AVIATION4SA (A4SA) PRIVACY POLICY

(Version 2)

Table of Contents
1. Introduction
2. Collection of Personal Information
3. Use of Personal Information
4. Disclosure of Personal Information
5. Obtaining Your Consent
6. Withdrawing Your Consent
7. Security of Personal Information
8. Retention of Personal Information
9. Accuracy of Personal Information
10. Access and Correction
11. Transfer of Personal Information Overseas
12. Contact Us
13. Disclaimer
14. Governing Law
15. Interpretation

1. INTRODUCTION

1.1	This personal information policy “Policy” applies to Aviation4SA Proprietary Limited, a company incorporated in South Africa under registration number 2017/510234/07 ("Aviation4SA").
1.2	We at Aviation4SA respect the privacy of your personal information and are committed to safeguarding your privacy online as far as possible. We are committed to implementing policies, practices and processes to safeguard the collection, use and disclosure of the personal information you provide us, in accordance with all applicable South African laws and regulations including without limitation the Protection of Personal Information Act 4 of 2013, as amended from time to time ("POPIA").
1.3	This Policy sets out how personal information that we collect from you, or that you provide to us will be used, processed or disclosed by us, including how certain information would be used to personalise advertising directed at you. This Policy also sets out the types of personal information we collect, how we keep it secure, as well as how you can access or alter your personal information stored by us. Please read the following carefully to understand our policy and practices regarding your personal information and how we will treat it.
1.4	Unless restricted by applicable law, by interacting with us and/or using our Platform, you agree that any and all personal information relating to you collected by us or provided by you from time to time may be used, processed, and disclosed for such purposes and to such persons as set out in this Policy.
1.5	We may amend this Policy at any time by posting a revised version on our Platform. Please note that no individual notice will be sent to you. You will acknowledge and agree to any amended version of the Policy if you continue to use our Platform, website or any of our products and services after the changes have taken effect. You are reminded to check our Platform from time to time for updates or amendments to this Policy.

2. COLLECTION OF PERSONAL INFORMATION

2.1	The POPIA defines personal information as "information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person, including, but not limited to:
(a)	information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth of the person;
(b)	information relating to the education or the medical, financial, criminal or employment history of the person;
(c)	and any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier or other particular assignment to the person;
(d)	the biometric information of the person;
(e)	the personal opinions, views or preferences of the person;
(f)	correspondence sent by the person that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence;
(g)	the views or opinions of another individual about the person;
(h)	the name of the person if it appears with other personal information relating to the person or if the disclosure of the name itself would reveal information about the person."
2.2	You can use and browse our website without disclosing your personal information. You are not required to provide personal information as a condition of browsing our website, except as may be necessary for us to be able to provide the products and services for your use and access and to respond to your requests, if any.
2.3	The types of personal information we collect about you include -
2.3.1	your contact information
2.3.2	your personal particulars;
2.3.3	your financial information; and
2.3.4	your educational and professional qualifications and work experience.
2.4	We collect personal information in the following situations -
2.4.1	when you carry out transactions or interact with us on or in relation to our Platform, website or services;
2.4.2	when you register a Profile with us;
2.4.3	when you contact us by email, telephone, or in person, to resolve any issues that you may be facing or with inquiries or requests;
2.4.4	when you leave your personal information for us to respond back to any request or query;
2.4.5	when you subscribe to any of our services or notifications;
2.4.6	when you engage any of our representatives or any of our services;
2.4.7	when you leave your contact details with any of our representatives or on our Platform, at our website or interact with any of our representatives;
2.4.8	when you fill in any application, inquiry or survey forms; and
2.4.9	when you provide feedback or make complaints to us.
2.5	We may collect certain information on your visits to our Platform and website including, but not limited to traffic data, location data, and the resources that you access and information about your computer, your IP address, operating system and browser type. This information is non-personally identifiable information (i.e. it cannot be used to identify you) and may be used by us, or by a third party advertiser, in tailoring advertising specifically for you or for compiling statistical data about our users' browsing actions and patterns. You may opt out of providing such information in accordance with the provisions set out below.
Cookies
2.6	Cookies are used on our website to distinguish you from other users. Cookies help us to provide you with a better experience when you browse our website and improve on our website services. In addition, cookies are used to personalise the advertising you see on our website.
2.7	You can manage the type of cookies that are allowed through your browser settings, including completely blocking all cookies if you so wish, though this may affect the quality of your browsing and use of our website.

3. USE OF PERSONAL INFORMATION

3.1	We use the personal information we have collected about you for one or more of the following purposes -
3.1.1	administering our Platform, website and any of our services;
3.1.2	improving your browsing experience;
3.1.3	enabling your use of the services available on our website;
3.1.4	providing to you the services that you have specifically requested;
3.1.5	responding to your enquiries or requests;
3.1.6	responding to and taking follow-up action on complaints regarding the use of our Platform or any service provided by us;
3.1.7	sending you general (non-marketing) commercial communications;
3.1.8	performing office and operational administrative matters;
3.1.9	providing third parties with statistical information about our users. Such statistical information may be used to personalise advertising on our website, but cannot be used to identify any individual user;
3.1.10	conducting market research and analysis;
3.1.11	processing any job application; and
3.1.12	any other purposes relating to the above.
3.2	We will not, without your express consent, disclose your personal information to third parties for the purposes of direct marketing.

