ESTUARY MEDIA
CLOSE CORPORATION

REGISTRATION NUMBER: 2008/209259/23

PHYSICAL ADDRESS: 85 SELBORNE ROAD, JOHANNESBURG NORTH, GAUTENG, REPUBLIC OF SOUTH AFRICA
POSTAL ADDRESS: PO BOX 88 JUKSKEI PARK, GAUTENG, REPUBLIC OF SOUTH AFRICA

(Trading as “Dynamic Voice Company & Al Prodgers Comedy”)

1. INTRODUCTION
1.1 Estuary Media is a duly registered Close Corporation in South Africa. The core business of Estuary Media is the coaching of communication skills, voice training and public speaking.
1.2 Estuary Media CC is owned by its members:
Juliette Rose Jenner – Prodgers (CEO & Founder)
Alistair Martin Prodgers (Co-Founder)
The Data Protection Officer and Information Officer (by delegation) of Estuary media is: – Ulandi Annandale (as envisaged in the Protection of Personal Information Act, 4 of 2013).
1.3 Estuary Media, “we / us / our” in this, our Privacy Policy (“this Policy”) explains how we protect, process, disseminate and use your/our customers/clients’ Personal Information we collect, as we are sensitive to all person’s personal information.
1.4 This Privacy Policy is available on our website and at our reception desk at Estuary Media’s physical address (business premises) on request, as stipulated above. This Policy must be read together with our Paia Manual – Part A of this document.

2. PROVISION OF PERSONAL INFORMATION AND CONSENT
2.1 By providing us with your Personal Information, you –
2.1.1 agree to the terms and conditions set out in this Privacy Policy and authorise us to retain, process, use and disseminate such information as set out herein, and; –
2.2.2 authorise Estuary Media, its Staff, Members, Service Providers and other third parties to use, disseminate and process your Personal Information for the purposes stated in this Policy.
2.2 We will not use your Personal Information for any other purpose than that set out in this Policy and will endeavour to protect your Personal Information that is in our possession, from unauthorised alteration, loss, disclosure, use, dissemination, or access.
2.3 Please note that we may review and update this Policy from time to time. The latest version of this Policy is available on request, free of charge, at our offices and available on our website. See our contact details herein below.
2.4 This Policy applies to our employees, customers/clients and all external parties with whom we interact, including but not limited to our consultants, agents, individuals, representatives of organisations, visitors to our offices and visitors to our website and social media platforms.
2.5 Defined terms used in this Policy are explained herein below, under the heading “Annexure A”.

3. COLLECTION OF PERSONAL INFORMATION
3.1 We may collect or obtain Personal Information about you / our customers/clients: –
3.1.1 directly from you; –
3.1.2 in the course of our relationship with you/our customers/clients; –
3.1.3 in the course of operating our business as a communication and coaching company; –
3.1.4 when you make your Personal Information public; –
3.1.5 when you visit and/or interact with our Website at www.dynamicvoice.co.za & www.alprodgers.co.za or our Facebook social media platform; –
3.1.6 when you interact with any third party content or advertising on our Website at www.dynamicvoice.co.za & www.alprodgers.co.za and/or our Facebook social media platform; –
3.1.7 when you register to use any of our services;-
3.1.8 when you attend any activity and/or event of whatsoever nature at Estuary Media and/or presented and/or organized by Estuary Media; –
3.1.9 when you visit our offices.
3.2 We may also receive Personal Information about you from third parties (eg, law enforcement authorities).
3.3 In addition to the above, we may create Personal Information about you such as records of your communications and interactions with us, including, but not limited to, electronic communications, your attendance at events or at interviews in the course of applying for a job with us, subscription to our newsletters and other mailings and interactions with you and also during the course of our digital and other marketing campaigns in any form.

