Users of our Website, affiliated mobile websites, and software programs—collectively referred to as “our Platforms”—which are used to access and buy our goods and services are subject to the terms of this privacy statement.

 In accordance with the Protection of Personal Information Act 4 of 2013 (the “POPI”), HURP PTY LTD has created this privacy statement to explain how, why, and when it uses your personal information.
When we collect or use your Personal Information, it’s vital that you read our Privacy Policy as well as any other terms and conditions, privacy notifications, or policies we may occasionally give.

 Also, please pay close attention to the following sections in this privacy statement, which are highlighted in the same font and style (i.e. bold): which may limit the risk or liability of HURP or a third party.

• may expose the user to risk or liability.
• may require the user to defend HURP or another party in court.
• serves as the user’s acknowledgement of a fact.

 We value your privacy and take seriously the safeguarding of Personal Information. Every time you shop with us, we work hard to provide outstanding service and to do this, we need to use some of your Personal Information. This privacy statement explains how we manage the Personal Information you provide to us or that we gather about you. You consent to the processing of your Personal Information in the manner described in this Privacy Policy by using our Platforms.

 

The terms in this privacy policy are

• The definitions are given in POPI for “Personal Information” and “process/processing” apply here as well.
• When we, us, or our are used, we mean HURP.
• All individuals who access or use our Platforms are referred to as users and are addressed as “you” and “your” in this document.
• Anybody who has registered on our Platforms and given us their unique email address, password, and other Personal Information in order to make purchases on our Platforms is referred to as a “registered user(s)”.

IF YOU ARE BELOW THE AGE OF 18

Before using our Platforms or providing us with your personal information if you are under the age of 18, you must always obtain consent from your parent or legal guardian. By asking you for your parent’s or guardian’s contact information so we may get in touch with them, for example, we can verify that your parent or guardian has granted you such authorization. We may also confirm that the contact information you have provided is accurate and belongs to the person who is genuinely your parent or legal guardian. You are only permitted to use our Platforms if we are able to confirm such permission or if a parent or legal guardian certifies that you do not have their consent.

What kinds of personal data do we gather and use?

Personal information is processed by HURP in a way that is appropriate, sufficient, pertinent, not excessive, and unique to the intended use. We gather and process some personal information from users in order for them to access and use our platforms. In order to provide you with our services as a registered user, we must collect and process your Personal Information.

We may gather the following Personal Information when you register to use one of our Platforms:

• name and surname.
• email address.
• physical address.
• gender.
• mobile phone number.
• online identifiers.
• date of birth.
• identification number.

 You can update your registered user information in your account profile if your personal information changes, or if you want to amend and/or modify this personal information.

 You represent and warrant that the data you have supplied is true, accurate, current, and complete and does not impersonate, falsely state, or otherwise misrepresent your association with anyone or anything. You represent and warrant that the data you have supplied is true, accurate, current, and complete and does not impersonate, falsely state, or otherwise misrepresent your association with anyone or anything.

Information gathered from our Platforms

HURP processes some of your Personal Information when you access our Platforms, whether or whether you are a registered user. In accordance with how you access and utilize our Platforms, we might receive

• log details on how, when, and for how long you use our Platforms and other services, the content you see, and the search terms you enter through online identifiers.
• information about the tools you use to access or use our platforms, including the kind of device you’re using, how you access our platforms, the browser or operating system you’re using, and your IP address.
• the geographic area from which you accessed our Platforms, including the GPS signal received by your device and details on nearby wifi hotspots and cell towers. When you use location-enabled services, we receive this data.
• any details about you obtained from third parties, such as social media.

 

WE PROCESS YOUR PERSONAL INFORMATION; WHY?

We use the personal data we acquire and process to

• identify you;
• verify your identity;
• create a user account for you; and/or
• enter into a contract with you.

 As registered users, we also use your personal data for the following purposes:

• When you order goods from us, we must deliver those things to you and handle returns in order to fulfil our contractual responsibilities to you.
• give you any information, goods, or services that you ask for from us.
  provide you with information, goods, or services, including billing, customer support, addressing grievances, and quality control. Communicate with you regarding our Platforms.
• notify you of any updates to our terms and conditions, privacy notices, or policies, as well as any other changes that may have an impact on our platforms, services, or products.
• send you information on contests, goods, or services that could be of interest to you (unless you have opted out of receiving such information). Please be aware that you might also get mailings based on your browsing habits, recent orders, and interests. Visit the Newsletter Subscriptions tab under “My Account” or unsubscribe when getting a newsletter if it is being sent to you based on your recent purchases and browsing habits.
• gather your comments, which we need to improve our offerings and expand our business.
• abide by all legal and regulatory requirements, such as tax and banking regulations.
  make an effort to conduct the statistical study. Your Personal Information is not included in the research or statistics we obtain through this procedure, and they cannot be linked to you or used to identify you.

 

RECORD RETAINING AND RESTRICTION

We retain your personal data as long as:

• we need it to provide our Platforms, products or services to you.
• it is required or allowed by law and is in line with our internal retention policies.
• it is necessary to uphold the contract between you and us.
• you have agreed to us keeping your Personal Information subject to your request for us to stop processing your Personal Information.

 Your Personal Information will be kept on file by us for as long as it takes to fulfil the original intent for which it was gathered or later processed. If your personal information is used for more than one reason, we will keep it until the purpose with the longest retention period expires; however, if the purpose with the shortest retention period ends, we will no longer use it for that purpose.

