Privacy Statement
  1. INTRODUCTION
    • Torch Solutioneers (Pty) Ltd (hereafter “Torch” or “we” or “us” or “our”) respects your privacy and protection of your personal information is important to us. We are committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection.
    • This privacy statement, together with Torch’s Data Management and Protection Policy, aims to inform you of how Torch will treat any personal information received from a data subject and how you can access such personal information held. Reference made to “POPIA” means the Protection of Personal Information Act 4 of 2013 and reference made to “PAIA” means the Promotion of Access to Information 2 of 2000 as amended.
    • By visiting our website, communicating electronically with us and using our services, you consent to the processing and transfer of your personal information as set out in this privacy statement below. Torch will take all reasonable measures, in accordance with this statement, to protect your personal information and to keep it confidential.
    • For purposes of this privacy statement, “personal information”, “data subject” and “processing” will have the meanings given to them in the POPIA.
    • We may use cookies to collect website usage information which allows us to collect standard internet visitor usage information that does not infringe on the rights of the visitor.
    • We reserve the right to amend this privacy statement at any time, without prior notice, by posting the amended statement on our website.
  1. APPLICATION OF THE PRIVACY STATEMENT
    • Our privacy practices apply to the processing of your personal information collected by us or on our behalf, such as data subjects who use of our website and/or our products and services, and/or who provide us with products and services, customers and any other data subjects who engage with us.
    • This privacy statement does not apply to third party websites linked to our website, or websites that link to or advertise on our website.
  1. COLLECTION OF PERSONAL INFORMATION
    • Personal information may be provided to us by you and/or collected by us when you engage with us on the website and/or on your use of our products and services, and/or when you provide us with your products and services.
    • The type of personal information we collect will depend on the purpose for which it is collected and used. The specific purpose for which the information is collected will be apparent from the context in which the information is requested including but not limited to when:
      1. You purchase and/or use our products and services.
      2. You submit enquiries to us or contact us and you may be required to provide your name and surname, postal or street address, title, contact numbers or e-mail address.
      3. You make use of our website or interact with us on social media, we may collect your non-personal browsing habits and click patterns, e-mail address, IP address, telephone data information or username and password.
      4. You apply for employment opportunities at Torch you may be required to provide your name and surname, identity number, employment history, and criminal behaviour.
      5. Where possible, we will inform you what information is voluntary or mandatory for you to provide to us and the consequences for failing to provide the requested information.
      6. We will only retain your personal information as long as necessary for the fulfilment of those purposes as have been identified by us and/or as required by law and/or as agreed with you.
    1. HOW WE USE YOUR INFORMATION
      • Personal information will only be processed for the purposes for which it was collected and/or to comply with legal and regulatory obligations and/or as authorised by law and/or with your consent.
      • The purposes for which we process personal information includes, but is not limited to:
      1. Respond to your enquiry.
      2. Provide services or products to you.
      3. Comply with legal requirements or industry codes.
      4. Market or promote our services and products.
      5. Safety and security reasons.
    1. DISCLOSURE OF INFORMATION
      • Torch may disclose your personal information to third parties in certain circumstances, which include, but are not limited to:
        1. Where we have your consent.
        2. Where we are required to do so by law.
        3. To our service providers who are involved in the delivery of products or services to you, where we have agreements in place to ensure that they comply with these privacy terms.
      • Third parties who we disclose personal information to include, but are not limited to:
        1. Service providers to Torch.
        2. Regulators, courts, tribunals and law enforcement agencies.
      • We may compile, use and share any information that does not relate to any specific individual and retain all rights to non-personal statistical information collected and compiled by us.
    1. TRANSFER OF INFORMATION
      • We may need to transfer your personal information to another country for processing or storage. We will ensure that anyone to whom we pass your personal information agrees to treat your information with similar protection as provided for in the POPIA.
      • We may, with your consent, transfer your information to other countries which do not have similar protection as provided for in the POPIA.
    2. INFORMATION SECURITY
      • We take appropriate and reasonable technical and organisational measures to prevent any unauthorised or unlawful access, loss of, damage to or unauthorised destruction of personal information.
      • We have implemented various policies, procedures and standards to safeguard personal information.
      • We regularly verify that the safeguards are effectively implemented and ensure that they are continually updated in line with best practice.
      • Torch has implemented procedures to address actual and suspected data breaches, and undertake to notify you and the relevant regulatory authorities of breaches in instances in which Torch is legally required to do so and within the period in which such notification is necessary.
      • Notwithstanding the points above, to the extent permissible by law, we shall not be liable for any loss, claim and/or damage arising from any unauthorised access, disclosure, misuse, loss, alteration or destruction of your personal information.
    3. DATA SUBJECT RIGHTS
      • Subject to the POPIA provisions, you have the right to:
        1. Request access to your personal information.
        2. Request, where necessary, the correction, destruction or deletion of your personal information.
        3. Object to the processing of your personal information.
        4. Submit a complaint to the Information Regulator regarding the alleged interference with the protection of the personal information.
        5. Institute civil proceedings regarding the alleged interference with the protection of your personal information.
    4. USE OF COOKIES
      • Torch may use cookies to enhance your experience as a customer (referred to as the “user”). The user’s web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. The user may choose to set their web browser to refuse cookies, or to be notified when cookies are being sent. If the user does so, note that some parts of the website service may not function properly.
      • Torch collects, stores and uses the abovementioned information for the following purposes:
        1. To communicate requested information to the User.
        2. For newsletter or email subscription services.
        3. To remember who has already taken part in surveys or questionnaires.
        4. To compile non-personal statistical information about browsing habits, click-patterns and access to the Torch website.
      • Information detailed above is collected either electronically by using cookies or is provided voluntarily by the User. Users may determine cookie use independently through their browser settings. For purposes of this clause, a cookie means a tiny computer file created by a web browser to save user information for web site.
      • Cookies ensure that Torch is able to continually improve its website. We utilise third party cookies (not originating from us) to provide traffic analysis and tracking.
        1. These third parties include, but are not necessarily limited to, Google Analytics. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content.
        2. For more information on Google Analytics cookies, see the official Google Analytics page.
      • Torch also use social media buttons and/or plugins on this site that allow you to connect with your social network in various ways. For these to work the following social media sites including; Facebook, LinkedIn, Instagram, will set cookies through our site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.
    1. CONTACT DETAILS

    Privacy enquiries may be submitted to dpo@torch.co.za or to the
    addresses below:

    The Information Officer
    PO Box 2976
    Rivonia
    2128

    1. INFORMATION REGULATOR

    You have the right to lodge a complaint with the Information Regulator in writing as per their website https://www.justice.gov.za/inforeg/contact.html to:

    E-mail

    Complaints email: complaints.IR@justice.gov.za
    General enquiries email: inforeg@justice.gov.za

    Physical address

    House 27 Stiemens Street
    Braamfontein
    Johannesburg
    2001

    Postal address

    PO Box 31533
    Braamfontein
    Johannesburg
    2107

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