4. CATEGORIES OF PERSONAL INFORMATION WE MAY USE AND PROCESS
We may use and process the following categories of Personal Information about you – 
4.1 personal details: full name and surname, photographs; –
4.2 demographic information: gender; date of birth / age; nationality; culture, ethnicity, religion, salutation; title; and language preferences; 
4.3 identifier information: passport or national identity number; utility provider details; –
4.4 contact details: correspondence address; telephone number; mobile number, email address; and details of your public social media profile(s); –
4.5 attendance records: details of meetings and other events organised by or on behalf of Estuary Media that you may and/or may not have attended; –
4.6 consent records: records of any consents you may have given, together with the date and time, means of consent and any related information; –
4.7 payment details: billing address; payment method; bank account number or credit card number; invoice records; payment records; SWIFT details; IBAN details; payment amount; payment date; and records of cheques and EFT payments; –
4.8 data relating to your visits to our Website and or social media platforms, your device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Website and/or social media platform, and other technical communications information; 
4.9 employer details: where you interact with us in your capacity as an employee of an organisation, the name, address, telephone number and email address of your employer, to the extent relevant; and 
4.10 content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages displayed to you, and any interaction you may have had with such content or advertising (including, but not limited to, mouse hover, mouse clicks and any forms you complete).

5. SENSITIVE PERSONAL INFORMATION
5.1 Where and when we need to process, disseminate and/or use your Sensitive Personal Information, we will do so in the ordinary course of the operation of Estuary Media, for a legitimate purpose, and in accordance with applicable law.
Children’s personal information and special personal information
We do not intentionally collect or use personal information of children (persons under the age of 18 years), unless with express consent of a parent or guardian and/or if the law otherwise allows or requires us to process such personal special information.

6. PURPOSES OF PROCESSING AND LEGAL BASES FOR PROCESSING
6.1 We will process your Personal Information in the ordinary course of Estuary Media’ business. We will primarily use your Personal Information only for the purpose for which it was originally or primarily collected.
We will use your Personal Information for a secondary purpose only if such purpose constitutes a legitimate interest and is closely related to the original or primary purpose for which the Personal Information was collected. We may subject your Personal Information to processing, use and/or dissemination and during the course of various activities, including, without limitation, the following: –
6.1.1 Estuary Media as an operational business;
6.1.2 analysis, evaluation, review and collation of information in order to determine legal issues and potential disputes, prepare or comment on opinions, memoranda, agreements, correspondence, reports, publications, documents relating to legal proceedings and other documents and records (whether in electronic or any other medium whatsoever) –
6.1.3 compliance with applicable law and fraud prevention;
6.1.4 transfer of information to our Service Providers and other third parties or
6.1.5 recruitment.
6.2 We may process your Personal Information for relationship management and marketing purposes in relation to our services (including, but not limited to, processing that is necessary for the development and improvement of our software provider and training related services), for accounts management, and for marketing activities in order to establish, maintain and/or improve our relationship with you and with our
Service Providers. We may also analyse your Personal Information for statistical purposes.
6.3 We may process your Personal Information for internal management and management reporting purposes, including but not limited to: conducting internal audits, conducting internal investigations, implementing internal business controls, providing central processing facilities, for insurance purposes and for management reporting analysis.
6.4 We may Process your Personal Information for safety and security purposes.

7. DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES
7.1 We may disclose your Personal Information to our Associates, Agents and Service Providers, for legitimate business purposes, in accordance with applicable law and subject to applicable professional and regulatory requirements regarding confidentiality. In addition, we may disclose your Personal Information –
7.1.1 if required by law;
7.1.2 legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law and/or regulation; –
7.1.3 third party Operators (including, but not limited to, data processors such as providers of data hosting services and document review technology and services), located anywhere in the world, subject to clause 7.2; –
7.1.4 where it is necessary for the purposes of, or in connection with, actual or threatened legal proceedings or establishment, exercise or defence of legal rights; –
7.1.5 to any relevant party for the purposes of the prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including, but not limited to, safeguarding against, and the prevention of threats to, public security; –
7.1.6 to any relevant third party acquirer(s), in the event that we sell or transfer all or any portion of our business or assets (including, but not limited to, in the event of a reorganization, dissolution or liquidation); and
7.1.7 to any relevant third party provider, where our Website and/or social media platforms uses third party advertising, plugins or content.
7.2 If we engage a third party Operator to process any of your Personal Information, we recognise that any Operator who is in a foreign country must be subject to a law, binding corporate rules or binding agreements which provide an adequate level of protection similar to POPIA. We will review our relationships with Operators we engage and, to the extent required by any applicable law if force, we will require such Operators to be bound by contractual obligations to –
7.2.1 only Process such Personal Information in accordance with our prior written instructions; and
7.2.2 use appropriate measures to protect the confidentiality and security of such Personal Information.

