Table of Contents
Customer Privacy Notice and Policy
- The purpose of our privacy notice and policy is to inform you about our use of the data and/or personal information we collect from you when you submit your data to us and to provide all our current customers and potential future customers, with a general understanding of the following;
- As the Data Controller and Responsible Party of your information we are complying with the provisions of the POPIA and informing you about what we use your data for, what your rights to the data you give us are, and to tell you about who we are.
- LIXIL Africa is the South African-based entity of LIXIL International. LIXIL produces water and housing products that touch the lives of more than a billion people around the world every day. Our stable of brands includes: Cobra, Vaal Sanitaryware, Grohe and APEX Valves.
Physical Address of Information Officer and Deputy Information Officer of Lixil Africa (Pty)Ltd:
Mr. Raj Naidoo
Mr. Nicky Swart
PO BOX 1096, Krugersdorp
Physical Address of Information Officer of Lixil Africa (Pty) Ltd:
20 Wright Street, Factoria, Krugersdorp
Contact number for Information Officer and Deputy Information Officer at Lixil Africa (Pty) Ltd:
0861 21 21 21
064 880 7503
Email address of Information Officer and Deputy Information Officer at Lixil Africa (Pty) Ltd:
Raj.naidoo@lixil.com
nicky.swart@lixil.com
This notice will inform you as to the circumstances under which we collect and process your personal data
- The type of data we collect
- The reasons for collecting the data
- How we handle your personal data.
Welcome to our privacy policy. This is our plan of action when it comes to protecting your privacy. We respect your privacy and take the protection of personal data very seriously. The purpose of this policy is to describe the way that we collect, store, use, and protect data that can be associated with you or another specific natural or juristic person and can be used to identify you or that person (personal data).
This policy applies to you if you are:
- a visitor to our website; or
- a customer who has ordered the goods or services that we provide.
You must accept all the terms of this policy when you order or use any of our goods or services, or our website. You may not order or use any of our goods or services, or our website if you do not accept this policy.
You may not access our website to order our goods or services if you are younger than 18 years old or do not have legal capacity to conclude legally binding contracts.
By accepting this policy, you are deemed to have read, understood, accepted, and agreed to be bound by all of its terms.
You may only send us your own personal data or the personal data of another data subject where you have their permission to do so.
We may change the terms of this policy at any time by updating this web page. We will notify you of any changes by placing a notice in a prominent place on the website or by sending you an email detailing the changes that we have made and indicating the date that they were last updated. If you do not agree with the changes, then you must stop using the website, and our goods or services. If you continue to use the website or our goods or services following notification of a change to the terms, the changed terms will apply to you and you will be deemed to have accepted those updated terms.
Once you register on our website, you will no longer be anonymous to us. You will provide us with certain personal data.
This personal data may include:
- your name and surname;
- your email address;
- your telephone number;
- your company name, company registration number, and VAT number;
- your postal address or street address; and
- your username and password
We will use this personal data to fulfil your account, provide additional services and information to you as we reasonably think appropriate, and for any other purposes set out in this policy.
The information collected is utilized by us in order to respond to your enquiries made on our website or to respond to queries made by you as a customer, for example, on your account with us. We need your data in order to send you information regarding our products and services as part of our legitimate interest in responding to your enquiry. We will send you newsletters and product updates and special offers only if you agree and consent to receive these from us to your email address. We will use your data for invoicing purposes on services and products supplied. We may transfer documents cross border for legitimate business purposes as we are part of a global organization.
- We will not share your Data with any other third parties or use your data for any purpose other than described above. The information collected by us that you provide will not be used to make any automated decisions about you.
- It is our policy to comply with all applicable laws, rules and regulations governing privacy and data protection in every country that we operate, ensuring legal compliance of processing of your personal data.
When you order any goods or services from us, you will be asked to provide us with additional information on a voluntary basis (goods information or services information).
When you become one of our resellers, you will be asked to provide us with additional information on a voluntary basis (services information).
