LeadRobot Privacy Notice
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Updated June 2020

Privacy Notice

We know that you care about your personal data and how it is used, and we want you to trust that LeadRobot uses your personal data carefully. This Privacy Notice will help you understand what personal data we collect, why we collect it and what we do with it.

As you read our Notice, please keep in mind that it applies to both LeadRobot and its clients as defined below.

Please take a moment to familiarise yourself with our privacy practices and let us know if you have any questions by sending us an email at privacy@LeadRobot.co.za or submitting a request through the “LeadRobot Contact Us.”

We have tried to keep this Notice as simple as possible, but if you’re not familiar with terms, such as cookies, IP addresses, and browsers, then please read about these key terms first in the annexure at the end of this policy.

You have the right to object to certain uses of your personal data including the use of your personal data for direct marketing.

Who is collecting it?

Any personal data provided to or collected by LeadRobot is controlled by LeadRobot (Pty) Ltd, ie. the data controller. This Privacy Notice applies to personal data collected by LeadRobot in connection with the services and products we offer.

This Privacy Notice applies to personal data collected by LeadRobot in connection with the services and products we offer. References to “LeadRobot” in this Notice means LeadRobot (Pty) Ltd and any company directly or indirectly owned and/or controlled by us that you are interacting with or have a business relationship with (hereinafter, “LeadRobot Group”).

This Privacy Notice also applies to LeadRobot’s marketing content, including offers and advertisements for LeadRobot products and services or that of our clients, which we (or a service provider acting on our behalf) send to you on any platform, including on third party websites, platforms and applications based on your site usage information. These third-party websites generally have their own Privacy Notice and Terms and Conditions. We encourage you to read them before using those websites.

What personal data is being collected?

Personal data means any information that can be used to identify directly or indirectly a specific individual. You are not required to provide LeadRobot the personal data that we request, but if you choose not to do so, we may not be able to provide you with our products or services, or with a high quality of service or respond to any queries you may have.

We may collect personal data from a variety of sources. This includes:

Ways in which we collect your personal data

We may collect personal data from a variety of sources. This includes:

When and why we collect “special categories of personal data”

Certain categories of personal data, such as race, ethnicity, religion, health, sexuality or biometric data are classified as “special categories of data” and benefit from additional protection under the European data protection legislation.

We limit the circumstances where we collect and process these special categories of data. LeadRobot sometimes collects data related to your health to send you tailored ads and relevant promotions. LeadRobot only collects and uses this personal data where you have provided us with your consent for us to do so. In some instances, you may have requested services or products that do not directly involve the collection of any special categories of data, but may imply or suggest your religion, health or other special categories of data.

To illustrate circumstances where LeadRobot collects and processes special categories of data we have provided the following examples:

How do we protect children’s privacy?

We understand the importance of taking extra precautions to protect the privacy and safety of children using LeadRobot products and services or that of our clients.

Most of LeadRobot and our clients’ websites are designed and intended for use by adults. Where one of our websites is intended for use by a younger audience, we will obtain consent from the person with parental responsibility before we collect personal data where it is required by applicable laws and regulations (the age at which consent is necessary varies from Country to Country).

If you are a child under the age where parental consent is required in your Country, you should review the terms of this Privacy Notice with your parent or guardian to make sure you understand and accept them. If we discover that we have collected personal data from a child without consent from a parent or guardian where such consent should have been obtained, we will delete that personal data as soon as practical. Access to certain parts of the LeadRobot’s websites and services, and/or eligibility to receive marketing communications, prizes, samples or other rewards are generally limited to users over a certain age.


We sometimes use your personal data to carry out age verification checks and enforce any such age restrictions where appropriate.

What purpose do we use your data for?

We collect, process and disclose your personal data only for specific and limited purposes. For example, to process your payments, to assess and handle any complaints, to develop and improve our products, services, communication methods and the functionality of our websites, to provide personalised products, communications and targeted advertising as well as product recommendations to you.

We also create profiles by analysing information about you, your online surfing, searching and buying behaviour and your interactions with our brand communications by building segments (creating groups that have certain common characteristics) and by placing your personal data in one or more segments.

Additionally, LeadRobot processes your personal data also using automated means. An automated decision is a decision which is made solely by automatic means, where no humans are involved in the decisionmaking process related to your personal data.

We collect, process and disclose your personal data for the following purposes:

Profiling

LeadRobot uses your personal data to build profiles. We create profiles by analysing the information about your online surfing, searching and buying behaviour and your interactions with our marketing or other communications by building segments (creating groups that have certain common characteristics) and by placing your personal data in one or more segments.


