Trail Digital

PRIVACY POLICY

  • Definitions

Unless otherwise defined below or the context indicates otherwise, capitalised terms in this Privacy Policy bear the meaning ascribed thereto in Trail Digital’s PAIA Manual and Terms of Website Use. Click here to review Trail Digital’s PAIA Manual and Terms of Website Use:

  1. “aggregate information” is the collective, consolidated information of users of the website that is pooled together and where users are only identified as part of the pool in general terms and are not identified individually;
  2. “data subject” shall have the meaning ascribed to it in Chapter 1 of POPIA;.
  3. “personal information” shall have the meaning ascribed to it in Chapter 1 of POPIA; 
  4. “process information” means the automated or manual activity of collecting, recording, organising, storing, updating, distributing and removing or deleting personal information.

  • Introduction

      1. We respect your privacy and personal information and are committed to collecting and processing same in accordance with POPIA. 
      2. This privacy policy (“privacy policy”), as amended by us from time to time, sets out the basis on which we may process material and information obtained from you when rendering the services.
  • Privacy Terms

    1. You agree that we may keep your personal information until such time as we are compelled or requested by you to delete it. Where we cannot delete your personal information, we will take all steps to de-identify (anonymise) the data. In some cases, we may use cookies and other tracking technologies to collect personal information, or to collect information that becomes personal information if we combine it with other information. This enables us to improve your future visits to our website.
    2. By making use of our website and/or services you consent to and indicate your acceptance of, the following terms:
      1. Collection of information
        1. The following information may be collected:
          1. information provided by you when completing our client on-boarding process (including your name, contact details, financial information as well as other necessary information), filling in electronic e-forms, completing surveys or competitions, submitting material or requesting further information;
          2. general material and information supplied may be used for marketing purposes; and
          3. information collected directly from you or from third parties (such as regulators, government authorities and registries).
      2. Usage of information
        1. The material and information provided to us per the above will be used as follows:
          1. to administer and manage our systems, websites and mobile applications; 
          2. to contact you in relation to our current and/or new services, including to inform you of new features, special offers and promotional competitions, etc.;
          3. to enter into, or carry out any obligations arising from, any agreements with you;
          4. to improve our current service offerings;
          5. for our business administration purposes, including fulfilling any regulatory, industry and/or legal requirements/obligations such as to make sure that our records are accurate and up to date;
          6. to analyse, assess and improve our business and/or services;
          7. recruitment and/or career advancement processes;
          8. to provide you with information and/or services; 
          9. personalise your experience and to communicate with you about our services and offerings;
          10. to reply to any of your queries;
          11. to assist us in any future dealings with you;
          12. to achieve a legitimate purpose and our reasons for using your personal information outweigh any prejudice to your personal information rights;
          13. to defend, prosecute or make a claim against you, us or a third party; and
          14. where you have consented to our use of your information or be contacted by us, including for purposes of providing you with content to which you have subscribed or information and/or services which we opinion may be of interest to you (which consent may be withdrawn through unsubscribing or similar action at any time).
        2. We endeavour to collect and process only your personal information which is necessary for the intended purpose of the collection and processing. 
        3. You agree that we may keep your Personal Information until such time as it is necessary to achieve the purpose for which we collected/processed it, unless there is a lawful basis or requirement to retain same for a longer period or you requested us to delete it. Where we cannot delete your personal information, we will take all steps to de-identify (anonymise) the data. In some cases, we may use cookies and other tracking technologies to collect personal information, or to collect information that becomes personal information if we combine it with other information. This enables us to improve your future visits to our website.
        4. If you include the personal information of other data subjects when engaging with us, we will also process their personal information for the purposes set out in this privacy policy. When you give us personal information about other data subjects, you confirm that you have received their permission to share their personal information with us for the purposes set out in this privacy policy or any other related purposes.
      3. Disclosing or sharing of information
        1. We will be entitled to disclose your personal information:
          1. where we have a duty or a right to disclose in terms of law, industry codes or a court order; and
          2. where we believe it is necessary to protect our rights,


to our affiliates, agents, advisors, bankers, auditors, brokers, employees and/or third-party service providers and suppliers and to government regulatory or law enforcement agencies, who assist us in our interactions with you and thus need to know your personal information to assist us in communicating with you, and in connection with enquiries, proceedings or investigations by such parties.

  1. We will take necessary steps to ensure that all such persons are bound by confidentiality and/or non-disclosure obligations in relation to your personal information.
  2. We will not sell or rent your personal information to third parties. Subject to the remainder of this clause 3, the only information about users we will ever disclose to third parties is aggregate information as defined above.
  3. Rest assured that our third-party service providers may not process your personal information for any purpose other than providing services on our behalf.
  1. Transfer of information
    1. Your personal information that we collect may have to be transferred to, and stored at, a destination outside of South Africa, where we have facilities or in which we engage third-party service providers. 
    2. Insofar as this may occur, we will take reasonable measures to ensure that a) your personal information is processed only for the purposes of which it has been provided to us and b) is protected appropriately (e.g., the required levels of protection have been implemented by a receiving party to safeguard your personal information) and in terms of applicable laws. 
    3. By using our website, you understand and agree that your information may be transferred to countries outside of your country of residence and which may have protection of personal information rules that are different from those of your country.
    4. In certain situations, courts, law enforcement agencies, regulatory or security authorities in those other countries may be permitted to access your personal information.
  2. Security of information

No data transmission via the internet can be completely secure. We implement a range of commercially reasonable physical, technical and procedural measures to prevent unauthorised access to your personal information. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to us via electronic means. Any such transmission is at your own risk.

  1. Update

We reserve the right to amend this privacy document from time to time without prior notice to you. The latest version of same will be made available on our website. 

  • How to contact us

If you have any questions regarding our collection and processing of your personal information, wish to withdraw consent, exercise preferences or access, correct and/or update your personal information, please contact us at the number/addresses listed on our website.

  • Complaints

    1. Should you believe that we have utilised your personal information contrary to this privacy policy or any applicable laws, you undertake to first attempt to resolve any concerns with us.
    2. Please do this by contacting us at the number/addresses listed on our website.
    3. You have the right to lodge a complaint with the Information Regulator on the below contact details should you not be satisfied with the outcome of the aforesaid resolution process: