Privacy Policy

This policy explains how JenileePR (Pty) Ltd handles data and information collected from you while using our website and/or our services.

By accessing and using this website and/or our services, the user acknowledges and accepts the processing of their personal information by JenileePR (Pty) Ltd on the basis set out in this Privacy Policy.

If the user does not agree with this Privacy Policy, the user must stop accessing and/or using this website and our services.

1. Introduction

JenileePR (Pty) Ltd collects, uses and, in some circumstances, shares the personal information of users in and through this website and during the provision of services.

JenileePR (Pty) Ltd respects the rights of users whose personal information is collected and used by it, including their right to protection against the unlawful collection, retention, sharing and use of such personal information.

The purpose of this Privacy Policy is to provide users with information about the information processing activities of JenileePR (Pty) Ltd and the manner in which their rights are protected.

This Privacy Policy shall serve as a notification to users about JenileePR (Pty) Ltd’s processing activities, which will remain valid for as long as one is using the website, has an active account with JenileePR (Pty) Ltd, or is making use of our services.

Users will not be notified separately on each occasion that JenileePR (Pty) Ltd processes the same personal information in the same way over the relevant period.

JenileePR (Pty) Ltd may amend the provisions of this Privacy Policy to comply with any changes in the law and/or pursuant to any changes to its information processing activities or privacy practices. Such amendments will be published on the website and will become effective from the date of such publication.

This Privacy Policy, and the interpretation and enforcement thereof, will be governed by the laws of the Republic of South Africa.

The provisions of this Privacy Policy are, as far as possible, incorporated into any agreement between JenileePR (Pty) Ltd and users.

2. Definitions and Interpretation

In this Privacy Policy, the following words bear the following meanings:

“consent” means any voluntary, specific and informed expression of will in terms of which permission is given by or on behalf of a user for the processing of their personal information;

“direct marketing” means to approach a data subject, either in person, by mail or electronic communication, for the direct or indirect purpose of promoting or offering to supply any goods or services to the data subject;

“information officer” means the Information Officer of JenileePR (Pty) Ltd from time to time;

“operator” means an outside third party who processes personal information for or on behalf of JenileePR (Pty) Ltd in terms of a contract or mandate;

“PAIA” means the Promotion of Access to Information Act 2 of 2000;

“personal information” means any information linked to a user or information that can identify a user, including but not limited to:

• information relating to a user’s name, company name, email address, physical address, telephone number, location information or online identifier;
• a user’s financial information, including invoice information and payment records;
• a user’s correspondence with JenileePR (Pty) Ltd;
• a user’s account, project, website, hosting or service information;
• information supplied by a user for website design, social media management, graphic design, domain registration, web hosting or related services;
• the user’s special personal information, where applicable; and
• the user’s name if it appears with other personal information relating to that user, or if the disclosure of their name on its own would reveal further personal information about that user;

“POPIA” means the Protection of Personal Information Act 4 of 2013, including any regulations or codes of conduct promulgated under it;

“process” or “processing” means, in relation to personal information, any operation or activity concerning personal information, including the collection, receipt, recording, organisation, storage, updating, use, sharing, transfer, restriction, erasure or destruction of that information;

“special personal information” means the religious or philosophical beliefs, race or ethnic origin, trade union membership, political persuasion, health, sex life or biometric information of a user, and may include criminal behaviour of a user where applicable;

“services” means the services provided to any user by JenileePR (Pty) Ltd;

“user” means a visitor or user of this website, or any person using the services of JenileePR (Pty) Ltd; and

“the website” means the website of JenileePR (Pty) Ltd.

Any reference in this Privacy Policy to:

• the singular includes the plural and the other way around;
• any one gender includes the other genders, as the case may be;
• an act, regulation or other law is to the version of that law in force at the effective date of this policy and includes any amendment or re-enactment made to that law after the effective date of this policy;
• the word “include” means “include without limitation”.

A requirement that any policy, request, demand or other communication made in terms of this Privacy Policy must be in writing will be met if it is in the form of a data message as defined in the Electronic Communications and Transactions Act 25 of 2002 and is accessible in a manner usable for subsequent reference.

3. Responsible Party and Operators

JenileePR (Pty) Ltd will be the party collecting and processing a user’s personal information and is therefore designated as the responsible party for the purposes of this Privacy Policy.

