BEAUTY BULLETINPRIVACY POLICY INTRODUCTIONBrand Influence CC, a close corporation with registered address at Office OE, Ground Floor, Nautica building, Waterclub Complex, 100 Beach Road, Granger Bay, Cape Town, 8005 (“Beauty Bulletin” “we”, “us”, “our”) respects, and is committed to ensuring, the privacy of every person who visits or uses this website, www.beautybulletin.com. This privacy policy (this “policy”) has been put together to explain how we may collect, use, share, retain and generally process your personal information obtained during your interactions with us (whether online, in writing or verbally) or which is collected or received in any other manner. This policy further explains your choices and rights in relation to our processing of your personal information. Any visit to or use of this website is deemed to include an acceptance of this policy. Please ensure that you have read, fully understand and agree with the provisions contained in this policy before browsing or using this website. This policy may be revised from time to time to take into account any changes in applicable laws, our services, this website or any aspect related to our business generally. We will inform you and, if appropriate, seek your consent if we intend to materially change the way in which we use your data. We therefore encourage you to monitor this policy periodically to note any changes made to it. CHILDREN’S PERSONAL INFORMATIONBeauty Bulletin shall not process any personal information relating to a person under the age of 18 years unless it has obtained consent from that person’s parent or legal guardian. If this website is being accessed by the parent or guardian of a child under the age of 18 years, and personal information pertaining to that child is being provided by the parent or guardian, then they hereby expressly consent to Beauty Bulletin processing such information according to the further provisions of this Privacy Policy.WHAT PERSONAL INFORMATION DOES BEAUTY BULLETIN COLLECT?Beauty Bulletin is subject to the Protection of Personal Information Act, 4 of 2013 (“PoPIA”).We may collect certain information about you when you visit this website, become a client, become a customer, provide goods or services to us, apply to be a brand influencer (“Realfluencer”) or apply for a job. The type of information we collect will depend on the purpose for which it is collected and used. We will only collect information that we need for that purpose. The information we collect includes–
information about the content and services you express an interest in when you use this website;
your login data, name, surname and contact information, including email address, and mobile number which you may submit to Beauty Bulletin when you interact with us on this website or when you create an account;
information when you enter into a competition posted on our website including name, surname and contact information, including email address, mobile number and banking details should you be declared or selected the winner in such competition and we need to transfer any cash reward to you;
information about your location or similar location-based information;
information regarding your personal or professional interests, preference or opinions;
information about how you use our website, surveys, events and services;
information regarding demographics, experiences with Beauty Bulletin’s services and contact preferences in order to provide you with further correspondence about Beauty Bulletin’s goods or services;
Information from Beauty Bulletin Realfluencers including:
Identifying information such as your name and surname, gender, race, age, marital status;
Information about your residential location;
Contact details such as social media contact details, phone numbers, email address and your physical address to enable Beauty Bulletin to send you products;
information regarding your personal or professional interests, preference, feedback and opinions. This allows Beauty Bulletin to present customized projects and content to you and also to show brands that correlate with your interests;
your username and password;
details of products and services that you have obtained from us;
data collected from you as a result of you agreeing to participate in our projects, events and/or research studies via surveys completed by you, including but not limited to, survey responses, interviews conducted with you, video diaries that you have filmed for us or any other content or posts generated by you in relation to you participation in the projects events or research studies, services which you have provided to us and any other content that you submit;
social network information (facebook, Instagram, twitter or such other social media platform that you have a presence on), your social network identifier, your reach and number of followers, all information accessible on your publicly available profile such as images, photos, photo tags, likes, followers, comments, posts, stories;
information from Beauty Bulletin clients, customers and their employees:
for invoicing and other administrative purposes (such information relating to your name, registration or identity number, contact details (such as phone numbers and email addresses), physical address and postal address and invoicing information, your bank account details should we need to refund any money into your bank account);
for the purposes of conducting business and commercial activities in the ordinary course;
identifying information (such as names, identification or registration number), contact details (such as phone numbers and email addresses), physical address and postal address, financial and tax information from suppliers and professional service providers so that we can place orders/instruct you and make payment in respect of any goods or services we receive; and
the information you provide in your curriculum vitae, in our application form and supporting documentation/information during the recruitment process purely for the purposes of assessing your suitability for the role, for contacting you to progress your application and to take up any references you have provided;
additional information which we are required or permitted by applicable legislation to collect and process, as well as any additional information you may choose to provide to us, publicly through social media or any other forums.
