Privacy Policy

Privacy Notice as of 18-APRIL-2020

StartupTV [a division of StartupApp (Pty) Ltd whose Company Registration Number is 2018/236181/07] (“StartupTV,” “we” or “us”) respects your right to privacy.

This Privacy Notice (this “Notice”) covers personal information collected by StartupTV® through our South Africa-based digital properties, such as websites, mobile apps, smart TV apps, games or other interactive features, or installed software (each, a “Site”).

Please read this Notice carefully and contact us with any questions.

SCOPE OF THIS NOTICE

Welcome to StartupTV. The Notice below explains how StartupTV and its affiliates to collect, use and share information about you when you interact with one of our Sites. This Notice describes how we use personal information we collect from your use of our Sites, including tracking technologies, cookies and browsing data, the measures we take to protect your information, and how to contact us if you have any questions or concerns.

Please read this Notice carefully to understand our practices regarding your information and how we will treat it.

The relevant StartupTV entity that is responsible for your personal information (i.e., the controller) will be the StartupTV entity to whom you provided your personal information. However, as we may share your personal information within our group, other StartupTV entities may also use your information in accordance with this Notice. This Notice applies to all StartupTV entities which are included on the Controller List. Activities of any company not listed in the Controller List will not be governed by this Notice. In those cases, please see the company’s applicable privacy notice, which typically will be found on its website.


TYPES OF INFORMATION WE COLLECT AND WHY

The personal information that we collect about you broadly falls into the following categories:

Information that you provide voluntarily

Certain parts of our Sites may ask you to provide personal information voluntarily. For example, we may collect the following information:
  • Site registration information (e.g., name, address, email, phone number, and zip code), in order to enable you to register an account with us, to subscribe to marketing communications from us, and/or to submit enquiries to us).

  • Information collected in forms you fill out on our Sites (e.g., email or mobile phone number to receive newsletters or request other information).

  • Any correspondence you have with us by phone, email, social media platforms, messaging platforms, or otherwise.
    Subscriptions or orders that you place through our Sites.

  • Information you provide to us as part of your participation in discussion boards or other social media functions on our Sites or our brand pages on social media properties.

  • Information you provide to us when entering a contest, sweepstakes, promotion, poll or survey.

  • Information that you provide to us when reporting a problem, feedback or requesting technical support or other customer service for our Sites.

  • We use this information in order to provide our Sites to users in an individualized and personalized way and to communicate with our users regarding content and services we believe may interest them, as well as for our other legitimate business purposes.


  • Information that we collect automatically

    When you visit our Sites, we may collect certain information automatically from you. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.

    Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g., country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Sites, including the pages accessed and links clicked (including date and time), videos, shows or content you watch or interact with on our Sites, Login information, social media ID, social media plug-in information, pages you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page or app.

    Collecting this information enables us to better understand the visitors who come to our Sites, where they come from, and what content on our Sites is of interest to them. We use this information for our internal analytics purposes and to improve the quality, security and relevance of our Sites to our visitors.

    Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies and similar tracking technology” below.


    Information that we obtain from third-party sources

    From time to time, we may receive personal information about you from third-party sources (including our other Sites or third parties). We may combine and use this information as described in this Notice.

    The types of information we collect from third parties includes the names or descriptions of videos or content viewed via our Sites or third-party Sites; and we use the information we receive from these third parties to provide you with a personalized and unified user experience, for example by allowing you to share, post or link our content through your accounts with third-party social media services.


    Please note that if you choose to interact with social media features on our Sites, or if you are logged in to your social media or other accounts (e.g., Facebook, Instagram, YouTube Twitter or Google) while using our Sites, those social media services may collect information about your use of our Sites. Information collected by third-party social media services is governed by the privacy notices of those third parties and we recommend that you make yourself aware of such privacy notices.

