Privacy Policy

Who we are

  1. This Privacy Policy (hereinafter referred to as the “Policy”) applies to the use of the website of TCS RUD (Pty) Ltd (hereinafter referred to as “TCS RUD”), with registered address at 10 Danie Theron St, Fochville, 2515, South Africa, as well any business transaction concluded between TCS RUD a data subject and applies generally to any interactions between TCS RUD and a data subject.
  2. TCS RUD is the operator of the website at and is responsible for processing the personal data of all data subjects making use of TCS RUD’S website, irrespective of whether the data subject registers to use certain functionalities on its website, including but not limited to subscription to TCS RUD’S newsletter and/or TCS RUD’S investment guide(s).
  3. For the purposes of meeting its contractual and other legal obligations, whether in existence at the date of publication of this Policy or thereafter, as it may arise, TCS RUD may need to process personal information of a data subject.
  4. , through this Policy, wishes to inform the data subject of the scope and purpose for which personal information is processed by TCS RUD in connection with the data subject’s use of TCS RUD’S website, online shop and/or any interactions with TCS RUD.
  5. In addition to clause 1.4 above, TCS RUD, may from time to time, require the services of an OPERATOR, to process personal information of a data subject for the purposes of meeting its contractual and other legal obligations, whether in existence at the date of publication of this Policy or thereafter, as it may arise.
  6. By accessing or utilising TCS RUD’S website and/or participating in any interactions with TCS RUD the data subject specifically agrees to the terms of this Policy as amended from time to time.
  7. TCS RUD reserves its right to amend this Policy from time to time and will do so without notice to any data subject. The latest version of this Policy will be indicated by the date information (below). The current version of this Policy can always be accessed directly via TCS RUD’S website.
  8. It is the duty of the data subject to remain informed of any changes to this Policy and TCS RUD recommends that the data subject should regularly check possible changes to this Policy.
  9. TCS RUD gathers, stores and uses the data subject’s personal information only in line with the contents of this Policy and with applicable data protection provisions, such as: –
  10. The European General Data Protection Regulation 2016/679 (GDPR); and
  11. The Protection of Personal Information Act 4 of 2013.
  12. TCS RUD is committed to safeguarding the privacy of the data subject’s personal information or data and TCS RUD takes protection of privacy and personal information very seriously. TCS RUD treats your personal information or data as confidential and in accordance with the applicable statutory data protection provisions.
  13. This Policy hereby notifies the data subject that TCS RUD, in terms of this Policy, collects personal information, as per section 18 of the Protection of Personal Information Act 4 of 2013, as amended and serves as compliance with Article 12(1) of the GDPR.

Scope

This Policy applies to all data subjects (i.e. persons (whether a natural or juristic person) to which the personal information relates), and the personal information TCS RUD processes and collects, whether it was provided to TCS RUD through the use of its website or through any other form of communications with TCS RUD, such as email, telephone, or otherwise.

Your Rights and Contact

TCS RUD places strong emphasis on explaining the processing of personal data as transparently as possible and informing data subjects of their rights. In the event that data subjects would like more detailed information or wish to exercise their rights, data subjects can contact TCS RUD at any time so that TCS RUD can take care of the data subject’s concerns.

TCS RUD AND ITS CONTACT DETAILS

  1. The responsible party/controller is TCS RUD, with registration number 2006/004511/07 is a private company duly incorporated and registered in South Africa in accordance with the provisions of the Companies Act 71 of 2008 , as amended, with its registered office at 10 Danie Theron St, Fochville, 2515, South Africa
  2. TCS RUD’s contact information, including details of the relevant person whom the data subject may contact for questions concerning the processing of personal data, may be located: -at clause 19 below; alternatively on TCS RUD’s website; alternatively in TCS RUD’s Manual in terms of section 51 of the Promotion of Access to Information Act 2 of 2000, as amended.

