ELAROLAH Privacy Policy
© Copyright 2021, ELAROLAH
All Rights Reserved
Last Updated: August 2021
ELAROLAH respects individuals’ concerns about the privacy of their information. This global Policy applies to the personal information practices of ELAROLAH, its affiliate companies (Elarolah Global Distributions, Elarolah Capital, Kelbix Creations and their subsidiaries) (together, “ELAROLAH”). This Privacy Policy was developed to explain our practices regarding personal information we collect from you or about you on our sites online, offline via written or verbal communications with us, mobile applications, social networking presence, or from other sources. While this Privacy Policy broadly describes the practices we have adopted across ELAROLAH globally, local laws vary and some jurisdictions may place restrictions on our processing activities. Therefore, our actual practices in such jurisdictions may be more limited than those described herein to enable us to comply with local requirements.
Personal Information We Collect and How We Use It
We may collect personal information from individuals through our websites or by other means (such as email, fax, mail, phone, mobile applications, third-party applications, our parent, subsidiary, or affiliate companies, business partners, and other third-parties such as commercial data vendors and public databases). The principal ways you may provide the information and the types of information you may submit, as well as the ways we may use the information, are listed below.
Business Alerts, Newsletters and Other Communications – You may provide personal information such as your name and contact details to receive business alerts, newsletters and other communications (including emails). It is in our legitimate business interests to use the information you provide to send you the communications and information you have requested and to communicate with you about our products and services. If you no longer want us to send you business alerts, newsletters or other communications, you may unsubscribe at any time by contacting us via the contact information provided in the “How to Contact Us” section of this Privacy Policy.
Business Purposes – On our websites and mobile applications you may be able to register using your personal information to gain access to information related to your business relationship with or products of ELAROLAH. We use these details to provide you with access to information about your business relationship with us and to facilitate your use of the websites or mobile applications. You may also choose to provide, or we may obtain, your personal information at trade shows or from our distributors. It is in our legitimate business interests to use this information so that we can manage our business relationships and carry out marketing and sales activities.
You may also choose to connect to us via social networking services (e.g., Facebook or Twitter). When you connect to us via a social networking service we may collect personal information that you have provided to that service in accordance with the service’s applicable Terms of Use and your privacy settings within that social networking service. We may also choose to supplement information you have provided to us by obtaining additional demographic information about you from third-party sources in order to improve our communications with you, give us better insight into your needs, and improve our business where permitted under local law.
Careers – Individuals from all over the world apply for jobs with ELAROLAH through the Elarolah Careers or similar websites, third-party job posting sites, job fairs, or directly to the business locations. The information job seekers provide through this process is often maintained by third-party service providers. This information may be maintained in locations within the South Africa jurisdiction, accessible to our global recruiting team, and be shared with our corporate affiliates for the purpose of evaluating you for positions within our company. The information submitted by job seekers, such as name, contact details and any other information relevant to the application is used to evaluate their qualifications for employment and to contact them regarding possible employment opportunities. It is in our legitimate business interests to use this information in the selection process and to communicate with you, and it will be necessary to provide us with this information so that we can assess your application.
Job seekers may also choose to provide sensitive personal information such as gender or ethnic background. Providing this data is optional and is not required to apply for a job with ELAROLAH. This information will not be considered in evaluating candidates’ qualifications for employment.
Contact – You may contact us with questions, requests or comments through the “Contact” link on our website, by similar means on Elarolah affiliates’ websites, or via the contact information provided in the “How to Contact Us” section of this Privacy Policy. When you do so, we may ask you for your personal information to verify your identity or to track the inquiry internally to ensure we respond to your questions, requests or comments.
Contests, Sweepstakes, Promotions and E-Commerce – We may collect personal information such as your name, contact details and payment details, if you request a coupon, or wish to participate in contests, sweepstakes, promotions, or e-commerce activities related to ELAROLAH or our products or services. If you provide another person’s information to us, you must first obtain appropriate consent from that individual prior to providing this information to us and in order for us to use this information in the manner indicated. It is in our legitimate business interests to use your personal information to communicate with you and to process your requests and purchases. When we process personal information to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.
