Data privacy

1. This Privacy Policy (hereinafter referred to as the “Policy”) applies to the use of the website or online shop of Jungheinrich South Africa (Pty) Ltd (hereinafter referred to as “Jungheinrich/we/us/our”) and any interactions between you and us.
2. We gather, store, and use personal information only in line with the contents of this Policy and with applicable data protection provisions, such as: -
   1. The European General Data Protection Regulation (GDPR); and
   2. The Protection of Personal Information Act 4 of 2013 (POPI).
3. We are committed to safeguarding your personal information and we take the protection of privacy and personal information very seriously. We treat your personal information as confidential and in accordance with the applicable statutory data protection provisions.
4. This Policy hereby notifies you that we, in terms of this Policy, collect personal information, as per Art. 12(1) of the GDPR and section 18 of POPI.

This Policy applies to all data subjects (i.e. persons (whether a natural or juristic) to whom the personal information relates), and the personal information we collect and process, whether it was provided to us through the use of our website, our online shop, or through any other form of communication with us, such as email, telephone, or otherwise.

1. The Responsible Party/Controller is Jungheinrich South Africa (Pty) Ltd, a private company duly registered and incorporated in accordance with the laws of the Republic of South Africa with registration number 2015/119219/07and whose registered address is situated at Unit 2, Cheia Crescent, Pomona AH, Kempton Park, 1619, South Africa.
2. If you have any questions regarding data protection, you can send an e-mail to us or to our Information Officer, using the details provided below: -
3. National or Head Office

Postal Address:                   Unit 2, Cheia Crescent, Corner Great North and Deodor Streets, Pomona Kempton Park Gauteng 1619.

Physical Address:               Unit 2, Cheia Crescent, Corner Great North and Deodor Streets, Pomona Kempton Park Gauteng 1619.

Telephone:                           +27 10 596 8460

Email:                                      privacy@jungheinrich.co.za

Website(s):                           https://www.jungheinrich.co.za/

                                                  https://www.jungheinrich-shop.co.za/ 

1. Deputy Information Officer

Name:                                     Mr Richard Tagg

Tel:                                           +27 10 596 8460

Email:                                      privacy@jungheinrich.co.za

1. If you have any questions about how we process and/or treat your personal information, please feel free to contact us using the details above at any time.

1. We will only process personal information in accordance with the relevant data privacy provisions where one of the following grounds is present: -
   1. Where we obtain consent to process your personal information, Article 6(1)(a) of the GDPR and section 11(1)(a) of POPI, serves as the legal basis for data processing.
   2. As far as your personal information is processed because processing is necessary to carry out actions for the conclusion or performance of a contract with you, Article 6(1)(b) of the GDPR and section 11(1)(b) of POPI serves as the legal basis for data processing.
   3. As far as we process your personal information to fulfil a legal obligation, Article 6(1)(c) of the GDPR and section 11(1)(c) of POPI serves as the legal basis for data processing.
   4. Where we process your personal information to protect your legitimate interests, Article 6(1)(d) of the GDPR and section 11(1)(d) of POPI serves as the legal basis for processing.
   5. In cases where processing is necessary for pursuing our legitimate interests or the legitimate interests of a third party to whom the information is supplied, Article 6(1)(f) of the GDPR and section 11(1)(f) of POPI serves as the legal basis for processing.
2. In this Policy, we will always indicate the legal basis upon which we process your personal information.

