Privacy Policy

PRIMU INFOTECH (PTY) Ltd
Reg: 2017/507623/07

INTRODUCTION

This Privacy Policy (“Policy”) governs the processing of Personal Information by Prim-U (“We”, “Us”, “Our”, “Ourselves”) in accordance with the Protection of Personal Information Act, 2013 (“the POPIA”) and this Policy. Your use of the Prim-U Website, https://www.prim-u.com (“the Website”) and the Prim-U Apps, https://www.prim-u.com/app/en and https://admin.primu.app/en/page/login (“the Prim-U Platform”) is subject to this Policy. By using the Website and the Prim-U Platform You signify Your consent to the processing of Your Personal Information in accordance with this Privacy Policy. Accordingly, We encourage You to read this Policy carefully and contact Us with any questions or concerns in regard to Our Privacy practices.

We are committed to the principle of accountability in maintaining the privacy of Personal Information that You provide to Us when using the Website and the Prim-U Platform as well as ensuring transparency between Ourselves and Yourself. This Privacy Policy describes how We treat Personal Information collected or received from You when You visit and engage with the Website and the Prim-U Platform.

1. DEFINITIONS

In this Policy the following definitions shall apply:

  • “Booking/s” shall mean the securing of Prim-U services by placing an order on the PrimU Platform;
  • “Merchant” shall mean any person, an Organisation or Entity that make use of or accesses the Prim-U Platform and/or Prim-U Services for the purposes of providing services or hiring a Prim-Lancer to provide services on its behalf;
  • “Customer” shall mean any individual in their personal capacity or on behalf of any organisation that makes use of or accesses the Prim-U Platform and/or Prim-U Services for the purposes of hiring a Prim-lancer to provide beauty and wellness services;
  • “Personal Information” shall mean any information relating to an identified or identifiable natural or juristic person (‘data subject’); an identifiable natural or juristic person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • “Prim-lancer” shall mean any natural or juristic person offering and providing beauty and wellness therapy services through the Prim-U Platform;
  • “Prim-U” shall mean the business owned by Prim-U Infotech (Pty) Ltd (Registration Number: 2017/507623/07), a private company domiciled in South Africa.
  • “Prim-U Platform” shall mean the online platform through which Prim-U Services are provided – accessible at https://www.prim-u.com/app/en ;
  • “Prim-U Service/s” shall refer to the on-demand platform for the empowerment of beauty and wellness entrepreneurs by connecting them online, anytime and anywhere with Customers, offering flexible and convenient services.
  • “Special Personal Information” shall mean any information relating to the race or ethnic origin, health or sex life of an identified or identifiable natural or juristic person (‘data subject’); an identifiable natural or juristic person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • “User/s” shall mean any natural or juristic persons who make use of or access the PrimU Platform and/or Prim-U Services;

2. PERSONAL INFORMATION

2.1 Purpose of Collection and Processing

We primarily collect and process Your Personal Information to provide the Prim-U Services You requested from Us by using the Website and the Prim-U Platform. This includes collecting Personal Information about You both for Our internal purposes as described in this Policy and for the Prim-U Services.

2.1.1 General additional purposes may include:

  • for research and analysis in relation to Our business and Prim-U Services, including but not limited to trends and preferences in sales and other related metrics as well as use of the Prim-U Platform;
  • internal accounting and administration;
  • to comply with Our legal obligations;
  • other purposes as authorised or required by law (e.g. to prevent a threat to life, health or safety, or to enforce Our legal rights).
  • servicing Our relationship with You by, among other things, creating and maintaining a profile to enable Us to service You better or presenting options on the Prim-U Platform that We think may interest You based on Your location, browsing and preferences;
  • we may use tracking technologies to collect information such as your activity or the information You request. This information collected is kept confidential. The use of tracking technologies enables us to keep track of services You use so that we may provide You with further information.
  • to communicate with the You;
  • to create and administer Your account;
  • to send SMS, email alerts and to engage in legitimate electronic communications and transactions with You;
  • to verify Your identity;
  • to process and respond to any complaint made by You;
  • to provide feedback on any related enquiries;

2.1.2. Additional purposes for the Prim-lancer may include:

  • making reservations and providing sales and support;
  • identification of fraud or error;
  • regulatory reporting and compliance;
  • developing and improving Our products and Prim-U Services;
  • involving You in market research, gauging customer satisfaction and seeking feedback regarding Our relationship with You and/or the quality of service We have provided;

2.1.3. Additional purposes for the Customer may include:

  • to facilitate Your participation in loyalty programs;
  • In some instances, Prim-U may also collect Special Personal Information about Users, such as information about their racial or ethnic origin, or information regarding children, for the purposes of providing personal individual Prim-U Services. Consent is obtained for the collection of such information;
  • GPS tracking information is collected as You navigate through Our Website and Platform and use the Prim-U Services, including, but not limited to geographic areas. We collect this information in order to match You with an appropriate prim-lancer, and to dispatch that provider to You. We may also use that information for internal purposes, such as analysis of future prim-lancer needs in Your area, and like uses.