Contractual Obligations – If you are a vendor or a contractor, we may ask you to provide personal information such as your name, photo, contact details or business and financial details to establish and administer your account, process payments, and for compliance with internal and legal requirements (which may include medical testing and monitoring requirements, where applicable). We use your information for this purpose so that we can comply with our contractual obligations to you.
Feedback – You may be able to submit feedback on our websites. If you choose to give us your feedback, we may ask you for your personal information. We may also ask you about your experience using our websites. It is in our legitimate business interests to use the information you provide to enhance our websites, evaluate the quality of our products, or to communicate with you about products and services.
Incidents and Allegations – When you provide information about an incident or allegation, detailed personal information including your name, contact details and any relevant information about the incident or allegation may be collected. We use these details to investigate and comply with any applicable company or legal requirement. We may transfer and disclose your information to third-parties as required in the course of the investigation or to comply with any legal obligation related to the information you provide.
Information Technology Security – We may collect personal information when detecting and defending against security threats in accordance with our legitimate business interests and our legal obligations. We use various IT tools to detect and defend against online security threats (e.g., attacks, viruses, malware, spam, phishing, malicious web content), to promote business continuity of our information systems and assets, and to maintain optimal performance of our IT systems. To ensure physical security of our facilities we may, where permitted under local law, utilize surveillance systems and/or location tracking while you are on Company property.
Other Uses of Information – We may use the personal information you provide to us for internal general business purposes in accordance with our legitimate business interests. These purposes include administration of our websites, data analytics, fraud prevention and compliance with our legal obligations, standards, policies and procedures (i.e., due diligence checks and sanction screening where applicable).
Scholarships, Grants and Awards – You may provide personal information such as your name, contact details, education details, employment details, qualifications, awards, etc. when applying for scholarships, grants or awards offered by ELAROLAH. It is in our legitimate business interests to use the information you provide in the selection process, to communicate with you and to publish a list of the recipients. It is necessary for you to provide us with the information requested so that we can assess your application.
We may obtain your explicit consent to collect and use certain types of personal information when we are required to do so by law (for example, in relation to our direct marketing activities, or when we process sensitive personal information). If we ask for your consent to process your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this privacy policy.
Information We Collect by Automated Means
When you visit and interact with our websites and applications, we may collect “Other Information” that does not inherently reveal your specific identity, in order to learn how to best tailor our websites for our visitors. Examples of what Other Information we may collect and how we and third-party service providers may collect this information include:
Aggregation Information – Aggregated user information does not personally identify you or any other user (for example, we may aggregate user information to calculate the percentage of our users who have a particular telephone area code). Aggregated data is treated in accordance with this Privacy Policy.
App Usage Data – When you download and use an App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
Browser and Device Information – Certain information is collected by most browsers or automatically through your device, such as your computer type, operating system name and version, device manufacturer and model, Internet browser type and version and the name and version of the online services (such as the Apps) you are using. We use this information to ensure that the online services function properly.
Cookies – Cookies are pieces of information stored directly on the computer or mobile device that you are using. Cookies allow us to collect information such as browser type, time spent on the online services, pages visited, referring URL, and other aggregated website traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, to collect statistical information, and to personalize your experience while online.
Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the online services or to send you advertisements and marketing emails. We may also use cookies or other technologies to track responses to our online advertisements and marketing emails. You can opt out of such interest-based advertising using cookies set by participating NAI members at: http://optout.networkadvertising.org/#!/. Opting out of interest-based advertising does not mean you will no longer see advertising online. It does mean that the company or companies from which you opt out will no longer show ads that have been tailored to your interests.
If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You can choose whether to accept cookies by changing the settings on your browser or, depending on your jurisdiction, by managing your tracking preferences as noted in a separately posted cookie statement or via a posted cookie manager. If, however, you do not accept cookies, you may experience some inconvenience in your use of the online services. For example, we may not be able to recognize your computer, and you may need to log in every time you visit. You also may not receive advertising or other offers from us that are relevant to your interests and needs. At this time, we do not respond to browser “Do-Not-Track” signals except in jurisdictions where we are required to do so by law.
IP Address – Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address may be identified and logged automatically in our server log files whenever a user accesses the online services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering our online services. We may also derive your approximate location from your IP address to understand from what regions of the world our website visitors come.
Physical Location and Mobile Location-Based Services – We may collect the physical location of your device if you have consented to us doing so, by, for example, using satellite, cell phone tower, Wi-Fi signals, or other technologies. We may use your device’s physical location to provide you with personalized location-based services and content.
