Privacy Policy

1. INTRODUCTION

• SOVIET respects your privacy and takes the protection of Personal Information seriously. The purpose of this Policy is to describe the way that SOVIET collects, stores, uses, and protects information that can be associated with you or any other natural or juristic person, and where the information in question could be used to identify you or that person.

2. DEFINITIONS

• In this Policy, ‘we’, ‘us’ and ‘our’ refers to Pretoria Clothing and Caps Pty Ltd t/a SOVIET, a company registered in the Republic of South Africa, which has as its registered address, 331 Roan Crescent, Corporate Park North, Midrand, Gauteng, 1685, South Africa.

• Anonymous Information: Information that does not directly or indirectly identify and cannot reasonably be used to identify an individual website customer.

• Application: A program or service operated by the practice that may be displayed on various online, mobile, or other platforms and environments, including those operated by third parties, which permits us to interact directly with our customers.

• Children: Refers to individuals under eighteen (18) years of age.

• Data Controller, also referred to as the ‘Responsible Party’: The entity, including a subsidiary or affiliated one, of SOVIET that is responsible for the personal information collected.

• Data Processor, also referred to as the ‘Operator’: A person or entity that processes personal information on behalf of the Responsible Party, and is permitted to perform data processing only as directed by the Responsible Party.

• IP Address: This is associated with the access point through which you enter the Internet and is typically controlled by your Internet Service Provider (ISP). We may use IP addresses to collect information regarding the frequency with which users visit various parts of our sites and applications, and we may combine IP addresses with personal information.

• Parent/s: A parent or legal guardian.

• Personal Information (PI): Data and information that identifies, whether directly or indirectly, an individual. This may be the individual’s name, postal address, email address, or telephone number. When anonymous data is directly or indirectly associated with personal data, the resulting data is also treated as personal data.

• Public Forums, also referred to as ‘Digital Platforms’: Our website, social media platforms and applications may offer message boards, conversation pages, blogs, chat rooms, social community environments, profile pages, and other forums that do not have a restricted audience. If you provide personal information when you use any of these platforms, this personal information may be publicly posted and otherwise disclosed without limitation as to its use by us or by a third party.

3. AUDIENCE

• This Policy applies to you if you are:

• A visitor to our website.
• A customer who has ordered or requested the goods or services that we provide from one of our stores or via our Digital Platforms.
• A subscriber to our newsletter.
• Someone who has downloaded our SOVIET Application.
• Someone who has visited and engaged with us on any of our Digital Platforms.

4. LEGAL CAPACITY

• The age requirement for engaging with us in any manner outlined above is eighteen (18) years of age. By engaging with us, you warrant that you can enter into binding contracts, that you are at least eighteen (18) years of age and that you have read, understood, accepted and agree to be bound by the terms of this Privacy Policy. To the extent required by applicable law, you must obtain parental or guardian consent if you are under eighteen (18) years of age prior to engaging with us in any manner.

5. YOUR RIGHTS

• SOVIET takes your rights seriously, especially considering our brand history and commitment to ‘real people’.

• In this section, we summarise the rights that you have under the applicable data protection laws, most notably the Protection of Personal Information Act 4 of 2013. Some of the rights are complex, and not all the details have been included in this Privacy Policy. You are therefore encouraged to read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

• Your principal rights under the data protection law are:

• The right to access;

• The right to object to processing: You have objected to processing, pending the verification of your information. Where processing has been restricted on this basis, SOVIET may continue to store your personal data. However, SOVIET will only otherwise process it:

• With your consent;
• For the establishment, exercise or defence of legal claims;
• For the protection of the rights of another natural or legal person;
• For reasons of important public interest.

• The right to data portability;

• The right to complain to the Information Regulator of South Africa;

• The right to withdraw consent;

• You have the right to have any inaccurate personal data about you rectified;

• You have the right to restrict the processing of your personal data when:

• You contest the accuracy of the personal data or processing is unlawful;

• You have the right to object to our processing of your personal data on grounds relating to your situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: The performance of a task carried out in the public interest or in the exercise of any official authority vested in us, or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise, or defence of legal claims.

• If you consider that our processing of your personal information infringes any applicable data protection laws, you have a legal right to lodge a complaint with SOVIET’s Information Officer, who is responsible for SOVIET’s data protection.

• To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw your consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

6. TYPES OF DATA THAT WE COLLECT

• We collect two basic types of information: Personal Information and Anonymous Information. We may use personal and anonymous information to create a third type of information, aggregate information.