1. General Use
   1. We collect personal information when you visit our website.
   2. Additional personal information may be collected when you use certain of the services on offer, such as registering on our online shop, subscribing for our newsletter, or when you contact us for any reason. Specific details in relation to these aspects appear in the corresponding sections of this Policy.
   3. When we request personal information, only the information that is mandatory must be provided. Further information can be provided on a voluntary basis. We will indicate whether it is a required or optional field.
2. Server Log Files
   1. When you visit our website, we collect and store information in so-called log files, which your server transmits to us.
   2. In the event that you have consented to cookies on our website, we will collect the following information through the use of log files: 
      1. The IP address of your device;
      2. The date and time of the request;
      3. The location of the device you used, such as the city and province;
      4. The duration of the time spent on our website;
      5. The name and URL of the requested file;
      6. The website/application from which the request was made (referrer URL);
      7. The browser type and version;
      8. the operating system of your Internet-enabled computer; and
      9. the name of your internet provider.
   3. We collect and temporarily store your IP Address, to enable us to transmit the contents of our website to your device, which includes, but is not limited to text, images and files. In order for these actions to occur, your IP Address must be stored by us for the entire duration of your session.
   4. The IP address of your end device and the data listed above are used by us to:
      1. Ensure that a smooth, problem-free connection to our website is established
      2. Ensure ease of use of our website
      3. Evaluate system security and stability
      4. Prosecution in the event of a cyber attack
   5. The supply of such information is mandatory in order to ensure that we can make the content of our website available to you and a failure to provide such information means that you will be unable to use our website.
   6. The legal basis for processing the IP address is Art. 6(1)(f) GDPR and/or section 11(1)(f) of POPI. Our legitimate interest results from the data collection purposes listed below. Please note that the collected data does not give us any indication as to your identity, nor do we use it to draw any conclusions about your person.
   7. The information collected by the us through server log files is not used for marketing purposes.
   8. The information collected through server log files will be deleted as soon as possible once the purpose for its collection has been fulfilled. As a general rule, the information collected in server log files is deleted following the expiry of a period of 180 (One Hundred and Eighty) days. Where information is stored for a longer period, we ensure that your IP Address is deleted or altered to ensure that you can no longer be identified from such information.
3. Use of content delivery networks (CDN)
   1. Any access to our websites or log files involves the use of the content delivery network (CDN) Amazon CloudFront. The provider is Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, L-1855 Luxembourg. The legal basis is Art. 6(1)(f) GDPR and/or section 11(1)(f) of POPI. In this instance, our legitimate interest lies in the secure, stable and efficient operation of our website via a CDN as well as the rapid delivery of required data to the visitors of our website with low latency and high transfer rates. In particular, fonts, images, CSS and JavaScript files as well as PDF documents are delivered via a Cloud architecture with a global server infrastructure.
   2. Further information can be found at:
      1. https://aws.amazon.com/de/cloudfront/
      2. https://d1.awsstatic.com/legal/aws-gdpr/AWS_GDPR_DPA.pdf
4. Cookies – General Information
   1. On our website, we use cookies or other storage technologies (local storage, session storage) of your browser. Cookies are small files that are created automatically by your browser and stored on your end device (laptop, tablet, smartphone, etc.) when you visit our website. Cookies do not cause damage to your device, and they do not contain any viruses, Trojans or other malware.
   2. The information stored in the cookie is produced in connection with the specific end device used. However, this does not mean that we can obtain direct knowledge of your identity from this information.
   3. The use of cookies is intended to make the use of our website a more pleasant experience for you. For example, we use session cookies to determine that you have previously visited specific pages of our website. These are erased automatically when you leave our site. In addition, we use temporary cookies to make our website more user-friendly. These temporary cookies are stored on your end device for a specific set period. If you visit our website again to take advantage of our services, the cookies will automatically recognise that you have visited the site previously and remember the entries and settings that you made so that you do not have to re-enter these details.
   4. We also use cookies to record statistics pertaining to the use of our website, to evaluate these statistics in order to optimise our website for you, as well as to display personalised information. If you re-visit our website, these cookies will automatically recognise that you have accessed the site previously. These cookies are automatically deleted after a predefined time. Most browsers accept cookies automatically.
   5. Cookies are stored on your device and transmitted to us. As such, you have full control over our use of such cookies and the supply of such information is entirely voluntary.
   6. You are able to alter your cookie setting in your internet browsers and can disable or restrict the transmission of cookies. Saved cookies are can also be deleted at any time.
   7. However, you may only have access to a restricted version of our website, or not at all, if you reject the storage of cookies or delete the necessary cookies.
   8. The information collected through this cookie is stored on your browser until such time as you clear and/or delete your stored cookies.  This information is stored on the individual’s browser and will remain private until the induvial deletes this information. The website will not be able to take this information and identify an individual.
   9. The storage period for cookies depends on their individual use and is not the same in all cases. The individual storage periods for cookies can be found here.
   10. The legal basis for processing information collected though our use of cookies is: -
       1. Based on your consent in terms of Section 11(1)(a) of POPI; and/or
       2. our legitimate interests in the proper and user-friendly functioning of our website in terms of section 11(1)(f) of POPI.
   11. We do not share the information we collect via cookies to any other person.
   12. Further information on the specific types of cookies we use may be found in the paragraphs which follow below.
5. "jh_medium" cookie for traffic channel tracking
   1. We use the "jh_medium" cookie to store general "channel information" concerning your visit to our website. For this purpose, we use a script that we have developed in-house to record the source of your visit so that we can evaluate the success of these channels (example value: "SEO").
   2. The cookie currently has a maximum lifespan of 6 (Six) months. This time can vary according to your browser and may be shorter.
   3. No personal data is stored in this cookie. In particular, no IP addresses or user IDs are stored, nor is any website usage behaviour analysed.
6. Google Analytics
   1. We use Google Analytics primarily to pursue our legitimate interest in the statistical analysis of our website and online activities as well as to support the needs-based design and ongoing optimisation of our web presence.
   2. This is a web analysis service provided by Google LLC (formerly Google Inc.), 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The responsible service provider for the European Union is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland – hereafter referred to as "Google".
   3. Where you have consented to the "statistics" category via our cookie banner or cookie consent tool, we will collect your personal information through the use of this cookie. This information includes the following:
      1. Browser type/version
      2. Language settings
      3. Operating system used
      4. Host name of the accessing computer (IP address)
      5. Referrer URL (the page previously visited)
      6. Time of the server request
      7. Loaded pages (URLs and page titles)
      8. Events such as PDF downloads, navigation clicks, etc.
      9. Usage behaviour such as session length, scroll depth, drop-offs
   4. To this end, we have concluded a commissioned data processing agreement with Google in which comprehensive data protection is ensured by means of standard contractual clauses. In this context, cookies are used, pseudonymous user profiles created, and information collected.
   5. The collected information regarding your usage of our website is combined with a pseudonymous ID (clientID) and transferred to Google servers via an encrypted connection (SSL, HTTPS) and subsequently stored. 
   6. We only use Google Analytics with active IP anonymisation. This means that the user's IP address is truncated by Google within member states of the European Union or in other countries party to the Agreement on the European Economic Area.
   7. Only in exceptional cases is the full IP address transferred to a Google server in the USA before being truncated. In addition to Google LLC, with headquarters in California, USA, the transmitted and stored data may also be accessed by US authorities in individual cases and under specific legal conditions.
   8. Google uses this information on our behalf in order to analyse the usage of our website by visitors, to measure the success of campaigns (e.g. via the Google Ads advertising platform), to compile reports regarding the activities on our website and to deliver additional services related to the usage of this website and general internet use.
   9. We have configured Google Analytics such that the transmitted data, which is linked to cookies or client IDs, is automatically deleted after 14 (Fourteen) months, at which point only aggregated data remains. Any data the retention period of which has been reached is automatically deleted by Google once per month.
   10. The collection of this information takes place exclusively based on your consent in accordance with Article 6(1)(a) of the GDPR and section 11(1)(a) of POPI, which consent may be revoked at any time.
   11. In general, users can prevent the saving of cookies or running of scripts such as Google Analytics by configuring the settings in their browser software or by using appropriate plug-ins. In this case, however, users may no longer be able to use all features and functions of this website in full.
   12. If you want to prevent Google Analytics from running, you can do so at any time and with future effect by one of the following methods:
       1. You can revoke your previously granted consent to data collection at any time and with future effect by rejecting the use of cookies and scripts for statistical purposes in our cookie consent manager.
       2. You can download and install Google's official opt-out browser plug-in via the following link in order to deactivate Google Analytics on all websites in your current browser: https://tools.google.com/dlpage/gaoptout
       3. You can use this link to set an opt-out cookie that prevents any future data collection by Google Analytics on this website with your current browser. Note that if you delete all cookies in your browser, you will have to set this opt-out cookie again.
   13. Additional information as well as Google data protection provisions and settings can be found here:
       1. https://policies.google.com/privacy
       2. https://policies.google.com/terms
       3. https://policies.google.com/terms/information-requests
       4. https://marketingplatform.google.com/about/analytics/terms/de/
7. Google Optimize
   1. Google Optimize is a web analysis and optimisation service as well as an extension/sub-service of Google Analytics (see section on Google Analytics). Once again, the provider is Google LLC (formerly Google Inc.), 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The responsible service provider for the European Union is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland – hereafter referred to as "Google".
   2. We use Google Optimize in combination with Google Analytics to pursue our legitimate interest in the statistical analysis of our website as well as to support the needs-based design and ongoing optimisation of our site.
   3. If you consented to the "statistics" category via our cookie banner or cookie consent, we may collect personal information from your through the use of this service in accordance with Art. 6(1)(a) of the GDPR and/or section 11(1)(a) of POPI.
   4. For additional information as well as Google data protection provisions and settings, refer to the section on Google Analytics, where you will also find information on objecting to these Google services.
8. Google Signals and Google remarketing / DoubleClick
   1. If you consented to the “statistics” and "marketing" categories via our cookie banner or cookie consent tool, we also activate the Google Analytics extension Google Signals on our website.
   2. With Google Signals, Google Analytics (see section on Google Analytics) records additional information such as demographic data and interest categories for Google users, who have activated personalised ads in their Google settings. Google links this data with individual signals to enable cross-device analyses. However, Google Analytics only makes this data available in anonymised form as aggregated reports, which enable an analysis of general behavioural patterns. We are unable to personally identify you on this basis.
   3. We use Google Signals to better understand the digital journey of our users and to provide personalised ads to users who have previously visited our website (retargeting). To this end, special target groups or Google audiences are created within Google Analytics, which can then be used as remarketing lists via Google's advertising platform Google Ads and, if necessary, DoubleClick cookies in order to provide cross-device, personalised advertising to selected target groups. In this case, the ads can be displayed in Google's advertising network, which includes Google Search, YouTube, other Google products as well as third-party websites that display ads from Google customers.
   4. For this purpose, Google may use the DoubleClick cookie on websites of the Google advertising network and for specific Google services to assist Google Ads customers and publishers with the placement and management of ads on the web. When you open a website and display or click on an ad placed via websites of the Google advertising network, a DoubleClick cookie may be stored in your browser. The DoubleClick cookie ID assigned to your browser is the same as that used when visiting websites on which DoubleClick advertising programs are used. If your browser already has a DoubleClick cookie, no further DoubleClick cookie should be stored.
   5. Once again, the provider is Google LLC (formerly Google Inc.), 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The responsible service provider for the European Union is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland – hereafter referred to as "Google".
   6. The activation of this service takes place exclusively based on your consent, which consent may be revoked at any time.
   7. If you object to the use of Google Signals, you can revoke your previously granted consent for marketing purposes in our cookie consent manager. and deactivate personalised ads in your personal Google settings: https://adssettings.google.com/
   8. Further information on Google Signals and Google's data protection provisions can be found here:
      1. https://support.google.com/analytics/answer/7532985
      2. https://policies.google.com/privacy
9. Facebook pixel (remarketing service)
   1. If you consented to the "marketing" category via our cookie banner or cookie consent tool, we may collect personal information from you through the use of the "Facebook pixel" tool of the social network Facebook on our website.
   2. The "Facebook pixel" is operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA or, if you are based in the EU, by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook").
   3. We use the "Facebook pixel" for the following purposes:
      1. Advertising/remarketing:

