Welcome to our privacy policy. We are NeuronMe (Pty) Ltd (Registration number 2017/377799/07), and this is our plan of action when it comes to protecting your privacy. We respect your privacy and take the protection of personal information very seriously. This privacy policy sets out the ways in which we collect, use, and disclose information relating to the operation of our website and application, including personal information about you, application users, visitors, and representatives. This Privacy Policy also applies to the usage of our platform via your mobile device.

Audience

This policy applies to you if you are:

a visitor to our website; or
a user of our mobile application.

Personal information

Personal information includes:

certain information that we collect automatically when you visit our website and platform.
certain information collected during the registration process on our platform (see below).
certain information collected on submission; and
optional information that you provide to us voluntarily (see below).

but excludes:

information that has been made anonymous so that it does not identify a specific person.
permanently de-identified information that does not relate or cannot be traced back to you specifically.
non-personal statistical information collected and compiled by us; and
information that you have provided voluntarily in an open, public environment or forum including any blog, chat room, community, classifieds, or discussion board (because the information has been disclosed in a public forum, it is no longer confidential and does not constitute personal information subject to protection under this policy).

Common examples

Common examples of the types of personal information which we may collect, and process include your:

identifying information – such as your name, date of birth, or identification number of any kind.
contact information – such as your phone number or email address.
address information – such as your physical or postal address; or
demographic information – such as your gender or marital status.

Sensitive personal information

We may also collect sensitive personal information including your:

financial information – such as your bank account details.
sensitive demographic information – such as your race or ethnicity.
medical information – such as information about your physical or mental health; and
employment information – including your membership of a trade union.

Acceptance
1. Acceptance required

You must accept all the terms of this policy when you visit our website or use our services via our mobile application. If you do not agree with anything in this policy, then you may not request our services or visit our website.

Legal capacity

You may not access our website or request our services if you are younger than 18 years old or do not have legal capacity to conclude legally binding contracts.

Deemed acceptance

By accepting this policy, you are deemed to have read, understood, accepted, and agreed to be bound by all of its terms.

Your obligations

You may only send us your own personal information or the information of another data subject where you have their permission to do so.

Collection
1. On registration

Once you register on our website, you will no longer be anonymous to us. You will provide us with certain personal information when you register on our website.

This personal information will include:

your name and surname.
ID or passport number
your email address.
your mobile number.
your username and password.

We will use this personal information to fulfil your account, provide additional services and information to you as we reasonably think appropriate, and for any other purposes set out in this policy.

From browser

We automatically receive and record Internet usage information on our server logs from your browser, such as your Internet Protocol address (IP address), browsing habits, click patterns, version of software installed, system type, screen resolutions, colour capabilities, plug-ins, language settings, cookie preferences, search engine keywords, JavaScript enablement, the content and pages that you access on the website, and the dates and times that you visit the website, paths taken, and time spent on sites and pages within the website (usage information). Please note that other websites visited before entering our website might place personal information within your URL during a visit to it, and we have no control over such websites. Accordingly, a subsequent website that collects URL information may log some personal information.

For information on how we deal with Cookies, please refer to our Cookies Policy.

Web beacons

Our website may contain electronic image requests (called a single-pixel gif or web beacon request) that allow us to count page views and to access cookies. Any electronic image viewed as part of a web page (including an ad banner) can act as a web beacon. Our web beacons do not collect, gather, monitor, or share any of your personal information. We merely use them to compile anonymous information about our website.

Optional details

You may also provide additional information to us on a voluntary basis (optional information). This includes content or products that you decide to upload or download from our website or when you enter competitions, take advantage of promotions, respond to surveys, order certain additional goods or services, or otherwise use the optional features and functionality of our website.

Recording calls

We may monitor and record any telephone calls that you make to us unless you specifically request us not to.