8. INTERNATIONAL TRANSFER OF PERSONAL INFORMATION
8.1 We may transfer your Personal Information to recipients outside of the Republic of South Africa.
8.2 Subject to clause 7.2 Personal Information may be transferred outside of the Republic of South Africa provided that the country to which the data is transferred has adopted a law that provides for an adequate level of protection substantially similar to POPIA, the Operator/third party undertakes to protect the Personal Information in line with applicable data protection legislation and the transfer is necessary in order to provide the services that are required by Estuary Media and/or its customers/clients / associates.

9. DATA SECURITY
9.1 We implement appropriate technical and organisational security measures to protect our customers/clients’ Personal Information that is in our possession against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, in accordance with applicable law. We keep hard copies and documentation containing Personal Information, under safe lock and key to which only authorized persons have access to. Electronic data is protected by regular password changes and firewalls.
9.2 Where there are reasonable grounds to believe that your Personal Information that is in our possession has been accessed or acquired by any unauthorised person, we will notify the relevant Regulator and you, unless a public body responsible for detection, prevention or investigation of offences or the relevant regulator informs us that notifying you will impede a criminal investigation.
9.3 Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Information that is in our possession, we cannot guarantee the security of any information transmitted using the internet and we cannot be held liable for any loss of privacy occurring during the course of such transmission.
9.4 Website Links to other sites When you are using our website or other social media platforms you could be directed to other sites that are beyond our control. We are not responsible for the content or the privacy policies of those third party websites.

10. DATA ACCURACY
The Personal Information provided to Estuary Media should be accurate, complete and up-to-date. Should Personal Information change, the onus is on the provider of such data to notify Estuary Media of the change and provide Estuary Media with the accurate data.

11. DATA MINIMISATION
Estuary Media will restrict its processing of Personal Information to data which is sufficient for the fulfilment of the primary purpose and applicable legitimate purpose for which it was collected.

12. DATA RETENTION
Estuary Media shall only retain and store Personal Information for the period for which the data is required to serve its primary purpose or a legitimate interest or for the period required to comply with an applicable legal requirement, whichever is longer.

13. YOUR LEGAL RIGHTS
You may have rights under the South African and other laws to have access to your Personal Information and to ask us to rectify, erase and restrict use of your Personal Information. You may also have rights to object to your Personal Information being used, to ask for the transfer of Personal Information you have made available to us and to withdraw consent to the use of your Personal Information. You may, therefore, on reasonable grounds, object to us using your Personal Information. If you object, we will stop using your personal information, except if the law allows its use.

Lodging a complaint
If you believe we are using your personal information unlawfully, please let us know first at: info@estuarymedia.co.za attention: (Information and Data Protection Officer) Ulandi Annandale (Office Manager)
Landline number: – +27 (0) 74 580 6040
Postal Address: PO Box 88 Jukskei Park, Gauteng, Republic of South Africa
Physical Address: 85 Selborne Road, Johannesburg North, Gauteng, Republic of South Africa

You may lodge a complaint to the Information Regulator (South Africa) with the following contact details:
Complaints email: complaints.IR@justice.gov.za.
General enquiries email: inforeg@justice.gov.za.
Website: https://www.justice.gov.za/inforeg/index.html.
Physical address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
P.O Box 31533, Braamfontein, Johannesburg, 2017

If you are in the European Union or the United Kingdom, the following details may be used for the relevant regulatory authority: –
GDPR: – The European Commission Online Complaint Procedure:
https://ec.europa.eu/info/about-european-commission/contact/problems-and complaints/how-make-complaint-eu-level/submit-complaint en.
Address: European Commission, Secretary-General, B-1049 Brussels, BELGIUM.
The independent Data Protection Authority (“DPA“) per member state – Website listing all DPA’s per member state:
https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
Data Protection Act, 1998 (UK): – The Information Commissioner’s Office: Website: https://ico.org.uk/global/contact-us/ Tel: 0303 123 1113

