Privacy Policy

Pertaining the Centricity Platform.

Effective Date: 26 August 2021

Centricity is a service that Rizzolve Limited makes available to its clients or the clients of its value added resellers.  At Rizzolve we respect your privacy and is committed to protecting your Personal Information. This policy (“Policy”) explains how we Process Personal Information and what your privacy rights are.

It is important that you read this Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing Personal Information about you so that you are fully aware of how and why we are using your information.

Reference to “Consent”, “your Consent” or “your explicit Consent” shall include the ticking of a tick box or clicking on a “Send message” button or “Login” or “Subscribe” button or “Register Account” button or sending a reply by email after we have made available our Privacy Policy to you.

1)     Important information and who we are

a)     Responsible Party

i)      As Responsible Party:  Rizzolve Limited (referred to as “Rizzolve”, "Centricity", "we", "us" or "our") act as Responsible Party where we process your Personal Information where you use our website (including the www.centricity.me website), communicate directly with Rizzolve or register as a user of any of our services through any of our channels. 

ii)     As Operator: Where Rizzolve Processes a Data Subject’s Personal information on instructions from a Centricity value added reseller or a client, Rizzolve will act as Operator and the client will act as the Responsible Party. Centricity consolidates and distributes electronic data sourced from various activity points in a logistical chain. As Responsible Party the client has sole responsibility for the legality, reliability, integrity, accuracy and quality of the Personal Information he/ she/ it or someone on their behalf makes available to Rizzolve and any of its value added resellers.

iii)    We have appointed an Information Officer (IO), who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests, or wish to submit a complaint then please contact us at:

(1)   Information Officer: Craig Househam

(2)   Email address: info@centricity.me

(3)   Other contact details and addresses: See our website (Contact Us)

iv)    You have the right to make a complaint at any time to the Information Regulator's office (IR), the Republic of South Africa’s authority for data protection issues (http://www.justice.gov.za/inforeg/). We would, however, appreciate the chance to deal with your concerns before you approach the IR, so please contact us in the first instance.

b)     Changes to the Privacy Policy and your duty to inform us of changes

i)      We keep our Privacy Policy under regular review. This version was last updates as per the date in the footer. Archived versions (if available) can be obtained by contacting us. Any changes made to our Privacy Policy in future will be posted on our website or made available during your engagement with Centricity (including access to the services). The new version will apply the moment it is published on our website or incorporated by reference in any of our policies or other communications or published on our services. Please take note of the last update to be aware of any changes to our Privacy Policy. 
ii)     It is important that the Personal Information we hold about you or where you use our services to perform certain services for the benefit of your Data Subject(s), the Personal Information about them, are accurate and current. Please keep us informed if any Personal Information changes during your relationship with us.

c)     Integration into other sites: This Privacy Policy applies to Centricity site(s) and services only. We do not exercise control over Third-party sites who provide Centricity services as part of their own offering (including Business Partners). These other Third-party sites may place their own cookies or other files on your computer, collect data or solicit Personal Information from you. We cannot be held responsible for any wrongful handling of end users’ information by our customers.

d)     Registered users of Centricity Helpdesk: You agree that, once the correct username and password relating to your account have been entered, irrespective of whether the use of the username and password is unauthorised or fraudulent, Centricity may accept that it is engaging with you and not with someone else. You agree to notify us, via our contact page, immediately upon becoming aware of or reasonably suspecting any unauthorised access to or use of your username or password and to take steps to mitigate any resultant loss or harm.

e)     Third-party links: Our sites or certain of our services may include links to Third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow Third parties to collect or share data about you.  If you disclose your personal information to a Third-party, such as an entity which operates a website linked to this Centricity Platform, Centricity SHALL NOT BE LIABLE FOR ANY LOSS OR DAMAGE, HOWSOEVER ARISING, SUFFERED BY YOU AS A RESULT OF THE DISCLOSURE OF SUCH INFORMATION TO THE THIRD-PARTY. This is because we do not regulate or control how that Third-party uses your personal information. You should always ensure that you read the privacy policy of any Third-party. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2)     What Information do we collect?

a)     Personal Information means the information as per the Definitions. It does not include data where the identity has been removed (anonymous data/ de-identified information).

b)     We may Process different kinds of Personal Information which we have grouped together.

