Please ensure you read and understand the below information.
VENTRIA’S PRIVACY AND PERSONAL INFORMATION POLICY
Ventria (Pty) Ltd. (reg: 2017/367352/07) (“Ventria”) adheres to the highest standards of protecting your personal information when we process it by virtue of your use of our Services, your use of our website http://ventria.co.za/ or any of its related blogs, websites, applications or platforms (collectively, “the Website”), or by providing us with your personal information in any other way. As such, we have created this specific and detailed Privacy Policy for you to read and appreciate exactly how we safeguard your personal information and respect your privacy (“Policy”).
Please use the following links to jump to the relevant sections described in this Privacy Policy:
1. Important information and who we are
1.1 Purpose of this Privacy Policy
1.1.1 This Privacy Policy aims to give you information on how Ventria collects and processes your personal data through any form of your engagement with Ventria such as your engagement with us when contracting or corresponding with us, when using our Services, accessing or using the Website, or providing us with your personal information in any other way (such as when participating in events or signing up for newsletters).
1.1.2 This Privacy Policy complies with, and facilitates the obligations required from, the South African Protection of Personal Information Act, No. 4 of 2013 (“POPI”), as amended.
1.1.2.1 Users with citizenships from jurisdictions other than of South Africa, please note that Ventria complies with all South African data protection laws when processing your personal information pursuant to the Services as we are a South African entity operating in the South African market. Should foreign law be applicable in any regard to your use of the Services and/or the Website in any way, including how we may process your personal information, please contact Ventria at info@ventria.co.za who will gladly engage you on its application and your rights.
1.1.3 It is important that you read this Privacy Policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.
1.1.4 We do not process special categories of personal data nor the data of minors. Do not provide us with any such personal data, where the provision of same will constitute an immediate and automatic material breach of these terms.
1.2 Responsible Party and Operator Roles
1.2.1 Ventria is the “Responsible Party” and is responsible for your personal data in instances where we decide the processing operations concerning your personal data. Sometimes we also operate as a “Operator” of personal data on behalf of a third-party Responsible Party, where that Responsible Party’s privacy terms will apply, but we will draw your attention to them, when applicable.
1.2.2 We have appointed an Information Officer (“IO”) at Ventria who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the IO using the details set out below.
Full name of legal entity: Ventria (Pty) Ltd.
Name of IO: Nicolette Grace
Email address: info@ventria.co.za
Postal address: PO Box 1329, Bedfordview,
Gauteng, 2008
Telephone number: +2711450 0096
1.2.3 You have the right to make a complaint at any time to the South African regulator’s office (Information Regulator’s Office of South Africa). We would, however, appreciate the chance to deal with your concerns before you approach any such regulator, so please contact us in the first instance.
1.3 Changes to the Privacy Policy and your Duty to Inform us of Changes
1.3.1 This Privacy Policy version was last updated on 13 January 2022 and historic versions are archived and can be obtained by contacting us.
1.3.2 It is important that the personal data we hold about you is accurate and current. Please update your personal data yourself using the relevant prompts on the Website, or keep us informed if your personal data changes during your relationship with us.
1.4 Third-Party Links on Website or otherwise
1.4.1 The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements or terms. When you leave our Website, or engage with such third parties, we encourage you to read the distinct privacy policy of every third-party you engage with.
2. The data we collect about you
2.1 Personal data, or personal identifiable information, means any information about an individual, both natural and juristic entities (i.e. people and companies), from which that entity can be identified. It does not include data where the identity has been removed (anonymous data).
2.2 We may collect, use, store and transfer (“process”) different kinds of personal data about you which we have grouped together as follows:
2.2.1 Identity Data including first name, last name, username or similar identifier, title, date of birth or the information about your company such as company registration details, company address and name;
2.2.2 Contact Data including email address, physical/registered addresses, social media contact details and telephone numbers;
2.2.3 Financial Data including bank account details, third-party payment provider information and payment card details (which we do not store but only provide to our authorised third-party payment service provider under contract with us);
2.2.4 Social Media Data including all information accessible on your publicly available profile such as images, photos, photo tags, likes, followers, comments, posts and stories;
2.2.5 Transaction Data including details about payments to and from you, contracts, contractual terms, contract fees, signups, subscriptions, invoices and other details of products and services you have obtained from us, or provide to us;
2.2.6 Technical Data including internet protocol address/es, your login data, browser type and version, time zone setting and location, cookies, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website;
2.2.7 Profile Data including your Website/Profile username and password, preferences, feedback, ratings, and reviews;
2.2.8 Usage Data including information about how you use our company, Website, products and Services; and
2.2.9 Marketing and Communications Data including your preferences in receiving notices and marketing from us and our third parties and your communication preferences.