The "Facebook pixel" allows Facebook to assign visitors of our website to specific target groups ("custom audiences" or "lookalike audiences") in order to display specific advertising and content to these users ("Facebook ads"). Accordingly, we use the "Facebook pixel" to display our placed Facebook ads to those Facebook users who have shown an interest in our online content or who possess specific characteristics (e.g. interests in specific topics or products determined on the basis of the websites visited), which are transmitted to Facebook.

1.  
   1.  Statistical analysis:

In addition, we use the "Facebook pixel" to measure, analyse and optimise the advertising we post on Facebook, for example, to understand whether users interact with our website after seeing and potentially clicking on an ad.

1. No "advanced data matching" takes place and no e-mail addresses are uploaded to Facebook (known as "custom audiences from file").
2. This also allows Facebook to use the following data for its own purposes:
   1. Usage data (e.g. visited websites, interest in contents)
   2. Metadata and communication data (e.g. device type, access times, IP addresses)
   3. Location data (provided that your end device is transmitting its location).
3. By using the "Facebook pixel", we also want to ensure that our Facebook ads match the potential interests of users and are not perceived as annoying.
4. We collect and process this personal information based exclusively on your consent in accordance with Art. 6(1)(a) of the GDPR and/or section 11(1)(a) of POPI, which consent can be revoked at any time.
5. If you do not agree with this usage and/or wish to object to it, you can do so by adjusting your Facebook settings accordingly at  https://www.facebook.com/settings?tab=ads.
6. Moreover, you can revoke your previously granted consent to the use of the "Facebook pixel" at any time and with future effect by selecting "Change your consent" or "Revoke your consent" under "Cookies" at the bottom of our website.
7. Information on the processing of your data by or via Facebook can be found at https://www.facebook.com/about/privacy. 
8. LinkedIn Insight Tag
   1. If you consented to the "marketing" category via our cookie banner or cookie consent tool, we may collect personal information through the use of the "LinkedIn Insight Tag" of the social network LinkedIn on our website.
   2. The LinkedIn Insight Tag is operated by LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA or, if you are based in the EU, by LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland.
   3. We use the "LinkedIn Insight Tag" for the following purposes:
      1. Advertising/remarketing:

The LinkedIn Insight Tag allows LinkedIn to assign visitors of our website to specific target groups ("matched audiences") in order to display relevant advertising and content to these users ("LinkedIn ads"). Accordingly, we use the "LinkedIn Insight Tag" to display our placed LinkedIn ads to those LinkedIn users who have shown an interest in our online content or who possess specific characteristics (e.g. interests in specific topics or products determined on the basis of the websites visited), which are transmitted to LinkedIn.

1.  
   1.  Statistical analysis:

In addition, we use the "LinkedIn Insight Tag" to measure, analyse and optimise the advertising we post on LinkedIn, for example, to understand whether users interact with our website after seeing and potentially clicking on an ad.