Purpose for collection

We may use or process any goods or services information, or optional information that you provide to us for the purposes that you indicated when you agreed to provide it to us. Processing includes gathering your personal information, disclosing it, and combining it with other personal information. We generally collect and process your personal information for various purposes, including:

goods or services purposes – such as sharing it with NeuronMe affiliated businesses where you have an account.
marketing purposes – such as pursuing lawful related marketing activities.
business purposes – such as internal audit, accounting, business planning, and joint ventures, disposals of business, or other proposed and actual transactions; and
legal purposes – such as handling claims, complying with regulations, or pursuing good governance.
Fraud prevention purposes – such as notifying customers of personal information updates to react faster to potential identity fraud.
Referrals – such as to generate new customer leads.
Transparency – such as to create transparency regarding businesses using your personal information.
verifying platform account such as registrations including conducting fraud, security, “Know Your Customer” and anti-money laundering checks in order to approve your account.
verifying your eligibility such as a platform blogger or influencer.

We may use your usage information for the purposes described above and to:

remember your information so that you will not have to re-enter it during your visit or the next time you access the website.
monitor website usage metrics such as total number of visitors and pages accessed; and
track your entries, submissions, and status in any promotions or other activities in connection with your usage of the website.
conducting research and analytics to ensure the security of our platform, to improve the content and layout of the platform, and to improve our product offerings and services.
We may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you, if and where this is permitted by applicable data protection laws.

Consent to collection

We will obtain your consent to collect personal information:

in accordance with applicable law.
when you provide us with any registration information or optional information.
when you verify updates made to your personal information by a NeuronMe affiliated business

Use
1. Our obligations

We may use your personal information to fulfil our obligations to you.

Messages and updates

We may send administrative messages and email updates to you about the website. We may wish to provide you with information about new goods or services in which we think you may be interested. This means that in some cases, we may also send you primarily promotional messages. We will not send you promotional messages unless you have chosen to opt-into them. But we may send you one message asking you to opt-into promotional messages without you having opted-into promotional messages.

Targeted content

While you are logged into the website, we may display targeted adverts and other relevant information based on your personal information. In a completely automated process, computers process the personal information and match it to adverts or related information. We never share personal information with any advertiser unless you specifically provide us with your consent to do so. Advertisers receive a record of the total number of impressions and clicks for each advert. They do not receive any personal information. If you click on an advert, we may send a referring URL to the advertiser’s website identifying that a customer is visiting from the website. We do not send personal information to advertisers with the referring URL. Once you are on the advertiser’s website however, the advertiser is able to collect your personal information.

Disclosure
1. Sharing

The following instances will require us to share personal information:

When you update your personal information on our website or mobile application, NeuronMe affiliated businesses will be notified and updated.
When your information is updated at a NeuronMe affiliated business, and you have verified the updates and/or registration.
When required by law.
When it is necessary to protect the right of NeuronMe, your safety or the safety of others.

We may share your personal information with:

other divisions or companies within the group of companies to which we belong to provide joint content and services like registration, for transactions and customer support, to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about our products, services, and communications (they will only use this information to send you marketing communications if you have requested their goods or services).
an affiliate, in which case we will seek to require the affiliates to honour this privacy policy.
our goods or services providers under contract who help provide certain goods or services or help with parts of our business operations, including fraud prevention, bill collection, marketing, technology services (our contracts dictate that these goods or services providers only use your information in connection with the goods or services they supply or services they perform for us and not for their own benefit).
credit bureaus to report account information, as permitted by law.
other third parties who provide us with relevant services where appropriate.

Regulators

We may disclose your personal information as required by law or governmental audit.

Law enforcement

We may disclose personal information if required:

by a subpoena or court order.
to comply with any law.
to protect the safety of any individual or the general public; and
to prevent violation of our customer relationship terms.

No selling

We will not sell personal information. No personal information will be disclosed to anyone except as provided in this privacy policy.

Marketing purposes

We may disclose aggregate statistics (information about the customer population in general terms) about the personal information to advertisers or business partners.