JenileePR (Pty) Ltd’s contact details are as follows:

Email: info@jenileepr.com
Website address: www.jenileepr.com 

JenileePR (Pty) Ltd may instruct third-party operators from time to time to undertake certain processing activities relating to the user’s personal information in order to render services.

This may include Afrihost, where Afrihost is used for website hosting, domain registration, email hosting, DNS or related hosting services.

By using our website and/or services, the user acknowledges that such third-party processing may be necessary for JenileePR (Pty) Ltd to provide its services.

4. What Personal Information is Collected

JenileePR (Pty) Ltd may collect the following personal information:

• personal information such as name, company name, address, email address and telephone number;
• contact records, such as emails sent to JenileePR (Pty) Ltd, website enquiries, project communication and other records of contact;
• account and service information, such as service type, project details, dates of payment owed and received, invoices and related account information;
• website, domain and hosting information, where required for website design, website management, domain registration, hosting or support services;
• information provided for social media management, social media marketing, graphic design, website design, domain registration, web hosting and related services;
• technical information collected through the website, such as IP address, browser type, operating system, usage information and cookies.

The supply of personal information by the user to JenileePR (Pty) Ltd is voluntary and not mandatory. However, if the user refuses to supply personal information, certain consequences may naturally follow, such as preventing JenileePR (Pty) Ltd from concluding or performing any contract with the user, providing services, responding to enquiries or complying with its obligations in law.

5. Purposes for Collection and Processing of Personal Information

JenileePR (Pty) Ltd shall only collect a user’s personal information for a specific, explicitly defined and lawful purpose relating to a function or activity of its business.

Such purposes may include the following:

• to enter into a contract with a user;
• to perform any obligations under a contract with a user;
• to provide social media management, social media marketing, graphic design, website design, domain registration, web hosting and related services;
• to manage website hosting, domain registration, DNS, email hosting and related services through Afrihost or another service provider, where applicable;
• to communicate with users;
• to prepare quotations, invoices and statements;
• to process payments and maintain business records;
• to comply with a legal obligation;
• to protect a legitimate interest of a user;
• to pursue the legitimate interests of JenileePR (Pty) Ltd;
• to process personal information for direct marketing purposes, where lawful;
• to send content, updates, notices or promotional material to the user, where lawful;
• to enable the user to participate in website forms, enquiries or interactive features;
• to notify the user about changes to the website or services.

If JenileePR (Pty) Ltd intends to process a user’s personal information for any other purpose not listed above, or which is otherwise not permitted by law, it shall obtain the user’s consent where required.

JenileePR (Pty) Ltd will not sell a user’s personal information to any third party.

6. Collection Directly from the User

JenileePR (Pty) Ltd shall, as far as possible, collect personal information about a user directly from the user, except in the following circumstances:

• where personal information is available in a public record;
• where the user has given consent to collect the information from another source;
• where it is more practical to collect the information from another source;
• where the collection of personal information from another source will not prejudice the user’s legitimate interests;
• where the collection of personal information from another source is necessary to maintain JenileePR (Pty) Ltd’s legitimate interests or those of any third party it intends sharing the information with;
• where collection directly from the user is not reasonably practical in the circumstances;
• where the information is received from Afrihost or another service provider in relation to hosting, domain, website, email or technical services.

The user may visit the website without providing personal information. However, the website’s servers may still collect technical information regarding the use of the website, which is used for analytical purposes, technical maintenance, security and improving the content offered on the website.

Such information may include details of the user’s visit, IP address, operating system, browser type, location information and usage information.

7. Cookies

Cookies are small text files transferred by a web server to a user’s device and stored on that device.

The types of information a cookie collects may include the date and time of visits to the website, browsing history and preferences.

JenileePR (Pty) Ltd may use cookies on this website to:

• distinguish one user from another on the website;
• remember the user’s previous session when they return to the website;
• estimate the website’s audience size and usage patterns;
• store information about the user’s preferences;
• customise the website and content according to user preferences;
• improve the website experience.

Third-party service providers may also use cookies on the website. JenileePR (Pty) Ltd cannot control all cookies used by third-party service providers and takes no responsibility for such third-party cookies.