We automatically receive and record Internet usage information on our server logs from your browser, such as your Internet Protocol address (IP address), browsing habits, click patterns, version of software installed, system type, screen resolutions, colour capabilities, plug-ins, language settings, cookie preferences, search engine keywords, JavaScript enablement, the content and pages that you access on the website, and the dates and times that you visit the website, paths taken, and time spent on sites and pages within the website (usage information).
Please note that other websites visited before entering our website might place personal data within your URL during a visit to it, and we have no control over such websites. Accordingly, a subsequent website that collects URL information may log some personal data.
We may place small text files called ‘cookies’ on your device when you visit our website. These files do not contain personal data, but they do contain a personal identifier allowing us to associate your personal data with a certain device. We use cookies to assist us in the collection of useful information about visitors to our website. These cookies assist in the functioning of our website. We do not ask for your consent for certain cookies to be placed onto your IT system/computer.
These files serve a number of useful purposes for you, including:
- tailoring our website’s functionality to you personally by letting us remember your preferences;
- improving how our website performs;
- allowing third parties to provide services to our website; and
- helping us deliver targeted advertising where appropriate in compliance with the applicable laws.
Your internet browser generally accepts cookies automatically, but you can often change this setting to stop accepting them. You can also delete cookies manually. However, no longer accepting cookies or deleting them will prevent you from accessing certain aspects of our website where cookies are necessary. Many websites use cookies and you can find out more about them at www.allaboutcookies.org.
Some of our business partners use their own cookies or widgets on our website. We have no access to or control over them. Information collected by any of those cookies or widgets is governed by the privacy policy of the company that created it, and not by us.
Our website may contain electronic image requests (called a single-pixel gif or web beacon request) that allow us to count page views and to access cookies. Any electronic image viewed as part of a web page (including an ad banner) can act as a web beacon. Our web beacons do not collect, gather, monitor or share any of your personal data. We merely use them to compile anonymous information about our website.
You may also provide additional information to us on a voluntary basis (optional information). This includes content or products that you decide to upload or download from our website or when you enter competitions, take advantage or promotions, respond to surveys, order certain additional goods or services, or otherwise use the optional features and functionality of our website.
We may monitor and record any telephone calls that you make to us. We will delete the recording at your request.
We may use or process any goods information, services information, or optional information that you provide to us for the purposes that you indicated when you agreed to provide it to us.
Processing includes gathering your personal data, disclosing it, and combining it with other personal data. We generally collect and process your personal data for various purposes, including:
- goods purposes – such as collecting orders for, supplying, and supporting our goods;
- services purposes – such as providing our services;
- marketing purposes – such as pursuing lawful related marketing activities;
- business purposes – such as internal audit, accounting, business planning, and joint ventures, disposals of business, or other proposed and actual transactions; and
- legal purposes – such as handling claims, complying with regulations, or pursuing good governance.
We may use your usage information for the purposes described above and to:
- remember your information so that you will not have to re-enter it during your visit or the next time you access the website;
- monitor website usage metrics such as total number of visitors and pages accessed; and
- track your entries, submissions, and status in any promotions or other activities in connection with your usage of the website.
We will obtain your consent to collect personal data:
- in accordance with applicable law;
- when you provide us with any registration information or optional information.
When we decide to develop a new product or start a new activity that involves the processing of personal data, we take the privacy and data protection laws and principles into account and try to build them into the product or activity.
We may use your personal data to fulfil our obligations to you.
We may send administrative messages and email updates to you about our service. In some cases, we may also send you primarily promotional messages. You can choose to opt-out of promotional messages.
While you are logged into the website, we may display targeted adverts and other relevant information based on your personal data. In a completely automated process, computers process the personal data and match it to adverts or related information. We never share personal data with any advertiser, unless you specifically provide us with your consent to do so. Advertisers receive a record of the total number of impressions and clicks for each advert. They do not receive any personal data. If you click on an advert, we may send a referring URL to the advertiser’s website identifying that a customer is visiting from the website. We do not send personal data to advertisers with the referring URL. Once you are on the advertiser’s website however, the advertiser is able to collect your personal data.
