Privacy Policy

1Definitions

1.1. In this Policy, the following terms shall have the meanings set out below, consistent with their use in POPIA:

• "Personal information" means information relating to an identifiable, living natural person, and where applicable, an identifiable, existing juristic person, including but not limited to information relating to race, gender, age, contact details, location, online identifiers, and opinions.
• "Processing" means any operation performed on personal information, including collection, receipt, recording, organisation, storage, updating, retrieval, use, dissemination, or destruction.
• "Data subject" means the person to whom personal information relates, that is, you, the user of the Site.
• "Responsible party" means the entity that determines the purpose of and means for processing personal information, being TradeAnswers in respect of this Site.
• "Operator" means any third party that processes personal information on behalf of TradeAnswers pursuant to a contract or mandate, such as a hosting provider or analytics service.

2Responsible Party

2.1. For the purposes of POPIA, TradeAnswers is the responsible party in respect of personal information collected through the Site.

2.2. Enquiries regarding this Policy or the processing of your personal information should be directed to the contact details set out in section 16 below.

3Information We Collect

3.1. We collect personal information through the following general categories and means:

3.2. We do not knowingly collect special personal information as defined under POPIA (such as information relating to health, religious belief, or criminal behaviour) through the Site, and we ask that you do not submit such information to us through any contact form or correspondence unless specifically requested and necessary.

4Purpose and Lawful Basis for Processing

4.1. We process personal information for the following purposes:

1. to operate, maintain, and improve the Site and its Content;
2. to understand how visitors use the Site, including which questions and topics are most read, in order to prioritise future content development;
3. to respond to enquiries, feedback, or correction requests submitted via our contact channels;
4. to send newsletter or update communications to readers who have voluntarily subscribed to receive them;
5. to detect, investigate, and prevent fraudulent, abusive, or unlawful activity in connection with the Site;
6. to comply with any applicable legal or regulatory obligation.

4.2. Our lawful basis for processing personal information for the purposes set out above is, depending on the specific processing activity: your consent (for example, where you voluntarily subscribe to a newsletter or submit a contact form); our legitimate interest in operating, securing, and improving the Site; and, where applicable, compliance with a legal obligation.

5Compliance with the Conditions for Lawful Processing

5.1. We process personal information in accordance with the eight conditions for lawful processing set out in Chapter 3 of POPIA, namely accountability, processing limitation, purpose specification, further processing limitation, information quality, openness, security safeguards, and data subject participation.

5.2. In particular, we limit our collection of personal information to what is reasonably necessary for the purposes set out in section 4 above, we do not process personal information for purposes materially incompatible with the purpose for which it was originally collected without obtaining further consent or establishing an applicable exception, and we take reasonable steps to ensure that personal information we hold is complete, accurate, and not misleading.

6Disclosure and Sharing of Personal Information

6.1. We do not sell, rent, or trade your personal information to third parties for their own independent marketing purposes.

6.2. We may share personal information with the following categories of recipients, strictly for the purposes described in this Policy:

• Service providers and operators: third parties that provide hosting, analytics, email delivery, or similar technical services on our behalf, who are contractually required to process personal information only in accordance with our instructions and to apply appropriate security safeguards;
• Legal and regulatory disclosures: where required to comply with a legal obligation, court order, or lawful request from a regulatory or governmental authority;
• Business transfers: in connection with any merger, acquisition, or sale of substantially all of our assets, subject to equivalent confidentiality protections being maintained.

7Cross-Border Transfer of Personal Information

7.1. Some of the service providers referred to in section 6.2 above may store or process personal information on servers located outside the Republic of South Africa.

7.2. Where personal information is transferred across South Africa's borders, we take reasonable steps to ensure that the recipient is subject to a law, binding corporate rules, or a binding agreement that provides an adequate level of protection that effectively upholds principles for the reasonable processing of personal information that are substantially similar to the conditions set out in POPIA, as required under section 72 of POPIA.

8Retention of Personal Information

8.1. We retain personal information only for as long as is reasonably necessary to fulfil the purposes for which it was collected, or as required by applicable law.

8.2. Voluntarily submitted contact information is generally retained for as long as necessary to address your specific enquiry and for a reasonable period thereafter for record-keeping purposes, after which it is securely deleted or anonymised unless a longer retention period is required by law.

8.3. Aggregated or anonymised analytics data, which no longer identifies any individual, may be retained indefinitely for the purpose of understanding long-term trends in Site usage.

9Security Safeguards

9.1. We implement reasonable technical and organisational measures designed to protect personal information against loss, unauthorised access, interference, modification, destruction, or disclosure, in accordance with the security safeguard condition under POPIA.

9.2. While we take reasonable steps to secure personal information, no method of electronic transmission or storage is entirely secure, and we cannot guarantee absolute security. You acknowledge that any information you transmit to us is done at your own risk.

9.3. In the event of a security compromise that has compromised, or that we reasonably believe has compromised, the personal information of any data subject, we will notify the Information Regulator and affected data subjects as required under section 22 of POPIA.

10Your Rights Under POPIA

10.1. As a data subject, you have the following rights in respect of personal information we hold about you, subject to the conditions and exceptions set out in POPIA:

1. Right to be informed: to be notified that personal information about you is being collected and processed;
2. Right of access: to request confirmation of whether we hold personal information about you, and to request access to that information;
3. Right to correction: to request that we correct or update any personal information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or obtained unlawfully;
4. Right to deletion: to request that we delete or destroy any personal information that we are no longer authorised to retain;
5. Right to object: to object, on reasonable grounds, to the processing of your personal information, including processing for purposes of direct marketing;
6. Right to withdraw consent: where processing is based on your consent, to withdraw that consent at any time, without affecting the lawfulness of processing carried out before such withdrawal.

10.2. To exercise any of these rights, please contact us using the details in section 16 below. We may require reasonable proof of identity before giving effect to any such request, in order to protect your information against unauthorised access.

11Cookies and Tracking Technologies

11.1. The Site uses cookies and similar tracking technologies as described in detail in our separate Cookie Policy, which forms part of this Privacy Policy by reference.

12Children's Information

12.1. The Site is not directed at, and is not intended for use by, children as defined under POPIA (generally, persons under the age of 18), and we do not knowingly collect personal information directly from children.

12.2. If you believe that a child has provided personal information to us through the Site, please contact us so that we may take appropriate steps to delete such information.

13Third-Party Links

13.1. The Site may contain links to third-party websites, including broker websites and regulatory bodies. This Policy does not apply to, and we are not responsible for, the privacy practices of any third-party website. We encourage you to review the privacy policy of any third-party website you visit.

14Changes to This Policy

14.1. We may update this Policy from time to time to reflect changes in our practices, the Site's functionality, or applicable law. The "Last updated" date at the top of this Policy indicates when it was most recently revised. We encourage you to review this Policy periodically.

14.2. Material changes to this Policy will, where reasonably practicable, be brought to your attention through a notice on the Site.

15Contact Information

15.1. For any questions, requests, or concerns regarding this Privacy Policy or our processing of your personal information, please contact us using the details below.