i)      Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.

ii)     Contact Data includes billing address, email address and telephone numbers.

iii)    Financial Data includes banking details.

iv)    Transaction Data includes details about payments to and from us and other details of products and/ or services you have acquired from us or accessed on our website.

v)     Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

vi)    Profile Data includes your username and password, product/ service inquiries made by you, your interests, preferences, feedback and survey responses. 

vii)   Usage Data includes information about how a Person’s use our website, products and/or services. This information shall include the full Uniform Resource Locators (URL) Clickstream to, through and from our website (including the date and time) and the services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), use of a certain function on any service and methods used to browse away from the page and any phone number used to call our customer service number, service transaction instructions from and to you via our API’s (if any).

viii)  Marketing and Communications Data marketing preferences in receiving marketing from Centricity and Third parties and your communication preferences (communications related to the products/ services).

ix)    Aggregate data and pattern data (“Pattern Data”): statistical, demographical or transactional information derived from Personal Information but is not considered Personal Information in law as this data will not directly or indirectly reveal the identity of the data subject. For example, we may aggregate the Usage Data of a data subject to calculate the percentage of users accessing a specific website or specific service feature or executing a specific transaction type. However, if we combine or connect Pattern Data with your Personal Information so that it can directly or indirectly identify you, we will treat the combined data as Personal Information which will be used in accordance with this Privacy Policy.

c)     You may choose to provide additional Personal Information to us, in which event you agree to provide accurate and current information, and not to impersonate or misrepresent any person or entity or falsely state or otherwise misrepresent your affiliation with anyone or anything.

d)     Special Personal Information and Children information: We do not collect any Special Personal Information or Children Information directly from Data Subjects where we act as Responsible Party. However, when you visit our offices, we may request Special Personal Information at our reception. In the case that we may rent from a Third party, such Third party may collect such information as per their own privacy policy. The collection of Special Personal Information by a Third party shall not be linked to our collection of such information. Special Personal Information may be made available to us by a client that utilises our services. We will process same in accordance with the Centricity client’s instructions and Data Protection Laws as an Operator. Where we may collect Special Personal Information, Centricity will Process same in accordance with the Data Protection Laws.

e)     Submission of Personal Information on behalf of another: If you provide information on behalf of someone else, then it is your responsibility to obtain the necessary consent from the person before making the Personal Information available to us.  On receipt of the Personal Information, we assume that the necessary consent has been obtained and will process the Personal Information as per your instructions and in accordance with this Privacy Policy. By submitting such Personal Information on behalf of another person, you indemnify us against any Third-party claim, where such Third-party claim relates to Personal Information that has been processed without the necessary consent or other available exception allowed by law.

f)      If you fail to provide Personal Information: Where we need to collect Personal Information by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services (including services for no charge)). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

3)     How is Personal Information collected?

We use different methods to collect Personal Information:

a)     Direct interactions. We may collect Personal Information directly from a Data Subject. This may be when you:

i)      register a new account and create a profile on our website

ii)     engage with us via Skype, Zoom or any other video conferencing facility;

iii)    request marketing material to be sent to you;

iv)    apply/ sign up for any of our services (may be subject to service specific terms and conditions);

v)     complete a COVID 19 questionnaire;

vi)    attend an event of Centricity;

vii)   engage with our support services and/ or call centres (if any);

viii)  give us feedback or contact us on our website; or

ix)    by communicating with us via email, our online contact form, WhatsApp or other social media messaging platforms we may subscribe to.

b)     Automated technologies or interactions. As you interact with our services or website, we will automatically collect Technical Data about your equipment, browsing actions, patterns and device. We collect this Personal Information by using cookies (see clause 3) below), server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

c)     Third parties or publicly available sources. We will receive Personal Information about you from various Third parties and public sources as set out below:

i)      Technical Data from the following parties:

(1)   analytics providers such as Google ("How Google uses information from sites or apps that use our services", (located at https://policies.google.com/technologies/partner-sites)

(2)   advertising networks; and

(3)   search information providers.

ii)     Contact, Financial and Transaction Data from providers of technical and payment services.

iii)    Technical and Transactional Data from Third-party service providers that provide a service or product to you, subject to your consent to us to collect the information.

