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Information Privacy Policy

We are committed to protecting your privacy. We recognise our obligation to respect and protect the confidentiality of your personal information. For this reason, we have developed this policy to govern the processing of your information.

On Key is a state-of-the-art enterprise asset management system developed by Pragma Products (Pty) Ltd. Pragma Products (Pty) Ltd is a subsidiary of Pragma Holdings (Pty) Ltd. As a product, On Key is marketed by:

  • Pragma Africa (PTY) Ltd within Africa,
  • Pragma International (Pty) Ltd
  • Pragma Netherlands (PTY) Ltd in Europe

This policy applies to all Pragma and Pragma Products websites, software applications, services and solutions regardless of how you access or use them (collectively referred to as “solution” in this policy document). Please read and consider this document carefully since it sets out our intended use of such information. We require your consent to the terms contained in this policy before we permit you to access or use our solutions. By accessing or using our solutions you agree that we may collect, hold, process, use and disclose your personal information on the basis described in this policy.

When we refer to “we”, “us” or “our” herein we are referring to Pragma Products (Pty) Ltd (Registration Number 2000/009492/07) and the affiliated entities within our company group.

This Privacy Notice applies to information we collect through our websites and services. By using our websites and services, you agree to the collection, use, disclosure and transfer of information as described here.

This Privacy Notice describes the types of information we collect or receive, how we may use that information, and third-party sharing. The information we collect includes personal information and non-personal information as these terms are defined below.

The Privacy Notice also describes the measures we take to protect the security of the personal information.

We also inform you how you can reach us to ask us to:

  • access, change or not use the personal information you have provided to us,
  • withdraw any consent you previously provided to us,
  • refrain from sending you email alerts, and
  • answer any questions you may have about our privacy practices.

Personal information is data that can be used to uniquely identify or contact a single person. You may choose to provide personal information to us when you use our websites. As we change our offerings and features from time to time, the options you have to give us personal information may also change, but here are some examples of situations in which you may decide to provide personal information to us:

  • Registering with our websites
  • Signing up for our newsletter
  • Completing a survey
  • Contacting us for any reason
  • Using our websites or online services when personal information is required for use or participation.

The personal information we collect from you will vary depending on the service you are using, the site you are visiting, and how you access it. However, the personal information you provide generally may include your name, surname, email address, phone number (which may include mobile phone number), and region.

Because we directly ask you to provide personal information in these cases, you will often be able to tell from our specific requests what types of information we receive from you.

We collect this information for these reasons:

  • To provide you with access to the site, service or feature you requested
  • To offer you tailored content, such as a newsletter
  • To provide you with technical support or customer service
  • To communicate with you, respond to your requests or provide you with updates and information
  • To better understand our users, their interests and their preferences
  • To develop, deliver and improve our products, services and other offerings.
  • To determine whether you qualify for our solutions and for making related decisions
  • To effectively deliver our solutions and to exercise our rights and comply with our obligations in respect thereof, including by processing and recording solution requests, managing solution accounts, delivering our solutions to you and to such other users as you may have consented to, communicating with you regarding our solutions and collecting payments you may owe
  • To render services and/or comply with our obligations to our clients insofar as such services relate to or involve you
  • To ensure that the information we receive and hold about you is accurate, complete and up to date;
  • To prevent, investigate and prosecute fraud, money laundering, terrorism, abuse of our solutions and other unlawful activities
  • To comply with legal and regulatory requirements, for audit purposes and legal proceedings
  • To inform and provide you with the opportunity to make use of solutions and benefits that we offer and that we believe may be of interest to you to the extent that we are lawfully permitted to do so, and
  • For such other purposes as you may consent to or as may otherwise be lawfully permitted, including for the purposes of protecting our and/or your legitimate interests and/or that of our business partners.

Please note that we will not contact you telephonically for unsolicited marketing purposes or send unsolicited marketing communications to you by mail, facsimile, SMS or electronic mail if you have objected to receiving such communications by way of a public register recognised for such purposes by law or by notifying us of your objection in the prescribed manner. We will provide you with reasonable opportunities to object to receiving marketing communications in the manner prescribed by law, including upon your application to access or use our solutions and on each occasion when we send you such communications.

We also collect non-personal information − data in a form that does not permit direct association with any specific individual. We may collect, use, transfer, sell and disclose non-personal information for any purpose. For example, when you use our services, we may collect data from and about the “commercial electronic mail messages” and “transactional or relationship messages”. We collect such commercial transactional messages so that we can better understand the behaviour of the senders of such messages, and better understand our customer behaviour and improve our products, services and advertising. We may disclose, distribute and transfer such messages and the data that we collect from or in connection with such messages, provided that if we do disclose such messages or data, all personal information contained in such messages will be removed prior to any such disclosure.