If you have downloaded one of our Apps, you may enroll to receive offers by agreeing to the use of technologies that enable us to collect information about your location through your mobile device’s Bluetooth or similar capabilities. We will collect this information if you opt-in through the App (either during your initial login or later) to receive the offers and by enabling these capabilities on your mobile device.
Pixel Tags or Similar Technologies – Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some online services to, among other things, track the actions of users of the online services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the online services and response rates. We also use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of our services and report on activities and trends. These services may collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/,and opt-out by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
With Whom We Share Your Information
We do not sell or otherwise disclose your personal information except as described in this Privacy Policy. We may also share your information as disclosed at the time you provide it and in the following circumstances:
Business Transfers – We may disclose your personal information, usage information, and other information about you to parties acquiring part or all of our assets, as well as to attorneys and consultants. If we transfer your information to an acquirer, we will use reasonable efforts to direct the acquirer to use your information in a manner that is consistent with this Privacy Policy. Also, if any bankruptcy or reorganization proceeding is brought by or against us, your information may be considered a company asset that may be sold or transferred to third parties.
Corporate Affiliates – We may share the information you provide (such as information about your orders, enquiries, applications or use of our websites) within ELAROLAH and with Elarolah affiliates for marketing, recruitment and internal reporting purposes. We do this to run our business more efficiently and to have a better understanding of our customers across business lines.
Law Enforcement Agencies, Courts, Regulators, Government Authorities or other Third Parties – We may transfer and disclose your information to third parties (i) to comply with a legal obligation, (ii) when we believe in good faith that the law requires it, (iii) at the request of governmental authorities conducting an investigation, (iv) to verify or enforce our policies, Terms of Use and other agreements or to protect the rights, property, or safety of ELAROLAH, our customers, or others (v) to respond to an emergency, (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity or (vii) otherwise to protect the rights, property, safety, or security of third parties, users of our services or the public.
Marketing Partners – In some cases, we may permit certain network advertising companies and publishers to collect personal information on our sites. In addition, our business partners may access personal information about you that we have combined with such business partners’ data. We may collaborate with our business partners to jointly send tailored promotional communications to you using the combined set of information. If you prefer not to receive these joint communications, you can opt out by following the instructions included in any such communication.
Non-Personal Information – We may share non-personal information, such as aggregate user statistics, demographic information, and usage information with third parties.
Sharing With Your Consent – Our services may present you with the opportunity to opt in to receive information or marketing offers from third parties or to otherwise consent to the sharing of your information with third parties. If you agree to have your personal information shared, your personal information will be disclosed to the third-party subject to the privacy notice and business practices of that third party.
Third-Party Service Providers – In order to carry out your requests, to make various features, services and materials available to you through the services, to respond to your inquiries, and for other purposes described in the “How We Use Your Information” section of this Privacy Policy, we may share your personal information or usage information with third parties that perform functions on our behalf (or on behalf of our partners), such as companies or individuals that: host or operate our sites; analyze data; provide customer service; mail product samples or manage payments; advertisers; sponsors or other third parties that participate in or administer our promotions, e-commerce activities, provide marketing or promotional assistance (such as in connection with winner selection, prize fulfillment, and as required by law, such as on a winners list), or assist with risk management, compliance, legal and audit functions. These service providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.
Because we operate as part of a global business, the recipients referred to above may be located outside the jurisdiction in which you are located (or in which we provide the services). See the section on “International Transfers of Personal Information” below for more information.
Automated Decisions About You
We may make automated decisions about you using your personal information in the following circumstances:
Automated processing may be used when evaluating large numbers of applicants for job vacancies. For these purposes we would request that you create a profile and answer some job-related questions to evaluate your skills as compared to the published job requirements. An algorithm may then be used to determine which candidates will be allowed to proceed to the next step within the selection process. We consider this data and process to be relevant because it will assist us to select the applicant most suitable for our vacancies. The outcome of the evaluation may have an impact on whether you are offered a role for the vacancy you apply to.
You can contact us via the contact information provided in the “How to Contact Us” section of this Privacy Policy to request further information about automated decision-making, object to our use of automated decision-making, or request an automated decision to be reviewed by us if required by local law.