iv)    Identity and Contact Data from data brokers or aggregators where same have been obtain in accordance with the Data Protection Laws.

v)     Identity and Contact Data from publicly available sources such as CIPC or such places where the Data Subject has deliberately made available his/ her/ its Personal Information.

vi)    Identity, Contact and Special Personal Information from a Third party that utilises the Centricity services for execution of his/ her/ its services to a Data Subject.

d)     With reference to par. c)vi) above, take note that where Personal Information is collected from and/or on behalf of a Centricity client for purposes of execution of a Centricity service:

i)      the Centricity client acknowledges and agrees that he/ she/ it will be solely responsible for: (i) the accuracy, quality, and legality of the Personal Information and the means by which he/ she/ it acquired Personal Information; (ii) complying with all necessary transparency (openness) and lawfulness requirements under applicable data protection legislation for the Processing of the Personal Information, including obtaining any necessary Consents and authorisations from Data Subjects; (iii) ensuring he/ she/ it has the right to grant Centricity the right to Process Personal Information in accordance with the Terms of Service (where applicable), including transfer of Personal Information to agreed External Parties; (iv) ensuring that his/ her/ its  instructions to Centricity regarding the Processing of Personal Information comply with applicable laws, including data protection legislation; (v) the appointment and authorisation of authorised users to use the services and Process Personal Information; and (vi) approve the actions and/ or omissions of its authorised users.

ii)     If Centricity is of the opinion that an instruction from the Centricity client violates Data Protection Laws, Centricity shall inform the Centricity client as soon as reasonably possible. Centricity shall be entitled to suspend the execution of the instruction in question until it is confirmed or amended by the Centricity client. Centricity may refuse to carry out an instruction that is obviously illegal.

4)     Cookies

a)     The Centricity website makes use of cookies to help Centricity understand its users better. Cookies are small pieces of information sent by an organisation to the user’s computer and stored on the user’s hard drive to allow that website to recognise the user when the user visit the website. Cookies do not harm a computer or any files on a computer.  Depending on the type of cookie Centricity uses, cookies also allow us to make the Centricity websites more user friendly.

b)     Centricity may use Third-party vendors, including but not limited to Google and MSN/ Bing to show Centricity-related ads on sites on the internet. Third-party vendors use cookies to serve ads based on a user’s prior visits to Our sites or other websites. Users may opt-out of Google’s use of cookies by visiting the Google Advertising Settings Page or the Network Advertising Initiative's opt-out page for other Third-party vendors’ use of cookies.

c)     The user should be able to adjust his/ her browser so that the user’s computer does not accept cookies.  If the user does this, the user will still be able to browse the website but the functions that allow the user to access an existing account or page that requires a username or password will not be available.

d)     The user can, alternatively, adjust his/ her browser to notify the user when a website attempts to put a cookie on his/ her computer.  How the user adjusts his/ her browser to stop it accepting, or to notify the user of cookies, will depend on the type of internet browser programme the user’s computer uses.

e)     Please remember, cookies do not contain Identity, Contacts or Financial Information. Centricity does not exchange cookies with any Third-party websites or external data suppliers.

5)     How we use your Personal Information

a)     Centricity will not sell Personal Information.

b)     All Personal Information that Centricity may receive from the Centricity client or any other Data Subject shall be dealt with as confidential information.

c)     Centricity will only use Personal Information within the framework of the law. Most commonly, Centricity will use Personal Information in the following circumstances:

i)      where the Data Subject or a Competent Person (on behalf of a Child) has given his/her/its consent; or

ii)     where Centricity needs to perform under a contract that Centricity is about to enter into or has entered into with a Centricity client or directly with a Data Subject; or

iii)    where it is necessary for Centricity’s legitimate interests (or those of a Third party) and the Data Subject’s interests and fundamental rights do not override those interests;

iv)    where Processing protects a legitimate interest of the Data Subject; or

v)     where Centricity needs to comply with a legal obligation.

d)     Purposes for which Centricity will use Personal Information:

i)      In the table below we provide a description of all the ways Centricity plan to Process Personal Information, and which of the legal bases Centricity relies on to do so. We have also stated what Centricity’s legitimate interests are where appropriate.

ii)     Note that Centricity may process Personal Information for more than one lawful ground depending on the specific purpose for which Centricity are using the data. Please contact Centricity if you need details about the specific legal ground, Centricity is relying on to Process Personal Information where more than one ground has been set out in the table below.

iii)    If the Data Protection Laws to which Centricity (as Operator) is subjected, obliges Centricity to carry out further Processing, Centricity shall notify the Centricity client of these legal requirements prior to Processing, and if so required under the POPI Act and/ or by the Information Regulator, obtain the necessary pre-authorisation for such further Processing as is required by section 57 of the POPI Act.