The user has the right and ability to either accept or decline cookies on their web browser. However, declining cookies may limit access to certain features on the website.

8. General Conditions for Processing Personal Information

JenileePR (Pty) Ltd shall comply with all applicable laws, contracts or regulations when it processes a user’s personal information.

JenileePR (Pty) Ltd shall not act unreasonably when processing a user’s personal information. This means that it will collect and process personal information in a way that the user can reasonably expect and in a way that is fair.

JenileePR (Pty) Ltd shall respect the user’s right to privacy at all times.

JenileePR (Pty) Ltd shall ensure that the personal information collected and processed is relevant to the identified purpose, and that such information is adequate but not excessive for achieving that purpose.

If JenileePR (Pty) Ltd no longer needs to process personal information to achieve the purpose originally specified, it will stop using that information, unless it is entitled or required by law to retain it.

9. Disclosure and Sharing of Personal Information

JenileePR (Pty) Ltd may, in the course of providing services, share certain personal information with third-party operators who perform processing activities on behalf of JenileePR (Pty) Ltd.

This may include:

• Afrihost, where Afrihost is used for website hosting, domain registration, email hosting, DNS or related hosting services;
• service providers involved in delivering services to the user;
• contractors or suppliers involved in service delivery;
• accounting or payment service providers;
• email, website, cloud, social media or analytics platforms;
• law enforcement agencies, regulatory organisations, courts or other public authorities, where required or authorised by law.

JenileePR (Pty) Ltd may release information where it is reasonable for the purpose of protecting itself against fraud, defending its rights or property, or protecting the interests of its users.

JenileePR (Pty) Ltd may also share aggregated information about users of this website and their usage patterns. Such information will be de-identified and the user’s personal information will not be disclosed.

Other than as stated in this clause, JenileePR (Pty) Ltd shall not share a user’s personal information with third parties unless it has a lawful basis to do so.

10. User’s Rights in Relation to the Processing of Their Personal Information

Users shall have the following rights in relation to the processing of their personal information:

• to access and correct any personal information held by JenileePR (Pty) Ltd about them;
• to object to the processing of their personal information;
• to request the deletion or destruction of personal information, where allowed by law;
• to object to direct marketing;
• to lodge a complaint with the Information Regulator.

Users may make a request by contacting JenileePR (Pty) Ltd at info@jenileepr.com.

Requests for access to records may be handled in accordance with JenileePR (Pty) Ltd’s PAIA Manual.

11. Further Processing

JenileePR (Pty) Ltd shall not process a user’s personal information for any purpose not previously specified except in the following circumstances:

• where the user has consented to such further processing;
• where the further processing is necessary for the exercise of any contractual rights or the fulfilment of any obligations between JenileePR (Pty) Ltd and the user;
• where the further processing is linked to or compatible with the original purpose;
• where the further processing is necessary for the prevention, detection, investigation, prosecution or punishment of an offence;
• where the further processing is necessary to enforce any law;
• where the further processing is necessary for legal proceedings;
• where the further processing is necessary to prevent or reduce a serious threat to the life or health of the user or another individual;
• where the further processing is necessary for historical, statistical or research purposes.
  
  

12. Accuracy, Correctness and Completeness of Personal Information

JenileePR (Pty) Ltd shall take reasonably practical steps to ensure that the personal information kept by it about users is complete, accurate, not misleading and updated when necessary.

If a user is aware of any personal information in JenileePR (Pty) Ltd’s custody that is incorrect, inaccurate or needs to be updated, the user must make a written request to info@jenileepr.com to update or correct the relevant information.

If a user contests the accuracy of any personal information being used by JenileePR (Pty) Ltd, JenileePR (Pty) Ltd shall take reasonable steps to verify the information and, where appropriate, stop using that information until its accuracy has been confirmed.

13. Security Safeguards

JenileePR (Pty) Ltd is committed to protecting personal information in its custody against loss, damage, unauthorised destruction and unauthorised access.

JenileePR (Pty) Ltd takes reasonable steps to identify risks to the personal information in its possession or under its control and to ensure that appropriate security safeguards are in place.

These safeguards may include password protection, access control, secure storage, backups, website security measures, reputable service providers and confidentiality obligations where applicable.