1. This also allows LinkedIn to use the following data for its own purposes:
   1. Usage data (e.g. visited websites, interest in contents)
   2. Metadata and communication data (e.g. device type, access times, IP addresses)
   3. Location data (provided that your end device is transmitting its location)
2. By using the "LinkedIn Insight Tag", we also want to ensure that our LinkedIn ads match the potential interests of users and are not perceived as annoying.
3. We collect and process this personal information based exclusively on your consent in accordance with Art. 6(1)(a) of the GDPR and/or section 11(1)(a) of POPI, which consent can be revoked at any time.
4. If you do not agree with this usage and wish to object to it, you can do so by adjusting your LinkedIn settings accordingly at: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
5. Moreover, you can revoke your previously granted consent to the use of the "LinkedIn Insight Tag" at any time and with future effect by selecting "Change your consent" or "Revoke your consent" under "Cookies" at the bottom of our website.
6. The data collected via the LinkedIn Insight Tag is encrypted and anonymised within a period of 7 days. LinkedIn does not share any personal data with the website owner, but instead provides only summarised reports regarding the website target group and ad performance.
7. Information on the processing of your data by or via LinkedIn can be found at https://www.linkedin.com/legal/privacy-policy. 
8. Contact Us Form
   1. Should you send us an inquiry using the contact form on our website, we may collect the following personal information from you: -
      1. Your title;
      2. Name and surname;
      3. The name of the company you work for;
      4. Your address, postal code, city and country;
      5. Email address;
      6. Telephone number; and
      7. The content of your request.
   2. The contact information you provide, will be processed by us for the sole purpose of responding to your inquiry and any follow-up questions you may have in response to us.
   3. It is mandatory to supply certain information to allow us to respond to your request, whereas the supply of additional information is voluntary. You will recognise the mandatory information which must be supplied by an asterisk “*” which appears in the relevant field.
   4. The information contained in the contact form is processed based on: -
      1. your consent in terms of Art. 6(1)(a) of the GDPR and/or section 11(1)(a) of POPI, which consent may be revoked at any time;
      2. Art. 6(1)(b) of the GDPR and/or section 11(1)(b) of POPI, to the extent that such contact with us is aimed at concluding or entering into a contract; and
      3. our legitimate interest in responding to your inquiry in accordance with Art. 6(1)(f) of the GDPR and/or section 11(1)(f) of POPI.
   5. Your information may be saved in our customer relationship management (CRM) system or a comparable means of enquiry organisation.
   6. We utilise the CRM system "SAP Hybris Cloud for Customer" and "SAP CRM" of the provider SAP on the basis of our legitimate interests pursuant to Art. 6(1)(f) GDPR and/or section 11(1)(f) of POPI (efficient and rapid processing of user enquiries).
   7. For this purpose, we have concluded a contract with the service provider on the basis of Art. 28 GDPR and/or section 21 of POPI, in which the service provider undertakes to process your personal information solely in accordance with our instructions and to maintain data protection levels in keeping with EU regulations and local laws.
   8. We will process the information provided by you on the contact form until such time as you request its deletion, revokes your consent or where it may be inferred from the circumstances that the request has been resolved, whereafter the personal information will be deleted, unless another ground for continued retention applies.
9. Newsletter
   1. Our newsletter provides you with the latest news and offers from Jungheinrich.
   2. You are able to subscribe for a free newsletter on our website. When subscribing, we collect, inter alia, the following personal information from you:
      1. Title;
      2. First name;
      3. Surname;
      4. Company;
      5. Postal Code;
      6. City;
      7. Country; and
      8. Email address.
   3. We ensure that we obtain your consent at the time that we collect this personal information as well as your agreement to the contents of this Policy.
   4. We collect this information in order to provide you with our newsletter.
   5. It is mandatory to supply certain information to allow us to process your request, whereas the supply of additional information is voluntary. You will recognise the mandatory information which must be supplied by an asterisk “*” which appears in the relevant field.
   6. We will process the personal information provided during the registration process based on: -
      1. the data subject’s consent in terms of Article 6(1)(a) of the GDPR and section 11(1)(a) of POPI, which consent may be revoked at any time; and
      2. our legitimate interest in keeping you informed of relevant product news, special offers and promotions and shows and events which may be of interest to you in accordance with Article 6(1)(f) of the GDPR and section 11(1)(f) of POPI.
   7. We will not disclose the data subject’s personal information to any other person.
   8. For as long as you remain subscribed to our newsletter, we will process your personal information for the purposes of sending you the newsletter.
   9. You can received news and current offers from Jungheinrich via our newsletter and emails. If you have entered your e-mail address under the heading "Newsletter", clicked on the "Subscribe" button and confirmed your subscription to us again via the link sent to the e-mail address you entered (double opt-in), we will process and use your e-mail address to send you the requested newsletter on a regular basis. 
   10. Within the scope of the registration for the newsletter as well as for sending information to you, we use the marketing automation software Marketo Engage of Marketo EMEA Limited, 4-6 Riverwalk Drive, Citywest Business Campus, Cooldown Commons, Dublin 24, Ireland.
   11. For this purpose, we have concluded a contract with the service provider on the basis of Art. 28 of the GDPR and/or section 21 of POPI, in which the service provider undertakes to treat information confidentially, process your personal information solely in accordance with our instructions and to comply with the applicable data protection provisions. Any forwarding of data to third parties within the meaning of the GDPR is excluded.
   12. You have the right and the opportunity to unsubscribe from the newsletter at any time. A corresponding "Unsubscribe" link is provided at the end of every newsletter. Alternatively, you can unsubscribe on our website via the "Newsletter Unsubscribe" link in the footer.
   13. Personal Data Processed
       1. With the help of Marketo, we collect data about the use of our website and communication measures in order to optimise our offer accordingly and to conduct email marketing, personalisation and sales activities. In doing so, the processing is partly automated with the aim of evaluating certain personal aspects (profiling / customer segmentation)
       2. The following master data is affected: Customer and prospect data (e.g. name, company address), business-related data (e.g. role, profession), marketing consents (e.g. newsletter consent), website usage data (e.g. length of visit, click behaviour, number of pages viewed, documents downloaded), data from marketing campaigns (e.g. website visits, webinar registrations), contract and delivery information (e.g. order or delivery date) and customer satsifaction data (e.g. from surveys)
       3. In addition, we store information about the browser you use and the settings made in your operating system as well as information about your internet connection with which you have accessed our website via the newsletter sent to you, we receive, among other things, receipt and read confirmations as well as information about the links you have clikced on in our newsletter. We also store which areas you have visited within our website and in our apps. 
   14. Legal Basis
       1. The legal basis for processing your personal data in Marketo and sending emails or newsletters to you is your consent in the contact form (seperate checkbox for newsletters) or the newsletter form. Ordering the newsletter is voluntary and the data processing is based on your consent within the meaning of Art. 6 (1) (a) DS-GVO and/or section 11(1)(a) of POPI.
       2. Based on your consent via the cookie banner or the cookie consent tool, we will evaluate your user behaviour on our websites as well as within the newsletter we send and assign it to your email address / user profile within our database.
       3. For more information on data protection at Marketo, please visit:
          1. https://www.adobe.com/africa/legal.html
   15. Cookies and Tracking
       1. Marketo collects your IP address and uses cookies to track and analyze site usage in order to provide information specifically tailored to the user's interests. For more information about cookies, please see "Cookies - General Information". The information generated by the cookies is transferred to a Marketo server (located within the EU/EEA) and stored there. You can prevent the storage of cookies by setting your brwoser accordingly. Broswer settings mad by you may, however, result in you possibly not being able to use all functions of our online offer.
   16. To protect your privacy
       1. You can object to the processing of your personal data at any time.
       2. Newsletter: you have the right and the possibility to unsubscribe from the newsletter distribution list at any time. At the end of each newsletter you will find a corresponding unsubscribe link. Alternatively, you can unsubscribe on the website using the link in the footer "Newsletter unsubscribe" or send and email to newsletter@jungheinrich.co.za with the unsubscribe request. 
       3. Tracking: You can revoke a previously given consent to data collection at any time with effect for the future by rejecting the use of cookies and scripts for statistical purpose in our Cookie Consent Manager Cookies | Jungheinrich - Intralogistics Experts
       4. To prevent you from being shown personalised advertising outside of our online offering, you can also adjust the advertising settings in your user accounts on various online platforms (e.g. Google) and deactivate personalised advertising.
   17. In the context of the processing of personal data with Marketo, only data centers in the EU are used. In the event that data is nevertheless processed in the USA, for example for maintenance and support, the European standard contractual clauses apply.
   18. Contacting:
       1. When contacting us (via contact form or email), the user's details are processed for the purpose of handling the contact request and its processing pursuant to Art. 6 (1) letter b DS-GVO and/or section 11(1)(a) of POPI. (for the performance of pre-contractual measure)
       2. The user's details may be stored in our Csutomer Relationship Management System ("CRM System"), in our Marketing Automation System (Marketo EMEA Limited, 4-6 Riverwalk Drive, Citywest Business Campus, Cooldown Commons, Dublin 24, Ireland) or comparable inquiry organisation.
       3. In Germany, we use the CRM system "SAP Hybris Cloud for Customer" and "SAP CRM", of the provider SAP on the basis of our legitiamte interests (efficient and fast processing of user requests). For this purpose, we have concluded a contract with the provider in accordance with Art. 28 DS-GVO, in which the provider undertakes to process user data only in accordance with our instructions and to comply with EU data protection level.
       4. In the event that you select the category Investor Relations, Press or HR, we process your data exclusively for the purpose of responding to your inquiry. The data will only be kept as long as it is necessary to fulfill the respective purpose. (Depending on which categories are specified in the form, the text must be adapted accordingly).
10. Website security
    1. Our website uses Secure Socket Layer (SSL) encryption to ensure that any information which is transmitted, including personal  and/or payment data, is secure and protected.
    2. SSL is a secure, tried-and-tested standard which is also used in online banking, for example and information transmitted in this manner cannot be read by third parties.
    3. You can recognize an encrypted connection in their browser's address bar when it changes from "http://" to "https://" and the system-specific lock icon is displayed in your browser's address bar

1. General information

We may integrate services and content of third parties on our website. These services include social media functions, videos, map services, CAPTCHA services, tag management services and cookie consent tools. Information on how we use the individual services is provided below.