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
To receive Centricity communications as client of CentricityTo sign you up for our newsletter (as a client)To sign you up for our newsletter (if any) (as a non-client)Identity, ContactExisting Client (as per POPI Act) of Centricity

Consent
To register a Person as a Centricity client(a) Identity, (b) Contact (c) Financial, (d) Marketing and Communications(a) Consent(b) Performance of a contract with Centricity client
Delivery of agreed services to Centricity clients, including but not limited to sharing of information with External Parties as part of the services(a)Identity, (b) Contact, (c) Financial of Centricity client(a) Consent(b) Performance of a contract with the Centricity client(c) Outsourcing of a Centricity client administration (section 32(1)(a) of the POPIA)
(a) Manage payments, fees and charges(b) Collect and recover money owed to Centricity(a) Identity, (b) Contact, (c) Financial, (d) Transaction, (e) Marketing and Communications(a) Performance of a contract with Centricity client(b) Necessary for our legitimate interests (to recover debts due to us) [TAKE NOTE: we do not store Financial Information - card details.  We use Third-party service provider(s) to execute transactions where you use your card.  You should read their privacy policy]
To manage our relationship with you as a client which will include:(a) Notifying you about changes to our Terms of Services or this Privacy Policy where required(b) Asking you to leave a review or take a survey(a) Identity, (b) Contact, (c) Profile(d) Marketing and Communications(a) Performance of a contract with you(b) Necessary to comply with a legal obligation(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
To reply to your submission via our “Contact Us” page(a) Identity, (b) Contact details(a) Consent
To follow our COVID 19 protocol and determine whether you can be allowed on to our premises(a) Identity, (b) Contact, (c) Special Personal Information(a) Consent, (b) Necessary to comply with a legal obligation, (c) Necessary for our legitimate interests and the interest of other persons on the premises, (d) Required by law
To enable you to partake in a prize draw, competition, referral, promotion or complete a survey (where available)(a) Identity, (b) Contact, (c) Profile(d) Usage, (e) Marketing and Communications(a) Performance of a contract with you,(b) You consent by submitting your information to us, specifically for competitions and promotions(c) Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business)
To administer and protect our business, website and other electronic platforms (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity, (b) Contact, (c) Technical(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)(b) Necessary to comply with a legal obligation
To deliver relevant website and service content and information about similar services and/or products to you and measure or understand the effectiveness of the advertising we serve to you(a) Identity, (b) Contact, (c) Profile(d) Usage, (e) Marketing and Communications, (f) TechnicalNecessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, customer relationships and experiences(a) Technical, (b) UsageNecessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you(a) Identity, (b) Contact, (c) Technical, (d) Usage, (e) Profile(f) Marketing and CommunicationsNecessary for our legitimate interests (to develop our services and grow our business)
Where Centricity acts as an Operator
To register you as an user on behalf of a Centricity client(a)    Identity, (b) Contact, (c) TechnicalPerformance of contract between Us and Centricity client

 

e)     Marketing: We strive to provide you with choices regarding certain Personal Information uses, particularly around marketing and advertising.

i)      Promotional offers from us

(1)   Once you have acquired any of our services including accessing our websites, you will be seen as a client of Centricity.

(2)   As a client we may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products and offers may be relevant for you (we call this marketing).

(3)   As a client you will receive marketing communications from us if you have not opted out of receiving that marketing.

(4)   As a potential client you may also receive certain information about Centricity and its services/products, however you will always have the option to unsubscribe to said communications (see par. iii) below).

ii)     Third-party marketing

(1)   We will get your express opt-in consent before we share your Personal Information with any Third party for marketing purposes.