These segments are used by LeadRobot to personalise the website and our communications to you (such as sending you relevant marketing materials by digital channels, or showing relevant content to you when you visit our site, or in a newsletter to you), and to display relevant offers and advertisements from the LeadRobot client brands on the LeadRobot sites, and via third-party websites.

The segments can also be used for third-party campaigns on the LeadRobot sites. LeadRobot profiles your data where you have provided consent for us to do so; for example, accepting the setting of cookies on your browser online, signing up for marketing communications from LeadRobot or one of our client brands.

You can withdraw your consent to prevent your personal data being used this way at any time using the manage cookies section of our Cookie Notice or unsubscribing to the use of your phone number or email address if you have logged into one of our websites or signed up to any marketing communications.

By way of example –

  1. Our websites about what you view and the way you interact with our content;
  2. Our digital display advertising that we serve to you on social platforms and other publisher’s websites; and
  3. Forms you fill in online and send to us about what your interests are.

Automated decision-making

In some instances, LeadRobot processes your personal data using automated means. An automated decision is a decision which is made solely by automatic means, where no humans are involved in the decision-making process related to your personal data. For example:

Who will it be shared with?

As a South African business, LeadRobot shares your personal data internally and with selected  third-parties. For example, we share your personal data with selected clients, third-party service providers, other third-parties, as well as in case of business transfers or legal disclosure.


As a South African business, LeadRobot shares your personal data internally and with selected third-parties in the following circumstances:

  1. To comply with a legal obligation;
  2. When we believe in good faith that an applicable law requires it;
  3. At the request of governmental authorities conducting an investigation;
  4. To verify or enforce our “Terms of Use” or other applicable policies;
  5. To detect and protect against fraud, or any technical or security vulnerabilities;
  6. To respond to an emergency; or otherwise
  7. To protect the rights, property, safety, or security of third-parties, visitors to LeadRobot’s websites, LeadRobot or the public.

International data transfers

LeadRobot shares personal data internally or with third-parties for purposes described in this Privacy Notice.

LeadRobot will only send personal data collected to foreign countries in circumstances such as:

How do we protect your personal data?

LeadRobot takes the security of your personal data very seriously. We take every effort to protect your personal data from misuse, interference, loss, unauthorised access, modification or disclosure.

Our measures include implementing appropriate access controls, investing in the latest Information Security Capabilities to protect the IT environments we leverage, and ensuring we encrypt, pseudonymise and anonymise personal data wherever possible.

Access to your personal data is only permitted among our employees and agents on a need-to-know basis and subject to strict contractual confidentiality obligations when processed by third-parties.

How long do we keep your personal data for?

We will keep your personal data for as long as we need it for the purpose it is being processed for. For example, where you make a purchase online with us or one of our clients, we will keep the data related to your purchase, so we can perform or help perform the specific contract you have entered and after that, we will keep the personal data for a period which enables us to handle or respond to any complaints, queries or concerns relating to the purchase.


Your data may also be retained so that we can continue to improve your experience with us and to ensure that you receive any loyalty rewards which are due to you or communications you have requested.

We retain the identifiable data we collect directly for targeting purposes for as little time as possible, after which we employ measures to permanently delete it. We will actively review the personal data we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or consumer need for it to be retained.

What are your rights?

Your rights in relation to your personal data how it is processed. You can exercise these rights at any point. We have provided an overview of these rights below together with what this entails for you. You can exercise your rights by sending an email at privacy@leadrobot.co.za or submitting a request through the “LeadRobot Contact Us Form”.

  1. to obtain human intervention;
  2. to express your point of view;
  3. to obtain an explanation of the decision reached after an assessment; and
  4. to challenge such a decision.

Further information and advice about your rights can be obtained from the data protection Regulator in your Country.

How do you contact LeadRobot?

LeadRobot’s nominated Chief Privacy Officer is Daniel Solomon who can be contacted by email at privacy@leadrobot.co.za. If you have any questions or concerns about LeadRobot’s Privacy Notice or data processing or if you would like to make a complaint about a possible breach of local privacy laws, please do so by sending an email privacy@leadrobot.co.za

When a privacy question or access request is received we have a dedicated team which triages the contacts and seeks to address the specific concern or query which you are seeking to raise. Where your issue may be more substantive in nature, more information may be sought from you. All such substantive contacts receive a response. If you are unsatisfied with the reply received, you may refer your complaint to the relevant Supervisory Authority in your Country. If you ask us, we will endeavour to provide you with information about relevant complaint avenues which may be applicable to your circumstances.

How do we keep this notice up to date?

We will update this Privacy Notice when necessary to reflect customer feedback and changes in our products and services. When we post changes to this statement, we will revise the “last updated” date at the top of this Notice. If the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Notice changes).

We will not reduce your rights under this Privacy Notice without your consent.