1. LinkedIn Lead Gen Form
   1. If, as part of our ad campaign, you complete a form ("LinkedIn Lead Gen Form") on the social network LinkedIn and transmit it to us, you will provide us with personal information which we will use for standard advertising purposes – in particular, to contact you by phone and to provide you with information about our products that may be of interest to you.
   2. Information on the service provider LinkedIn and on LinkedIn's data privacy statement is provided in the section above ("Accessing our website").
   3. In transmitting the form to us, you consent to the usage of the transmitted data (Art. 6(1)(a) of the GDPR and/or section 11(1)(a) of POPI).
   4. You have the right to revoke this consent at any time without stating reasons. To do so, please send an e-mail to privacy@jungheinrich.co.za.
   5. Upon receipt of your revocation, we will ensure that the information we collect in this manner is not processed any further. However, the legality of any processing which takes between consent and revocation will not be affected.
2. Friendly Captcha
   1. We use the “Friendly Captcha” service from Friendly Captcha GmbH, Am Anger 3-5, 82237 Wörthsee (Germany) on our website. Friendly Captcha is used to check whether data is entered on our website (e.g. in a contact form) by a human or by an automated program. For this purpose, Friendly Captcha collects the following log data:
      1. The request headers User-Agent, Origin and Referrer.
      2. The cryptographic puzzle, to solve by your Browser.
      3. The version of the Friendly Captcha widget used on our website.
      4. A timestamp.
      5. An anonymized counter per IP address. The IP address is anonymized by Friendly Captcha using a one-way hash function.
      6. Friendly Captcha does not ask for other information or personal information, such as your name, email, and online profiles.
   2. The data processing that takes place in connection with the use of Friendly Captcha is carried out for the purpose of being able to guarantee the security of our websites. The legal basis for data processing is Art. 6 (1) (f) GDPR. Our legitimate interest lies in the fulfilment of legal requirements to ensure the security of data processing. Further information on how Friendly Captcha handles your data can be found on the website and in the data protection declaration of the provider, which can be accessed via the following links:
      1. https://friendlycaptcha.com/
      2. https://friendlycaptcha.com/legal/privacy-end-users/
3. Google Maps
   1. We use Google Maps on our website to display our location and create route directions. This is a service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA, hereafter referred to as "Google". 
   2. To allow specific fonts to be displayed on our website, a connection to the Google server in the USA is established when our website is opened.
   3. If you access the Google Maps component integrated in our website, Google will save a cookie on your end device via your internet browser. To display our location and create route directions, your user settings and data are processed. We cannot exclude the possibility of Google employing servers in the USA for this purpose.
   4. The legal basis in this case is your consent in accordance with Art. 6(1)(a) of the GDPR and/or section 11(1)(a) of POPI. The integration of this service subsequently also supports our legitimate interest in optimising the functionality of our website.
   5. The connection thus established to Google allows Google to identify from which website your request originates and to which IP address the route description is to be transmitted. If you do not agree with this processing of data, you can choose to block the installation of cookies by making corresponding settings in your internet browser.
   6. In addition, Google Maps and the information obtained via Google Maps are used in accordance with the Google terms of service and the additional terms of service for Google Maps. Further details are also available at https://adssettings.google.com/authenticated and https://policies.google.com/privacy.
4. Google Tag Manager
   1. We also make use of Google Tag Manager based on our legitimate interest in the analysis, optimisation and efficient operation of our online presence.
   2. This service is provided by Google LLC (formerly Google Inc.), 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The responsible service provider for the European Union is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland – hereafter referred to as "Google".
   3. This service allows website tags to be managed via an interface. Google Tag Manager implements scripts and general services on our website according to defined rules and triggers, and these in turn may use cookies, tracking pixels or similar technologies and also collect personal information.
   4. Google Tag Manager does not itself act as a tracking or analysis service but instead enables integration of such services as well as the inclusion of opt-out scripts (means of objecting) and similar functions. Google Tag Manager thus serves as an invaluable aid when it comes to fulfilling transparency and legal obligations in the sphere of data privacy.
   5. For example, based on the consent you may have given via our cookie consent manager, we can use this service to control whether or not analysis or ad services are integrated in our website.
   6. Further information on Google Tag Manager and Google data protection is available via the following links:
      1. https://marketingplatform.google.com/about/analytics/tag-manager/use-policy/
      2. https://policies.google.com/privacy
      3. https://policies.google.com/terms
   7. Users have the option of preventing the future transmission of statistical and marketing tags from Google Tag Manager.
   8. To do so, the user must click on this opt-out link in order to set a Google Tag Manager deactivation cookie in their internet browser. This blocks any future integration via Google Tag Manager for this browser only, and not for other browsers and/or end devices.
   9. No existing cookies are deleted. Moreover, we expressly point out that users may no longer be able to use all features and functions of the website in this case. If you delete all cookies in your browser, you will have to set the opt-out cookie again.
5. CookieBot
   1. As a further means of complying with our legal obligations, our website also uses the cookie consent manager/tool CookieBot, provided by Cybot A/S, Havnegade 39, 1058 Copenhagen, Denmark.
   2. The CookieBot service allows us to provide you with comprehensive information regarding the use of analysis and ad services as well as their cookies and to obtain and manage your consent to data processing. In particular, the following data is collected:
      1. The truncated (and thereby anonymised) IP address
      2. The date and time of consent
      3. Browser information
      4. The URL from which the consent was submitted
      5. An Anonymous, random and encrypted key
      6. The user's consent status
   3. The data is then stored by CookieBot as proof of the user's consent. The key allows the user's consent to be checked retrospectively.
   4. The key and the corresponding consent status are stored in the "CookieConsent" cookie for a period of 12 months. This ensures that the user's settings remain intact for all future page requests on our website without the user having make a new selection upon each visit.
   5. The use of cookie bot and the processing of any personal information collected through the service is based on our legitimate interest in accordance with Art. 6(1)(f) of the GDPR and/or section 11(1)(f) of POPI.
   6. Further information on the data protection provisions of CookieBot or Cybot A/S can be found here: https://www.cookiebot.com/de/privacy-policy/
   7. The overview created by CookieBot for our website can be found here.
6. YouTube
   1. If you consented to the "marketing" category via our cookie banner or cookie consent tool, we may use functions of the YouTube service to display and play back videos on our website. These functions are provided by YouTube, LLC 901 Cherry Ave. San Bruno, CA 94066, USA. Additional information is provided in the YouTube privacy policies.
   2. In this case, the enhanced data protection mode is used which, according to the provider, ensures that user information is only stored during video playback. When the user initiates playback of embedded YouTube videos, 
   3. YouTube may employ cookies or other storage technologies to collect information regarding user behaviour. According to YouTube, this is done, among other things, to record video statistics, improve usability and prevent misuse.
   4. Independently of any playback of the embedded videos, the integration of the YouTube service may also result in a connection being established to the Google network "DoubleClick", which can trigger additional data processing operations over which we have no influence.
   5. Further details regarding the use of YouTube, data protection provisions and setting options can be found here: 
      1. https://adssettings.google.com/authenticated
      2. https://policies.google.com/privacy
      3. https://myaccount.google.com/yourdata/youtube
      4. https://www.youtube.com/static?template=terms
      5. https://www.youtube.com/intl/ALL_de/howyoutubeworks/user-settings/privacy/
      6. https://www.youtube.com/intl/ALL_de/howyoutubeworks/user-settings/ad-settings/
      7. https://www.youtube.com/intl/ALL_de/howyoutubeworks/our-commitments/protecting-user-data/
7. Vimeo
   1. To enable remote access to our press conference on financial statements, Jungheinrich offers a corresponding video transmission service. For this transmission, we employ the services of the provider Vimeo, Inc., 555 West 18th Street, New York, New York 10011, USA.
   2. Jungheinrich does not obtain any personal data as a result of the data processing.
   3. For technical reasons, use of this video function requires access to Vimeo servers. With regard to the associated use of data from your browser or end device, we refer you to the relevant data privacy notices of the provider or of the controller responsible for this aspect of data processing. Vimeo's data privacy policies can be found at: https://vimeo.com/privacy
8. Excentos product guides
   1. We employ product guides on our website to provide users with online product advice, thereby facilitating the product selection process and allowing us to offer improved customer service.
   2. The provider of the product guides is excentos Software GmbH, Reiterweg 1, 14469 Potsdam, Germany.
   3. The product guides record the activities of the user, such as selected response options and navigation activities in the product guide. This usage data is permanently stored in a web analysis system operated by excentos.
   4. No IP addresses are stored in the web analysis system and all stored data is anonymised. In addition, the product guides or the necessary server services collect the IP address and activities of the user based on a balancing of interests in order to protect against cyber-attacks. This precautionary measure is essential for us to be able to offer our services.
   5. The data is retained only temporarily in order to identify potential attack patterns. Thereafter, the IP addresses incl. all log data are fully erased. The user activities during a session with the product guide are also recorded. This is necessary for the basic function of the product guide, including its interactions and generated recommendations. This data is merely held in the memory but is not stored persistently. 
   6. The product guides will only be available on our website if you have consented to the "marketing" category via our cookie banner or cookie consent tool (consent according to Art. 6(1)(a) of the GDPR and/or section 11(1)(a) of POPI). By using the product guides as well the advice, search and chatbot systems provided on this website, you declare your consent to these conditions. 
   7. Accordingly, we collect and process information through the product guides based exclusively on your consent, in accordance with Art. 6(1)(a) of the GDPR and/or section 11(1)(a) of POPI), which consent may be revoked at any time.
   8. When using the product guides integrated in this website, you can prevent the collection of your data by the excentos web analysis system and view or change the status by clicking the following link. This sets an opt-out cookie, which prevents the collection of your data on future visits to this website.
   9. Alternatively, you can revoke your previous consent for marketing purposes, in which case the excentos product guides will no longer be loaded on our website.
9. Jungheinrich Chat
   1. You can rest assured that your personal data is secure. We want to offer you an easy way to get in touch with us through our chat function Cognigy. Please note the following information in the processing of your data:
      1. It is not necessary to provide personal information to use Jungheinrich's digital assistant. We recommend that you do not share such information.
      2. by using our digital assistant, you agree to this privacy policy. The processing of your personal data as part of the chat function is based on your consent according to Art. 6(1)(a) of the GDPR and/or section 11(1)(a) of POPI.
      3. All data collected in the chat will be deleted after 30 days at the latest. Your data will be transferred to the service provider Cognigy, which offers the chat funtion. Cognigy is contractually obliged to protect your data in accordance with applicable privacy laws, and data processing by Cognigy takes place exclusively within the European Union (EU). Address: Cognigy GmbH, Speditionstrasse 1, 40221 Dusseldorf, Germany.
      4. Jungheinrich AG, Friederich=Ebert-Damm 129, 22047 H amburg, Germany is responsible for the processing of your personal data in connection with Jungheinrich's chat function.
   2. If you want to get in touch with our customer service, you will be forwarded to human customer advisors inside the digital assistant. You can withdraw your consent to use the chat at any time. All personal data stored in connection with the use of the chat will then be deleted.

