TOP DRAWER SOCIAL & DIGITAL MARKETING WEBSITE PRIVACY STATEMENT
Top Drawer Social & Digital Marketing is committed to protecting your privacy and takes its responsibility regarding the security of customer information very seriously. Our website Privacy Statement sets out what information we collect, how we collect it, what we do with it and how we protect this information. Any personal data is collected and processed in accordance with South African data protection laws.
COLLECTION OF PERSONAL DATA
Information you provide to us, we collect personal details from you together with information we learn about you from your use of our website. These details may include (where applicable) your name, address, telephone number, e-mail and IP addresses, credit/debit card or other payment details, personal goals, account profile photos, ratings, webinar chat, or otherwise provide information to us through our services elsewhere.
Information we collect automatically: We collect information about you and your use of our service, your interactions with us and our advertising, as well as information regarding your computer or other device used to access our service (such as smart TVs, gaming systems and mobile devices). This information includes:
- your activity on the Top Drawer Social & Digital Marketing service;
- your interactions with our email, webinar chat, push and text messaging;
- device IDs or other unique identifiers;
- advertising identifiers, such as those on mobile devices, tablets, and streaming media devices that include such identifiers (see the “Cookies and Internet Advertising” section below for more information);
- device and software characteristics (such as type and configuration), connection information, statistics on page views, referring source (for example, referral URLs), IP address (which may tell us your general location), browser and standard web server log information;
To provide location-based services we may collect, use, and share precise location data, including the real-time geographic location of your computer or device through GPS, Bluetooth, and your IP address, along with crowd-sourced Wi-Fi hotspot and cell tower locations. This location data is collected anonymously, unless you provide consent. You may withdraw consent to Top Drawer Social & Digital Marketing and our partners’ collection, use, transmission, processing and maintenance of location and account data at any time by not using the location-based features and turning off the Location Services settings (as applicable) on your device and computer.
USE OF PERSONAL DATA
We use information to provide, analyze, administer, enhance and personalize our services and marketing efforts, to process your registration, your orders and your payments, and to communicate with you on these and other topics. For example, we use information to: provide products and services you request, contacting you regarding your course, credit or other payment card verification/screening, legal purposes, statistical and marketing analysis, systems testing, customer surveys, customer relations communications and offering you services and products we believe may interest you.
Our legal basis for collecting and using the personal information described in this Privacy Statement will depend on the personal information concerned and the specific context in which we collect and use it. We will normally collect personal information from you where we need the personal information to perform a contract with you (for example, to provide our services to you), where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms (for example, our direct marketing activities in accordance with your preferences), or where we have your consent to do so (for example, for you to participate in certain consumer insights activities like specific surveys and focus groups). In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person (for example, to prevent payment fraud or confirm your identity). For questions about our use of your personal information (including legal bases and transfer mechanisms we rely on), cookies or similar technologies, please contact our Data Protection Officer/Privacy Office by email at firstname.lastname@example.org.
SHARING INFORMATION ABOUT YOU
We follow strict security procedures in the storage and disclosure of student information.
We may disclose your information to trusted contracted companies who act as “data processors” on our behalf for the purposes set out in this Privacy Statement. Top Drawer Social & Digital Marketing has transfer agreements in place with all entities to which it transfers data for processing on its behalf. The agreements provide for specific and limited processing of user data in service of Top Drawer Social & Digital Marketing’s operations and have been prepared so as to meet the requirements of South African Law.
We may also pass your information on to government authorities or enforcement bodies for compliance with legal requirements.
Top Drawer Social & Digital Marketing operates businesses in multiple jurisdictions, some of which are not located in South Africa (SA). While countries outside the SA do not always have strong data protection laws, we will ensure that Top Drawer Social & Digital Marketing and our services providers process your information in a secure manner and in accordance with this Privacy Statement.
DIRECT MARKETING MATERIAL
From time to time we or our selected partners may contact you with information regarding course promotions and ancillary products via email or SMS. However, you will be given the opportunity on every e-communication that we or our trusted partners send you to indicate that you no longer wish to receive our or their direct marketing material.
Email and Text Messages: If you no longer want to receive certain communications from us via email or text message, simply click the “unsubscribe” link in the email or reply STOP (or as otherwise instructed) to the text message. Please note that you cannot unsubscribe from service-related correspondence from us, such as messages relating to your student account transactions or course lesson reminders or information directly relating to your course progress.
Push Notifications: You can choose to receive mobile push notifications from Top Drawer Social & Digital Marketing. If you subsequently decide you no longer wish to receive these notifications, you can use your mobile device’s settings functionality to turn them off.
Interest-Based Ads: Interest-based ads are online ads that are tailored to your likely interests based on your use of various apps and websites across the Internet. If you are using a browser, then cookies and web beacons can be used to collect information to help determine your likely interests. If you are using a mobile device, tablet, or streaming media device that includes an advertising identifier, then that identifier can be used to help determine your likely interests. For your choices about interest-based ads from Top Drawer Social & Digital Marketing, please see the “Cookies” section (below).
We use tracking software to monitor customer traffic patterns and site usage to help us develop the design and layout of the websites. This software does not enable us to capture any personal passenger information.
What are cookies? Cookies are small text files that are transferred to your computer’s hard drive through your web browser to enable us to recognise your browser and help us to track visitors to our site; thus enabling us to understand better the products and services that will be most suitable to you. A cookie contains your contact information and information to allow us to identify your computer when you travel around our site for the purpose of helping you accomplish your registration. Most Web browsers automatically accept cookies, but, if you wish, you can set your browser to prevent it from accepting cookies. The “help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. The cookies we use do not detect any information stored on your computers.
For more information about cookies and how to stop cookies being installed visit the following website: http://www.allaboutcookies.org
LINKS TO THIRD PARTY WEBSITES
We take great care to ensure the security of our website. The data you provide to us is protected using SSL (Secure Socket Layer) technology. SSL is the industry standard method of encrypting personal information and credit card details so that they can be securely transferred over the Internet.
You can request access to your personal information or correct or update out-of-date or inaccurate personal information we hold about you.
You can most easily do this by visiting the “account” section within your Members Area, where you have the ability to access and update your contact information. You must be signed in to access the “account” section. You may also request that we delete personal information that we hold about you.
To make requests, or if you have any other question regarding our privacy practices, please contact our data protection officer/privacy office at email@example.com. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Please also see the “your choices” section of this privacy statement for additional choices regarding your information.
You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information; if we have collected and process your personal information with your consent, then you can withdraw your consent at any time; withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent; you have the right to complain to a data protection authority about our collection and use of your personal information by contacting us here.
We may retain information as required or permitted by applicable laws and regulations, including to honor your choices, for our billing or records purposes and to fulfill the purposes described in this privacy statement. We take reasonable measures to destroy or de-identify personal information in a secure manner when it is no longer required.
OUR REGISTERED ADDRESS IS:
Top Drawer Social & Digital Marketing
CHANGES TO PRIVACY STATEMENT
Our Privacy Statement may change from time to time and any changes to the statement will be posted on this page.