14. COOKIES AND SIMILAR TECHNOLOGIES POLICY
14.1 We may Process your Personal Information by our use of Cookies and similar technologies in future.
14.2 When you visit our Website and/or social media platforms, we may, in future, place Cookies onto your device, or read Cookies already on your device, subject always in accordance with applicable law. We may, in future, use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We may, in future, process your Personal Information through Cookies and similar technologies, in accordance with our Cookie Policy, which Policy we shall make available via our websites and/or social media platforms if, and when applicable.
14.3 Cookies are information that is used to track visitor use of a Website and to compile statistical reports on Website activity. If you wish to restrict or block cookies, you can do this through your browser settings.
Social Plugins
We may use social plugins of social networks such as Facebook, YouTube, LinkedIn, Google+ and Twitter.

Please note that we have no influence on or control over the extent of the data retrieved by the social networks’ interfaces and we can accordingly not to be held responsible or liable for any processing or use of personal information transmitted via these social plugins. For information on the purpose and extent of the data retrieval by the social network concerned, and about the rights and settings possibilities for the protection of your private sphere, please refer to the data protection information provided by the social network in question.

15. DIRECT MARKETING
15.1 We may Process your Personal Information for the purposes of providing you with information regarding services that may be of interest to you. You may unsubscribe for free at any time.
15.2 If you currently receive marketing information from us which you would prefer not to receive in future please notify us at: info@estuarymedia.co.za – Attention: Information Officer/ Data Protection Officer:
Ulandi Annandale (Office Manager) – or
Landline number: + 27(0) 74 580 6040 – or
Postal Address: PO Box 88 Jukskei Park, Gauteng, Republic of South Africa
Physical Address: 85 Selborne Road, Johannesburg North, Gauteng, Republic of South Africa

16. CONTACT DETAILS
You may contact us at info@estuarymedia.co.za –
Information Officer / Data Protection Officer: Ulandi Annandale (Office Manager)
Landline: +27 (0) 74 580 6040
Postal Address: PO Box 88 Jukskei Park, Gauteng, Republic of South Africa
Physical Address: 85 Selborne Road, Johannesburg North, Gauteng, Republic of South Africa

ANNEXURE A – DEFINITIONS
“Associates” means and include Estuary Media and where applicable, members, partners, directors, customers/clients, agents, employees, consultants of Estuary Media; if and when applicable.
“Cookie” means a small file that is placed on your device when you visit a website. In this Policy, a reference to a “Cookie” includes analogous technologies such as web beacons and clear Graphic Interchange Format files (“GIFs”). You may disable “cookies” by following the instructions to disable it on any of your devices.

“Operator” means any person or entity that Processes Personal Information on behalf of the Responsible Party.
“Personal Information” means information that is about any individual, or from which any individual is directly or indirectly identifiable, 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 individual – which includes children.
Where we refer to “personal information”, it means “personal information” as defined in the Protection of Personal Information Act, 4 of 2013 as amended from time to time (“POPI“), and “personal data” as per the General Data Protection Regulation 2016/679 (“the GDPR“). Personal information includes any information about a person that can be used to identify a person directly or indirectly. It includes information like a name, an identification number, location information, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person. POPI includes the personal information of juristic persons in its ambit – so we will protect the personal information of juristic persons in the same manner as any other person’s personal information.
“POPIA” means the Protection of Personal Information Act 4 of 2013, as amended from time to time.
“Process”, “Processing” or “Processed” means anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Responsible Party” means the entity that decides how and why Personal Information is Processed – For purposes of this Privacy Policy – Estuary Media CC.
“Sensitive Personal Information” means Personal Information about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that may be deemed to be sensitive under applicable law.
“Service Provider” – third party providers of various services whom we engage, including, but not limited to, providers of information technology, communication, file storage, data storage, copying, printing, accounting or auditing services, counsel, experts, investigators, attorneys, legal advisors, translators, taxation consultants and our insurers and professional advisors.

“Website” means www.dynamicvoice.co.za & www.alprodgers.co.za or our Facebook social media platform; -operated, or maintained, by us or on our behalf and includes all social media platforms – if and when we operate such Websites and/or social media platforms.