PERSONAL INFORMATION

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  1. Personal Information/Data, in terms of the GDPR and the Protection of Personal Information Act 4 of 2013 collectively, refers to information relating to an identified or identifiable natural person and where it is applicable, an identifiable, existing juristic person.
  2. Such information may include, but is not limited to: a name, age and/or gender; an identification or registration number; national and/or social origin; financial and/or economic information; any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier or other particular assignment to the person; correspondence sent by the person that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence; and the personal opinions, views or preferences of the person.
  3. In contrast, information that cannot be connected to the data subject’s identity (e.g. statistical information, such as the number of website users) is not considered personal information.
  4. reserves the right to share non-personal, non-individual information in aggregate form with third parties for business purposes, for example with advertisers on TCS RUD’S website or business associates and partners. The data subject shall not be identifiable from such data.
  5. TCS RUD warrants that it shall conclude operator agreements with third parties with whom agreements for business purposes are concluded as referred to in clause 5.4.
  6. TCS RUD is not responsible and cannot be held liable for the privacy practices of such third parties should the operator agreement be breached by the third party.
  7. TCS RUD‘s website can be used without disclosing the data subject’s identity and without providing personal data. [DW1] Only general information about the data subject’s visit to TCS RUD’S website will be collected. However, personal information may be collected from the data subject for some of the services offered, such as providing the subject with market and trade related information.
  8. This information will then be processed by TCS RUD only for the purpose of using this online service, especially for providing the desired information. When TCS RUD requests personal data, only the data that is mandatory for the purpose of the business engagement must be provided. Further information can be provided on a voluntary basis. TCS RUD will appropriately indicate whether it is a required field or optional details. TCS RUD provides specific details in relation to this aspect in the corresponding section of this Policy.

LEGAL BASES FOR DATA PROCESSING

  1. Where TCS RUD obtains consent to process the data subject’s personal data, Article 6(1)(a) of the GDPR and section 11(1)(a) of the Protection of Personal Information Act, as amended, serves as the legal basis for data processing.
  2. Insofar as the data subject’s personal data is processed because processing is required to fulfil a contract or as part of a contract-like relationship with the data subject, Article 6(1)(b) of the GDPR and section 11(1)(b) of the Protection of Personal Information Act, as amended, serves as the legal basis for data processing.
  3. Insofar as TCS RUD processes the data subject’s personal data to fulfil a legal obligation, Article 6(1)(c) of the GDPR and section 11(1)(c) of the Protection of Personal Information Act, as amended, serves as the legal basis for data processing.
  4. As a legal basis for data processing, Article 6(1)(f) of the GDPR and section 11(1)(f) of the Protection of Personal Information Act, as amended, is taken into further consideration if the processing of the data subject’s personal data is required to protect a legitimate interest of TCS RUD or a third party and the data subject’s interests, basic rights and freedoms do not require personal data to be protected.
  5. In line with this Policy, TCS RUD will always indicate on which legal basis TCS RUD processes the data subject’s personal data.
  6. TCS RUD undertakes not to use personal information other than for the purpose for which it was provided or collected, and in accordance with TCS RUD’S legitimate interests and legal obligations.
  7. TCS RUD collects, processes, and uses personal information only to the extent necessary to establish, design or modify legal relationships with TCS RUD.
  8. This is conducted by TCS RUD in terms of Article 6(1)(b) of the GDPR and section 11(1)(b) of the Protection of Personal Information Act, as amended, which permits the processing of information to fulfil a contract or for measures preliminary to a contract.