2.3 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
2.4 Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services or allow you to provide us with your services). In this case, we may have to cancel Website-access or Services you have with us, but we will notify you if this is the case at the time.
3. How is your personal data collected?
3.1 We use different methods to collect data from and about you, including through:
3.1.1 Direct interactions: You may give us your Identity, Contact, Profile, Social Media, Transaction, Usage, Technical and Financial Data by filling in various Ventria forms, Website forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
3.1.2 Automated technologies or interactions: As you interact with our Website, we may automatically collect Technical Data, Profile and Usage Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
3.1.3 Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
3.1.3.1 analytics providers Google Analytics based in the USA;
3.1.3.2 social networks Facebook, Instagram, LinkedIn, YouTube, Twitter and TikTok based in the USA;
3.1.3.3 survey data providers Survey Monkey Momentive based in the USA;
3.1.3.4 marketing platforms MailChimp and Salesforce based in the USA; and
3.1.3.5 search information providers Google, Yahoo and Bing based in the USA;
3.1.3.6 providers of technical and/or payment services being PayFast based in South Africa; Sage Accounting based in South Africa; Netcash based in South Africa, Debtsource based in South Africa; Transunion based in the USA; Takealot based in South Africa; and
3.1.3.7 publicly available sources being the Companies and Intellectual Properties Commission based in South Africa and South African Health Products Regulatory Authority based in South Africa.
4. How we use your personal data
4.1 We will only use your personal data when the law allows us to and for legitimate reasons, which you hereby expressly understand and consent to. Most commonly,
4.1.1 we will use your personal data in the following circumstances:
4.1.2 where we have your express consent to do so;
4.1.3 where we need to consult with you or perform on the Services contract we are about to enter into or have entered into with you;
where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and/or
4.1.4 where we need to comply with a legal or regulatory obligation.
4.2 Purposes for which we will use your personal data:
4.2.1 We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate, and which exact External Third Parties your personal data is handed to for same reasons.
4.2.2 Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose / Activity | Type of Data | Lawful Basis For Processing Including Basis Of Legitimate Interest | SPECIFIC EXTERNAL THIRD PARTY TO WHOM THE INFORMATION IS PROVIDED (IF ANY) |
|---|---|---|---|
| To engage with you after you have contacted us requesting an engagement via the Website or otherwise |
|
| Salesforce based in San Francisco, CA, USA. Mailchimp based in Atlanta, Georgia, USA. Facebook based in, Menlopark, CA, USA. LinkedIn based in Sunnyvale CA, USA. Instagram based in Menlopark, CA, USA. Microsoft Outlook based in Redmond, Washington, USA. |
| To provide you with our Services as contracted (such as buying our Products) |
|
| Salesforce based in San Francisco, CA, USA. Mailchimp based in Atlanta, Georgia, USA. Facebook based in, Menlopark, CA, USA. LinkedIn based in Sunnyvale CA, USA. Instagram based in Menlopark, CA, USA. Microsoft Outlook based in Redmond, Washington, USA. Sage Accounting PayFast and Debtsource based in South Africa. RAM Couriers based in Kempton Park, JHB, SA. FEDEX based in Memphis, Tennessee, USA. |
| To contract with you as a service provider to Ventria |
|
| Salesforce based in San Francisco, CA, USA. Mailchimp based in Atlanta, Georgia, USA. Facebook based in, Menlopark, CA, USA. LinkedIn based in Sunnyvale CA, USA. Instagram based in Menlopark, CA, USA. Microsoft Outlook based in Redmond, Washington, USA. Sage Accounting PayFast and Debtsource based in South Africa. RAM Couriers based in |
| To allow you to use the Website or participate in any Ventria event |
|
| Salesforce based in San Francisco, CA, USA. Mailchimp based in Atlanta, Georgia, USA. Facebook based in, Menlopark, CA, USA. LinkedIn based in Sunnyvale CA, USA. Instagram based in Menlopark, CA, USA. Microsoft Outlook based in Redmond, Washington, USA. Sage Accounting PayFast and Debtsource based in South Africa. |
| To provide it to our authorised third-party service providers who need your personal data to provide their private services to you (such as payment gateway providers or couriers) |
|
| Salesforce based in San Francisco, CA, USA. Netcash based in Parklands Cape Town, SA. Sage Accounting based in Waterfall, Midrand, SA. Debtsource based in Blackheath, Randburg, SA. Transunion based in Chicago, Illinois, USA. PayFast based in Claremont, Cape Town, SA. RAM Couriers based in Kempton Park, JHB, SA. FEDEX based in Memphis, Tennessee, USA. |