We may share your personal data with:
- other divisions or companies within the group of companies to which we belong so as to provide joint content and services like registration, for transactions and customer support, to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about our products, services, and communications (they will only use this information to send you marketing communications if you have requested their goods or services);
- an affiliate, in which case we will seek to require the affiliates to honour this privacy policy;
- our goods suppliers or service providers under contract who help supply certain goods or help with parts of our business operations, including fraud prevention, bill collection, marketing, technology services (our contracts dictate that these goods suppliers or service providers only use your information in connection with the goods they supply or services they perform for us and not for their own benefit);
- credit bureaus to report account information, as permitted by law;
- banking partners as required by credit card association rules for inclusion on their list of terminated merchants (in the event that you utilise the services to receive payments and you meet their criteria); and
- other third parties who provide us with relevant services where appropriate.
- When sharing your personal information cross border, we will do so in terms of POPI cross border international policy that can be accessed through the following link: POPI Cross Border International Policy
We may disclose your personal data as required by law or governmental audit.
We may disclose personal data if required:
- by a subpoena or court order;
- to comply with any law;
- to protect the safety of any individual or the general public; and
- to prevent violation of our terms of service.
We will not sell personal data. No personal data will be disclosed to anyone except as provided in this privacy policy.
We may disclose aggregate statistics (information about the customer population in general terms) about the personal data to advertisers or business partners.
We may need to disclose personal data to our employees that require the personal data to do their jobs. These include our responsible management, human resources, accounting, audit, compliance, information technology, or other personnel. Any of our employees or personnel that handle your personal data will have signed non-disclosure and confidentiality agreements.
If we undergo a change in ownership, or a merger with, acquisition by, or sale of assets to, another entity, we may assign our rights to the personal data we process to a successor, purchaser, or separate entity. We will disclose the transfer on the website. If you are concerned about your personal data migrating to a new owner, you may request us to delete your personal data.
We cannot accept any liability whatsoever for unauthorised or unlawful disclosure of your personal data by third parties who are not subject to our control.
We take the security of personal data very seriously and always do our best to comply with applicable data protection laws. We will implement and maintain appropriate technical and organisational measures to protect the security and confidentiality of the personal data. We host on a secure server environment that uses a firewall and other advanced security measures to prevent interference or access from outside intruders. All personal data is securely stored in our customer database. We authorize access to personal data only for those employees who require it to fulfil their job responsibilities. We implement disaster recovery procedures where appropriate.
We will try to keep the personal data we collect as accurate, complete and up to date as is necessary for the purposes defined in this policy. From time to time we may request you to update your personal data on the website. You are able to review or update any personal data that we hold on you by accessing your account online or emailing us. Please note that in order to better protect you and safeguard your personal data, we take steps to verify your identity before granting you access to your account or making any corrections to your personal data. Throughout your interaction with us you retain the right to rectify personal data that is incorrect or inaccurate. This does not apply if we process your personal data in our capacity as a processor on behalf of you or the Administrator when you or the Administrator act as the data controller.
We will only retain your personal data for as long as it is necessary to fulfil the purposes explicitly set out in this policy, unless:
- retention of the record is required or authorised by law; or
- you have consented to the retention of the record.
During the period of retention, we will continue to abide by our non-disclosure obligations and will not share or sell your personal data.
We may retain your personal data in physical or electronic records at our discretion.
You may choose to correct or update the personal data you have submitted to us by contacting us via email or via the website.
You are entitled to a right to be forgotten. We will delete any personal data that you don’t want us to have. If you are a data subject of the Administrator or one of our customers (who is the data controller), then you must submit your request to the relevant data controller who will then delete your personal data.
You may request that we restrict the use of your personal data. When we restrict your personal data, we still have the right to store it but not use it.
We will notify our customers of any confirmed data breaches that has occurred. It is our customers’ responsibility to notify relevant supervisory authority and any affected data subjects of the data breach.
We are not responsible for, give no warranties, nor make any representations in respect of the privacy policies or practices of linked or any third-party websites.
If you have any questions or concerns arising from this privacy policy, please contact us on the email and telephone number provided within this document.