In general, you may navigate this website without directly providing Beauty Bulletin with any personal information. Any domain name information that Beauty Bulletin collects is not used to personally identify you but is instead aggregated to measure the number of visits, average time spent on this website and the web pages viewed. Such other information includes browser and device information, website and application usage data, IP addresses, demographic information such as marketing preferences, geographic location, home language, and information collected through cookies and other technologies or information that has been anonymised or aggregated. Beauty Bulletin uses this information to improve its contents. If we link this information with your personal information, we will treat such linked information as personal information. You can choose not to provide personal information to us when requested. However, if this is necessary to provide you with our services, access to our Internet Services, or to perform administrative functions, we may be unable to do these things.Certain of your survey responses may reveal information about you which is considered to be a “special personal information” (this may include details about your race or ethnicity, political opinions, religious or philosophical beliefs, trade union memberships, genetic or biometric data, health or mortality, sex life or sexual orientation, and criminal behavior). We will only ask questions which relate to special categories of data where we are permitted to do so by the law.and we will also give you an option to “prefer not to say” as a response to any questions which concern any special personal information.WHERE DO WE COLLECT PERSONAL INFORMATION FROMAs far as possible, we will always collect personal information about you directly from you, except in the following circumstances:
Where personal information about you is collected from a public record, or from another source if the information has already been made public by you or on your behalf with your consent;
where you have given us your express consent to collect your personal information from another source;
where the collection of your personal information from another source will not prejudice any of your legitimate interests;
where the collection of personal information from another source is necessary to maintain our legitimate interests or those of any third party we are permitted to share that information with;
where the collection of personal information directly from you would prejudice the purpose for that collection; or
where the collection of personal information directly from you is not reasonably practicable in the circumstances.
WHEN DO WE COLLECT YOUR PERSONAL INFORMATION?
We collect your Personal Information when you:
Use our website;
register an online profile or complete any forms on our websites;
voluntarily provide us with information when you interact with us, for example when you make general enquiries either online, in person, through the website or telephonically, lodge complaints, and communicate with us, or you subscribe or consent to receiving newsletters or other communications from us;
provide any goods or services to us as a supplier or service provider to us;
apply to be a Beauty Bulletin Realfluencer by submitting your application and thereafter should you be accepted as a Beauty Bulletin Realfluencer by Beauty Bulletin;
apply for vacancies by submitting your cv and thereafter should you be employed by Beauty Bulletin;
subscribe for a service or any publications or newsletters, enter into a competition or promotion or participate in a survey offered via social media or our website;
participate in any of our surveys, projects or events.
From time to time we may collect your Personal Information from trusted third parties, in such event we will ensure that you have provided your consent to those third parties for your Personal Information to be disclosed to us.LEGAL BASIS FOR OUR PROCESSING OF YOUR PERSONAL INFORMATIONWe rely on one or more of the following reasons for processing your personal information –
you consenting to our processing your personal information for a specific purpose;
where processing is necessary for the performance or conclusion of a contract to which you are a party;
where processing is necessary to achieve Beauty Bulletin’s legitimate interests, for example the management, operations and improvement of our business (to the extent that they don’t unjustifiably and unlawfully limit your interests or rights which require protection);
where processing is necessary to comply with an obligation imposed by law;
where processing is necessary to protect your legitimate interests; and
where processing is necessary to pursue the legitimate interests of a third party to whom the personal information is lawfully supplied.
