Privacy Policy

1. Introduction

Tapnet Solutions (Pty) Ltd (Registration No. 2023/135522/07) ("Tapnet", "we", "us", or "our") is committed to protecting your personal information in accordance with the Protection of Personal Information Act 4 of 2013 ("POPIA") and all applicable South African data protection legislation.

This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you interact with tapnet.co.za and all other websites, applications, and digital services operated by Tapnet Solutions (Pty) Ltd (collectively, the "Services").

In terms of POPIA, Tapnet Solutions (Pty) Ltd is the responsible party for the processing of your personal information.

By using our Services, you acknowledge that you have read and understood this Privacy Policy. Where we rely on your consent as a legal basis for processing, we will obtain that consent explicitly before processing your personal information.

2. Information We Collect

We collect personal information in the following categories:

2.1 Information You Provide Directly

When you interact with our forms and services, we collect the information you voluntarily submit:

2.2 Information Collected Automatically

When you visit our website, certain information is collected automatically through cookies and similar technologies:

3. Purposes and Legal Basis for Processing

In terms of POPIA Section 18, we process your personal information only where we have a lawful basis to do so. The table below sets out each processing activity, its purpose, and the legal basis relied upon:

4. Third-Party Recipients

We share your personal information with the following third-party service providers, each of whom is bound by their own privacy policies and data processing agreements:

We do not sell, rent, or trade your personal information to any third party. We only share data with the providers listed above for the specific purposes described, and we require each provider to protect your data in accordance with applicable data protection laws.

5. Cross-Border Transfers

In terms of Section 72 of POPIA, personal information may only be transferred outside of South Africa under certain conditions. As our infrastructure providers are located outside South Africa, your personal information may be transferred to and processed in the following jurisdictions:

We rely on the following legal bases for these cross-border transfers under Section 72 of POPIA:

• Consent: Where you have provided explicit consent via our cookie consent banner (for analytics data) or by voluntarily submitting your information through our forms.
• Contractual necessity: Where the transfer is necessary for the performance of a contract between you and Tapnet (e.g., processing your booking or quote request).
• Binding corporate rules and contractual safeguards: Our service providers maintain data processing agreements and privacy commitments that provide adequate protection for your personal information.
• Adequate protection: The European Union is recognised as providing adequate data protection under various international frameworks.

6. Data Retention

We retain your personal information only for as long as is necessary to fulfil the purposes for which it was collected, or as required by law. The specific retention periods are as follows:

After the applicable retention period expires, personal information is securely deleted or anonymised. Where data is required to be retained by law, it will be archived securely and access will be restricted until the legal retention period expires.

7. Your Rights Under POPIA

As a data subject under POPIA, you have the following rights in relation to the personal information we hold about you:

• Right of access (Section 23): You may request confirmation of whether we hold personal information about you and request a copy of that information.
• Right to correction (Section 24): You may request that we correct or update any personal information that is inaccurate, incomplete, or misleading.
• Right to deletion (Section 24): You may request that we delete your personal information where it is no longer necessary for the purpose for which it was collected, or where you withdraw your consent.
• Right to data portability: You may request that we export your personal information in a structured, commonly used, and machine-readable format.
• Right to object to processing (Section 11(3)): You may object to the processing of your personal information on grounds of legitimate interest, and we will cease processing unless we demonstrate compelling legitimate grounds.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time. This does not affect the lawfulness of processing conducted before the withdrawal.
• Right to restrict processing: You may request that we limit the processing of your personal information in certain circumstances, for example while we verify the accuracy of your data following a correction request.
• Right to complain to the Information Regulator (Section 74): If you believe that we have violated your rights under POPIA, you have the right to lodge a complaint with the Information Regulator (see Section 12 below).

How to Exercise Your Rights

To exercise any of the above rights, please contact our Information Officer:

• Email: wynand@tapnet.co.za
• Phone: 079 174 8357

We will respond to your request within 30 days of receipt. We may request proof of identity before processing your request to protect the security of your personal information. There is no fee for submitting a request, unless the request is manifestly unfounded or excessive.

8. Cookies and Tracking Technologies

Our website uses cookies and similar technologies. Cookies are small text files stored on your device that help us provide and improve our Services.

8.1 Essential Cookies (No Consent Required)

These cookies are strictly necessary for the operation of our website and cannot be disabled:

8.2 Analytics Cookies (Consent Required)

These cookies are only placed on your device after you provide explicit consent via our cookie consent banner:

8.3 Managing Cookies

You can manage your cookie preferences at any time through our cookie consent banner or by adjusting your browser settings. You may also opt out of Google Analytics tracking across all websites by installing the Google Analytics Opt-out Browser Add-on.

9. Children Under 18

Our Services are not directed at children under the age of 18. We do not knowingly collect personal information from children under 18. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us immediately at wynand@tapnet.co.za and we will take steps to delete that information.

In terms of POPIA Section 35, where we become aware that personal information of a child has been collected without prior consent of a competent person (parent or guardian), we will delete such information without delay unless retention is authorised by law.

10. Direct Marketing

In terms of POPIA Section 69, we will only use your personal information for direct marketing purposes where you have given us explicit opt-in consent to do so.

• We will never send you unsolicited marketing communications without your prior consent.
• Every marketing communication will include a clear and easy mechanism to unsubscribe or opt out.
• You have the right to object to direct marketing at any time by contacting us at wynand@tapnet.co.za or by using the unsubscribe mechanism in any marketing communication.
• Once you opt out, we will cease direct marketing communications without undue delay.

11. Data Breach Notification

In accordance with POPIA Section 22, Tapnet is committed to protecting your personal information and has implemented appropriate technical and organisational measures to prevent unauthorised access, loss, or damage.

In the event of a security compromise where there are reasonable grounds to believe that your personal information has been accessed or acquired by an unauthorised person, we will:

• Notify the Information Regulator as soon as reasonably possible after the discovery of the breach.
• Notify affected data subjects (you) as soon as reasonably possible, providing details of the breach, the personal information involved, the measures we have taken and recommend you take to mitigate potential harm.
• Take immediate steps to investigate the breach, contain it, and implement measures to prevent recurrence.
• Maintain a breach register documenting all incidents and our responses.

12. Information Regulator

If you are not satisfied with our response to a privacy concern, or if you believe that we have violated your rights under POPIA, you have the right to lodge a complaint with the South African Information Regulator:

We encourage you to contact us first so that we may attempt to resolve your concern directly. However, you are entitled to approach the Information Regulator at any time.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes to this policy:

• We will update the "Last Updated" date at the top of this page.
• For significant changes that affect how we process your personal information, we will provide prominent notice on our website or contact you directly where possible.
• Where changes require your consent under POPIA, we will obtain that consent before implementing the changes.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal information.

14. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal information, please contact our Information Officer:

This Privacy Policy applies to tapnet.co.za and all other websites, applications, and digital services operated by Tapnet Solutions (Pty) Ltd.