(2)   TAKE NOTE: We may provide (without your consent) Third-party marketing parties/advertisers with anonymous aggregate information (Aggregate Data (see above)) about our users (for example, we may inform them that 500 men aged under 30 have clicked on a specific product or advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in a specific region). We may make use of the Personal Information we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience. IMPORTANT: We do not disclose information about identifiable individuals to our advertisers.

iii)     Opting out

(1)   You can ask us or Third parties to stop sending you marketing messages at any time by logging into the website or unsubscribe on the email communication or by contacting us at any time and requesting to op-out of our marketing services.

(2)   Where you opt out of receiving these marketing messages, this will not apply to Personal Information provided to us as a result of a service purchase, warranty registration, service experience or other transactions.

(3)   Cookies: You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

f)      Change of purpose

i)      We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

ii)     If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

iii)    Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6)     Disclosures of Personal Information

a)     We may share Personal Information with the parties set out below for the purposes set out in the table above.

i)      Internal Third Parties as set out in the Definitions. Where we share Personal Information to our group (collaborating companies and/or Affiliates, if any), we ensure your Personal Information is protected by requiring all our collaborating companies to follow this policy when processing your Personal Information.

ii)     External Third parties as set out in the Definitions.

iii)    We may provide such information to collaborating companies or other trusted businesses or persons for the purpose of processing Personal Information on our behalf, subject to appropriate written agreement.

iv)    Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Information in the same way as set out in this Privacy Policy.

b)     We require all Third-Parties to respect the security of your Personal Information and to treat it in accordance with the law. We do not allow our Third-Party service providers to use your Personal Information for their own purposes and only permit them to process your Personal Information for specified purposes and in accordance with our instructions.

7)     International transfers

a)     Taking into consideration the type of services offered by Centricity (i.e. Software as a service and making use of certain international service providers for purposes of technology), Centricity (or any subcontractor) may need to transfer or otherwise Process Personal Information outside the Republic of South Africa (RSA).  The transfer of Personal Information shall only be transferred where:

i)      Centricity enters into a written contract with the Third-party service provider that contains terms substantially the same as those set out in this Privacy Policy, in particular, in relation to requiring appropriate technical and organisational data security measures and relating to the further transfer of Personal Information from the Third party recipient to Third parties who are in a foreign country.

ii)     Processing of Personal Information takes place in a territory which is subject to Data Protection Laws similar to the Data Protection Legislation and that the territory provides adequate protection for the privacy rights of individuals.

iii)    Confirmation that the necessary pre-authorisation from the Information Regulator (only where said pre-authorisation is required by the Data Protection Legislation), has been obtained by the Responsible Party, i.e. section 57 of the POPI Act.

b)     By submitting your Personal Information to us (as Data Subject or as Responsible Party utilising the Centricity services) you consent to the transfer of Personal Information outside the borders of the Republic of south Africa.

8)     Data security

a)     Centricity has put in place appropriate technological and organisational measures to prevent Personal Information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, Centricity limits access to Personal Information to those employees, agents, contractors and other Third parties who have a business need to know. They will only process Personal Information on our instructions, and they are subject to a duty of confidentiality.

b)     We have put in place procedures to deal with any suspected Personal Information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

c)     Where Centricity acts as Operator, the Responsible Party must ensure that it has implement appropriate technical and organisational measures against unauthorised or unlawful processing, access, disclosure, copying, modification, storage, reproduction, display or distribution of Personal Information, and against accidental or unlawful loss, destruction, alteration, disclosure or damage of Personal Information. Other than securing the Personal Information on collection of same from the Responsible Party via the Centricity services, Centricity shall not be responsible for any other Responsible Party’s security safeguard obligations.

9)     Data retention

How long will Centricity retain Personal Information?

a)     Centricity will only retain Personal Information for as long as reasonably necessary to fulfil the purposes Centricity collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. Centricity may retain Personal Information for a longer period in the event of a complaint or if Centricity reasonably believe there is a prospect of litigation in respect to its relationship with a Centricity client or Data Subject or any claim as a result of a Responsible Party (Centricity client) not obtaining the required consent as per par.1)c) above.

b)     To determine the appropriate retention period for Personal Information, Centricity consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which Centricity process your Personal Information and whether Centricity can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

c)     In some circumstances you can ask Centricity to delete your data: see your legal rights below for further information.

d)     In some circumstances Centricity will anonymise/de-identify the Personal Information (so that it can no longer be associated with the Data Subject) for research or statistical purposes, in which case Centricity may use this information indefinitely without further notice to you.

10)   Records

Centricity will keep detailed, accurate and up-to-date written records regarding any Processing of Personal Information it carries out, including but not limited to, the access, control and security of the Personal Information and approved subcontractors, the processing purposes, categories of processing, any transfers of Personal Information to a Third-party country and related safeguards, the instructions as received from the Centricity client and a general description of the technical and organisational security measures and retention and destruction of Personal Information.

11)   Social Media

a)     Our sites or services may, in certain circumstances, provide you with social plug-ins from various social media networks. If you choose to interact with a social network such as Facebook or LinkedIn (for example by registering an account or click on the link from our website), your activity on our sites will also be made available to that social network. This is necessary for the performance of your contract with Us which allows you to interact with a social network.  If you are logged in on one of these social networks during your visit to one of our websites or are interacting with one of the social plug-ins, the social network might add this information to your respective profile on this network based on your privacy settings.  If you would like to prevent this type of information transfer, please log out of your social network account before you enter one of our sites, or change the necessary privacy settings, where possible.

b)     Communication, engagement and actions taken through external social media networks that we participate in are custom to the terms and conditions as well as the privacy policies held with each social media platform respectively.

c)     You are advised to use social media networks wisely and communicate/engage with them with due care and caution in regard to their own privacy policies (if any). PLEASE NOTE: WE WILL NEVER ASK FOR PERSONAL OR SENSITIVE INFORMATION THROUGH SOCIAL MEDIA NETWORKS AND ENCOURAGE USERS, WISHING TO DISCUSS SENSITIVE DETAILS OR TO RESOLVE ISSUES/CONCERNS, TO CONTACT US THROUGH PRIMARY COMMUNICATION CHANNELS SUCH AS BY TELEPHONE OR EMAIL.

d)     Our social media network page(s) may share web links to relevant web pages.  By default, some social media platforms shorten lengthy URL's.  You are advised to exercise caution and due care before clicking on any shortened URL's published on social media platforms by this website.  Despite our best efforts to ensure that only genuine URL's are published many social media platforms are prone to spam and hacking and therefore our website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.

12)   Data Subject’s legal rights

a)     Under certain circumstances, a Data Subject has the following rights under Data Protection Legislation in relation to his/her/its Personal Information:

i)      Request access to Personal Information (commonly known as a "data subject access request"). There may be a fee associated with this request – see below.  This enables the Data Subject to receive a copy of the Personal Information the Responsible Party holds about the Data Subject and to check that the Responsible Party is lawfully processing it.

ii)     Request correction of the Personal Information. This enables the Data Subject to have any incomplete or inaccurate data the Responsible Party holds about the Data Subject corrected, though the Responsible Party may need to verify the accuracy of the new data the Data Subject provides to the Responsible Party.

iii)    Request erasure of Personal Information. This enables the Data Subject to ask the Responsible Party to delete or remove Personal Information where there is no good reason for the Responsible Party continuing to process it. The Data Subject also have the right to ask the Responsible Party to delete or remove his/her/its Personal Information where the Data Subject has successfully exercised his/her/its right to object to processing (see below), where the Responsible Party may have processed the Data Subject’s information unlawfully or where the Responsible Party is required to erase the Data Subject’s Personal Information to comply with local law. Note, however, that the Responsible Party may not always be able to comply with the Data Subject request of erasure for specific legal reasons which will be notified to the Data Subject, if applicable, at the time of the Data Subject request. Take Note: Erasure of the Data Subject’s Personal Information shall further not limit the Responsible Party rights in terms of Aggregate Data and Pattern Data

iv)    Object to processing of Personal Information where the Responsible Party is relying on a legitimate interest (or those of a Third party) and there is something about the Data Subject’s particular situation which makes the Data Subject wants to object to processing on this ground as the Data Subject feels it impacts on his/her/its fundamental rights and freedoms. The Data Subject also has the right to object where the Responsible Party are processing the Data Subject’s Personal Information for direct marketing purposes. In some cases, the Responsible Party may demonstrate that the Responsible Party has compelling legitimate grounds to process the Data Subject’s information which override the Data Subject’s rights and freedoms.

v)     Request restriction of processing of Personal Information. This enables the Data Subject to ask the Responsible Party to suspend the processing of Personal Information in the following scenarios:

(1)   If the Data Subject wants the Responsible Party to establish the data's accuracy.