Where third-party operators process personal information on behalf of JenileePR (Pty) Ltd, JenileePR (Pty) Ltd will take reasonable steps to ensure that such operators process personal information lawfully and securely.

14. Notification of Breach of Security

If personal information about a user is leaked or JenileePR (Pty) Ltd’s security has been unlawfully breached by any unauthorised party, JenileePR (Pty) Ltd shall take reasonable steps to identify the relevant users who may be affected by the security breach.

Where required by law, JenileePR (Pty) Ltd shall notify affected users and the Information Regulator.

JenileePR (Pty) Ltd shall provide sufficient information to allow the user to take the necessary protective measures against the potential consequences of the compromise, where applicable.

Where a breach relates to hosting, domain, email or website services hosted by Afrihost, JenileePR (Pty) Ltd may rely on information provided by Afrihost in order to assess and respond to the incident.

15. Cross-Border Transfers of Personal Information

The user acknowledges that personal information may be transferred outside South Africa where required for storage, hosting, email, website, cloud, social media, analytics or related digital services.

Where Afrihost or another service provider uses systems, infrastructure or service providers outside South Africa, personal information may be processed outside South Africa in accordance with the relevant provider’s terms, privacy policy and applicable law.

JenileePR (Pty) Ltd will take reasonable steps to ensure that such transfer is lawful where required by POPIA.

16. Retention of Information

JenileePR (Pty) Ltd may keep records of a user’s personal information for as long as reasonably required for the purpose for which it was collected, unless the user objects and JenileePR (Pty) Ltd is not lawfully entitled or obliged to retain the information.

JenileePR (Pty) Ltd may retain personal information where required for legal, tax, accounting, contractual, service, website, hosting, support or recordkeeping purposes.

17. Returning, Destroying or Deleting Personal Information

Where JenileePR (Pty) Ltd is no longer authorised or required to retain a record of any personal information, it shall either:

• ensure that the information is permanently destroyed or deleted as soon as reasonably practical; or
• return the information to the user or transfer it to a third party, if requested by the user in writing and where lawful.

Where information is held by Afrihost or another service provider, deletion may be subject to that service provider’s processes, retention rules and technical systems.

18. Consent

Where consent is required by law, the user consents to the processing of their personal information in terms of this Privacy Policy.

The user acknowledges and agrees that such consent has been given voluntarily after the user has read and understood the provisions of this Privacy Policy.

Should a user wish to withdraw any consent previously given, they must notify JenileePR (Pty) Ltd in writing at info@jenileepr.com.

Withdrawal of consent may affect JenileePR (Pty) Ltd’s ability to provide certain services.

19. How to Request the Removal of Your Information

A user may request the removal of certain personal information by contacting JenileePR (Pty) Ltd at info@jenileepr.com.

The request should clearly state what information the user wants removed.

Please note that not every request will necessarily result in the removal of the information.

If the user has an active service with JenileePR (Pty) Ltd, certain information may need to be retained in order to continue providing services.

JenileePR (Pty) Ltd may also retain information where it is lawfully entitled or obliged to do so.

Where the information is held by Afrihost or another service provider, removal may be subject to that service provider’s own processes and legal obligations.

20. Lodging an Objection

A user may, on reasonable grounds, object to the processing of their personal information at any time after that processing has started.

If a user wishes to object to the processing of their personal information, they should contact JenileePR (Pty) Ltd in writing at info@jenileepr.com and provide reasons for doing so.

Users may also use the process and forms contained within JenileePR (Pty) Ltd’s PAIA Manual, where applicable.

21. Choice of Law

This Privacy Policy shall be governed and interpreted in accordance with the laws of the Republic of South Africa.

22. Amendment of this Privacy Policy

JenileePR (Pty) Ltd reserves the right to change, update, add, remove and/or amend any of the provisions of this Privacy Policy from time to time.

Such changes, updates, additions, removals or amendments will become effective from the date of their publication on this website.

It is the user’s responsibility to periodically check the provisions of this Privacy Policy for any changes, updates, additions, removals or amendments.

The user’s continued use of this website following any changes to this Privacy Policy will be considered as the user’s acceptance of this Privacy Policy, as amended.

23. Contact

For more information on your rights to privacy over your information, or the information processing activities of JenileePR (Pty) Ltd, please contact us at info@jenileepr.com.