HOW WE USE YOUR PERSONAL INFORMATIONWe use the personal information provided by you for the following purposes (“purpose/s”) –
to monitor and evaluate, continually improve and enhance the use, functionality and performance of the website, products and services;
to manage the security of our sites, networks and systems
to enter into a contract with you;
to perform our obligations under the contract with you;
to notify your of promotions and competitions;
to provide and deliver our products and services to you, as a client or customer, that you order from us to send statements or invoices and any other legal documents and for any other purpose relating to providing our products and services to you;
to provide and deliver to you, as Beauty Bulletin Realfluencer, the products or services forming the subject matter of the survey, project or event that you are participating in;
to process market research data provided by you, as an influencer, as a result of you opting in to participate in a survey, project or event for market research purposes;
to analyse the effectiveness of our client’s advertising campaigns, to provide clients with statistical results of surveys tailored to their marketing campaign or brand;
in connection with legal proceedings;
to contact you and offer you opportunities to take part in surveys, projects and events;
to update Beauty Bulletin’s records about you and for the purpose of retaining records about you;
to assist with business development;
to confirm and verify your identity or to verify that you are an authorized influencer or client for security purposes;
to communicate with you in the course of Beauty Bulletin’s ordinary business activities;
to contact you regarding the products and services which may be of interest to you, provided you have given us consent to do so or you have previously requested a product or service from us and the communication is relevant or related to that prior request and made within any timeframes established by applicable laws;
research, training and statistical analysis with the aim of improving Beauty Bulletin’s content and services by making them easier to use and by providing access to certain sections of this website;
to prevent or detect any unlawful activities;
to follow up and responding to your enquiries and complaints or processing your requests in relation to your personal information;
to notify you of any changes to our products and/or services;
contacting you for market research purposes;
to comply with legal and regulatory requirements and obligations or industry codes to which we subscribe or which apply to us, or when it is otherwise allowed by law.
RETENTION OF YOUR PERSONAL INFORMATIONYour personal information is retained by us for our business purposes and to comply with any applicable laws and regulations. To the extent not specifically prohibited or prescribed by applicable laws, we will retain your personal information for periods that we believe are reasonably necessary to serve our legitimate business interests. When we no longer have an ongoing legitimate business need to process your personal information, we will either delete or de-identify it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and keep it from any further processing until deletion is possible. RIGHTS AVAILABLE TO YOU IN RELATON TO YOUR PERSONAL INFORMATION You have the right to control the manner in which your personal information is processed by Beauty Bulletin, including the following rights–
to obtain from us confirmation as to whether or not personal data concerning you is processed, and where that is the case, you have the right to request and get access to that personal data;
to update and correct your personal information that is held by us;
in certain cases, and to the extent not prohibited by applicable laws, you may request us to remove your personal information, partially or completely;
to request us to limit processing of your personal information to any one or more of the Purposes listed above (note that this may impact the accessibility of our services);
in certain cases, to object to processing of your personal information, including with regards to profiling. You have the right to opt-out from any communications from us (whether marketing or otherwise). You may withdraw any consent previously provided in relation to the collection, use and processing of your personal information; and/or
to escalate any complaint in relation to your personal information to the Information Regulator, whose contact details are:
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001P.O Box 31533Braamfontein, Johannesburg, 2017Complaints email: complaints.IR@justice.gov.zaGeneral enquiries email: inforeg@justice.gov.za. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changesTo ascertain whether you are eligible for, and, to send a request with regards to, any one of the above rights please send an email to info@beautybulletin.com. We may charge a small fee, to the extent lawfully prescribed or permissible, for any such request where we believe the request to be unfounded, repetitive or excessive. Before processing any one of the above-listed requests, we may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. PROTECTION OF YOUR PERSONAL INFORMATIONWe maintain technical, physical and administrative security measures aimed at protecting your personal information against accidental or unlawful access, damage, alteration, loss or destruction, by implementing reasonable and appropriate physical, administrative, organizational and technical safeguards. We require the same standards of protection from any third parties to