    Other ways we use personal information

    Regardless of how we have received your information, we use your personal information for our business purposes in the following ways:


    • To enable us to provide and maintain our Sites, including Site administration and internal operations such as troubleshooting, data analysis, testing, research, statistical and survey purposes;

    • To improve our Sites to ensure that content is presented in the most effective manner for you and for your device of choice;

    • To carry out market research and to improve existing or develop new products and services;

    • To deliver products and services you request, purchase, subscribe to or order from us;

    • Where permitted by law, to provide you, or permit selected third parties to provide you, with information about content, services or goods we feel may interest you, including interest-based advertisements, newsletters, brand promotions, re-targeted advertisements displayed on third-party sites, and promotions offered in partnership with third parties;

    • To measure or understand the effectiveness of advertising we and our third-party partners serve to you and others;

    • To notify you about changes to our Sites;

    • To keep our Sites safe and secure; and

    • To comply with legal and regulatory requirements.



    In general, we will use the personal information we collect from you only for the purposes described in this Notice, or for purposes that we explain to you at the time we collect your personal information. However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.


    HOW WE SHARE YOUR INFORMATION

    We may share or disclose your personal information with the following categories of recipients:


  • To our group companies, third-party service providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Sites, for advertising services so we can select and serve relevant advertisements to you, for market research assistance, or for analytics and search engine services to improve and optimize our Sites), or who otherwise process personal information for purposes that are described in this Notice or notified to you when we collect your personal information.

  • To any competent law enforcement body, regulatory, government agency, court or other third-party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights or those of our customers or other third parties, or (iii) to protect your vital interests or those of any other person.

  • To an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of all or any part of our business.

  • To any other person with your consent to the disclosure.


  • LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION (EEA VISITORS ONLY)

    If you are a visitor from the European Economic Area (“EEA”), our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

    However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

    If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

    If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our Sites and communicate with you as necessary to provide our services to you and for our legitimate commercial interests, for instance, when responding to your queries, improving our Sites, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are. If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “Contact Us” heading below.


    STORAGE AND SECURITY OF YOUR PERSONAL INFORMATION

    We use technical and organizational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.

    Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Sites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.


    COOKIES AND OTHER TRACKING TECHNOLOGIES

    We and third parties may use cookies and other tracking technologies to enable certain features and functionality of our Sites and to provide you with content that is customized to your interests. Our Sites may also collect information as described in this notice, including identifiers designed to enable advertising on your mobile device or other internet connected device. Some tracking technologies used on our Sites may be implemented and controlled by third-party partners.

    For further information about the types of cookies we and third parties use, why, and how you can control cookies, please see our Cookie Notice.

    Depending on your mobile device or other internet connected device, you may be able to reset the device’s advertising identifier at any time by accessing the privacy settings. If you are using an iOS-based device, please visit Apple. If you are using an Android based device (including Kindle), please visit Google. If you are using an Xbox- or Windows-based device, please visit Microsoft’s website. If you are using an Amazon Kindle, please visit Amazon. If you are using a Samsung device, please read Samsung’s privacy policy . If you use a device based on another platform, you should check the provider’s instructions for reset the device’s advertising identifier.

    Facebook is an advertising partner and may collect and use data to display advertisements on all StartupTV® digital websites and apps. For more information and to control the ads you see, visit facebook .

    For more information or to opt-out of certain online behavioral advertising, please visit our ad choices website.

    DO NOT TRACK SIGNALS At this time, StartupTV® does not respond to browser “Do Not Track” signals, which is a standard still under development.


    INTERNATIONAL DATA TRANSFERS

    Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

    Specifically, our website servers are located in South Africa, and our group companies and third-party service providers and partners operate around the world. This means that when we collect your personal information, we may process it in any of these countries.

    However, we have taken safeguards to require that your personal information will remain protected in accordance with this Notice. These include implementing an intra-group data transfer agreement incorporating the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect personal information they process from the EEA in accordance with European Union data protection law. A copy of our intra-group data transfer agreement can be provided upon request.

