Overview

1. Introduction: CONSTITUTION HILL takes your privacy seriously. This privacy policy describes how and why we obtain, store and process data which can identify you. We may update this policy from time to time and shall indicate on the web site when changes have been made.
2. The Information we collect: Information is collected from you when you register with us, or when you contribute to or use some of the advanced features on the site. The information we collect is clearly set out on the web page on which we collect it. See for example our registration page, order form and/or contact forms. In addition, we may collect your IP address and use cookies unless you configure your web browser not to accept them.
3. Why we collect it: We collect information about you so that we can personalise your use of the site, assist your use of the site and improve the site generally. Depending upon your selections for our data protection questions we may arrange for you to be sent information about related products and services from us and carefully selected third parties. You may update the answers to your questions at any time.
4. Who we disclose it to: We will only pass on information about you as an individual (as opposed to aggregate information) to third parties to enable us to perform services requested by you or with your prior consent.
   • If you give your consent, we will pass your contact details to third parties who may then occasionally send communications to you to provide information, offers and services that may be of interest to you.
   • In certain circumstances we may need to disclose information about you if you breach this privacy policy or if you breach the Terms and Conditions. We may also disclose or access your account if required to do so by law or by any Governmental body.
   • We will only pass on information about you as an individual (as opposed to aggregate information) to third parties overseas to enable us to perform services requested by you.
5. Data Protection: The Privacy Regulations or Protection of Personal Information (including, but not limited to GDPR, CCPA, CPRA, LGPD, POPI) states that it will regulate, in harmony with international standards, the processing of personal information by public and private bodies in a manner that gives effect to the right to privacy subject to justifiable limitations that are aimed at protecting other rights and important interests.
   • Users of bashauhuru.co.za acknowledge that CONSTITUTION HILL takes the protection of personal information seriously, and in particular the compliance with data privacy laws.
6. Security: Keeping information about you secure is very important to us and certain sections of the site may encrypt data using SSL or a comparable standard. However, no data transmission over the Internet can be guaranteed to be totally secure. As a result, whilst we strive to protect your personal information, we cannot ensure or warrant the security of any information which you send to us, and you do so at your own risk.
7. Accessing and updating your personal information: We will always let you have a copy of personal information we have about you, should you request it, and you may correct it if you wish. Instructions about how to do this are available from info@constitutionhill.org.za.
8. Questions?: If you have any questions or complaints relating to this Privacy Policy or how we use the personal information we have about you, please contact info@constitutionhill.org.za. We will endeavour to respond to you promptly.

Last updated: 14 June 2023

We are committed to respecting your privacy and protecting your personal data. This privacy and cookie policy (“Policy”) sets out how we use data relating to you and applies to all use of your personal data by CONSTITUTION HILL, a company registered in South Africa under company registration and with registered office at The Old Fort, 11 Kotze Street, Braamfontein, Johannesburg (“we”,“us” or “our”).

• This Policy sets out the basis on which personal data will be processed by us. This Policy applies to personal data we may collect from you, or that you provide to us, through or in connection with our website at: bashauhuru.co.za/ (the “Website”). Please read the Policy carefully to understand our views and practices regarding your personal data.
• We will only collect and process information about you in accordance with this Policy and we will only use information collected about you in accordance with applicable data protection laws and equivalent legislation. Where we decide the purpose or means for the processing of the personal data that you provide when using our Website, we are the “data controller”.
• Your access to and use of the Website is conditional upon your acceptance of and compliance with this Privacy Policy. This Privacy Policy applies to everyone, including, but not limited to: visitors, users, and others, who wish to access or use the Website.
• By accessing or using the Website, you agree to be bound by this Privacy Policy. If you disagree with any part of the Privacy Policy, then you do not have our permission to access or use the Website.
• You have the right to object to the processing of your personal data, including where your personal data is being processed for direct marketing purposes. Further information on this right, and your other rights, is set out below.
• If you have any concerns over privacy, or this Policy, contact us at info@constitutionhill.org.za.

How we collect and use your personal data

The following explains what data we collect, how we use it, and which recipients it might be shared with.

