By accessing and using our website or our services, you agree for Sortitt Private Limited (“Sortitt” or “we” or “our” or “us”) to collect and use your personal information in accordance with this Privacy Policy.
The purpose of this Privacy Policy is to provide you with information about the way we process your information and the protection of your rights.
We collect, use and, in some circumstances, share your personal information in and through this website and during the provision of services to you.
This Privacy Policy will remain valid for as long as you are using our services, which includes visiting and using our website. We may amend the provisions of this Privacy Policy and will update them on the website as and when the amendments are made effective.
1. DEFINITIONS AND INTERPRETATION
The following terms are defined for the purpose of this privacy policy:
“data protection laws” means the data protection laws that are applicable to our relationship with you, and the provision of our services (such laws may include the European Union’s General Data Protection Regulation (“GDPR”), and the Data Protection Law Enforcement Directive, and/or the Protection of Personal Information Act of 2013, including any regulations or codes of conduct promulgated under it);
“direct marketing” means to communicating with you, either in person or by mail or electronic communication, for the direct or indirect purpose of promoting or offering to supply any goods or services to you;
“operator” means an outside third party who processes personal information for or on our behalf in terms of a contract or mandate;
“personal information” means any information linked to you or information that can identify you, including but not limited to
“process or processing” means, in relation to personal information, any operation or activity or any set of operations, whether or not by automatic means, including: the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use of that information; dissemination by means of transmission, distribution or making available in any other form; or merging, linking, as well as restriction, degradation, erasure or destruction of that information;
“special personal information” means any biometric information linked to you or or biometrical information that can identify you, including without limitation a photographic image of you; and
“services” means the services provided to you by us.
2. RESPONSIBLE PARTY
We will collect and process your personal information and may instruct third party operators to undertake certain processing activities relating to your personal information. You consent for us to do so.
3. PERSONAL INFORMATION COLLECTED
You voluntarily give this personal information to us and can choose not. However, if you refuse to supply any personal information it may impact the way our services are provided to you.
We may collect the following personal information from you:
| Data Category | Details |
|---|---|
| Identity Data | Your full name, date of birth, nationality, country of residence, gender, occupation, image of Identity Card. |
| Contact Data | Your email address, billing address, residential address, telephone number. |
| Financial and Transaction Data | Your bank account and payment card details including payments to and from you and other details of products and services you have purchased from Sortitt. |
| Technical Data | Information relating to your device, such as IP address, device model, OS type & version, timezone settings, geo-location details, network information like details and logs of when, where and how you used the service; browser information such as type, version and browser plug-in, and other technology on the devices you use to access this website. |
| Usage Data | How you use our website, products, and services. |
| Marketing and Communications Data | Your preferences in receiving marketing from us and our third parties and your communication preferences. |
4. HOW YOUR PERSONAL INFORMATION IS USED
We may collect and use your personal information for the following purposes:
· To provide, maintain, monitor and enhance our services
· To fulfill the performance of a contract with you
· To manage your account including registration of services and allowing access to various functionalities within the website
· To process and deliver your order including a) managing payments, fees and charges and b) collect and recover any money owed to Sortitt.
· To perform KYC checks to enable a risk assessment if required
· To manage our relationship by notifying you of changes in our policies and asking for your feedback
· To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
· To make suggestions and recommendations to you about goods or services that may be of interest to you
· To process personal information for direct marketing
If we intend to process your data for any purpose not listed above we will update our list as soon as reasonably possible.
5. COLLECTION OF PERSONAL DATA
Personal information may be collected from or supplied by you in any of the following ways:
· Automated Technologies or interactions: As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns.
· Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources such as Google.
· Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as PAYPAL or any other providers worldwide. Please see their privacy policy.
· Identity and Contact Data from data brokers or aggregators which may based anywhere in the world.
· Identity and Contact Data from publicly available sources including but not limited to the respective jurisdiction’s relevant authorities’ sanction lists and international sanction lists.
If you visit our website without providing any personal information our website’s servers may still collect technical information on your use of the website, for analytical purposes, technical maintenance and for improving the content offered on the website.