4. DISCLOSURE OF PERSONAL INFORMATION

We may disclose some of the personal information we have collected about you to other third parties for the following purposes -
4.1	to any external service provider to facilitate the provision of our services to you;
4.2	to comply with any legal requirement;
4.3	to protect our rights, property, and safety, and the rights, property and safety of other users of the website;
4.4	in connection with any legal proceedings or prospective legal proceedings; and
4.5	in connection with a business asset transaction (i.e. the purchase, sale, lease, merger or amalgamation or any other acquisition, disposal or financing of an organisation or a portion of an organisation or of any of the business or assets of an organisation) to which we are a party or a prospective party.

5. OBTAINING YOUR CONSENT

5.1	Before we collect, use or disclose your personal information, we will notify you of the purpose why we are doing so. As far as possible, we will not collect more personal information than necessary for the stated purpose.
5.2	Under certain circumstances, when you voluntarily provide your personal information for stated purposes, we accept that you consent for us to collect, use or disclose your personal information.
5.3	If you interact and transact with us on behalf of another individual, you must first obtain consent from that individual in order for us to collect, use or disclose his personal information.

6. WITHDRAWING YOUR CONSENT

6.1	You can withdraw your consent at any time for any or all of the purposes stated herein by contacting our data protection officer below.
6.2	If you wish to withdraw consent, please give us reasonable advance notice.
6.3	Please be aware that upon your withdrawal of consent, we will not be able to provide you with services or access to our Platform.

7. SECURITY OF PERSONAL INFORMATION

7.1	We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information and any unauthorised access, use or disclosure.
7.2	We will store all the personal information you provide on secure server. Please understand that the transmission of information is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our website and any transmission is at your own risk.
7.3	Where we have given you (or where you have chosen) a password which enables you to access the Platform, certain services or accounts, you are responsible for keeping this password confidential. Please do not share the password with anyone.

8. RETENTION OF PERSONAL INFORMATION

We will not retain any of your personal information under our charge when it is no longer necessary for any business or legal purposes and will ensure that your personal data that are no longer needed by us will be destroyed or disposed of in a secure manner.

9. ACCURACY OF PERSONAL INFORMATION

We will take reasonable precautions and verification checks to ensure that the personal information we have collected from you is reasonably accurate, complete and up-to-date. From time to time, we may verify the same with you and take such steps for you to update us on any changes to your personal information.

10. ACCESS AND CORRECTION

10.1	You have the right to -
10.1.1	check whether we have any personal information relating to you and, if so, obtain copies of such information;
10.1.2	find out how we have been using or disclosing your personal information; and
10.1.3	require us to correct any personal information relating to you which is inaccurate for the purpose for which it is being used.

11. TRANSFER OF PERSONAL INFORMATION OVERSEAS

11.1	We may temporarily store, process or transfer your personal information between countries in order to enable us to use your personal information in accordance with this Policy.
11.2	If there is a need for us to transfer your personal information to another country, we will ensure that the standard of data protection in the recipient country is comparable to that of the POPIA. Should such standard of data protection not be provided for in terms of legislation, we will enter into appropriate contractual arrangements accordingly.

12. CONTACT US

12.1	If you have any query or feedback, or any complaint you have relating to how we manage your personal information, you may contact our Data Protection Officer at - Attn: Data Protection Officer Email: Craig@aviation4sa.co.za
12.2	Any query or complaint should include the following -
12.2.1	your full name; and
12.2.2	contact information; and
12.2.3	description of query or complaint

13. DISCLAIMER

No information transmission or storage can be guaranteed to be full proof and secure in all circumstances. As such, please note that while we strive to protect your personal information, you provide us your personal information at your own risk.

14. GOVERNING LAW

This Policy shall be governed in all respects by the laws of South Africa.

15. INTERPRETATION

15.1	Words importing the singular number only shall include the plural number and vice versa.
15.2	Words importing only one gender shall include any gender and the neuter gender.
15.3	Headings of clauses have been inserted for guidance only and shall not be deemed to form any part of the context or be taken into consideration in the interpretation of this Agreement.
15.4	References to a person shall be construed as including an individual, sole proprietorship, firm, company, corporation, government, unincorporated body of persons, state or agency of a state or any association or partnership (whether or not having separate legal personality) or two or more of the foregoing.
15.5	References to any person shall include their successors-in-title, assigns, transferees and/or personal representatives.
15.6	References to times of day shall unless otherwise stated be references to South Africa time.
15.7	References to a day, month or year shall unless otherwise stated be construed by reference to the Gregorian calendar.
15.8	This “Personal Information Policy” may also be referred to as “Privacy Policy” on our Platform or Website.
15.9	This Policy should be read together with the “Terms of Service” also referred to as “Subscriber Agreement” which is hereby incorporated into these terms by reference.
15.10	Any reference to any statute or legislation shall be deemed a reference to such statute or legislation as amended from time to time or to a newly adopted statute or legislation replacing a repealed statute or legislation and be deemed to include any subsidiary legislation made thereunder.