We may collect and use your commercial transactional messages and associated data to build anonymous market research products and services with trusted business partners. If we combine non-personal information with personal information, the combined information will be treated as personal information for as long as it remains combined. Aggregated data is considered non-personal information for the purposes of this Privacy Notice.

We may obtain certain personal and non-personal information by automated means when you visit our sites. The type of information we collect by automated means may vary, but generally includes technical information about your device, such as the Internet protocol (IP) address or other device identifier. The information we collect may also include usage information and statistics about your interaction with our websites. That information may include the URLs of our web pages that you visited, URLs of referring and exiting pages, page views, time spent on a page, number of clicks, platform type, and other information about how you used our websites.

In cases where you use a mobile device to access our sites, we will receive information about the location of your device. In some cases, even if you are not using a mobile device, information about your general location may be discernible from your device’s IP address or the URLs we receive. If you access or use our sites or services with your mobile telephone, we may collect your telephone number.

Please note that if adverts or other features on our site are provided by third parties, those parties may also use automated means of data collection that are subject to those third parties’ privacy notices and policies.

We use information we collect by automated means to understand our users and to determine their preferences. As a result, we can develop and deliver new or modified offerings that are improved with our users’ preferences in mind. As described below, we may also use such information to provide a more personalised user experience and to manage advertising.

Web browsers

When you visit our websites, your browser automatically sends us your IP address so that the web pages you request can be sent to your computer or device. We use your IP address to determine additional information such as whether the computer or device has ever been used to visit our site before, which site features were used most often, and how much time was spent on a page.

Web beacons and log files

We may use “web beacons” (also known as Internet tags, pixel tags, tracking pixels and clear GIFs) on pages of our websites. These web beacons allow third parties to collect information such as the IP address of the device, the URL of the web page, the time the page was viewed, the type of browser used, and any additional information in cookies that may have been set by the third party. The information is typically collected in log files, which generally track traffic on our websites. Purposes for this information collection may include managing our online advertising, including determining which adverts brought users to our websites. The information is also used for analytical purposes and to manage technical issues that may arise. We do not attempt to identify individual users through this information.

Sharing of information

We may share personal information we collect with our parent company, other affiliated companies and trusted business partners. We will also share personal information with service providers that perform services on our behalf. Our non-affiliated business partners and service providers are not authorised by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.

We may also disclose information about you:

  • if we are required to do so by law or legal process,
  • when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity, or
  • if necessary to protect the vital interests of another individual,
  • to the entities in our company group, including to the directors, employees, contractors, agents, auditors, legal and other professional advisors of such entities,
  • to entities (including to the directors, employees, contractors, agents, auditors, legal and other professional advisors of such entities) with whom we have contracted to provide services in respect of which you are involved,
  • to any person that supports or authorises your participation in a solution we provide insofar as it pertains to your registration for and participation in such solution, including your legal guardian where appropriate,
  • to governmental, judicial, regulatory and law enforcement bodies and agencies, including the South African Police service,
  • to persons employed by us to provide solutions on our behalf that adhere to principles similar to ours regarding the treatment of your information, including data hosting, processing and management services,
  • to any person to whom we cede, delegate, transfer or assign any of our rights or obligations pertaining to the solutions provided by us or contracts concluded by us,
  • to any person that acts as your executor of your estate, curator or in a similar capacity,
  • to such other persons as may be permitted by applicable law or that you may consent to, including persons and entities who may request such information to evaluate your creditworthiness

Please note that our sharing of your information may also involve the transfer thereof to third parties outside South Africa. In the event of such transfer, we will require that such third party also subscribes to protecting your information on terms similar to the terms of this policy.

We also reserve the right to transfer personal information we have about you if we sell or transfer all or a portion of our business or assets.

As described in “Our collection and use of non-personal information” above, we may collect, use, transfer and disclose non-personal information for any purpose. When you use our websites, you agree that we may share information about you as described in this Privacy Notice.

Your choices

In certain cases, you may have choices about how we use and disclose your personal information. For example, we will ask you before we use your personal information for any purpose incompatible with those purposes identified in this Notice. If we provide you with any marketing messages, we will also give you an opportunity to opt out of receiving further messages.

You can also choose not to give us the information we request. In some cases, if you decide not to provide information, we will not be able to provide you with access to the site you requested, or we may not be able to provide you with the service, feature or information you requested.

In some cases, you can stop or limit the information we collect by automated means. Please review the sections of this Notice titled “Information collected by automated means” to learn more about how you may be able to stop or limit our receipt of that information.

You may choose to opt out of interest-based adverts in the settings page after logging in. You may also exercise and amend your choices by sending an email to us as specified in the “How to contact us” section below.

Access and correction

We will provide you with the ability to access and update certain information we have about you, such as your contact information. Your right to access or amend personal information may be limited in some circumstances. Please include your name, email address and postal address in your request so that we may respond appropriately and promptly.