User-Generated Content
Some of our services and social networking features may enable you to submit your own content for public posting. Information you post in this fashion becomes public information and is not subject to this Privacy Policy. Certain areas of our websites and our social media pages may enable users to submit personal information to ELAROLAH or its affiliates. Such information will be used in accordance with the website’s Privacy Policy. Postings, letters, and other submissions become the property of ELAROLAH and may be reproduced in whole or in part, including your name, for any purpose and in any manner.
Links to Other Sites
Our websites and communications may provide links to other websites, including to social networks or partners that may use our logo(s) as part of a co-branding agreement. To the extent that any linked services are not provided by ELAROLAH, we are not responsible for the services, or any of the content found on these websites. If you provide information on and use third-party services or websites, the privacy policy and terms of service on those sites are applicable. We encourage you to read the privacy policies of websites that you visit before submitting personal information.
How We Protect Personal Information
In proportion to the sensitivity of the information, we maintain reasonable administrative, technical and/or physical safeguards and appropriate security measures to protect personal information from loss, misuse or unauthorized access, disclosure, alteration, or destruction of the information you provide. However, we cannot guarantee the security of your personal information, as no electronic data transmission or storage of information is completely secure. If an incident is reported affecting your information, we will investigate and comply with all required reporting obligations.
International Transfers of Personal Information
ELAROLAH is a global organization – headquartered in South Africa – that does business in many countries. We may share your personal information among ELAROLAH, its affiliates, our service providers, and other third parties that may be located in countries outside of your own. Although the data protection laws of these various countries may differ from those in your own country, we have put in place appropriate safeguards (such as contractual commitments) to ensure that your personal information is handled as described in this Privacy Policy and in accordance with the law. For transfers of data outside of the European Union, this includes standard contractual clauses approved by the European Commission. For more information on the appropriate safeguards in place, please contact us via the contact information provided in the “How to Contact Us” section of this Privacy Policy.
How Long is Personal Information Retained
We will keep your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period of time that enables us to:
- Maintain business records for analysis and/or audit purposes
- Comply with record retention requirements under the law
- Defend or bring any existing or potential legal claims
- Address any complaints regarding the services
We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.
Changing and Accessing Your Personal Information
You may have certain rights regarding your personal information, subject to local law. These include the following rights to:
- access your personal information;
- correct the information we hold about you;
- erase your personal information;
- restrict our use of your personal information;
- object to our use of your personal information;
- withdraw your consent for us to use your personal information, if applicable;
- receive your personal information in a usable electronic format and transmit it to a third party (right to data portability); and
- lodge a complaint with your local data protection authority (if applicable).
We encourage you to contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate. Please note that we will likely require additional information from you in order to verify your identity and respond to your requests. If you would like to discuss or exercise your applicable rights, subject to limitations established under local law, please contact us via the contact information provided in the “How to Contact Us” section of this Privacy Policy. We will respond to you within a reasonable time and within the time limits established by applicable law.
Children
Our services are generally not directed to children under 16. We do not knowingly collect personal information from anyone under 16 without parental consent. If you become aware that we have collected personal information from a child under the age of 16 without parental consent, please let us know so we can take appropriate action.
South African Residents
If you are a South African resident and have provided us with your personal information, you may ask us to refrain from sharing you personal information with third parties, including our affiliates if they are separate legal entities, for direct marketing purposes in accordance to the PAIA’s Act. Please tell us your preference by contacting us via the contact information in the “How To Contact Us” section of this Privacy Policy.
Updates to Our Privacy Policy
We may modify or update this Privacy Policy from time to time. We will always indicate at the top of the Policy when it was most recently updated. If we substantially change this Privacy Policy, we will notify you of the changes. Any changes will be effective immediately upon the posting unless otherwise indicated. Where changes to this Privacy Policy will have a fundamental impact on the nature of processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights.
How to Contact Us
If you have any questions or comments about this Privacy Policy or if you would like us to remove or update information we have about you or your preferences, please email us or write to the following applicable contact at ELAROLAH or its affiliates:
ELAROLAH (PTY) LTD
108 Elizabeth Avenue,
POD OFF Grayston,
Parkmore,
Sandton, 2196,
Gauteng, South Africa.
Tel: +27 87 551 8318
Email: admin@elarolah.com