2.1.4. Additional purposes for the Merchant may include:

  • for research and analysis in relation to Our business and Prim-U Services, including but not limited to trends and preferences in sales and other travel-related metrics as well as use of the Prim-U Platform;

2.2. Collection: What and How?

WHAT: We collect Personal Information relating to You – such as Your name, email address, location and business address if You are a Merchant, date of birth or information regarding child, in Your capacity as a User and qualifications in Your capacity as a Primlancer. We may also collect other information, such as Your IP address, search terms, and site pages You visit whilst on the Prim-U Platform, whenever You visit the Website, the Prim-U Platform or view Our online advertisements. The technologies We use for this automatic data collection may include cookies and log data. Except for the above, We do not collect any Personal Information unless You provide it voluntarily. Although You may make a Booking through the Prim-U Platform, We do not collect or store any of Your financial/card details. We also do not collect any Personal Information that You may provide to Third-Parties, such as payment gateways.

HOW: We collect Your Personal Information either directly or indirectly, including, without limitation: by using the Website, by using the Prim-U Platform; by having an account Us, by otherwise communicating via e-mail.

2.3. Accuracy

You agree that any and all Personal Information that You provide to Us or an applicable Third-Party such as payment gateways, is accurate. In the event that Your Personal Information contains any errors or inaccuracies, You agree to indemnify and hold Us, Our officers, directors, employees, agents, licensors, and members harmless from and against any claims, damages, actions and liabilities including without limitation, loss of profits, direct, indirect, incidental, special, consequential or punitive damages arising out of Our reliance on such Personal Information.

You must also let Us know immediately if You become aware that Your Personal Information has been provided to Us by another person without Your consent or if You did not obtain consent before providing another person’s Personal Information to Us.

2.4. Processing of Personal Information

The processing of Your Personal Information by Us shall include the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation, use; dissemination by means of transmission, distribution or making available in any other form; or merging, linking, as well as blocking, degradation, erasure or destruction of information.

We will only process Your Personal Information, where:

  • You have consented to such processing (which You may withdraw at any time, as detailed at section 3 (three) below);
  • The processing is necessary to provide the Prim-U Services to You in terms of Our contractual relationship with Yourself;
  • The processing is necessary for compliance with Our legal obligations; and/or
  • The processing is necessary for Our legitimate interests or those of any Third-Party recipients, such as customer relationship management, website hosting providers or email-hosting providers that receive Your Personal Information – as detailed in section 2.5 below.

2.5. Further Processing: Who Do We Share Your Personal Information With And Why?

We do not and will not sell, rent out or trade Your Personal Information. We will only share Your Personal Information to Third-Parties in the manner set out in this Policy and in accordance with the POPIA. Note that the term ‘share’ includes the act of ‘disclosing’; ‘transferring’; ‘sending’ or otherwise making Your Personal Information available or accessible to another person or entity

We may share Your Personal Information with one or several of Our Service-Providers, Prim-U Platform Partners or other Third-Parties (which include, but are not limited to include, email-hosting providers, website-hosting providers, customer relationship management (CRM) so that we may deliver You the Prim-U Services. Information processed on the Website and the Prim-U Platform will only be disclosed in accordance with the consent provided by Yourself.

Prim-U does not permit any of its Service-Providers, Prim-U Platform partners or other necessary Third-Parties to use Your Personal Information for any other purpose than to perform the services that Prim-U has instructed them to provide. All processing is compatible with such purpose. When We share Your Personal Information with Third-Party Operators, such Operators will be bound by contractual terms requiring them to treat Your Personal Information confidentially and to implement appropriate organisation and technical safeguards.

Other than the above, We will not disclose Your Personal Information without Your consent unless We reasonably believe that disclosure is necessary to lessen or prevent a threat to life, health or safety of an individual or to public health or safety or for certain action to be undertaken by an enforcement body (e.g. prevention, detection, investigation, prosecution or punishment of criminal offences), or where such disclosure is authorised or required by law (including the POPIA).

