As a trusted guardian of customer personal information, Smartcall is committed to processing personal information honestly, ethically, with integrity, and always consistent with applicable laws and our privacy commitments.

Your privacy is important to us – just as knowing how we use your information is important to you. This Smartcall Privacy Policy gives you access to how we collect, use, share and protect your personal information based on your interactions with Smartcall, our products and services that you use or subscribe to and how you make use of these products and services.

Smartcall Privacy Policy:

1. Purpose
Smartcall respects the privacy of individuals whose personal information it processes and is committed to processing personal information lawfully, responsibly and transparently.
This Privacy Policy explains how Smartcall collects, uses, stores, protects and discloses personal information and describes the rights available to individuals in relation to their personal information. Smartcall is committed to complying with the Protection of Personal Information Act, 4 of 2013 (POPIA) and other applicable privacy and data protection requirements.
This Policy also supports Smartcall’s information security management framework and its commitment to protecting information against unauthorised access, use, disclosure, alteration, loss or destruction.

2. Scope
This Privacy Policy applies to personal information processed by Smartcall in connection with:
•  our customers and prospective customers;
•  suppliers, service providers and business partners;
•  employees, contractors and other personnel;
•  individuals who communicate with us;
•  users of our websites, systems and online services; and
•  other individuals whose personal information Smartcall processes in the course of its business activities.
This Policy applies whether personal information is collected directly from the individual or obtained from another lawful source.
Where Smartcall processes personal information on behalf of a customer or other organisation, that processing may be governed by the terms of the applicable agreement and the instructions of that organisation.

3. What is Personal Information?
For the purposes of this Policy, personal information has the meaning given to it in POPIA.
Depending on the nature of our relationship with an individual, personal information may include:
•  name and contact details;
•  identification or account information;
•  business and employment information;
•  information contained in correspondence and communications with us;
•  information relating to services provided to or used by an individual;
•  billing and payment information;
•  information required to authenticate or secure access to systems and services;
•  information relating to use of our websites, systems or services;
•  photographs or other information captured at our premises or events, where applicable; and
•  other information reasonably required for legitimate business, contractual or legal purposes.
Smartcall will only collect personal information that is reasonably necessary for an identified and lawful purpose.

4. How We Collect Personal Information
Smartcall may collect personal information:
•  directly from the individual;
•  when an individual or organisation requests or uses our services;
•  when an individual communicates with us by telephone, email, website, support system or other communication channel;
•  when entering into or administering a contractual relationship;
•  through our websites and online services;
•  from authorised representatives of customers or suppliers;
•  from third parties where there is a lawful basis for doing so; or
•  from publicly available sources where permitted by law.
Where reasonably practicable, Smartcall will collect personal information directly from the individual to whom it relates.
Where personal information is obtained from another source, Smartcall will take reasonable steps to ensure that the information is obtained lawfully and is appropriate for the intended purpose.

5. Why We Process Personal Information
Smartcall processes personal information only for specific, lawful purposes connected with our business activities.
Depending on the circumstances, these purposes may include:
5.1 Providing and managing services
We may process personal information to:
•  provide products and services;
•  manage customer and supplier relationships;
•  provide technical or other support;
•  communicate with customers and users;
•  administer accounts and agreements; and
•  maintain appropriate records relating to our services.

5.2 Business administration
We may process personal information to:
•  manage billing, payments and financial records;
•  administer contracts;
•  maintain business records;
•  communicate with customers, suppliers and other stakeholders;
•  manage enquiries and requests; and
•  perform general administrative and operational activities.

5.3 Information security
We may process personal information where necessary to:
•  protect our information and technology environments;
•  authenticate users and manage access;
•  monitor and investigate security events;
•  detect, prevent and respond to fraud, misuse or unauthorised activity;
•  investigate suspected security incidents; and
•  maintain the security, availability and integrity of our systems and services.

5.4 Legal and regulatory requirements
We may process personal information where necessary to:
•  comply with applicable legislation or regulatory requirements;
•  respond to lawful requests from public authorities;
•  establish, exercise or defend legal rights or claims; and
•  maintain records required by law.

5.5 Improving our services
Where appropriate and lawful, we may use information to understand how our services and systems are used, identify areas for improvement, troubleshoot issues and improve the quality, security and effectiveness of our services.
Where information can reasonably be used in aggregated, anonymised or de-identified form, Smartcall will seek to use it in that form.

5.6 Marketing
Smartcall may use personal information for direct marketing where permitted by applicable law.
Where consent is required, Smartcall will obtain the required consent before sending direct marketing communications.
Individuals may opt out of direct marketing communications at any time by using the unsubscribe mechanism provided or by contacting Smartcall using the details in the PAIA Manual.
Opting out of marketing communications does not prevent Smartcall from sending necessary service, contractual, security or administrative communications.