(2)   Where the Responsible Party use of the data is unlawful, but the Data Subject does not want the Responsible Party to erase it.

(3)   Where the Data Subject needs the Responsible Party to hold the data even if the Responsible Party no longer requires it as the Data Subject needs it to establish, exercise or defend legal claims.

(4)   The Data Subject has objected to the Responsible Party use of his/her/its data, but the Responsible Party needs to verify whether the Responsible Party have overriding legitimate grounds to use it.

vi)    Request the transfer of Personal Information to the Data Subject or to a Third party. We will provide to you, or a Third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Contact us if you need to transfer your Personal Information.

vii)   Withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

b)     If you wish to exercise any of the rights set out above and where we act as Responsible Party, then please contact us at the details mentioned par. 1 a) above.

c)     Take note of the following that will apply where Centricity acts as Operator and the Centricity client as the Responsible Party:

i)      Centricity will notify the Centricity client immediately if it receives any complaint, notice or communication that relates directly or indirectly to the processing of the Personal Information or to either party's compliance with the Data Protection Legislation.

ii)     Centricity will notify the Centricity client within 2 (two) working days if it receives a request from a Data Subject for access to their Personal Information or to exercise any of their related rights under the Data Protection Legislation.

iii)    Centricity will give the Centricity client its full co-operation and assistance in responding to any complaint, notice, communication or Data Subject request and the Centricity client shall remunerate Centricity for any reasonable costs that Centricity may incur as a result of said request. Centricity shall not be liable for the Centricity client’s non-compliance of any Data Subject requests.

iv)    Centricity must not disclose the Personal Information to any Data Subject or to a Third party other than at the Centricity client’s request or instruction, as provided for in the Terms of services or as required by law.

v)     Where you, as a data subject is a client/ customer/ employee of the Centricity client and wishes to submit a complaint or request, then we recommend that you submit it to the Centricity client.

d)     Fee required: Apart from any prescribed fees under any applicable data protection legislation, the Data Subject will not have to pay a fee to access his/her/its Personal Information (or to exercise any of the other rights). However, a reasonable fee may be charged if the Data Subject request is clearly unfounded, repetitive or excessive. Alternatively, the Responsible Party could refuse to comply with the Data Subject request in these circumstances.

e)     What we may need from the Data Subject: We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

f)      Time limit to respond: Centricity try to respond to all legitimate requests within 30 (thirty) days. Occasionally it could take Centricity longer than 30 (thirty) days if your request is particularly complex or the Data Subject has made a number of requests. In this case, Centricity will notify the Data Subject and keep the Data Subject updated.

13)   Subcontractors

a)     Centricity may authorise a Third party (subcontractor) to Process the Personal Information.  Were Centricity uses sub-contractors, Centricity will:

i)      enter into a written contract with the subcontractor that contains terms substantially the same as those set out in this Privacy Policy, in particular, in relation to requiring appropriate technical and organisational data security measures; and

ii)     maintain control over all Personal Information it entrusts to the subcontractor.

b)     Centricity agrees to select subcontractors carefully according to their suitability and reliability.

c)     A subcontractor within the meaning of this Privacy Policy shall not exist if Centricity commissions Third parties with additional services, that are not an essential part of this Privacy Policy.

d)     Where the subcontractor fails to fulfil its obligations under such written agreement, Centricity remains fully liable to the Centricity client for the subcontractor's performance of its agreement obligations.

e)     The Parties consider Centricity to control any Personal Information controlled by or in the possession of its subcontractors.

f)      Centricity undertakes to ensure that all subcontractors who process Personal Information of Data Subjects shall not amend, modify, merge or combine such Personal Information and Process same as per instructions from Centricity.