2.6. Consent for Processing Personal Information

By using Prim-U Services You hereby consent to Your Personal Information (including Special Personal Information) for the abovementioned purposes, associated purposes and to (a) update our records; (b) keep Your contact details up to date; (c) to comply with any law, rule, regulation, lawful and binding determination, decision or direction of the Information Regulator, or co-operate with any governmental authority.

By Using the Prim-U Services, You represent that You are of the age of 18 or where You are under 18, a Competent Person, as defined by the POPIA, has given consent to allow You to utilise the Prim-U Platform. This consent is effective on access of the Prim-U Platform.

You consent to the processing of Personal Information/Special Personal Information.

You understand that Your consent to the processing of Your Personal Information/Special Personal Information by Us pertains to the provision of information and the Prim-U Platform; as well as associated purposes.

You consent to the receipt of direct marketing communications regarding all Prim-U activities and news.

You expressly consent to Prim-U retaining Your Personal Information/Special Personal Information once Your relationship with Prim-U has been terminated and using the information for aggregate, statistical and reporting purposes.

3. YOUR RIGHTS:

You may choose what Personal Information (if any) You wish to provide to Us. You also have the right to withdraw Your consent. However, if You choose not to provide certain details, or withdraw Your consent, Your experience with some, or all of the Prim-U Services, may be affected. To the extent required by law, You have certain rights in respect of Your Personal Information. In particular, the POPIA provides You with the rights to:

  • Access, Update, Modify, Rectify, Erase or obtain a Copy of the Personal Information that We hold on You;
  • Object to the processing of Your Personal Information or Restrict or stop Us from using any of the Personal Information which We hold on You, including by withdrawing any consent You have previously given to the processing of such information.

These rights are not absolute, and We, therefore, reserve the right to refuse any requests in terms of the above-mentioned rights, for any reason permitted under applicable laws.

In the event that You wish to enforce any of the above rights, You can request this by emailing Us at the address set out in Section 7 below. We will endeavour to respond to Your requests as soon as operationally possible.

You also have the rights to:

  • lodge a complaint with the Information Regulator; and
  • exercise Your rights under the POPIA in respect of and against Us.

4. SECURITY OF INFORMATION

We are committed to safeguarding and protecting Your Personal Information and will implement and maintain appropriate technical and organisational measures to ensure a level of security appropriate to protect any Personal Information provided to Us from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Personal Information transmitted, stored or otherwise processed. We have implemented various physical, electronic and managerial security procedures in order to protect the Personal Information We hold from loss and misuse, and from unauthorised access, modification, disclosure and interference – such procedures are regularly reviewed.

We cannot be held responsible for any Third-Party’s actions or their security controls with respect to information that Third-Parties may collect or process via their websites, services or otherwise. We will destroy or de-identify Personal Information once We no longer require it for Our business purposes, or as required by law.

5. HOW LONG DOES PRIM-U RETAIN YOUR PERSONAL INFORMATION?

Prim-U retains Personal Information until You have requested Us to delete it. In which case we will delete Your Personal Information, unless it not reasonable for us to do so, taking into account the necessity of the Personal Information for the provision of the Prim-U Services in fulfilment of your contractual obligations with Ourselves, those of Our Primlancers, Prim-U Platform Partners or other Third-Parties, as well as applicable laws, regulations and legal obligations. We may also retain records to investigate or defend against potential legal claims.

When retention of the Personal Information is for analytic purposes the Information will be de-identified.

6. THIRD PARTY SERVICE PROVIDERS

6.1. Third-Party Service Providers

Prim-U may share Your PersonaI Information with authorised third parties such as emailhosting providers, website-hosting providers or customer relationship management (CRM) that provides services to Prim-U.

Prim-U does not permit these parties to use such information for any other purpose than to perform the services that Prim-U has instructed them to provide. All processing is compatible with such purpose.

6.2. Third-Party Websites

Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third-party website and we are not responsible for the privacy policies or the content of any third-party website. Third-party websites are responsible for informing You about their own privacy practices.

7. POLICY CHAMPION

If You have any questions about this Privacy Policy or the way in which We handle Your Personal Information, please contact Us on +27(0)600703045 or info@prim-u.com

8. CHANGES TO THIS POLICY

We may change this Policy at any time, in which case any amended terms shall be effective immediately upon the posting of the revised Policy and any subsequent activity in relation to the Website and the Prim-U Platform shall be governed by such amended terms. We therefore recommend that You check Our website regularly. If You do not agree with any term in this Policy, please do not use the Prim-U Platform or Website.

This Privacy Policy was last updated on 15 November 2019.

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