6. Lawful Processing
Smartcall processes personal information in accordance with the conditions for lawful processing established by POPIA.
Depending on the circumstances, processing may be based on:
•  the individual’s consent;
•  the performance of a contract or steps taken at the individual’s request before entering into a contract;
•  compliance with a legal obligation;
•  protecting a legitimate interest;
•  pursuing legitimate interests of Smartcall or another party, where permitted by law; or
•  another lawful basis recognised by applicable legislation.
Where consent is used as the basis for processing, the individual may withdraw that consent, subject to any legal or contractual limitations and the consequences of doing so.
Where personal information is necessary for Smartcall to provide a particular service or comply with a legal obligation, failure to provide the required information may affect Smartcall’s ability to provide that service or fulfil that obligation.

7. Accuracy of Personal Information
Smartcall takes reasonably practicable steps to ensure that personal information in its possession or under its control is:
•  complete;
•  accurate;
•  not misleading; and
•  updated where necessary.
Individuals are encouraged to notify Smartcall where their personal information changes or where they believe information held by Smartcall is inaccurate.

8. Sharing Personal Information
Smartcall may disclose personal information where reasonably necessary for legitimate business purposes and where permitted by applicable law.
Recipients may include:
•  employees and authorised personnel who require access to perform their responsibilities;
•  service providers and contractors who provide services to Smartcall;
•  technology and hosting providers;
•  professional advisers;
•  auditors and other assurance providers;
•  financial institutions and payment service providers, where applicable;
•  customers or authorised representatives where necessary to provide contracted services;
•  regulatory authorities, law enforcement agencies or other public bodies where required or authorised by law; and
•  other parties where the individual has consented or where disclosure is otherwise lawful.
Smartcall does not sell personal information.
Where a third party processes personal information on behalf of Smartcall, Smartcall will take reasonable steps to ensure that appropriate contractual and security requirements are in place and that the third party processes the information only for authorised purposes.

9. Personal Information Processed on Behalf of Customers
Smartcall may process personal information on behalf of customers in providing IT, technology, support, security or other services.
In such circumstances, Smartcall will process personal information in accordance with the applicable contractual requirements and the lawful instructions of the responsible party.
Where applicable, Smartcall will implement appropriate confidentiality, security and processing requirements for personal information entrusted to it by customers.
Individuals who wish to exercise rights relating to personal information processed by Smartcall on behalf of another organisation may, depending on the circumstances, need to direct their request to that organisation as the responsible party.

10. Special Personal Information and Children
Smartcall recognises that POPIA provides additional protection for certain categories of personal information and for personal information relating to children.
Smartcall will only process special personal information or personal information relating to children where permitted by applicable law and where appropriate safeguards are in place.

11. Information Security
Smartcall implements appropriate technical and organisational measures designed to protect personal information against:
•  unauthorised access;
•  unauthorised use;
•  unlawful disclosure;
•  accidental or unlawful loss;
•  alteration or destruction; and
•  other forms of unauthorised or inappropriate processing.
Security measures are proportionate to the nature of the information, the processing activities and the risks involved.
Access to personal information is restricted to authorised persons who require access for legitimate business purposes.
Smartcall maintains information security policies, procedures and controls as part of its information security management framework.

12. Security Incidents and Personal Information Compromises
Smartcall maintains processes for identifying, assessing, managing and responding to information security incidents.
Where a security compromise involves personal information, Smartcall will assess the incident and take appropriate action in accordance with applicable legislation and Smartcall’s incident management processes.
Where POPIA or another applicable law requires notification of a security compromise, Smartcall will notify the Information Regulator and affected data subjects as required by law.

13. Retention of Personal Information
Smartcall retains personal information only for as long as reasonably necessary for the purpose for which it was collected or processed, or where retention is required or permitted by law.
Retention periods may also be determined by:
•  contractual requirements;
•  legitimate business requirements;
•  legal or regulatory obligations;
•  dispute resolution or legal proceedings; or
•  other lawful purposes.
Smartcall maintains appropriate retention and disposal requirements for information under its control.
When personal information is no longer required, it will be securely deleted, destroyed, anonymised or otherwise disposed of in accordance with applicable requirements.

14. International Transfers
Where Smartcall transfers personal information outside South Africa, Smartcall will take appropriate steps to ensure that the transfer is lawful and that the personal information receives an appropriate level of protection in accordance with POPIA and other applicable legislation.
Where required, Smartcall will implement appropriate contractual, organisational or other safeguards for international transfers.