    Where required by applicable data protection law, we have implemented similar safeguards with our third-party service providers and partners and further details can be provided upon request.


    DATA RETENTION

    We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

    When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.


    YOUR DATA PROTECTION RIGHTS (EEA VISITORS ONLY)

    If you are a resident of the EEA, subject to applicable law, you may have certain rights regarding your personal information.

    Specifically, you may be able to make the following choices:


    Access, correct, update or request deletion of your personal information by contacting us using the contact details provided under the “Contact Us” heading below.
    Object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information by contacting us using the contact details provided under the “Contact Us” heading below.
    Opt out of marketing communications we send you at any time by clicking on the “unsubscribe” or “opt out” link in the marketing emails we send you, or by logging into your account and managing your email preferences.
    Withdraw your consent at any time to our collection and processing of your personal information. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
    Complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

    To exercise these rights, please contact us as described in the “Contact Us” section below. We respond to requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.


    CHILDREN

    Our Sites are not intended for or directed toward children under 13 years of age and nor does StartupTV knowingly collect or store personal information on our Sites from children under 13. If you are under 13 years of age, you are not permitted to submit any personal information to us on any Site, and if we become aware that we have inadvertently received personal information from a visitor under the age of 13, we will delete that information from our records.

    Some Sites we own or operate may be directed toward children under 13 (“Children’s Sites”). Children’s Sites are not governed by this Notice. The Notice that applies to a Children’s Site will be posted in an easily accessible location on the Children’s Site.


    THIRD-PARTY SITES AND PLATFORMS

    Our Sites may contain links to websites and apps operated by a third party. If you follow a link to any third-party website or app, please note that the privacy notice of that third party will apply.

    Please also keep in mind that when you use a third-party platform to access our Sites (for example, when you access one of our Smart TV apps), the information you provide may be separately collected by the third-party platform, and the privacy notice of the third party will apply.

    We are not responsible for the collection, use or sharing of your information by these third parties.


    CHANGES TO OUR NOTICE

    We may update this Notice from time to time in response to changing legal, technical or business developments. However, when we update our Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Notice changes if and where this is required by applicable data protection laws.

    You can see when this Notice was last updated by checking the “last updated” date displayed at the top of this Notice.

    Trans-border flow of Information: We may transfer your information to foreign countries; only if our service providers are cross-border or use systems cross-border and mainly for retention purposes. If you continue to use our platform, you agree that we may transfer your information cross-border for these purposes. We will share information cross-border to recipients who have similar laws to South Africa in respect of data protection that apply to them, or who agreed with us to include relevant data protection principles.

    LODGING A COMPAINT

    If you believe we are using your information unlawfully, you may lodge a complaint to the Information Regulator with the following contact details:

    Website: http://www.justice.gov.za/inforeg/index.html.
    Address: SALU Building, 316 Thabo Sehume Street, Pretoria.
    Contact number: 012 406 4818.
    Fax number: 086 500 3351.
    Email: inforeg@justice.gov.za.
    Legal disclosure in terms of section 43 of the Electronic Communications and Transactions Act 25 of 2002

    Site owner: StartupApp (Pty) Ltd trading as StartupApp, registration number 2018/236181/07.

    Legal status: StartupApp (Pty) Ltd is a private company, duly incorporated in terms of the applicable laws of South Africa.

    Director(s): Sandile Shabangu.

    Description of main business of StartupApp: Platforms for startups, entrepreneurs and self-starters.

    Email address: hello@startupapp.africa.

    Website address: https://www.startupapp.africa & https://www.startuptv.co.za

    Registered address: 1 Tom Jones Street, Benoni, Gauteng, 2057


    CONTACT US

    Questions, comments and requests regarding this Notice are welcomed and should be addressed to:

    Email: hello@startuptv.co.za (subject line: “Notice Contact”)