1. We welcome your interest in working for our company and look forward to receiving your online application.
2. By accepting our data privacy declaration for our online application process, you agree that we, as well as the Jungheinrich Group at large may save and process your personal information for the purposes of considering your application for employment.
3. Data collection

Following submission of your application for employment, we collect and process, inter alia, the personal information listed below:

1. Last name;
2. First name;
3. Address and telephone number;
4. Email address; and/or
5. Application documents (covering letter, CV, credentials, certificates, etc.).
6. Purpose for which personal information is processed

The personal information collected by us through the application process is used to consider your suitability for employment with us, as well as to communicate with you regarding the outcome of your application.

1. Mandatory/Voluntary Supply of information
   1. In order for us to consider your application, certain mandatory information must be provided. The supply of any additional information takes place on an entirely voluntary basis.
   2. In the event that you do not provide the mandatory information to consider your employment, we will be unable to consider your application and/or offer you employment.
   3. We will be sure to inform you whether we require any additional information in order to consider your application.
2. Cross Border Transfer of Information
   1. Access to your personal information is granted to the relevant employees of the Jungheinrich Group who are involved in the personnel selection process. The parties involved in the selection process may be employed by different companies of the Jungheinrich Group and based in different locations and/or countries.
   2. As a result, your application data may be transferred within the Group as necessary. Any further use or forwarding of the personal information contained in your application is excluded
3. Data security

The personal information contained in your application will be transmitted in an encrypted manner and then stored in our database. We will save and process your data in accordance with the applicable data privacy regulations. At all times, we will ensure that your personal information remains secure and confidential by using appropriate technical and organizational measures to protect against loss, destruction, access, alteration or dissemination of your data by unauthorized persons.

1. Applicant pool

If you have applied for a specific position that has already been filled, or if we consider you to be equally or better suited to a different position, or if you submitted a speculative application, we will forward your application within our Group so that you may be considered for future application procedures – provided that you have consented to this processing of your personal information.

1. Deletion of data / revocation of consent

Should you withdraw your application, or if your application is unsuccessful, your personal information will be deleted immediately. If you wish to object to the collection, processing and use of your personal data within the scope of the consent given as part of the application process, please email: privacy@jungheinrich.co.za.

1. Your rights in respect of your personal information
   1. As well as your right to revoke any consent you have given to us, you are afforded the following additional rights where the relevant statutory requirements are met:
      1. Right of access to information regarding the personal data stored by us in accordance with Art. 15 of the GDPR and/or section 23 of POPI;
      2. Right to rectification of incorrect data or to completion of incomplete data in accordance with Art. 16 of the GDPR and/or section 24 of POPI;
      3. Right to erasure of data stored by us in accordance with Art. 17 of the GDPR and/or section 24 of POPI, provided that no legal or contractual retention periods must be observed and/or no other legal obligations or rights exist with regard to continued storage
      4. Right to restriction of processing of personal data in accordance with Art. 18 of the GDPR and/or section 14 of POPI;
      5. Right to data portability in accordance with Art. 20 GDPR
      6. Right to lodge a complaint with a supervisory authority; as a rule, you may contact the supervisory authority of your usual place of residence or workplace or our company headquarters.
   2. Please feel free to send us an email at privacy@jungheinrich.co.za should you wish to exercise any of your rights as set out above.

1. Categories of processed personal data and data sources
   1. When handling investor-related matters, we process the following categories of personal information:
      1. Contact information (e.g. name, postal address and/or e-mail address);
      2. Information about your shares (e.g. number of shares);
   2. Time of conversations and information regarding general meetings (e.g. the list of attendees of a general meeting, which will also include your name if you attended).
   3. It is important to note that in addition to our actual shareholders, the term "investors" also includes potential investors and interested parties.
2. Purpose and legal basis of data processing

We process your data for the purposes stipulated in the Companies Act 71 of 2008, as amended and other laws, in particular to conduct our general meetings as well as to ensure appropriate communication with you as our shareholder. We only process personal information that is required to fulfil the aforementioned purposes. We process the aforementioned information in accordance with Art. 6(1)(b) GDPR and/or section 11(1)(b) of POPI, alternatively Art. 6(1)(c) GDPR and/or section 11(1)(c) of POPI.