15. Cookies and Website Technologies
Smartcall may use cookies and similar technologies on its websites and online services.
Cookies may be used for purposes such as:
•  enabling essential website functionality;
•  remembering preferences;
•  maintaining sessions;
•  understanding website usage; and
•  improving website performance and user experience.
Where applicable, non-essential cookies will be managed in accordance with applicable legal requirements.

16. Data Subject Rights
Subject to applicable law and any relevant limitations, individuals may have rights in relation to their personal information, including the right to:
•  request access to personal information held by Smartcall;
•  request correction or updating of inaccurate or incomplete information;
•  object to certain processing;
•  object to direct marketing;
•  withdraw consent where processing is based on consent;
•  request deletion or removal of personal information where applicable;
•  request restriction of processing in circumstances permitted by law; and
•  lodge a complaint regarding the processing of their personal information.
Requests should be submitted to the Smartcall Information Officer using the contact details in the PAIA Manual.
Smartcall may take reasonable steps to verify the identity of a requester before releasing, correcting or otherwise acting on personal information.
Certain requests may be refused or limited where permitted or required by law.

17. Information Officer and Privacy Enquiries
Smartcall has appointed an Information Officer in accordance with applicable information and privacy legislation.
Requests or enquiries relating to personal information, privacy rights or the processing of personal information may be directed to Smartcall’s Information Officer using the contact details provided in the Smartcall PAIA Manual.
The Smartcall PAIA Manual also provides information on how to request access to records held by Smartcall in terms of the Promotion of Access to Information Act.

18. Complaints
Smartcall encourages individuals to raise privacy concerns with Smartcall in the first instance so that the matter can be investigated and resolved where possible.
Privacy-related complaints may be submitted to the Information Officer using the contact details in the Smartcall PAIA Manual.
An individual also has the right to lodge a complaint with the Information Regulator of South Africa where permitted by applicable law.
Current contact details for the Information Regulator are available through its official website.

19. Changes to this Policy
Smartcall may update this Privacy Policy from time to time to reflect changes in our business activities, technology, legal requirements or privacy practices.
The current version will be made available through the appropriate Smartcall communication or website channels.
Material changes will be communicated where reasonably appropriate.
The effective date and version of the current Policy are shown at the beginning of this document.

20. Further Information
Further information regarding access to records held by Smartcall is available in the Smartcall PAIA Manual.

21. Review and Approval
This Policy is a controlled document and will be reviewed periodically and when significant changes occur to:
•  applicable legislation or regulatory requirements;
•  Smartcall’s business activities;
•  information processing activities;
•  information security risks; or
•  relevant technology or services.
Changes to this Policy are subject to Smartcall’s document governance and approval requirements.

Access Information:
To ensure exceptional customer service and convenience for our customers, Smartcall provides you with a number of channels to access information and to further exercise your rights.

Exercising your rights:
You have various rights in relation to your personal information. In the ‘Your Rights’ section of our privacy statement, we’ve provided the pertinent information and instructions on what to do if you wish to exercise any of your rights. Below are some links that may help you to exercise these rights relating to your personal information:
Contact us: Our customer services team will gladly assist you with queries, including how to manage your marketing preferences. Contact us on 011 507 4789 or support@smartcall.co.za.
Privacy queries: Our privacy statement was created to ensure transparency on the collection, sharing and protection of your personal information. If you are unable to find an answer to any of your privacy questions, or if you’d like to contact our Privacy Officer, please click on the Privacy queries link.
Data and voice usage request form: To request your URL or data usage information, please fill the relevant form under the access to information tab, and submit with all the documents as requested.
General Data Protection Regulation (GDPR): The rights under this section also cover the rights guaranteed under the GDPR. You can exercise the rights that are conferred to you under GDPR by sending a request to our customer service team who will gladly be able to assist you.

Our Cookies Policy:
This section is about what cookies are, how we use them and how you can manage them.

What are Cookies:
A cookie is a small text file that can be stored on and accessed from your device when you visit one of our websites. Cookies are used to collect information that makes the website remember you and tells us how you use our website, web-related products and services. This, in turn, helps us make our website relevant to your interests and needs. They also help us find information once you have logged in or help us link your browsing information to you and your personal information, for example, when you choose to register for a service. We may use a persistent cookie (a cookie that stays linked to your browser) to record your details so we can recognise you if you visit our website again. If you choose not to accept cookies from our website this may limit its functionalities or performance.
You can set your browser to block different types of cookies. Some of the more popular browsers are:
•  Internet Explorer
•  Firefox
•  Safari
•  Google Chrome
If you choose not to accept certain cookies from our website this may limit its functionalities or performance. You can find more information about cookies at www.aboutcookies.org or www.allaobutcookies.org (please note that these links open a new window or browser tab).