THE INFORMATION BEING COLLECTED, THE SOURCE FROM WHICH IT IS COLLECTED, THE PURPOSE FOR ITS COLLECTION AND PROCESSING

  1. The nature of the personal information that TCS RUDcollects from data subjects is dependent on: the transaction that the data subjectis completing; the reason that the data subject is communicating with TCS RUD; and the channel, or manner, that is used to communicate with TCS RUD.
  2. Generally, TCS RUD collects the personal information from the data subject when it, inter alia,: voluntarily provides TCS RUD with information;browses, visits or participates on TCS RUD’S website; subscribes to or consents to receiving newsletters or other communications from TCS RUD; purchases or enquires about the products/services sold by TCS RUD; makes general enquiries or lodges complaints with TCS RUD; and/or communicates with TCS RUD.
  3. From time-to-time TCS RUD may collect personal information from trusted third parties, in which case it shall ensure that the data subject has provided its consent in respect thereof.
  4. INFORMATION ABOUT THE DATA SUBJECT’S DEVICE WHEN VISITING AND/OR PARTICIPATING ON TCS RUD’S WEBSITE
  5. TCS RUD‘s IT systems automatically collect personal information from data subjects when accessing TCS RUD’S website, which information generally takes the form of technical information such as the data subjects internet browser, operating system or the time of the data subject’s visit to the website, uses this data to operate the online service, particularly to identify and remedy errors in order to determine the utilization of the online service and make adjustments or improvements.

CONTACT FORM

  1. Should a data subject send TCS RUD an inquiry using the contact form on TCS RUD’s website, the data subject’s information, as contained in the contact form, including the contact information the data subject provides therein, will be stored by TCS RUD for the purpose of responding to the data subject’s inquiry and any follow-up questions which may arise by virtue of TCS RUD’s response to the inquiry.
  2. TCS RUD will not share the information provided by the data subject without the data subject’s consent.
  3. The data subject’s delivery of information to TCS RUD is entirely voluntary and a failure to provide such information means TCS RUD will be unable to address the data subject’s inquiry.
  4. The information contained in the contact form is processed exclusively based on your consent in terms of Article 6(1)(a) of the GDPR and section 11(1)(a) of the Protection of Personal Information Act, which consent may be revoked at any time.
  5. A further legal basis for the processing of the data is TCS RUD’S legitimate interest in responding to the data subject’s inquiry in accordance with Article 6 (1)(f) of the GDPR and section 11(1)(f) of the Protection of Personal Information Act, as amended.
  6. Should the data subject’s contact with TCS RUD be aimed at concluding or entering into a contract, Article 6(1)(b) of the GDPR and section 11(1)(b) of the Protection of Personal Information Act, as amended, is an additional legal basis for the processing of the data subject’s personal information.
  7. TCS RUD will retain the information provided by the data subject on the contact form until such time as the data subject requests its deletion, revokes its consent in respect of its storage, or the purpose for its storage has been fulfilled.
  8. Any mandatory statutory provisions, in particular those regarding statutory information retention periods, remain unaffected by this provision.