14)   Personal Information breach

a)     Centricity will without undue delay notify the Centricity client if any Personal Information (of the Centricity client or its Data Subjects) is lost or destroyed or becomes damaged, corrupted, or unusable.

b)     Centricity will without undue delay and where reasonably possible, after it has come to knowledge of Centricity, notify the Centricity client of:

i)      any accidental, unauthorised or unlawful processing of the Personal Information; or

ii)     any Personal Information Breach.

c)     Where Centricity becomes aware of (a) and/ or (b) above, it shall, without undue delay, also provide the Centricity client with the following information:

i)      description of the nature of (a) and/or (b), including the categories and approximate number of both Data Subjects and Personal Information records concerned;

ii)     the likely consequences; and

iii)    description of the measures taken or proposed to be taken to address (a) and/or (b), including measures to mitigate its possible adverse effects.

d)     Immediately following any unauthorised or unlawful Personal Information processing or Personal Information Breach, the parties will co-ordinate with each other to investigate the matter. Centricity will reasonably co-operate with the Customer in the Customer's handling of the matter, including:

i)      assisting with any investigation;

ii)     providing the Customer with physical access to any facilities and operations affected;

iii)    facilitating interviews with Centricity's employees, former employees and others involved in the matter;

iv)    making available all relevant records, logs, files, data reporting and other materials required to comply with all Data Protection Legislation or as otherwise reasonably required by the Customer (subject to confidentiality); and

v)     taking reasonable and prompt steps to mitigate the effects and to minimise any damage resulting from the Personal Information Breach or unlawful Personal Information processing.

e)     Centricity will not inform any Third party of any Personal Information Breach without first obtaining the Customer's prior written consent, except when required to do so by law.

f)      Centricity agrees that the Customer has the sole right to determine:

i)      whether to provide notice of the Personal Information Breach to any Data Subjects, supervisory authorities, regulators, law enforcement agencies or others, as required by law or regulation or in the Customer's discretion, including the contents and delivery method of the notice; and

ii)     whether to offer any type of remedy to affected Data Subjects, including the nature and extent of such remedy.

g)     The Customer indemnifies Centricity against any claim from the supervisory authorities or Data Subjects where the Customer refuse or neglect to provide the required notices.

h)     Centricity will cover all reasonable direct expenses associated with the performance of the obligations under clause b), clause c) and clause d) unless the matter arose from the Customer's specific instructions, negligence, willful default or breach of this Agreement or any contract or any Third party actions outside the reasonable control of Centricity, in which case the Customer will cover all reasonable expenses.

15)   Definitions

a)     Consent: means any voluntary, specific and informed expression of will in terms of which permission is given for the processing of Personal Information.

b)     Data Protection Laws means any and all applicable laws relating to the protection of data or of Personal Information and shall include the Protection of Personal Information as per the POPI Act and where applicable, the General Data Protection Regulations (GDPR).

c)     Data Subject means the person to whom Personal Information relates and, in this document, refers to you, as the party providing Personal Information that will be processed by Centricity or a relevant Third party.

d)     Centricity client means a client/ customer of Centricity, making use of Centricity services.

e)     Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/ product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Information for our legitimate interests. We do not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

f)      Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

g)     Personal Information means information as defined in the protection of Personal information Act of 2013 (POPI Act (click on link to view));

h)     Process means processing as defined under the POPI Act.

i)      Responsible Party means a party as defined in the POPI Act (click on link to view).

j)      Special Personal Information means as defined in the POPI Act (click on link to view).

k)     THIRD PARTIES

i)      Internal Third Parties: Other companies in the Centricity group (if applicable), acting as joint responsible parties or Operators and who may also provide IT and system administration services and undertake leadership reporting.

ii)     External Third Parties

(1)   service providers acting as operators who provide IT and system administration services or such service providers that assist us in detecting, preventing, or otherwise address fraud, security or technical issues.

(2)   service providers integrated into the Centricity services as notified to you and where you have given us the required authorisation (by utilisation of the services) to obtain information from or to submit information to, including but not limited to pathology and/ or radiologist reports, electronic remittance advises and debit orders for purposes of payments.

(3)   Professional advisers acting as operators or joint Responsible Parties, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services, debt collectors (where payments are due and payable).

(4)   The Revenue services, regulators and other authorities acting as operators or joint Responsible Parties who require reporting of processing activities in certain circumstances.

(5)   Court of law or any other authority where we have an obligation under law to share your Personal Information.

(6)   In the event that we sell or buy any business or assets, in which case we may disclose your Personal Information to the prospective seller or buyer of such business or assets.

END OF POLICY



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