1. Mandatory/Voluntary Supply of information
   1. It is mandatory to supply the information which is necessary for us to discharge our legal and/or contractual obligations, whereas the supply of any additional information over and above what is mandatory takes place on an entirely voluntary basis.
   2. A failure to supply the relevant mandatory information means that we will be unable to manage your shareholding and/or investment as is required in terms of law.
2. Disclosure of personal data
   1. As a rule, your personal information is not transferred to third parties. However, we may, in certain circumstances: -
      1. be required to allow access to information regarding our annual meetings, communications in respect of securities and our securities register in order to comply with obligations which are imposed by law, such as the Companies Act 71 of 2008, as amended;
      2. grant third parties’ access to this information if they have been commissioned by us to deliver services relating to the management of investor matters. These may be auditors, consultants, banks, investor relations service providers and general meeting agencies. The scope of the personal information provided to these service providers is restricted to that required to deliver the relevant service. In such cases, we ensure that the relevant service provider is contractually bound to ensure that the information that is disclosed is only processed in accordance with our instructions, treated as confidential and that the service provider takes appropriate technical and organisational measures to prevent loss of, damage to or unauthorised destruction of personal information and/or any unlawful access to or processing of such personal information.
3. Storage period

In terms of law, we are required to retain the personal information for a minimum period of 7 (Seven) years (or for a longer period where specific legislation requires such record keeping in excess of 7 (Seven) years. The personal information specified above will be erased when it is no longer required to fulfil legal obligations and no statutory retention period applies. However, we may, in certain circumstances retain personal information in excess of the required retention periods for historical, research or statistical purposes. In such cases, we implement appropriate technical and organisational measures to ensure that the personal information we retain is not processed for any other purpose.

1. Where you register to use our online shop, we may collect the following information from you: -
   1. Email address;
   2. Title;
   3. First name;
   4. Surname;
   5. Company name;
   6. Company registration number;
   7. VAT Number;
   8. Address;
   9. Postal Code;
   10. City; and
   11. Telephone number.
2. We collect the information listed above in order to register your profile on our online shop, process any orders you place with us, render an invoice for the goods you purchase and to deliver any products you buy to your selected address.
3. It is mandatory to supply the information listed above, failing which we will be unable to register your profile on our online shop or process any orders you place with us. The supply of any additional information takes place on an entirely voluntary basis.
4. The personal information we collect at the time you register on our online shop may be made available to the relevant employees of our company, including employees employed in the Jungheinrich Group.
5. The information they will have access to includes your Company name, Contact Name and Surname, email address, physical address, contact number, and/or job title
6. At all times, you will be able to access the information you have supplied to us by logging into your user profile. Where your information may have changed or has otherwise become outdated, you are also able to change or rectify your information from your user profile as well.
7. In the event that you are experiencing difficulty in executing your access or rectification request, please send an email to privacy@jungheinrich.co.za so that we may assist you.

1. Where you contact us for any reason, be it via email or telephone we may collect the following information: -
   1. Name and surname;
   2. Company;
   3. Email address; and/or
   4. Telephone number.
2. The contact information you provide, will be processed by us for the purpose of responding to your inquiry and any follow-up questions which may arise by virtue of our response.
3. It is mandatory to supply the information which is necessary to allow us to respond to your request, whereas the supply of additional information is voluntary. A failure to provide the mandatory information means that we are unable to respond to your request.
4. The information collected from you during a telephone call or upon receipt of an email is processed based on: -
   1. Your consent in terms of Art. 6(1)(a) of the GDPR and/or section 11(1)(a) of POPI, which consent may be revoked at any time.
   2. Art. 6(1)(b) of the GDPR and/or section 11(1)(b) of POPI, to the extent that your contact with us is aimed at concluding or entering into a contract or performing in terms thereof.
   3. Our legitimate interest in responding to your inquiry in accordance with Art. 6(1)(f) of the GDPR and/or section 11(1)(f) of POPI.
5. We will not share the information provided by you to any third parties unless we require a third-party service provider to assist in responding to the request. In such cases, we will ensure that you cannot be identified from the relevant request where such request is forwarded to the third-party service provider.
6. We will process the information provided by you during the telephone call or in the email until such time as you request its deletion, revoke your consent or where it may be inferred from the circumstances that your request has been resolved, whereafter the personal information will be deleted.

In certain cases, we make use of third-party service providers to assist us in performing our functions and duties. Where we transfer personal information to our third-party service providers in order for them to process such information on our behalf, we commit them to safeguarding the security of the personal information which is provided to them in terms of written contracts, which oblige them to treat such information as confidential and not disclose it, to implement appropriate technical and organisational measures to ensure that processing complies with legal requirements and to adopt appropriate security measures to protect the relevant personal information from unauthorised access. The processing of personal information in such cases is performed: -

1. Where necessary to conclude and/or perform in terms of a written contract to which you are party in terms of Art. 6(1)(b) of the GDPR and/or section 11(1)(b) of POPI;
2. Where it complies with an obligation which is imposed in terms of law in terms of Art. 6(1)(c) of the GDPR and/or section 11(1)(c) of POPI;
3. To protect the legitimate interests of the data subject in terms of Art. 6(1)(d) of the GDPR and/or section 11(1)(d) of POPI; or
4. In pursuit of our legitimate interests to render services which are of a high quality in accordance with Art. 6(1)(f) of the GDPR and/or section 11(1)(f) of POPI.

1. Marketing is an important way in which we conduct business and is key to our continued success. We ensure our marketing activities are conducted strictly in accordance with POPI.
2. We will only direct market to you via electronic communication if you are an existing customer, or in circumstances where you have provided your consent to receive such marketing materials.
3. In order to enable such direct marketing activities, we will collect personal information from you such as your name and email address, this information is collected from you either at the time your purchased products from us, or at the time your provided us with your information.
4. We process the personal information of data subjects who have provided their consent, or who are customers of ours for the purpose of informing them of products and services, promotions, and other opportunities.
5. We process this personal information based on: -
   1. your consent in terms of section 11(1)(a) of POPI; or
   2. actions which are necessary for the performance of a contract to which you are party in terms of section 11(1)(b) of POPI; and
   3. Our legitimate interest in informing you of products and services, promotions, and other opportunities in accordance with section 11(1)(f) of POPI.
6. The supply of such personal information for the purposes of direct marketing is entirely voluntary and a failure to provide such information would mean that we are unable to keep data subjects informed of products, services, and opportunities, which may be of interest to you.
7. In order to conduct our marketing activities, we may transfer your personal information to service providers. However, we include contractual provisions which ensure that your information is always protected in compliance with POPI.
8. At all times, you have the right to object to the processing of your personal information for the purposes of direct marketing in terms of Art. 21(2-4) of the GDPR and/or section 69(3)(c) of POPI. To exercise this right, you can simply opt out of receiving further electronic communications by clicking the unsubscribe button at the bottom of every marketing email we send, or by emailing us directly.
9. We may also process your personal information to direct market in other ways, which do not involve electronic communications. In such cases, you are also entitled to object to the processing of your personal information in terms of Art. 21(1) of the GDPR and/or section 11(3)(b) of POPI. Please visit the corresponding section below to find out more information on how to exercise this right.
10. If you have objected to the processing of your personal information for the purposes of direct marketing, either in terms of electronic communication or otherwise, we will remove you from our marketing data base and will ensure that we no longer process your personal information for these purposes. However, the legality of any processing which may have taken place either prior to objection, or which continues to take place based on other grounds will not be affected.
11. For the management of marketing consents, we use the internet-based service of the provider OneTrust Technology Limited, 82 St John St, Farrington, London EC1M 4JN, UK, to ensure that we can obtain and manage your consent to the processing of personal data in accordance with the applicable data protection regulations. OneTrust allows us to be transparent and efficient with your privacy preferences. At the end of each newsletter you will find a corresponding target link to manage your marketing consents. Alternatively, you can access this via the link in the footer of the website. There you have the option of granting or withdrawing your consent and adjusting your data protection settings.
12. You have the right and the option to unsubscribe from the newsletter mailing list at any time. Please note that OneTrust acts as a third-party provider on our behalf and processes your personal data in accordance with our instructions and the applicable data protection laws. We have taken appropriate security measures to protect your data and prevent unauthorised access, loss or misuse.