By using the Platform and gaining access to it, you agree that we may keep a record of your Personal Information for no longer than is reasonably necessary to fulfil the purposes for which it was originally acquired or later processed.

USER TRACKING AND COOKIES

We may use a variety of technical methods, such as cookies and/or user tracking, when you access and use our Platforms to enhance your online experience.
When you access our Site using a device, it stores a little text file called a cookie on that device. These files do not include any of your Personal Information, but they do enable us to link you to a certain device. Many websites employ cookies, and our company does too. We may use a variety of technical methods, such as cookies and/or user tracking, when you access and use our Platforms to enhance your online experience.

When you access our Site using a device, it stores a little text file called a cookie on that device. These files do not include any of your Personal Information, but they do enable us to link you to a certain device. Many websites employ cookies, and our company does too.

• make our platforms easier to use.
• personalize your encounters with our platforms, make sure they function on your device and customize our services and platforms to your interests and needs.
• based on your online activities, such as the websites and apps you use or the content you view, and the information we have about you, we may deliver advertising that is relevant to you, restrict the number of times you see the same advertisement, and assess the effectiveness of the advertisements on our Platforms and other websites.
• If you are not a registered user, please send Opt-In marketing communications.

 

Without your consent, we won’t use your personal information in any other way.

 You agree to our usage of cookies if you access and use the Platform.

 

DECLINE DIRECT MARKETING

By “opting out” of any direct marketing communications we may send to you, you have the right to ask us not to contact you for direct marketing purposes via any kind of electronic communication, including automated call-answering services, email, and/or SMS alerts.

WHO ELSE GETS TO USE YOUR PERSONAL INFORMATION FOR PROCESSING?

Your Personal Information is not sold to other parties for marketing or any other uses.

 Your Personal Information might be given or made available to

• To help us interact with you via our Platforms for the marketing, ordering, or delivery of items, we may share your information with our employees, the personnel of HURP, and/or third-party service providers.
• When the disclosure of Personal Information is required or appropriate in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may subject us to legal liability or financial loss, to report or support the investigation into suspected illegal activity, we may disclose Personal Information to law enforcement, government officials, fraud detection agencies, or other third parties.
• In the case of any reorganization, merger, dissolution, sale, joint venture, or another disposal of any or all of our assets, other parties (such as a possible purchaser and its professional advisors) may be consulted.
• our service providers who assist with some of our business processes and are under contract with us (fraud prevention, marketing, public relations, technology services etc). However, according to our contracts, these service providers are only permitted to use your Personal Information in connection with the tasks they carry out on our behalf and not for any other reason. They also have to treat it as confidential information.

 

 

SECURITY FOR YOUR PERSONAL DATA

We take appropriate, reasonable organizational and technical measures to prevent the loss, damage, or unauthorized destruction of personal information as well as unauthorized access to or processing of personal information. This protects the integrity and confidentiality of your personal information that is in our possession or that is under our control.

 We have policies, procedures, and related processes in place that are regularly reviewed and updated in order to implement and maintain such measures. For instance, our rules, controls, and processes cover

• physical, technical and network security.
• access controls and monitoring of access.
• secure storage, destruction and encryption of records of Personal Information.
• Personal Information breach reporting and remediation.
• imposing security and confidentiality duties through written contracts on third parties (located inside or outside the borders of South Africa) who handle Personal Information as part of providing services to us.

HURP shall not be liable for any loss or damage occurring or caused by you as a result of the sharing of such Personal Information to any third party if you choose to disclose your Personal Information to any third party other than HURP. This is so because we have no control over the manner in which the third party will utilize your personal information. Always make careful to read the privacy statement of any third party.

KNOW YOUR RIGHTS

After presenting sufficient identification, you are entitled to

• view, amend, or correct the personal information we process about you. Please take note that you can access the Personal Information contained therein using your user account if you are a registered user.
• a record or explanation of your personal information can be requested. To give you access to this record of your Personal Information, HURP may impose a fee. HURP has the right to refuse requests for access and amendment of your personal information that are clearly unfounded, numerous, or excessive.
• you can ask to have your personal data updated, removed, or destroyed. Please be aware that closing your account will result in your termination as a registered user. In this case, HURP will only keep your personal information as long as it is necessary to comply with any applicable laws and internal retention guidelines
• We will fulfil your requests as soon as we get them unless we have a good reason not to.
• If we are unable to agree on whether to rectify or delete your personal information as requested, we will let you know where a correction or deletion was requested but not implemented.
• If we alter your Personal Information and it has an effect on how choices are made about you, we will, if reasonably possible, notify you.
• notify you of the action taken by us because of your request.
• notify you of unauthorised access to your Personal Information.
• provide you with reasonable evidence of our compliance with our obligations under this Privacy Policy on reasonable notice and request.
• Submit a complaint to the Information Regulator.

 As a registered user, you can exercise all your rights set out above in terms of POPIA by going to the Data & Privacy section of our Help Centre.

 As any other user, you can exercise all your rights as set out above by referring to our process set out in our PAIA Manual, here.

HOW TO LODGE A COMPLAINT WITH THE INFORMATION REGULATOR

You can file a complaint with the Information Regulator if you have any concerns about this privacy statement or our adherence to it.

On its website at https://inforegulator.org.za/wp-content/uploads/2020/07/PAIA-Manual-Template-Public-Body.pdf, you may find the Information Regulator’s contact information.

 

Any previous privacy policy clauses on our website are now superseded by this one. This Privacy Policy may occasionally be updated by us. The Privacy Policy posted on this page is the version that applies to you when you use our platforms.