rights under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Jurumani Solutions (Pty) Ltd aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed about what Personal Data the Company holds about you and if you want it to be removed from the Company’s systems, please contact the Company.

In certain circumstances, you have the following data protection rights:

The right to access, update or delete the information the Company has on you. Whenever made possible, you can access, update, or request the deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact the Company to assist you.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to the Company’s processing of your Personal Data.
The right of restriction. You have the right to request that the Company restrict the processing of your personal information.
The right to data portability. You have the right to be provided with a copy of the information the Company has on you in a structured, machine-readable, and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time when Jurumani Solutions (Pty) Ltd relied on your consent to process your personal information.

Please note that the Company may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about the Company’s collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

10. Service Providers

The Company may employ third-party companies and individuals to facilitate the Company’s Service (“Service Providers”), provide the Service on the Company’s behalf, perform Service-related services or assist the Company in analysing how the Company’s Service is used.

These third parties have access to your Personal Data only to perform these tasks on the Company’s behalf and are obligated not to disclose or use it for any other purpose.

11. Analytics

The Company may use third-party Service Providers to monitor and analyse the use of the Company’s Service.

11.1. Google Analytics

This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

11.2. Behavioural Remarketing

Jurumani Solutions (Pty) Ltd uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimise and serve ads based on your past visits to our Service.

Google AdWords
Google AdWords remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads. Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

12. Links to Other Sites

The Company’s Service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third-party’s site. The Company strongly advises you to review the Privacy Policy of every site you visit.

The Company has no control over and assumes no responsibility for the content, privacy policies, or practices of any third-party sites or services.

13. Children’s Privacy

The Company’s Service does not address anyone under the age of 18 (“Children”).

The Company does not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided the Company with Personal Data, please contact the Company. If the Company becomes aware that the Company has collected Personal Data from children without verification of parental consent, the Company takes steps to remove that information from the Company’s servers.

14. Changes to This Privacy Policy

The Company may update the Company’s Privacy Policy from time to time. The Company will notify you of any changes by posting the new Privacy Policy on this page.

The Company will let you know via email and/or a prominent notice on the Company’s Service, prior to the change becoming effective, and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

15. Your Data Protection Rights under the Protection of Personal Information (POPI)

You have the right to request access to the personal information the Company has about you by contacting the Company. This includes requesting:

Confirm that the Company holds your personal information.
a copy or description of the record containing your personal information; and
the identity or categories of third parties who have had access to your personal information.

The Company will attend to requests for access to personal information within a reasonable time. You may be required to pay a reasonable fee to receive copies or descriptions of records, or information about third parties. The Company will inform you of the fee before attending to your request.

15.1. The law may limit your right to access information

You have the right to request the Company to correct or delete the personal information the Company has about you if it is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, obtained unlawfully or the Company is no longer authorised to keep it. You must inform the Company of your request in writing. It may take up to 15 business days for the change to reflect on the Company’s systems. The Company may request documents from you to verify the change in personal information.

A specific agreement that you have entered into with the Company may determine how you must change your personal information provided at the time when you entered into the specific agreement. Please adhere to these requirements. If the law requires the Company to keep the personal information, it will not be deleted upon your request. The deletion of certain personal information may lead to the termination of your business relationship with the Company.

15.2. You may object on reasonable grounds to the processing of your personal information

The Company will not be able to give effect to your objection if the processing of your personal information was and is permitted by law; you have provided consent to the processing and the

The company’s processing is done according to your consent, or the processing is necessary to conclude or perform under a contract with you.

Where you have provided your consent for the processing of your personal information, you may withdraw your consent. If you withdraw your consent, the Company will explain the consequences to you. The Company may proceed to process your personal information even if you have withdrawn your consent if the law permits or requires it. It may take up to 15 business days for the change to reflect on the Company’s systems, during this time the Company may still process your personal information. You must inform the Company of any objection in writing.

You have a right to file a complaint with the Company or any Regulator with jurisdiction about an alleged contravention of the protection of your personal information by the Company. The Company will address your complaint as far as possible.

15.3. Contact details for the Information Regulator

Email:	Complaints.IR@justice.gov.za
Postal Address:	P.O. Box 31533, Braamfontein, Johannesburg, 2017
Physical Address:	JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001.

16. Contact us

For any queries in relation to this letter or the Company’s processing of your personal information in general, you can contact the Company’s Information Officer and/or Deputy Information Officer at the following details:

Information Officer	Mark Fricke
Contact Number	010 593 0500
Email Address	info@jurumani.com
Physical Address	International Business Gateway 4 Challenger Road Midrand 1685

17. PAIA Manual

For more information on how to request information of our company or access to your personal information, please complete the request form in our PAIA Manual: Jurumani PAIA Manual