Cookies

  1. When visiting TCS RUD’S website, statistical analyses may be made of the data subject’s internet browsing behaviour.
  2. TCS RUD utilises cookies and analytics to analyse the data subject’s internet browsing behaviour. The data collected through cookies and analytics is anonymous and TCS RUD will be unable to identify you based on the data which is collected in this manner.
  3. Cookies are small text files that are stored on a data subject’s computer and store, via the data subject’s web browser, the settings and data which are shared with TCS RUD’S online service.
  4. Cookies usually contain the name of the domain from which the cookie file was sent and information about the age of the cookie and an alphanumerical identifier. This enables TCS RUD to identify the data subject’s device and make possible default settings available immediately.
  5. The majority of the cookies used by TCS RUD are known as session cookies, which are automatically deleted at the end of the data subject’s visit to TCS RUD’S website.
  6. TCS RUD also uses cookies that are stored in the data subject’s device memory until such time as they are deleted. These cookies are used so the data subject’s default settings and preferences may be recognised during the data subject’s next visit to TCS RUD’S website.
  7. Cookies assist TCS RUD in improving the functionality of its website and provides the data subject with a more user-friendly service that is specific to the data subject’s needs. This information is also used to identify and remedy errors in order to make adjustments or improvements as well as to identify and track abuse.
  8. Cookies which are necessary to allow electronic communications or to provide certain functions that data subjects wish to use and are stored pursuant to Article 6(1)(f) of the GDPR and section 11(1)(f) of the Protection of Personal Information Act, as amended, as TCS RUD has a legitimate interest in the storage of cookies to ensure an optimized service provided free of technical errors.
  9. Some cookies are necessary for technical reasons to enable the use of TCS RUD’S online service. With these cookies, TCS RUD gathers and stores the following data: Language settings; Search settings; Information to identify or authenticate the user; Data for smooth forwarding of audio or video content.Some functions can be provided only by using cookies. This concerns the search function and language settings, amongst other things.
  10. From this follows the TCS RUD’S justifiable interest for the legal basis for processing data by means of cookies in accordance with Article 6 (1)(f) of the GDPR and section 11(1)(f) of the Protection of Personal Information Act, as amended.
  11. Most web browsers are set up so that the data subject automatically accepts cookies. However, the data subject can deactivate cookie storage or set up its web browser so that it notifies the data as soon as cookies are sent. It is also possible to delete already stored cookies manually using the web browser settings.
  12. Data subjects may object to processing in this manner or may prevent the processing entirely via their internet settings.

However, TCS RUD hereby provides notification that the data subject may only have access to a restricted version of TCS RUD’S website, or not at all, if the data subject rejects the storage of cookies or deletes the necessary cookies.

USE OF SOCIAL MEDIA

  1. In TCS RUD’S online service, data subjects may find hyperlinks to the social media site LinkedIn.
  2. The hyperlink can be recognized by the provider’s respective logo.
  3. Clicking on the link will open the corresponding social media page, for which this privacy policy does not apply.
  4. Please check the relevant privacy policy of the individual provider for details on the applicable terms and conditions; these can be found under: LinkedIn: https://www.linkedin.com/legal/privacy-policy
  5. Before calling up the relevant hyperlinks, the data subject’s personal information is not transferred to the respective provider.
  6. Retargeting and remarketing” refer to technologies in which data subjects who have visited a certain website are shown similar and/or applicable advertisements even after having left the website. For this, it is required that data subjects acknowledge for what purpose the cookies of the corresponding service provider are used. Previous usage behaviour is also taken into account in this regard. services, these services, or similar services, could then be shown later as advertisements on other websites. This concerns personalized advertisements that are adapted to the needs of the individual data subject. For these personalized advertisements, it is not necessary for the data subject to be identified beyond initial recognition. The data used for retargeting or remarketing is therefore not combined with further data. uses these kinds of technologies to connect advertisements on the internet. relies on third-party providers to connect advertisements and TCS RUD uses Google services (Google AdWords Conversion and Google Remarketing) to this end.
  7. TCS RUD with information on the success of its advertisements.
  8. TCS RUD to track whether users respond to its advertisements placed on other websites by Google or its partners. If a user clicks on such an advertisement and is thus redirected to TCS RUD’S website, a cookie is stored on the data subject’s device. In addition, Google AdWords can identify which specific advertisement brought a data subject to TCS RUD’S website. data subjects. TCS RUD, however, has no influence on Google’s use of the data.
  9. TCS RUD uses the Google Remarketing advertising program in connection with personalized advertising on its website. With this program, you can be shown TCS RUD’S advertising and its products when using other websites after visiting TCS RUD’S website.
  10. TCS RUD’S website and place relevant advertisements for TCS RUD. (http://www.google.com/intl/de/policies/privacy; and https://services.google.com/sitestats/de.html.

WEBSITE PROTECTION

  1. TCS RUD’S website uses SSL (Secure Sockets Layer) encryption for security reasons and for the protection of the transmission of confidential content. This information could be anything sensitive or personal which can include financial information, names and addresses, including the inquiries data subject’s send to TCS RUD as the site operator.
  2. Data subjects can recognize an encrypted connection in their browser’s address bar when it changes from “http://” to “https://” and the system-specific lock icon is displayed in your browser’s address bar.
  3. If SSL encryption is activated, the data you transmit to TCS RUD cannot be read by third parties.