• For example, we collect:

• Registration information: Information you provide us with when you create an account;
• Information you provide in public forums, Digital Platforms, on our website and Applications, such as your public posts;
• Information sent either one-to-one or within a limited group using our message, chat, post, or similar functionalities, where we are permitted by the applicable law to collect this information;
• Information we obtain from a third party, such as a site or platform provider, about the use of our applications on third-party platforms or devices;
• Location information: Information provided by a mobile device or other device interacting with one of our sites or applications (including through beacon technologies), or associated with your IP address, where we are permitted by law to process this information;
• Activity information about your use, and the use by any person(s) you authorise through your account, of our sites and applications, such as the content you view or post, how often you use our services, and your preferences;
• Use, view device data when you visit our sites, use our applications on third-party sites or platforms, or open emails we send, including your browser or unique device identifier, and IP addresses.

7. HOW WE COLLECT DATA

• We collect information you provide us with when you request a service, or information from us, register with us (including when you link your profile on a third-party site or platform with your registration account), participate in public forums or other activities on our website and Applications, respond to guest surveys, or otherwise interact with us using one or more devices.

• We collect information through a variety of technologies, such as cookies, analytics tools, Flash, pixels, and web beacons.

• You consent to us acquiring information from other trusted sources to update or supplement the information you provided, or that we collected automatically, such as when we validate postal address information. Applicable laws may require that you authorise the third party to share your information with us before we can acquire it.

8. HOW WE USE DATA

• We use the collected data to understand your needs, so that we can provide you with the best possible service and customer experience. To deliver on this promise of high-quality service and product quality we collect data for the following reasons:

• Internal record keeping;
• We may use the information to improve our products and services;
• We may periodically send promotional emails about new products, special offers or other information which we think you will find interesting, using the email address that you have provided;
• From time to time, we may also use your information to contact you for market research purposes. We may contact you by email or phone;
• We may use the information to customise the website according to your interests.

• We will only contact you if you have given us your express permission to do so.

• We may process data about your use of our website and services (usage data). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. This usage data may be processed for the purposes of analysing the use of the website and services.

• We may process account data, which may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.

• We may process your personal data that is provided in the course of the use of our services (service data). The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.

• We may process information contained in any enquiry you submit to us regarding goods and services (enquiry data). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and services to you.

• We may process information relating to transactions, including purchases of goods and services, that you enter into with us and through our website (transaction data). The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions.

• We may process information that you provide to us for the purpose of subscribing to our newsletter (notification data). The notification data may be processed for the purposes of sending you the relevant notifications and newsletters. You will always have the option of withdrawing consent to this service.

• We may process information contained in or relating to any communication that you send to us (correspondence data).

• Please do not supply any additional or irrelevant personal data to us unless we prompt you to do so.

9. SHARING INFORMATION

• We will not share your Personal Information with a third party outside SOVIET except in limited circumstances, including:
• When you allow (implying consent) us to share your Personal Information with another company, such as:
• Electing to share your Personal Information with carefully selected companies so that they can send you offers and promotions about their products and services;
• Directing us to share your Personal Information with third-party sites or platforms, such as social networking sites (please note that once we share your Personal Information with another company, the information received by the other company is controlled by that company and becomes subject to the other company’s privacy policy);
• When companies perform services on our behalf, like package delivery, marketing and advertising, and customer service. However, these companies are prohibited from using your Personal Information for purposes other than those requested by us or required by law;
• When we share your Personal Information with third parties in connection with the sale of a business, to enforce our Terms and Conditions, to ensure the safety and security of our guests and third parties, to protect our rights and property and the rights and property of our guests and third parties, to comply with legal process, or in other cases if we believe in good faith that disclosure is required by law.

10. DATA SECURITY

• The security, integrity, and confidentiality of your Personal Information are extremely important to us. We have implemented technical, administrative, and physical security measures that are designed to protect your personal and sensitive information from unauthorised access, disclosure, use, and modification. We regularly review our security procedures to consider appropriate new laws, technology and methods. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable.

11. RETENTION

• SOVIET will only retain your Personal Information 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;
• You have consented to the retention of the record.

• During the period of retention, SOVIET will abide by our non-disclosure obligations and will not share or sell your Personal Information. We may retain your Personal Information in physical or electronic records at our discretion.

12. CUSTOMER OBLIGATIONS

• You may only send us your own Personal Information or the information of another data subject where you have their permission to do so.

13. UPDATING YOUR PERSONAL INFORMATION

• You may choose to adjust or update the Personal Information that you have submitted to SOVIET, by contacting us by phone or email.

• SOVIET will not be held responsible for, give no warranties, nor make any representations in respect of the privacy policies or practices of linked or any third-party websites.

• Data subject access requests may be requested via phone or email.

14. UPDATES TO OUR PRIVACY POLICY

• From time to time, we may change this Privacy Policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. It is your obligation to check on a regular basis whether the Policy has changed.

15. ACCEPTANCE OF THE PRIVACY POLICY

• By accepting this Policy, you are deemed to have read, understood, accepted, and agreed to be bound by all its terms.

16. CONTACT US

• If you have any questions or concerns arising from this Privacy Policy or about your Personal Information, please contact us on support@sovietdenim.co.za.