SABITA Privacy Policy
Introduction
The Southern African Bitumen Association (SABITA) respects your privacy and is committed to protecting your personal information. This policy informs you on how we look after your personal information when you visit our website (regardless of where you visit it from) and how the law protects your right to privacy.
Please refer to the glossary of terms at the end of this document where necessary.
Purpose of the policy
This privacy policy aims to give you information on how SABITA collects and processes your personal information through your use of this website. This includes information provided to join the Members Only section of the website, as well as any information provided by members and non-members who transact through the website.
This website is not intended for children, and we do not knowingly collect personal information relating to children.
It is important that you read this privacy policy together with any other policy we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your information. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Responsible party
SABITA is the party responsible for your personal information (collectively referred to as “we”, “us” or “our” in this privacy policy).
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact SABITA using the details below. You have the right to make a complaint to the Regulator at any time.
Contact details
Full name of legal entity: Southern African Bitumen Association (SABITA)
Email address: info@sabita.co.za
Postal address: Postnet Suite 56, Private Bag X21,|Howard Place 7450
Telephone number: 021 531 2718
Changes to the privacy policy and your duty to inform us of changes.
This privacy policy will be reviewed from time to time (This version was updated on 30th June 2021).
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
Third party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We do not control these third-party websites and are not responsible for their privacy statements.
Personal information means any information about a natural or juristic person by which that person can be identified. It does not include information where the identity has been removed (anonymous information).
We may collect, use, store and transfer different kinds of personal information about you as follows:
- Identity Information includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Information includes billing address, email address.
- Financial Information includes bank account and payment card details.
- Transaction Information includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Information includes internet protocol (IP) address, your login information, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Information includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
- Usage Information includes information about how you use our website, products and services.
- Marketing and Communications Information includes your preferences in receiving marketing from us and your communication preferences.
We also collect, use and share Aggregated Information such as statistical or demographic information for any purpose. Aggregated Information could be derived from your personal information but is not considered personal information in law as this information will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Information to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Information with your personal information so that it can directly or indirectly identify you, we treat the combined information as personal information which will be used in accordance with this privacy policy.
We do not collect any Special Personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, health, and genetic and biometric information). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal information
Where we need to collect personal information by law, or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us and you will be notified of this.
We use different methods to collect personal information from and about you, including through:
- Direct interactions. You may give us your identity, contact and financial information by filling in forms or by corresponding with us by post, phone, e-mail or otherwise. This includes personal information you provide when you:
- Apply for our products or services;
- Create an account on our website;
- Apply for membership of SABITA
- Apply to join the Members Only section of our website;
- Request marketing to be sent to you;
- enter a competition, promotion or survey; or
- Give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect technical information about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs and other similar technologies. We may also receive technical information about you if you visit other websites employing our cookies. Please see below section dealing with cookies.
- Third parties or publicly available sources. We will receive personal information about you from various third parties and public sources as set out below:
- Technical Information from analytics providers such as Google based outside the Republic.
- Contact, financial and transaction information from providers of technical, payment and delivery services.
- Identity and contact information from data brokers or aggregators.
- Identity and contact information from publicly available sources.
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- Where you have requested that we enter into a contract with you;
- Where it is necessary for our legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests;
- Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal information although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal information
The following table outlines all the ways we plan to use your personal information, and the legal basis of each. We also identify our legitimate interests where appropriate.
Note that we may process your personal information for more than one lawful basis depending on the specific purpose for which we are using your information.
| Purpose/Activity | Type of personal information | Lawful basis for processing including basis of legitimate interest |
| To register you as a new member or customer | (a) Identity
(b) Contact |
Performance of a contract with you |
| To process and deliver your order including:
(a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(a) Identity
(b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
(a) Identity
(b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how members/customers use our products/services) |
| To enable you to partake in a prize draw, competition, or complete a survey | (a) Identity
(b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how members/customers use our products/services, to develop them and grow our society) |
| To administer and protect our society and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity
(b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our society, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or restructuring exercise)
(b) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the content we deliver | (a) Identity
(b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how members/customers use our products/services, to develop them, to grow our society and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical
(b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about services that may be of interest to you | (a) Identity
(b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
Marketing
We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising.