Additional Privacy Terms or Notices

In addition to this Privacy Notice, there may be specific campaigns or promotions which will be governed by additional privacy terms or notices. We encourage you to read these additional terms or notices before participating in any such campaigns or promotions as you will be required to comply with them if you participate. Any additional privacy terms or notices will be made prominently available to you.


Annexure - Privacy Key Terms

Below is a list of recurring terms in LeadRobot’s privacy policy and procedures.

Glossary

Key term

Definition

Anonymisation

The process of either encrypting or removing personal data from a database, so that the individuals whom the data describe remain anonymous. This is done for the purpose of protecting individuals’ private activities while maintaining the integrity of the data gathered and shared.

Behavioural Advertising

The act of tracking users’ online activities and then delivering ads or recommendations based upon the tracked activities.

Binding Corporate Rules (BCRs)

Personal data protection policies which are adhered to by a controller or processor established on the territory of a Member State for transfers or a set of transfers of personal data to a controller or processor in one or more third countries within a group of undertakings, or group of enterprises engaged in a joint economic activity.

Biometric Data

Personal data resulting from specific technical processing relating to the physical, physiological or behavioural characteristics of a natural person, which allow or confirm the unique identification of that natural person, such as facial images or dactyloscopy data.

Chief Privacy Officer

The individual appointed by LeadRobot globally to carry out certain responsibilities and functions in respect of privacy and data protection.

Consent

Any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

Cookies

A small text file stored on a user machine that may later be retrieved by a web server from the machine. Cookies allow web servers to keep track of the end user’s browser activities, and connect individual web requests into a session.

Data Controller

An entity that has the authority over the processing of personal data. It controls the use of personal data by determining the purposes for its use and the way personal data will be processed.

Data Enrichment

A process used to enhance, refine or otherwise improve existing data.

Data Processing

Any operation or set of operations which is performed on personal data, such as collecting, recording, organizing, storing, adapting or altering, retrieving, consulting, using, disclosing by transmission, dissemination or otherwise making the data available, aligning or combining data, or blocking, erasing or destroying data. Not limited to automatic means.

Data Protection Officer

The individual appointed by LeadRobot locally to carry out certain responsibilities and functions in respect of privacy and data protection.

Data Retention

The policies and processes used within LeadRobot for determining the time period for archiving and storing of personal data.

Data Subject

The natural person that the personal data refers to.

Direct Marketing

A form of advertising in which companies provide physical or digital marketing materials to consumers to communicate information about a product or service.

EEA

European Economic Area.

Encryption

The method by which plaintext or any other type of data is converted from a readable form to an encoded version that can only be decoded by another entity if they have access to a decryption key.

GDPR

General Data Protection Regulation.

Genetic Data

Personal data relating to the inherited or acquired genetic characteristics of a natural person which give unique information about the physiology or the health of that natural person and which result, in particular, from an analysis of a biological sample from the natural person in question.

Health Data

Personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status

International Organisation

An organisation and its subordinate bodies governed by public international law, or any other body which is set up by, or on the basis of, an agreement between two or more countries.

IP Address

A unique address that identifies a device on the Internet or a local network and which allows a system to be recognized by other systems connected via the Internet protocol.

Online Behavioural Advertising

Websites or online advertising services that engage in the tracking or analysis of, e.g., search terms, browser or user profiles, preferences, demographics, online activity, offline activity, location data, and offer advertising based on that tracking.

Personal Data

Any information relating to an identified or identifiable individual. An identifiable individual is one who can be identified, directly or indirectly, in particular, by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity.

Personal Data Breach

A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.

Privacy and Data Protection

The collection of laws and regulation that applies to the collection, usage, storage, protection and other processing of personal data.  This includes data protection, privacy, banking secrecy, electronic communications and confidentiality laws and regulations, and any other applicable laws or regulations to the extent they relate to privacy of personal data.

Privacy Champion

An internal employee who serves as the privacy practice sponsor and acts as an advocate to further foster privacy as a core organization concept.

Processor

A natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Profiling

Any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

Pseudonymization

The processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

Recipient

A natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third-party or not. However, public authorities which may receive personal data in the framework of a inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

Representative

Natural or legal person established in the Union who, designated by the controller or processor in writing pursuant to Article 27, represents the controller or processor regarding their respective obligations under this Regulation

Restriction of Processing

The marking of stored personal data with the aim of limiting their processing in the future.

Special Categories of Personal Data

Special categories of personal data, include: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic data, biometric data (for uniquely identifying an individual) and of data concerning health, sex life or sexual orientation.

Supervisory Authority

Independent Authority or division associated with an Authority in any relevant jurisdiction, whose primary purpose and function is to regulate matters related to personal data.

Third-Party

A natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.