Your personal data belongs to you, as the owner of your personal data. The processing of your personal data forms an important part of the provision of our products and services to you, our customer and we strive not to make any assumptions regarding your personal privacy, and you can choose whether you wish to share your data with us. Lixil Africa (Pty)Ltd only processes customer personal information that is adequate, relevant and not excessive in relation to the purpose for which the data is collected. The necessary processing in the pursuit of our legitimate interest will not outweigh the need to protect your privacy, however we may process certain personal data without obtaining your express consent. For more information on this please see our “Consent” section of this notice. Where we can anonymize your personal data for a function or service for non-personal data (e.g. For statistical purposes), it will only be treated as personal data for as long as it remains combined.
- Your name, organization, and email address are used when directing you to a link for any documents that you wish to download or for downloadable purchases.
Your name and email address are not shared with a third-party mailing system. Any third-party service provider company used by us is bound contractually to safeguard and protect your personal information as per the provisions of the POPI Act.
Your personal data is electronically stored unless you withdraw your consent for our continued usage of your data and are instructed by you at any time to delete and erase your data or alter your data as per your request.
By accepting this document you hereby consent to the collection, processing and further processing of your personal information(including special personal information) as defined in the Protection of Personal Information Act, 2013 and further consent to such personal information being sent and processed outside the Republic of South Africa for legitimate business purposes. Your consent can be revoked and withdrawn at any time. Further, by accepting this document you are obliged to report any data breaches to our Information/Deputy Information Officer as set out herein.
We will not sell, trade or share your personal information with any third parties for marketing purposes unless we have your express consent to do so.
,
Lixil Africa (Pty)Ltd will only retain your data for as long as it is necessary to fulfil the purposes for which it has been collected and outlined in this policy notice or for the purposes of which you have otherwise been informed. This means that we will retain your data in accordance with the consent given or until such consent is revoked by you.
All requests for data deletion, alteration and information concerning personal information Lixil Africa (Pty)Ltd may hold about you, may be made in writing to our Information Officer (Data Protection Officer) at the address below. You will be responded to within 30 days and advised of progress made with your request and whether there are any applicable and lawful charges attached to your request.
We restrict access to your personal data to our employees and suppliers who need to use the information in order to process it on our behalf and who are contractually bound and required to keep the integrity of your personal data secure and confidential.
How to make a formal request.
Address your request to:
The Information Officer (Data Protection Officer)
The requester must complete Form B and submit this form together with a request fee, if any has been specified, to;
the Information Officer of the private body
Lixil Africa (Pty) Ltd)
at his/her physical address, or
P.O. Box number or email address
- The form must:
provide sufficient particulars to enable the head of the private body to identify the record/s requested and to identify the requester
indicate which form of access is required - specify a postal address or fax number or email address of the requester in the Republic
- identify the right that the requester is seeking to exercise or protect
- provide an explanation of why the requested record is required for the exercise or protection of that right.
In addition to a written reply, if the requester wishes to be informed of the decision on the request in any other manner, the requester is to state that manner or format and the necessary particulars to be informed of in any other manner. If the request is made on behalf of another person, the requester is to submit proof of capacity in which the requester is making the request, to the reasonable satisfaction of the head of the private body, as described above.
Nicky Swart
Find the REQUEST FOR ACCESS TO RECORD OF PRIVATE BODY – FORM B here.
- certain information that we collect automatically when you visit our website;
- certain information collected on registration (see below);
- certain information collected on submission; and
- optional information that you provide to us voluntarily (see below);
- information that has been made anonymous so that it does not identify a specific person;
- permanently de-identified information that does not relate or cannot be traced back to you specifically;
- non-personal statistical information collected and compiled by us; and
- information that you have provided voluntarily in an open, public environment or forum including any blog, chat room, community, classifieds, or discussion board (because the information has been disclosed in a public forum, it is no longer confidential and does not constitute personal data subject to protection under this policy).
Common examples of the types of personal data which we may collect and process include your:
- identifying information – such as your name, date of birth, or identification number of any kind;
- contact information – such as your phone number or email address;
- address information – such as your physical or postal address;
Depending on the goods or services that you require, we may also collect sensitive personal data like your bank account details.