Website support / enquiry information (information we receive when you get in touch with us via our website):

• Name;
• Contact details (phone number, email);
• Details of the organisation you may be contacting us on behalf of; and
• Other personal data you may send to us

1. How we use it
   • In line with the legitimate interest we have in promoting our business, we will process your enquiries to provide you with information about the services we offer.
   • This might include replying to your enquiry. We may also process enquiries to take steps you ask of us with a view to entering into an agreement to provide you with our services.
   • You are under no obligation to provide us with any details, but if you don’t provide all relevant information, we may not be able to help.
2. Third Party Recipients
   • Including, but not limited to Typeform, Google Cloud Platform, HubSpot, Intercom, Salesforce, PostHog, Sentry

Website analytics and usage information

(collected automatically when you visit the Website):

• When you visit our Website, we collect log and analytical information, such as your anonymised internet protocol (IP) address, browser type and version, time zone setting and location, operating system and platform and other technology on the devices you use.

1. How we use it
   • We process this information to understand how visitors use our Website and to compile statistical reports regarding that activity (for example, your IP address is anonymised and then used to approximate the country from which you access our Website. In many cases the data would be aggregated and/or anonymised so that it would not identify you.
   • Where this processing requires consent to the use of cookies or similar technologies, we process this information on the basis of consent. Otherwise we rely on the basis we are pursuing our legitimate interest of understanding the use of our Website and in order to run our business.
2. Third Party Recipients
   • We may share data about you with third party analytics services providers.

Email Newsletters

(if we operate them):

• your email address; and
• other information collected and clearly identifiable to you at the point of your signing up to our email newsletter.
• For the purposes of acquiring new users, we may process your hashed email, your mobile device’s unique device ID (Device ID) and device name, and your user preferences.

1. How we use it
   • We may process your data to make suggestions and recommendations to you and other users of our Website about: (i) news and updates relating to us, our partners, products, services and content; (ii) content, goods and services that may interest you; and (iii) other promotional activity and events we think may be of interest.
   • If required by law, we rely upon your consent in order for us to undertake this data processing activity. You can revoke your consent at any time by letting us know, including by emailing us. Otherwise we rely on the basis we are pursuing our legitimate interest of marketing our business.
   • We may process your personal data to improve the relevancy of our marketing, including the creation of ‘lookalike’ or ‘custom’ audiences where your personal data (including hashed email) may be shared with our user acquisition partners to find users like you or to serve you ads on social media platforms. We process this information on the basis of consent.
2. Third Party Recipients
   • We may share your data about you with third party providers of marketing automation platforms and email marketing services.

Users of our products and services

When you use our product (“user”) on behalf of an organisation such as your employer (“customer”), your organisation may choose to upload or submit to, or ask us to ingest, any content that could include your personal data from third party data sources.

These are bound by your organisation’s own policies regarding privacy and personal data collection, and your organisation acts as the “data controller”. Please refer to your organisation’s policies regarding your rights to how these data are processed.

Personal data provided to us in the use of our products and services:

• Your name
• Your email address
• Your phone number
• A profile photo you may have uploaded to a third party data source account

1. How we use it
   • When you use our product, we process your email address in order to log you into these third party data sources, access the data stored in them, and to enforce permissions on any documents displayed to you.
   • This processing is done on the basis of consent, and you may disconnect your email from any third party data source or going to the third party data source and revoking access to CONSTITUTION HILL.
   • We additionally process email addresses collected in this way on the basis of our legitimate interest to link accounts across different third party data sources belonging to the same person in order to provide our service.
2. Third Party Recipients
   • These data are stored on our cloud provider in encrypted databases without public access from the internet.

Customer content, including any personal data therein, sent to us as requested by you or your organisation.

• These personal data are processed alongside other data sent to us, and stored in a search index in order to provide the functionality in our products. We perform this processing to fulfil our contractual obligations to our customers.
• We also combine this data in aggregate using the basis of our legitimate interest to improve the quality of our services. Data processed in this way can only affect the accuracy of the search results, and will not be revealed in the contents of the search results.

1. Third Party Recipients
   • These data are stored on our cloud provider and our text search provider in encrypted databases without public access from the internet.