Promotional offers from us
We may use your identity, contact, technical, usage and profile information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased products/services from us and you have not opted out of receiving that marketing.
Third party marketing
We will get your express opt-in consent before we share your personal information with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences, or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal information provided to us as a result of a product/service purchase, product/service experience or other transactions.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you require further details in this event, please contact us.
If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We do not transfer your personal information outside the Republic of South Africa.
We will only retain your personal information as long as is reasonably necessary to fulfil the purposes we collected it for or subsequently processed, unless the retention of the information is required or authorised by any legal or regulatory requirements, we reasonably require the information for lawful purposes relating to one of our functions or activities, the retention of the information is required by a contract entered into between us, or you consent to such retention of information.
We may also retain your personal information for a longer period for historical, statistical or research purposes only where we have implemented appropriate safeguards against your information being used for any other purpose (for example, by anonymising the information so that it can no longer be associated with you). To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory or other requirements.
In some circumstances you can ask us to delete your information as detailed below.
Under certain circumstances, you have the following rights under personal information protection laws:
- Notification that your personal information is being collected. When your personal information is collected, you have the right to be informed that your information is collected and where the information is not collected from you, you have the right to be informed of the source from which it is collected.
- Notification of security compromises. Where reasonable grounds exist for us to believe that your personal information has been accessed or acquired by an unauthorised person, you have the right to be notified.
- Request access to your personal information. You have the right to confirm, free of charge, whether or not we hold any of your personal information and, to the extent that we do hold your information, to request a copy or description of that record for a prescribed fee or free of charge. You will be required to provide adequate proof of identity so that we can confirm your identity and ensure your right to access your personal information. We may need to request other specific information from you to help us process your request. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also request further information in relation to your request to speed up our response.
- Request correction of your personal information. You have the right to request us to correct or delete your personal information where it is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully.
- Request destruction or deletion of your personal information. You have the right to ask us to delete or remove your personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with the law. Note, however, that we may not always be able to comply with your request of destruction or deletion for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal information. You have the right to object to our processing of your personal information where we are relying on a legitimate interest (or those of a third party) and your specific situation leads you to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object to processing.
- Request restriction of processing your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios:
- If you want us to establish the information’s accuracy;
- Where we no longer need the information for the purpose for which the information was initially collected but we need it for purposes of proof;
- Where our use of the information is unlawful but you do not want us to erase it;
- If you want us to transmit your personal information into another automated processing system.
- Withdraw consent. You have the right to withdraw your consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.
- Submit a complaint to the Regulator. You will only have the right to submit a complaint to the Regulator after 30 June 2021. In the interim we will endeavour to resolve any complaints or concerns you may have.
- Institute civil proceedings. You have the right to institute civil proceedings regarding an alleged interference with the protection of your personal information. However, please note that until 1 July 2021 the Regulator does not have the power to enforce your protection under POPI.
If you wish to exercise any of the rights set out above, please contact us.
Time limit to respond
We try to respond to all legitimate requests as soon as is reasonably possible. Where your request is particularly complex or you have made a number of requests, we may take some time in order to process the request/s. In this case, we will notify you and keep you updated.
- Glossary
“personal information” means all information relating to individuals that is processed in terms of this privacy policy and, where applicable, information relating to an identifiable, existing juristic person; and includes identity information, contact information, financial information, transaction information, technical information, profile information, usage information, marketing and communications information, and special personal information;
“process” means any operation or activity or any set of operations, whether or not by automatic means, concerning personal information, including
- the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use;
- 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 information,
“Regulator” means South Africa’s Information Regulator established in terms of section 39 of POPI;
“responsible party” means a public or private body or any other person which, alone or in conjunction with others, determines the purpose of and means for processing personal information; and for the purposes of this privacy policy is SABITA.