How we protect personal information

We maintain appropriate administrative, technical and physical safeguards to protect your personal information from accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use and other unlawful forms of processing. No data transmissions through the Internet or via mobile devices, or even the physical transfer of information, can be guaranteed to be completely secure. We cannot fully eliminate all security risks associated with personal information. We do not ensure or warrant the security of any data or information you transmit to us, and you do so at your own risk.

Transfers of information

As part of our international operations, we may transfer information about you to any jurisdiction where we do business. Even if those jurisdictions do not have the same privacy laws as the jurisdiction where you reside, we will treat your information as subject to the protections described in this Notice.

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your personal information to the Republic of South Africa by On Key online. By providing your personal information you consent to any transfer and processing in accordance with this Notice.

The personal information and company information we collect from you will vary depending on the services and products you are using or the services or products that you are providing to the Pragma Group of Companies and our clients. Your information will be kept for the duration of our formal agreement. Upon the conclusion of our agreement, only information that is required by law will be kept for the period specified by law.

Personal information

Depending on the nature of your business and your engagement with Pragma as a business, sole proprietor or individual (training), the personal information you provide generally may include:

  • your title, name and surname
  • contact information such as your email address, phone number (which may include mobile phone number) and physical address
  • your role within your company
  • your identification number or passport number (where legally required for compliance purposes)
  • tax number (where legally required)
  • the disclosure of specific aspects of your health (where legally required for compliance purposes)
  • proof of accreditations, certifications or specific documentation to perform certain jobs (where legally required for compliance purposes).

Because we directly ask you to provide personal information in these cases, you will often be able to tell from our specific requests what types of information we receive from you.

We collect this information for these reasons:

  • To set up formal agreements
  • To register you on our ERP for transactional purposes
  • To provide you with technical support or customer service
  • To communicate with you, respond to your requests or provide you with updates and information.

Company, corporation, partnership and other

The company, corporation or partnership information we collect from you will vary depending on the Pragma services and products you are using or the services or products that you are providing to the Pragma Group of Companies and our clients. This information will be kept for the duration of our formal agreement. Upon the conclusion of our agreement, only information that is required by law will be kept for the period specified by law.  In all instances, the information collected will be done with the knowledge or authorisation of the client and will be used to perform the work or service agreed with the client.

Statutory information

Depending on the nature of the agreement and services rendered, the following statutory information will be collected:

  • registered name of the business, including the trading name
  • the nature of the business
  • statutory documents that can include the company registration number and the country of registration, VAT number, BBBEE certificate and more
  • invoicing postal address
  • contact information such as your email address, phone number (which may include mobile phone number) and physical address
  • name and contact information of accountant clerk.

Operational information

Depending on the nature of the agreement between the Pragma Group of Companies and the client the type of operational information collected will vary.  All information collected will be done with the knowledge or authorisation of the client and will be used to perform the work or service agreed with the client.

Third-party contractors

In the event where the Pragma Group of Companies appoint a third-party contractor to perform work for clients on behalf of us, an agreement and strict measures are put in place to ensure that the contractor complies with the POPIA requirements and adheres to the collection, management, storage and disposal of such information.

The Pragma Group of Companies is committed to adhering to the requirements of the POPI act and endeavours to do so as such:

  • To process personal information with the knowledge or authorisation of our clients, contractors and suppliers in accordance with our operational agreement or as required by POPIA and as necessary to perform our obligations and for no other purpose.
  • To treat personal information as confidential and not disclose it, unless required by law or in the course of the proper performance of our duties.
  • To secure the integrity and confidentiality of personal information by taking appropriate, reasonable technical and organisational measures to prevent loss of, damage to or unauthorised destruction of personal information and unlawful access to or processing of personal information by taking reasonable measures to:
    • identify all reasonably foreseeable internal and external risks to personal information
    • establish and maintain appropriate safeguards against the risks identified
    • regularly verify that the safeguards are effectively implemented.
  • To ensure that the safeguards are continually updated in response to new risks or deficiencies in previously implemented safeguards.
  • To have due regard to generally accepted information security practices and procedures that may apply to that client generally or be required in terms of a specific industry or professional rules and regulations.
  • To notify the client, contractor or vendor as soon as reasonably possible after obtaining actual knowledge of reasonable grounds to believe that the personal data has been accessed or acquired by any unauthorised person.

Updates to our Privacy Notice

This Privacy Notice may be updated periodically to you to reflect changes in our information practices or relevant laws. We will indicate at the top of the Notice when it was updated. Please review this Notice any time you access or use our sites to make sure you have reviewed the most recent version.

How to contact us

Our principal place of business is at Pragma Building, DJ Wood Way, Bellville West, 7530, South Africa but we recommend you contact us via telephone at +27 21 943 3900 or electronic mail at support@pragmaworld.net.