whom we disclose your personal information. Despite the above security measures, the transmission of data over the internet cannot be guaranteed to be 100% secure and protected. Accordingly, we cannot ensure or warrant the security of any information you send to us or receive from via electronic transmission. This is particularly true for information you send to us via email, which we cannot guarantee is protected in transit. Once we receive your information, we apply the methods mentioned above to ensure its protection while in our possession. If you are concerned about submitting your personal information to us electronically, please contact us to enquire about making other arrangements. SHARING OF PERSONAL INFORMATION WITH THIRD PARTIES AND LINKS TO THIRD PARTY WEBSITESThere are instances when we need to share your personal information with and obtain information about you from third parties, all to the extent necessary for, and incidental to, the performance of our services and/or your use of this website. These include sharing your information with –
entities with whom we have partnered to jointly create and offer our content and services;
our employees that require the personal information in the performance of their jobs;
Our clients where we have agreed to provide access to our survey data ((which for the avoidance of any doubt may include, among other things, your feedback and opinions and identifying information such as your name and surname, gender, race, age, marital status, location, and other information about you which is considered to be a “special personal information”), or where we have agreed to undertake a survey on their behalf, or where we have agreed to assist them in monitoring the effectiveness of their advertising campaign;
Beauty Bulletin’s business partners who are involved in the delivery of our products or services to you and may, directly or indirectly, render certain services to Beauty Bulletin or to you or in undertaking activities linked to the operation of such services on Beauty Bulletin’s behalf; or
Other companies in our industry when we believe it will enhance to services and products we can offer to you, but only where you have not objected to such sharing;
third parties, where the disclosure is in compliance with legal and/or contractual requirements that Beauty Bulletin is subject to;
third parties, where we believe it is necessary to protect our rights.
Given the nature of our business and information technology infrastructure, your personal information may be transferred to other countries, some of which may have different data protection laws to those that are applicable in the country in which you reside. We will at all times ensure that your personal information is protected in terms of this Policy. You consent to your personal information being transferred to other countries regardless of the data protection laws applicable in those countries. Our website may contain links to third party websites and applications. We are not responsible for and make no representations or warranties in relation to the privacy practices or content of any third-party websites and applications. Your use of such websites and applications is subject to the applicable third-party privacy statement and is at your own risk. CHANGE OF OWNERSHIPWe may share your Personal Information with third parties in the event of a reorganisation, merger, sale, joint venture, assignment, transfer or other type of sale of all or any portion of our business, assets or stock.USE OF COOKIES AND OTHER TRACKING TECHNOLOGIESCOOKIESCookies are small pieces of data, that act as a tracking file, sent from a website and stored on the user’s computer by the user’s web browser while the user is browsing. A cookie enables us to analyse usage patterns on our website and tailor the website to your needs. Most web browsers are set to accept cookies, however if you do not wish to accept cookies you can adjust your internet browser settings to refuse the cookies. Please note that some parts of this website may not function fully if you disallow cookies.Cookies do not personally identify you, but rather your browser. The cookies simply operate as a unique identifier, which help us to know what our users find interesting and useful in this website. We do not link this information back to other information that you have provided to us, unless required by law. We do not store any personal information inside cookies. We use cookies to enhance your browsing experience. By continuing to use our website without changing your browser’s settings, you agree to our use of cookies. We may engage third party services from time to time for website monitoring, reporting and analysis purposes. Those services may also use cookies and gather anonymous web usage information (as described above) through this website. Note that we do not use cookies for tracking purposes. OTHER TRACKING TECHNOLOGIESDo Not Track (“DNT”) is a web browser setting that requests that a web application disables its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites you encounter while browsing to stop tracking your activity. We honour DNT signals and do not track, plant cookies, or use advertising when a DNT browser setting is activated.CONTACT USShould you have any queries regarding this Policy or the manner in which your personal information is processed, please feel free to contact us as follows –Information OfficerBrand Influence CC
Office OE, Ground Floor, Nautica building,
Waterclub Complex, 100 Beach Road, Granger Bay,
Cape Town, 8005
info@beautybulletin.com
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