Version 1: released on 5th August 2021
This policy details how we collect, store, protect and use personal information – that is information that can be used to identify an individual or a company (juristic person) – in connection with the services we may offer through our Bloom Centre website (referred to as the “Site”) and through your dealings with us (referred to as the “Services”).
As the Responsible Party
What is personal information?
Personal information includes:
- • certain information that is collected automatically when you visit our website,
- • certain information collected on engaging our Services;
- • certain information collected on submission; and
- • optional information that you provide to us voluntarily.
Additional information captured on the website that does not classify as personal information may also be collected and processed, including but not limited to:
- • anonymised information,
- • de-identified information that cannot be associated with an individual,
- • statistical information,
- • information that is public knowledge, which has been publicly and voluntarily disclosed.
Who is processing your data?
As the Responsible Party, data processing is processed by us, an entity incorporated within the laws of South Africa, with the following contact details:
Eden Village, FoxHill, Salt Rock, KZN
General enquiries: Info@bloomcentre.co.za
Data Related Queries: Info@bloomcentre.co.za
What are we processing and why?
There are various ways in which we may process your data. This section details our purposes for processing, our legal basis for the processing, and our storage periods.
In certain cases, we will process your data after obtaining your consent. You are free to withdraw your consent at any time. We may process your data with your consent for the following purposes:
- • Electronic communications, such as contacting us via a form or email address upon the Site.
- • Cookies, in order to grant you a personalised experience when dealing with us. You may decline the installation of cookies; however, this may affect the functionality of our website or prevent you from using the Site entirely. If you opt out of using cookies, we may store a single cookie in order to remember this preference.
- • For website analytics, storing details such as your IP address, bounce rate, page time, cost per click, most visited pages, and device information. These tracking cookies may be declined at any time.
- • For other offerings, in which case additional information may be volunteered by you in order to participate in the campaign or receive more information.
We will process your data when we have to perform a contract; for as long as the contractual relationship is in place, and in line with the various laws on record keeping following the end of the relationship. In order to fulfil our obligations to you in terms of the Services you have engaged us for, we will need to process your data.
We may also process your data in terms of legitimate interest, as long as the data being processed is strictly necessary, proportional, and does not infringe on your individual rights to privacy. Processing may take place in terms of the following necessary scenarios:
- • To monitor and analyse how to improve our Service and/or our Site, as well as to keep the same secure and free from abuse. This may include communications such as surveys or direct electronic communications.
- • To keep active communications with you while you are contracted with us. Certain communications are necessary during delivery of our Services, and we have a legitimate interest in keeping you informed about our Services.
Where is your data processed?
In some cases, your information may be stored and processed outside of the country or region where it was originally collected in order to complete our obligations to you, such as management systems. In some of these countries, you may have fewer rights in respect of your information than you do in your country of residence. In these cases, we will enter strict agreements with these providers in order to ensure safety and security of data.
Our primary region for storing and processing data is South Africa.
Who else will have access to your personal information?
When you authorise us to do so, we may also share your data with other companies so that they can process the data for other purposes, as explained in more detail when we request your prior consent. In addition, if you provide consent for the installation of cookies on our website, your data may be processed by third parties. These cookies are subject to the third parties’ respective Privacy Policies.
Where necessary and compelled by authorities to do so, we may share your information with law enforcement and competent courts. We may also share your information where we have to take legal action to protect our, or third-party rights.
How are we processing your data?
We will only process personal data as a result of the provision of our Services, or in operating our Site. These instructions are included in our enrolment forms and engagement contracts.
We will ensure that our employees are subject to confidentiality agreements and any statutory privacy obligations.
In the event that we should change upstream service providers that are involved in providing you with Services, or where we may need to hire additional companies to provide the Services, you have the right to reasonably oppose such an appointment. Such opposition shall be addressed on a case-by-case basis in accordance with the appropriate data protection regulation.
We will implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk.
What happens in the event of a breach?
In the event of a confirmed breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, we shall promptly assess the risk to people’s rights and freedoms and without undue delay report this breach to the appropriate authorities, responsible parties, and subjects as required by law.
We will cooperate with you and take such reasonable commercial steps as are directed by you to assist in the investigation, mitigation, and remediation of each such data breach.
You have the right to request access to, and rectification or erasure of your personal information. You may also restrict processing, or object to processing in accordance with relevant data protection regulation.
In cases where consent was given, you have the right to withdraw consent at any time.
If you do request that your information is deleted, and should your request be accepted, all information will be permanently erased, except for information that we are required to keep by law or by other exception in line with data privacy regulation. You may exercise your rights at any time by lodging a request with our Information Officer at email@example.com
Updating your information
You may update your information in writing at any time by submitting a support request or sending an email to our Information Officer at firstname.lastname@example.org. Please remember that it is your duty to keep information updated so we can correctly provide you with the Services, and you undertake to verify the information you have handed us from time to time to make sure that it is accurate.
Changes to this policy