STORAGE OF PERSONAL INFORMATION

  1. TCS RUD undertakes to secure the integrity and confidentiality of the personal information that is in its possession and under its control, by taking the appropriate reasonable technical and organisational measures to prevent loss, damage, unauthorised destruction, unlawful access, or unlawful processing of thepersonal information of data subjects. In doing so, TCS RUDshall have due regard to generally accepted applicable or industry information security practices and procedures.
  2. All information stored by TCS RUD, is stored in compliance with the Protection of Personal Information Act No. 4 of 2013 (as amended from time to time), as well as the GDPR.
  3. Unless stated otherwise in this Policy, TCS RUD, or its hosting providers, will store the personal information of data subjects on specially secured servers.
  4. The storage thereof is a technical and organizational measure employed by TCS RUD to protect against loss, destruction, access, alteration or dissemination of your data by unauthorized persons.
  5. Only authorized persons are able to access the personal information of data subjects. These individuals are responsible for the technical, commercial and editorial supervision of the server. Despite regular inspections, complete protection against all risks is not possible and TCS RUD in no way guarantees complete protection in this regard.
  6. TCS RUD undertakes to delete the personal data of a data subject when the purpose for the storage thereof is fulfilled.
  7. However, storage may also take place if this is designated by legal provisions to which TCS RUD is subject, for example in terms of statutory retention periods and documentation obligations.
  8. In a case such as this, TCS RUD will delete or block the data subject’s personal information following expiry of the relevant retention period.

REQUESTS FOR CONSENT TO PROCESS PERSONAL INFORMATION FOR PURPOSES OF DIRECT MARKETING BY ELECTRONIC COMMUNICATION

  1. Where TCS RUD wishes to process the data subject’s personal information for the purpose of direct marketing by electronic communication it will in terms of section 69(2) of the Act provide the data subject with a request for written consent in a form similar to Form 4 of the Regulations Relating to the Protection of Personal Information, which form may be accessed at – http://www.justice.gov.za/inforeg/docs/20181214-gg42110-rg10897-gon1383-POPIregister.pdf.