6. COOKIES
“Cookies” are small text files transferred by a webserver to your device and thereafter stored on your device. The types of information a Cookie collects includes your username, the date and time of your visits to the website, your browsing history and preferences.
We may use Cookies on our website to:
· distinguish you from another person on the website;
· remember your last session when you return to our website;
· estimate our website’s audience size and usage patterns;
· store information about your preferences, which allows us to customize our website and content according to your individual preferences; and
· speed up searches on our website.
This only applies to Cookies used by us. We cannot and do not control or access Cookies used by third party service providers and take no responsibility therefor.
You can accept or decline the use of Cookies on your web browser. Declining the use may limit your access to certain features on our website.
7. YOUR RIGHTS IN RELATION TO THE PROCESSING OF YOUR PERSONAL INFORMATION
You will have the following rights in relation to the processing of your personal information:
· Request access to your personal data that we hold
· Request correction of your personal data
· Request erasure of your personal data as long as we are no longer legally obliged to hold that data and you cease to be a user of the services
· Request restriction of processing your personal data
· Right to withdraw consent
If you wish to exercise any of these rights please contact us.
8. SECURITY MEASURES
· We will ensure the following in any contracts entered into with third party operators who process personal information on our behalf:
· the operator shall not process any personal information without our knowledge and authority;
· the operator shall treat all personal information given to it as confidential and shall not disclose it to any unauthorised third parties;
· the operator shall establish and maintain adequate security measures which offer similar or the same protection over your personal information as offered by us;
· the operator shall notify us immediately where there are reasonable grounds to believe that any personal information has been leaked to or accessed by any unauthorised person;
· if the operator is situated in another country, it must comply with the data protection laws in that country and be able to provide verification that it is compliant; and
· if an operator is legally obliged to disclose any personal information processed by them on our behalf to other parties, it must notify us beforehand to enable us and/or you to protect your rights if necessary.
9. THIRD PARTY SITES
· Our website may contain links or references to other websites, including those of our data processors or advertisers (“third party websites”), these are not in our control. The provisions of this Privacy Policy are not applicable to third party websites and we will not be responsible for the information processing practices and/or privacy policies of those third party websites, or the cookies that those websites may use.
· Certain third parties may have access to your personal data but will always process it in accordance with law. We do not allow any third parties to process your personal data for their purposes but only permit them to process your personal data for specified purposes and in accordance with our instructions. Please view their privacy policy.
10. CHILDREN’S PERSONAL INFORMATION
Our services and website are not intended for a person under the age of 18 years old. If you are under 18 years old you require parental consent to utilize these services.
11. CROSS COUNTRY TRANSFER OF PERSONAL INFORMATION
We may transfer personal information to another country in the following circumstances:
· the transfer is necessary for the performance of a contract that we have with you;
· the transfer is necessary for the conclusion or performance of a contract with a third party which is for your benefit or in your interests;
· the transfer is otherwise for your benefit; or
· you have consented to the transfer of your information.
If we need to transfer your personal information we will ensure that the third party is subject to a law, binding code of conduct or contract which effectively upholds principles for the reasonable processing of personal information which are substantially similar to the data protection offered in terms of the GDPR.
12. RETENTION OF INFORMATION
We will retain your Personal Data for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your data as necessary to comply with legal obligations, resolve disputes, and enforce our legal agreements and policies. We may also retain usage data for internal analysis purposes.
13. CONSENT
You hereby consent to the processing of your personal information in terms of the provisions of this Privacy Policy. You acknowledge and agree that such consent has been given voluntarily after you have read and understood the provisions of this Privacy Policy, in particular, regarding the following:
· the types of personal information to be processed, including specifically special personal information;
· the specific processing activities to be undertaken;
· the specific purpose/s for such processing; and
· the possible consequences that may arise from such processing.
· Should you wish to withdraw any consent given, you must notify us in writing.
14. CONTACT
For more information on your rights to privacy over your information, or our information processing activities, please do not hesitate to contact us directly on [email protected].