1. Save as specified in this Policy and/or our Manual prepared in accordance with section 51 of the Promotion of Access to Information Act 2 of 2000, as amended, we will not transfer your personal information outside of the Republic of South Africa. In cases where personal information is transferred to third parties based outside of the Republic of South Africa, we will only transfer such information: -
   1. in terms of a written contract which: -
      1. Effectively upholds the principles of reasonable processing as set out in POPI; and
      2. Limit the further transfer of such personal information in terms of provisions which are substantially similar to the provisions of section 72 of POPI.
   2. With your explicit consent to such transfer; or
   3. Where such transfer may be authorised in accordance with POPI.
2. In all cases, we will ensure that your personal information remains safe and secure.

1. Should you wish to access any information held by us for the purposes of exercising any of your rights, please refer to our manual, which has been prepared in accordance with section 51 of the Promotion of Access to Information 2 of 2000, as amended, which manual is accessible on our website or may be obtained upon request.
2. Although you have the right to request access to information held by us, in certain instances we are obliged to refuse access to information based on the grounds contained in the provisions of Chapter 4 of Part 2 and Chapter 4 of Part 3 of the Promotion of Access to Information Act 2 of 2000, as amended.
3. In the event that a particular ground of refusal applies, we will not provide you access to such information.

1. We ensure the confidentiality, integrity and availability of the personal information we process by placing same onto specially secured servers, which are only accessible: -
   1. from password protected computers;
   2. by designated members of staff with specific access permissions.
2. The storage thereof is a technical and organizational measure employed by us to protect against loss, destruction, access, alteration or dissemination of your data by unauthorized persons.
3. We have a dedicated hardware firewall, to protect the corporate network from external attacks. Up to date Anti-virus software is installed on all machines and regular patches and updates of software is performed to keep systems compliant.
4. Only authorized persons are able to access the personal information of data subjects. These individuals are responsible for the technical, commercial and editorial supervision of the server. Despite regular inspections, complete protection against all risks is not possible and we in no way guarantees complete protection in this regard.
5. Our security measures are continuously enhanced in line with technological advancement.
6. For more information in respect of our security practices, please refer to our Manual which has been prepared in accordance with section 51 of the Promotion of Access to Information Act 2 of 2000, as amended, which Manual is available on our website.

1. We place strong emphasis on explaining the processing of your personal information as transparently as possible and informing you of your rights. In the event that you would like more detailed information or wish to exercise your rights, you can contact us at any time so that we can take care of your concerns.
2. As well as your right to revoke any consent you have given to us, you are afforded the following additional rights where the relevant statutory requirements are met:
   1. Right of access to information regarding the personal data stored by us in accordance with Art. 15 of the GDPR and/or section 23 of POPI;
   2. Right to rectify or correct any inaccurate in accordance with Art. 16 of the GDPR and/or section 24 of POPI;
   3. Right to erasure of data stored by us in accordance with Art. 17 of the GDPR and/or section 24 of POPI, provided that no legal or contractual retention periods must be observed and/or no other legal obligations or rights exist with regard to continued storage;
   4. Right to restriction of processing of personal data in accordance with Art. 18 of the GDPR and/or section 14 of POPI;
   5. Right to data portability in accordance with Art. 20 GDPR
   6. Right to lodge a complaint with a supervisory authority; as a rule, you may contact the supervisory authority of your usual place of residence or workplace or our company headquarters.
3. In the paragraphs below, we provide more detailed information on how to exercise your rights.
4. Right of Access to, Correction and/or Deletion of Personal Information
   1. Provided you are able to prove your identity, you have the right to request confirmation, free of charge, whether we hold personal information about you, as well as information about the categories of third parties who have, or have had, access to your personal information.
   2. Should you wish to establish whether we hold any personal information about you, you are invited to send us an email with your request using the information set forth above.
   3. Should personal information be disclosed to the data subject in response to any requests as aforesaid, the data subject is hereby notified of its right to request correction, deletion and/or blocking of the personal information, in line with section 24 of the Protection of Personal Information Act 4 of 2013, as amended.
   4. Should you wish to request the correction or deletion of your personal information or the destruction or deletion of a record of personal information, please submit a request to us on Form 2, which may be accessed at https://www.justice.gov.za/legislation/notices/2018/20181214-gg42110-rg10897-gon1383-POPIregister.pdf. We will render such reasonable assistance, as may be necessary and free of charge, to enable you to complete Form 2.
5. Withdrawal of Consent and Right to Object to processing of Personal Information
   1. You have the right to revoke your consent to any processing of your personal information and may exercise your right by simply sending us an email. However, the revocation of such consent will not affect the lawfulness of continued processing where legal grounds authorise or require us to continue processing such information, nor will it affect the lawfulness of any processing that was carried out by us between the time of consent and withdrawal.
   2. Please take note that you may also object, in terms of section 11(3)(a) of POPI, to the processing of your personal information, where processing takes place on the following grounds: -
      1. In order to protect your legitimate interest; or
      2. Where processing is necessary for pursuing our legitimate interest, or those of a third party.
   3. Should you wish to object to the processing of your personal information in terms of section 11(3)(a) of POPI, please submit your objection to us on Form 1, in accordance with the Regulations relating to POPI.
   4. The Form 1 document may be accessed through the following link: https://www.justice.gov.za/legislation/notices/2018/20181214-gg42110-rg10897-gon1383-POPIregister.pdf
   5. We  will render such reasonable assistance as is necessary, free of charge, to enable you to make an objection on Form 1.
   6. Any objections must be based on reasonable grounds relating to your particular situation unless legislation provides for such processing, in which case we shall continue to process such personal information in compliance with our statutory obligations.
   7. In the absence of such legislative obligations, we will review and, if necessary, cease the processing of such personal information.
   8. We will inform you of the results of the review and if the data processing is to continue nevertheless, we will provide you with detailed information about why the continued processing is permitted and/or required.
6. Right to Lodge a Complaint
   1. Should you feel as though we have used your personal information contrary to POPI and/or the GDPR, please send us an email in order for us to address any of your concerns.
   2. If we are unable to resolve the issue to your satisfaction, you have the right to lodge a complaint with the Information Regulator.
   3. In terms of the Regulations relating to POPI, any person who wishes to submit a complaint must submit such a complaint to the Information Regulator on Part I of Form 5.
   4. The relevant form is accessible via the following link: https://www.justice.gov.za/legislation/notices/2018/20181214-gg42110-rg10897-gon1383-POPIregister.pdf
   5. The available contact details of the Information Regulator are recorded as follows:
      1. Address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001;
      2. Postal Address: PO Box 31533, Braamfontein, Johannesburg, 2017.
      3. Email: complaints.IR@justice.gov.za.

We reserve our right to amend this Policy from time to time and will do so without notice to you. The latest version of this Policy will be indicated by the date information (below). The current version of this Policy can always be accessed directly via our website(s).

Last updated: 16 July 2024