THE RIGHT OF ACCESS TO AND THE RIGHT TO RECTIFY, delete or block THE INFORMATION COLLECTED by TCS RUD

  1. In terms of the Protection of Personal Information Act, data subjectshave the following options available in respect of its personal information that TCS RUDprocesses: it may inquire, at no cost, whether TCS RUDholds its personal information, as long as it provides TCS RUD with adequate proof of its identity; where necessary, request the correction, destruction or deletion of its personal information, as per clause 15.12.1 above; object to, in terms of clause 16.6.1 below, restrict or limit the processing of its personal information; object to the TCS RUD utilising personal information for purposes of direct marketing, in terms of clause 16.6.1 below; request that its personal information not be used to send unsolicited emails.
  2. Data subjects are entitled to exercise any of its rights listed above by sending an email to TCS RUD. Data subjects are advised that the rights detailed above are not absolute, and TCS RUDmay be entitled to refuse requests, where exceptions apply. Should TCS RUDdetermine that a data subjectis not entitled to exercise a specific right, TCS RUD will provide it with the reasons in respect thereof.
  3. TCS RUD hereby provides notification that a data subject who may prove their identity has the right to request confirmation from TCS RUD, free of charge, as to whether it holds personal information on that data subject.
  4. Where TCS RUDhas reasonable doubt as to the identity of the person making an enquiry, it may request additional information in order to confirm the identity of the person, such as an identity document, including a driver’s licence or passport.
  5. Should TCS RUD hold personal information in respect of a data subject, TCS RUD hereby notifies the data subject further that the data subject may request the record or a description of the personal information about the data subject held by TCS RUD, including information about the identity of all third parties, or categories of third parties, who have, or have had, access to the information.
  6. Should a data subject require the direct transfer of personal information to another responsible party/controller, TCS RUD will only do so where such transfer is technically feasible and does not carry with it an excessive expense.
  7. In response to any requests for records or descriptions of personal information about the data subject, TCS RUD undertakes to deliver its response within a reasonable time and in a manner and form which is understandable.
  8. TCS RUD reserves its rights to charge a fee, in accordance with the prescribed tariff, for the delivery of records or descriptions of personal information and will provide the data subject with a written estimate of such fee, prior to delivery of the record and/or description.
  9. Although the data subject has a right to request access to personal information from TCS RUD, in certain instances, TCS RUD is obliged to refuse access to personal information based on the grounds contained in the provisions of Chapter 4 of Part 2 and Chapter 4 of Part 3 of the Promotion of Access to Information Act 2 of 2000, as amended.
  10. In the event that a particular ground of refusal applies, TCS RUD will not provide the data subject access to such personal information.
  11. Should personal information be disclosed to the data subject in response to any requests as aforesaid, the data subject is hereby notified of its right to request correction, deletion and/or blocking of the personal information, in line with section 24 of the Protection of Personal Information Act 4 of 2013, as amended.
  12. In terms of the Regulations Relating to the Protection of Personal Information: http://www.justice.gov.za/inforeg/docs/20181214-gg42110-rg10897-gon1383-POPIregister.pdf).
  13. TCS RUD, or a designated person, must render such reasonable assistance, as may be necessary and free of charge, to enable a data subject to complete Form 2.
  14. Please feel free to contact TCS RUD at any time should the data subject have any further questions in respect of personal information.

Complaints

  1. Should data subjectshave any concerns regarding or relating to TCS RUD’Sprivacy policy it may submit an email to TCS RUD. TCS RUDwill review the data subject’s concerns and attempt to resolve any complaint in accordance with this Policy and applicable law.
  2. If a data subject believes that the processing of the data subject’s personal data by TCS RUD is not in line with this Policy or the applicable data protection requirements, data subjects can complain to TCS RUD’S data protection officer.
  3. The data protection officer will then review the matter and inform the data subject of the result of the review.
  4. Furthermore, data subjects also have the right to complain to the relevant Regulatory Authority.
  5. Should data subjects have reasonable grounds to believe that their personal information has been accessed or acquired by any unauthorised person, they shall notify TCS RUD in writing of such belief, and grounds upon which such belief is based, without delay.
  6. Upon notification, TCS RUD shall, as soon as is reasonably possible and lawfully required, notify the applicable regulator/s, as well as the data subject, unless it is unable to ascertain the personal information that has been unlawfully accessed.

RIGHT TO LODGE A COMPLAINT TO THE COMPETANT REGULATORY AUTHORITIES

  1. Data subjects may submit a complaint to the Regulator in the prescribed manner and form, alleging interference with the protection of the personal information of a data subject.
  2. In terms of the Regulations Relating to the Protection of Personal Information, any person who wishes to submit a complaint must submit such a complaint to the Information Regulator on Part I of Form 5.
  3. The Form 5 document may be accessed at http://www.justice.gov.za/inforeg/docs/20181214-gg42110-rg10897-gon1383-POPIregister.pdf.
  4. The available contact details of the Information Regulator are recorded as follows: Address: 33 Hoofd Street, Forum III, 3rd Floor Braampark, Braamfontein, Johannesburg; Email: inforeg@justice.gov.za.

Data Protection Information Officer

TCS RUD’S data protection/Information officer and their team are available for questions related to TCS RUD’S handling of personal information or more information on issues relating to data protection and may be contacted using the details provided below:

  1. Address: 10 Danie Theron Street, Fochville, South Africa, 2515
  2. Email: info@tcsrud.com