Product analytics and usage information

(collected automatically when you use our products or services):

• your email address
• your operating system and platform
• Your time zone setting and general location
• The product screens you have interacted with
• Your user preferences for the product or service
• Which third party data sources you have connected to CONSTITUTION HILL

1. How we use it
   • We process this information as we have the legitimate interest to understand how our product is used in order to improve it. Such data is analysed in aggregate to understand how certain features are performing or how users react to new features.
   • We may also process this information in order to fulfil our legitimate interest to improve our products’ performance, security, and stability, and to identify and fix bugs in our products.

Your rights in relation to your personal data

1. You have certain rights over the way we process personal data relating to you. We aim to comply without undue delay, and within one month at the latest, in response to any requests submitted by you to us:
   • for a copy of personal data we are processing about you and/or to have inaccuracies corrected;
   • to restrict, stop processing, or to delete your personal data;
   • for a machine-readable copy of your personal data, which you can use with another service provider. Where it is technically feasible, you can ask us to send this information directly to another provider if you prefer; and
   • to make a complaint to a data protection regulator.
2. To make a request in relation to any of the aforementioned rights, please send your request to info@constitutionhill.org.za.
3. You may request deletion of your personal data by sending an e-mail to info@constitutionhill.org.za. Please note that some information may remain in our private records after deletion. We may use any aggregated data derived from or incorporating your personal data but not in any manner that would identify you personally.

Disclosure of your personal data

1. We will share your personal data with third parties only in the ways that are described in this Policy.
2. Group, suppliers, subcontractors, service providers. We keep your personal data confidential, but may disclose it to any member of our corporate group, our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Policy.
3. Government authorities. In addition, we may disclose your personal data to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
4. Potential acquirers or investors. If we are involved in a merger, acquisition, or sale of all or a portion of our business or assets, the personal data we hold may be included as part of that sale, in which case you will be notified via email, your account and/or a prominent notice on the website of any changes in ownership or use of your personal data, as well as any choices you may have.
5. Enforcement. We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of us, our personnel or customers, or others.
6. We only permit our suppliers and subcontractors to process your personal data for specified purposes and in accordance with our instructions. All our third-party service providers are required to take appropriate security measures to protect your personal data.

Data Retention

1. We will only hold data about you for as long as necessary, bearing in mind the purpose for which that data was collected, or as otherwise described in this Policy.
2. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Security

1. We will take commercially reasonable, appropriate technical and organisational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our Website taking into account the likelihood and severity those risks might pose to the rights and freedoms of our Website visitors and customers.
2. In particular, we will take precautions to protect against the accidental or unlawful destruction, loss or alteration, and unauthorised disclosure of or access to the personal data transmitted, stored or otherwise processed by us.

International Data Transfers

1. Where necessary, there are agreements in place to ensure that personal data is processed using appropriate safeguards that meet the requirements of data protection laws. Such appropriate safeguards may include standard data protection clauses adopted by a data protection regulator or other appropriate measures.
2. If you would like to find out more about these safeguards or if you have any other queries or comments in relation to this Policy, please let us know by emailing us at info@constitutionhill.org.za.

Children

1. We do not use the Website to knowingly solicit data from or market to children. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at: info@constitutionhill.org.za . We will delete such information within a reasonable time.

General

1. If you follow a link from the Website to any third party websites, you should be aware that those websites may have their own privacy policies. We do not accept any responsibility or liability for those websites. Please check the policies of any third party websites before submitting any personal data to those websites.
2. We may make changes to this Policy in the future. You should check this page from time to time to ensure you are aware of any changes. Where appropriate we may notify you of changes by email.
3. All questions, comments or enquiries should be directed to us. We will try to respond to you within 48 hours or otherwise within a reasonable time.

Cookie Policy

Cookies (and equivalent devices in the context of mobile devices) are small text files that are placed on your computer or device by websites that you visit and mobile applications you use. They are widely used in order to make websites and applications work, or work more efficiently, as well as to provide information to the owners of the sites and apps. The below explains the main cookies we use in our Website and App and why.

Google Analytics

1. Duration – 90 Days
   • This cookie is used to collect information about how visitors use our Website. We use the information to compile reports and to help us improve our Website.
   • Google’s privacy information is available here. You can also read Google’s overview of privacy and safeguarding data here.