MRC Privacy Policy

Purpose of this privacy policy

This privacy policy aims to give you information on how MRC collects and processes your personal information through your use of this website, including any data you may provide through this website when you sign up to our newsletter or purchase a product or service or take part in a competition or promotion.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your data.

Responsible Party Contact details

All inquiries regarding our privacy policy and procedures must be addressed to;

1. Full name of legal entity: More Real Information technology PTY Ltd.
2. Email address: sales@mrcomputerservices.co.za
3. Registered address: 7 Alberton Lifestyle Centre, St Austell Street, Alberton
4. Postal address: PO Box 221 Alberton, 1450
5. Telephone number: (011) 869 2980

i. You have the right to make a complaint at any time to the Information Regulator’s office (IR), the Republic of South Africa’s authority for data protection issues (http://www.justice.gov.za/inforeg/). We would, however, appreciate the chance to deal with your concerns before you approach the IR so please contact us in the first instance.
ii. You have the right to make a complaint at any time to the Information Regulator’s office (IR), the Republic of South Africa’s authority for data protection issues (http://www.justice.gov.za/inforeg/). We would, however, appreciate the chance to deal with your concerns before you approach the IR so please contact us in the first instance.
The data we collect about you

1. Personal information means the information as per entered on the website. It does not include data where the identity has been removed (anonymous data).
   i. We may collect, use, store and transfer different kinds of personal information about you which we have grouped together as follows:
2. Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.
   ii. Contact Data includes a billing address, delivery address, email address, and telephone numbers.
   iii. Financial Data includes payment card details.
   iv. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
   v. Technical Data includes internet protocol (IP) address, your login data, browser type, and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
   vi. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
   vii. Usage Data includes information about how you use our website, products, and services. This information shall include the full Uniform Resource Locators (URL) Clickstream to, through and from our website (including the date and time) and the products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page and any phone number used to call our customer service number.
   viii. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
3. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal information but is not considered personal information in law as this data will 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 information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this privacy policy.
4. We do not collect any Special Personal information about you.
5. Submission of Personal Information on behalf of another: If you provide information on behalf of someone else, then it is your responsibility to obtain the necessary consent from the person/ User before making the Personal Information available to us. On receipt of Personal Information, we assume that the necessary consent has been obtained and will process the Personal Information as per your instructions. By submitting such Personal Information on behalf of another person/ User, you indemnify us against any third-party claim, where such third party claim relates to Personal Information that has been processed without the necessary consent or other available exception allowed by law.
6. If you fail to provide personal information: Where we need to collect personal information 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 goods or services (including services for no charge)). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal information collected?

We use different methods to collect data from and about you including through:

1. Direct interactions. You may give us your Identity and Contact by filling in forms or by corresponding with us by phone, email or otherwise. This includes personal information you provide when you apply for our products or services;
2. Create an account (login facility) on our website;
   i. subscribe to our service or publications (i.e. newsletters);
   ii. request marketing to be sent to you;
   iii. enter a competition, promotion or survey; or
   iv. give us feedback or contact us.
3. Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal information by using cookies (see section 4) below), server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
   i. Third parties or publicly available sources. We will receive personal information about you from various third parties and public sources as set out below:
4. Technical Data from the following parties:
5. Analytics providers such as Google;
   i. advertising networks; and
   ii. search information providers.
6. Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
   i. Identity and Contact Data from data brokers or aggregators.
   ii. Identity and Contact Data from publicly available sources such as CIPC.

How we use your personal information

1. We will not sell your personal information.
2. We will only use your personal information within the framework of the law. Most commonly, we will use your personal information in the following circumstances:

– Where you have given us your consent; or
– Where we need to perform the contract we are about to enter into or have entered into with you; or
– 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; or
– Where we need to comply with a legal obligation.

3. Generally, we do not rely on consent as a legal basis for processing your personal information although we will get your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal information

We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so.

Marketing:

We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising. Promotional offers from MRC.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or acquired goods or services from us and you have not opted out of receiving that marketing.

Disclosures of your personal information

We may share your personal information with the parties set out below for the purposes set out in the table above.

Internal Third Parties as set out in the Definitions. Where we share your personal information to our group (including franchisees) we ensure your personal information is protected by requiring all our group companies (or franchisees) to follow this policy when processing your personal information.

External third parties as set out in the Definitions.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

Data security

We have put in place appropriate technological and organizational measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal information for?

We will only retain your personal information for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for five years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

Your legal rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal information:

– Request access to your personal information (commonly known as a “data subject access request”). Currently, you have this right under the PAI Act. There may be a fee associated with this request see below. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
– Request correction of the personal information 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.
– Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information 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 information 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 notified to you, if applicable, at the time of your request.
– Object to the processing of your personal information 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 information 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.
– Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios:

1. 1. If you want us to establish the data’s accuracy.
   2. Where our use of the data is unlawful but you do not want us to erase it
   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.
   4. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it

– Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information 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 a contract with you.
– Withdraw consent at any time where we are relying on consent to process your personal information. 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Definitions

PAI Act – means the Promotion of Access to Information Act 2 of 2000.
Personal Information – means information as defined under the POPI Act.
POPI Act – means the Protection of Personal Information Act of 2013.
Special Personal Information means information as defined under section 26 of the POPI Act (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and biometric information or criminal convictions and offenses.

THIRD PARTIES

1. Internal Third Parties: Other companies in the MRC Group, acting as joint responsible parties or operators and who are based in South Africa and who may also provide IT and system administration services and undertake leadership reporting.
2. External Third Parties
   2a. Service providers acting as operators who provide IT and system administration services.
   2b. Professional advisers acting as operators or joint Responsible Parties, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance, and accounting services.
   2c. The South African Revenue Services, regulators and other authorities acting as operators or joint Responsible Parties based in the Republic of South Africa who require reporting of processing activities in certain circumstances.
   2d. Court of law or any other authority where we have an obligation under law to share your personal information;
   2e. In the event that we sell or buy any business or assets, in which case we may disclose your Personal Information to the prospective seller or buyer of such business or assets.