How we use Cookies:
We use cookies for a number of reasons, for example, remembering your preferences, recording what you have put in your shopping basket, or counting the number of people visiting our website. We might also use cookies to keep track of what you have bought from us, what you have done on the website and to make online offers and promotions more relevant to you.
Cookies themselves do not hold Personal Information nor do they pose danger to your device. They only have a unique alphanumerical identifier that is stored on your device. However, the information can be considered Personal Information as defined under PoPIA, when used as part of certain activities. For example, cookies can help us to find information once you’re logged in or help us link your browsing information to you and your personal information, for example, when you choose to register for a service, white paper or newsletter.
Cookies have a unique alphanumeric identifier that sits on your browser. In many cases, we won’t be able to link the information we collect by using a cookie back to you. They can, however, enable us to link that information back to you and your personal information, for instance, when you log in or choose to register for a service, white paper or newsletter. For example, we may use web analytics to determine which ISP your IP address uses for browsing which can then be used to personalise the communications you receive from us (if you are opted in to receiving personalised communications). For further information on how we use your information please see our Privacy Policy.
We have categorised our cookies into the following categories:
1.  Strictly necessary – these are used to help make our website work efficiently.
2.  Performance – these are used to analyse the way our website works and how we can improve it.
3.  Functionality – this help to enhance your experience by doing things like remembering products you’ve added to your basket.
4.  Targeting/advertising – these are used to share some information with third parties who we advertise with, so we know how you’ve reached our website and to be able to reconcile at an aggregate level with our affiliate partners. We can also use cookies to identify the parts of the website that you are interested in. We then use this information to show you adverts and pages we think may also be of interest to you, to tailor how we communicate with you, or to tailor the contents of the communications we send to you. If you prefer, you can manage your cookies on our website. Tailoring of content means it includes information reflecting the interest you’ve shown in the content of our web pages, or offers or promotions that we think may interest you, and to improve how we respond to your needs.
Sometimes, other companies will add a cookie on our website to show you adverts and pages which may be of interest to you. Details on these, and how to opt-out if you prefer, can be found in the ‘Third-party cookies’ section of this cookies policy
In addition to the cookies we use on our website, we also use cookies and similar technologies in some emails and push notifications we send to mobile devices from our apps. These help us to understand whether you have opened the email and how you have interacted with it. If you have enabled images, cookies may be set on your computer or mobile device. Cookies will also be set if you click on any link within an email.

Cookies and you
We use cookies to enable certain online functionalities, for example, so you can make a purchase online or sign up for services.
If you choose not to enable cookies, you will still be able to browse our website, but it will restrict some of the functionality or performance of our website and what you can do.

What type of Cookies do we use:
First-Party Cookies:
First-party cookies are cookies issued from the smartcall.co.za domain that are generally used to identify language and location preferences or render basic website functionality.

Third-Party Cookies:
Third-party cookies originate from a domain that’s different to the website being visited. For example, when you visit our website, we may link to another company’s website – like our Facebook or Twitter account, or a video from our YouTube page. We don’t control how they use their cookies, so we suggest you check their website to see how they’re using them and how you can manage them.

Session Cookies:
Session cookies are temporary cookies that are used to remember you during the course of your visit to the website, and they expire when you close the web browser.

Persistent Cookies:
Persistent cookies are used to remember your preferences within the website and remain on your desktop or mobile device even after you close your browser or restart your device. We might use some of these cookies to analyse user behavior to establish visit patterns so that we can improve our website functionality for you and others who visit our website(s). These cookies also allow us to serve you with targeted offers and promotions and measure the effectiveness of our website functionality and offer and/or promotions.

Controlling your Cookies:
You can opt-in or out of cookies – except strictly necessary cookies (these are used to help make our website work efficiently) at any time by clicking the cookie settings button (below) to control your cookies. You can select by category or individual cookie.
Go to Cookie Settings
Alternatively, you can enable or disable cookies in your browser. If you wish to restrict or block the cookies set by any website – including a Smartcall website – you can do this through the web browser settings for each web browser you use, on each device you use to access the internet.
Information on controlling and deleting cookies, including on a wide variety of browsers, is also available at allaboutcookies.org
In this Policy under the heading ‘What are Cookies’, we have also provided a few links for some of the more popular browsers – but check your particular browser and device for correct and up-to-date information.
Some services – Smartcall, for example – may not function or may have more limited functionality if your web browser blocks all cookies, including functional cookies. However, you can allow cookies from specific websites by making them “trusted websites” in your web browser.
If you don’t wish to accept cookies from one of our emails, you can choose not to download any images or click on any links. You can also set your browser to restrict cookies or to reject them entirely. These settings will apply to all cookies, whether included on websites or in emails. Depending on your email or browser settings, cookies in an email may sometimes be automatically accepted (for example, when you’ve added an email address to your address book or safe senders list). For more information, refer to your email browser or device instructions.