Employees

We may need to disclose personal information to our employees that require the personal information to do their jobs. These include our responsible management, human resources, accounting, audit, compliance, information technology, or other personnel.

Change of ownership

If we undergo a change in ownership, or a merger with, acquisition by, or sale of assets to, another entity, we may assign our rights to the personal information we process to a successor, purchaser, or separate entity. We will disclose the transfer on the website. If you are concerned about your personal information migrating to a new owner, you may request us to delete your personal information.

Security

We take the security of personal information very seriously and always do our best to comply with applicable data protection laws. Our hosting company will host our website in a secure server environment that uses a firewall and other advanced security measures to prevent interference or access from outside intruders. We authorize access to personal information only for those employees who require it to fulfil their job responsibilities. We implement disaster recover procedures where appropriate.

Upon becoming aware of a data breach, we will notify you and the regulatory authorities in accordance with the timescales and scope required by applicable data protection laws. For registered users of the website, some of your information can be viewed and edited through your account, which is protected by a password. We strongly recommend that you do not divulge your password to anyone. Our personnel will never ask you for your password in an unsolicited phone call or in an unsolicited email. If you share a computer with others, you should not choose to save your log-in information (e.g., email address and password) on that shared computer. Remember to sign out of your account and close the browser window when you have finished your session.

Your Account

You can log into your account to make any updates to your personal information or settings. Alternatively, you can update your information at any NeuronMe affiliated business. Should you wish to terminate your account with NeuronMe, you can do so through the NeuronMe website/mobile application or at a NeuronMe affiliated business. You will be required to verify via OTP/Email when you are closing your account. Your account will be deactivated within 30 days.

Accurate and up to date

We will try to keep the personal information we collect as accurate, complete, and up to date as is necessary for the purposes defined in this policy. From time to time we may request you to update your personal information on the website. You can review or update any personal information we have about you, by accessing your account online, emailing us, or phoning us. Please note that in order to better protect you and safeguard your personal information, we take steps to verify your identity before granting you access to your account or making any corrections to your personal information.

Retention

We will only retain your personal information for as long as it is necessary to fulfil the purposes explicitly set out in this policy, unless:

retention of the record is required or authorised by law; or
you have consented to the retention of the record.

During the period of retention, we will continue to abide by our non-disclosure obligations and will not sell your personal information.

We may retain your personal information in physical or electronic records at our discretion.

Transfer to another country

We may transmit or transfer personal information outside of the country in which it was collected to a foreign country and process it in that country. Personal information may be stored on servers located outside the country in which it was collected in a foreign country whose laws protecting personal information may not be as stringent as the laws in the country in which it was collected. You consent to us processing your personal information in a foreign country whose laws regarding processing of personal information may be less stringent.

Updating or removing

You may choose to correct or update the personal information you have submitted to us, by clicking the relevant menu in any of the pages on our website or contacting us by phone or email.

Changes

We may change the terms of this policy at any time by updating this web page. We will notify you of any changes by placing a notice in a prominent place on the website, sending a push notification on our mobile application, or by sending you an email detailing the changes that we have made and indicating the date that they were last updated. If you do not agree with the changes, then you must stop using the website and mobile application. If you continue to use the website or mobile application following notification of a change to the terms, the changed terms will apply to you, and you will be deemed to have accepted those updated terms.

Should you have questions regarding this Privacy Policy, do not hesitate to contact us at info@neuronme.co.za.

Limitation

We are not responsible for, give no warranties, nor make any representations in respect of the privacy policies or practices of linked or any third-party websites. No data transmission over the internet or any wireless network can be guaranteed to be perfectly secure. As a result, while we use reasonable technical and organisational measures to protect the information we hold for you, we cannot guarantee the security of any information you transmit over the internet.

Enquiries

If you have any questions or concerns arising from this privacy policy or the way in which we handle personal information, please contact us.