| To process and service your payment for any services rendered by Ventria or its service providers To manage payments, fees and charges |
|
| Netcash based in Parklands Cape Town, SA. Sage Accounting based in Waterfall, Midrand, SA. Debtsource based in Blackheath, Randburg, SA. Transunion based in Chicago, Illinois, USA. PayFast based in Claremont, Cape Town, SA. |
| To manage our relationship with you which may include notifying you about changes to our terms or Privacy Policy or Services |
|
Performance of a contract with you | Salesforce based in San Francisco, CA, USA. Mailchimp based in Atlanta, Georgia, USA. Microsoft Outlook based in Redmond, Washington, USA. |
| To administer and protect our organisation and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
|
| Salesforce based in San Francisco, CA, USA. Microsoft Outlook based in Redmond, Washington, USA. Aglet based in JHB, SA. |
| To deliver relevant Website content and services to you and measure or understand the effectiveness of the information we serve to you |
|
| Salesforce based in San Francisco, CA, USA. Mailchimp based in Atlanta, Georgia, USA. Microsoft Outlook based in Redmond, Washington, USA. |
| To use data analytics to improve our Website, Services, engagee relationships and experiences |
|
| Salesforce based in San Francisco, CA, USA. Microsoft Outlook based in Redmond, Washington, USA. Aglet based in JHB, SA. Google Analytics based in the USA. |
| To provide you with direct and user-specific marketing, make suggestions and recommendations to you about events or services that may be of interest to you |
|
| Salesforce based in San Francisco, CA, USA. Mailchimp based in Atlanta, Georgia, USA. Microsoft Outlook based in Redmond, Washington, USA. Aglet based in JHB, SA. Google Analytics based in the USA. Xeenlo based in Cape Town, SA. |
10. Glossary
10.1 Lawful Basis
10.1.1 Legitimate Interest means the interest of our organisation in conducting and managing our organisation to enable us to give you the best service and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
10.1.2 Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
10.1.3 Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
10.1.4 Express consent means the confirmed express consent you have provided to our processing of your personal data by actively accepting this Privacy Policy.
10.2 Third Parties
10.2.1 Internal Third Parties means other entities or parties in the Ventria group acting as joint responsible parties or operators and who are based in South Africa and provide IT and system administration services and undertake reporting.
10.2.2 External Third Parties means:
10.2.2.1 Authorised third-party service providers under contract with Ventria who need your personal information in order to contact and transact with you pursuant to your use of the Services;
10.2.2.2 specific third parties who have been identified in the table above;
10.2.2.3 service providers acting as processors based in South Africa who provide IT and system administration services;
10.2.2.4 South African or other national governments and/or their respective authorities pursuant to our adherence with anti-corruption and crime-fighting legislation; and/or
10.2.2.5 professional advisers acting as operators or joint responsible parties including lawyers, bankers, auditors and insurers based in South Africa who provide consultancy, banking, legal, insurance and accounting services as required.
10.3 Your legal rights
You have the right to:
10.3.1 Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
10.3.2 Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
10.3.3 Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no valid reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be communicated to you, if applicable, at the time of your request.
10.3.4 Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
10.3.5 Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
10.3.5.1 if you want us to establish the data’s accuracy;
10.3.5.2 where our use of the data is unlawful but you do not want us to erase it;
10.3.5.3 where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
10.3.5.4 you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
10.3.6 Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform on a contract with you.
10.3.7 Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain Website access or Services to you. We will advise you if this is the case at the time you withdraw your consent. Please take note that regardless of your right to withdraw consent under POPI, other South African legislation applies and may require that we continue to process your data in order to comply with anti-corruption, medical device, medical services, crime-fighting and/or other national legislation, which you expressly understand and agree to.
At Ventria we believe that we truly
understand what is needed to
confidently help save a life.
