Who we are
Our website address is: https://togetherproject.co.za.
The Together Project (collectively referred to as “we,” “us,” or “our” in this privacy policy) is committed to safeguarding the privacy of individuals (“you” or “data subjects”) whose personal information we collect and process. This Privacy Policy outlines how we collect, use, disclose, and protect your personal information in compliance with the Protection of Personal Information Act, 2013 (POPIA) of South Africa. By engaging with us, you consent to the practices described in this policy.
1. Definitions
- Personal Information: Information relating to an identifiable, living, natural person, and where applicable, an identifiable, existing juristic person, including but not limited to contact details, demographic information, and opinions of and about individuals.
- Processing: Any operation or activity concerning personal information, including collection, storage, modification, dissemination, or destruction.
- Data Subject: The person to whom personal information relates.
- Responsible Party: The entity that determines the purpose and means of processing personal information.
2. Information We Collect
We may collect various types of personal information, including but not limited to:
- Contact Information: Name, address, telephone number, email address.
- Demographic Information: Age, gender, race, nationality.
- Financial Information: Banking details, donation history.
- Health Information: Medical history, disabilities.
- Employment Information: Occupation, employer details.
- Digital Information: IP address, browser type, browsing behaviour.
3. Methods of Collection
We collect personal information through various methods:
- Direct Interactions: When you provide information by filling out forms, subscribing to our services, or communicating with us.
- Automated Technologies: Through cookies and similar technologies when you interact with our website.
- Third Parties: From partners, service providers, or public databases.
4. Purpose of Processing
We process personal information for the following purposes:
- Service Delivery: To provide and manage our programs and services.
- Communication: To send updates, newsletters, and respond to inquiries.
- Fundraising and Donations: To process donations and maintain donor records.
- Compliance: To comply with legal obligations and regulatory requirements.
- Research and Development: To improve our services and develop new programs.
- Security: To protect our operations and prevent fraud.
5. Legal Basis for Processing
Our processing of personal information is based on one or more of the following legal grounds:
- Consent: Where you have provided explicit consent for specific processing activities.
- Contractual Necessity: Where processing is necessary for the performance of a contract to which you are a party.
- Legal Obligation: Where processing is required to comply with applicable laws.
- Legitimate Interests: Where processing is necessary for our legitimate interests, provided these do not override your rights.
- Failure to provide personal data
Where we need to collect personal data by law or to provide our services and you fail to provide that data when requested, we may not be able to provide you with these services. In this case, we may have to suspend or stop the provision of our services, but we will notify you if this is the case at the time.
7. Special Personal Information
We may process special categories of personal information, such as:
- Health Information: To accommodate specific needs in our programs or in the event of an emergency.
- Race or Ethnic Origin: For reporting and compliance with diversity initiatives.
Processing of such information will only occur with your explicit consent or where legally permitted.
8. Sharing of Personal Information
We may share your personal information with:
- Service Providers: Third parties who provide services on our behalf, bound by confidentiality agreements.
- Affiliated Organizations: Partners and affiliates involved in delivering our programs.
- Legal Authorities: When required by law or to protect our rights.
- Donors and Sponsors: Aggregated data may be shared to demonstrate impact, without revealing identifiable information.
9. International Transfers
Your personal information may be transferred to and processed in countries other than South Africa. We will ensure that such transfers comply with applicable data protection laws and that appropriate safeguards are in place.
10. Data Security
We implement appropriate technical and organizational measures to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. These measures include:
- Access Controls: Restricting access to personal information to authorized personnel.
- Encryption: Using encryption technologies to protect data during transmission.
- Regular Audits: Conducting regular security assessments and audits.
11. Data Retention
We retain personal information only for as long as necessary to fulfil the purposes for which it was collected or as required by law. Retention periods are determined based on:
11.1 Legal Requirements: Compliance with statutory obligations.
11.2 Operational Needs: Ensuring the continuity of our services.
11.3 Historical Record: Maintaining archives for research and historical purposes.
12. Your Rights
As a data subject, you have the following rights:
12.1 Access: To request a copy of the personal information we hold about you.
12. 2 Rectification: To request correction of inaccurate or incomplete information.
12.3 Erasure: To request deletion of your personal information, subject to legal constraints.
12.4 Restriction: To request limitation of processing under certain circumstances.
12.5 Objection: To object to processing based on legitimate interests or for direct marketing purposes.
12.6 Data Portability: To receive your personal information in a structured, commonly used format.
13. Exercising Your Rights
To exercise your rights, please contact us using the details provided in Section 16. We may require verification of your identity before processing your request. We will respond to your request within a reasonable timeframe and in accordance with applicable laws.
14. Cookies and Similar Technologies
Our website uses cookies and similar technologies to enhance user experience and analyse website traffic. You can control the use of cookies through your browser settings. However, disabling cookies may affect the functionality of our website.
15. Third-Party Links
Our website may contain links to third-party websites. We are not responsible for the privacy practices of these websites and encourage you to read their privacy policies.
16. Contact Information
If you have any questions or concerns about this Privacy Policy or our data processing practices, please contact us at:
The Together Project
togetherprojectza@gmail.com
17. Complaints
If you believe that we have infringed your privacy rights, you have the right to lodge a complaint with the Information Regulator:
Information Regulator (South Africa)
JD House
27 Stiemens Street
Braamfontein, Johannesburg, 2001
P.O Box 31533, Braamfontein, Johannesburg, 2017
complaints.IR@justice.gov.za
18. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The updated policy will be posted on our website with the effective date. We encourage you to review this policy periodically.
19. Acceptance of Terms
By engaging with us or using our services, you signify your acceptance of this Privacy Policy. If you do not agree with this policy, please refrain from providing us with your personal information.
20. Governing Law
This Privacy Policy is governed by the laws of South Africa. Any disputes arising from this policy shall be subject to the jurisdiction of South African
Comments
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.
Media
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
Cookies
If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
Embedded content from other websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
Who we share your data with
Suggested text: If you request a password reset, your IP address will be included in the reset email.
How long we retain your data
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
What rights you have over your data
If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
Where your data is sent
Visitor comments may be checked through an automated spam detection service.