Scope of this Privacy Policy
This Privacy Policy applies to all Centrax Systems websites that link to it. It also applies to the products and services provided by Centrax Systems through these websites.
Introduction
Centrax Systems is committed to implementing reasonable measures to support its Customers and Suppliers’ ability to comply with applicable Data Protection Laws. As far as possible,
the principles of data protection by design and by default are applied during the development and delivery of Centrax Systems services.
Part I – Information Centrax Systems collects and processes as a responsible party
What information Centrax Systems collects
We collect information about you only if we need the information for some legitimate purpose. Centrax Systems will have information about you only if
(a) You have provided the information yourself,
(b) Centrax Systems has automatically collected the information, or
(c) Centrax Systems has obtained the information from a third party. Below we describe the various scenarios that fall under each of those three categories and the information collected in each one.
Information that you provide us:
i.
Account signup: When you sign up for an account to access one or more of our services, we ask for information like your name, contact number, email address, company name and country to complete
the account signup process. You'll also be required to choose a unique username and a password for accessing the created account. You may also provide us with more information such as your photo, time zone and language,
but we do not require that information to sign up for an account. After signing up, you will have the option of choosing a security question and an answer to the security question — if you provide these, they will be used only while resetting your password.
ii.
Event registrations and other form submissions: We record information that you submit when you:
(i) register for any event, including webinars or seminars,
(ii) Subscribe to our newsletter or any other mailing list,
(iii) Submit a form in order to download any product, whitepaper, or other materials,
(iv) Participate in contests or respond to surveys, or
(v) Submit a form to request customer support or to contact Centrax Systems for any other purpose.
iii.
Payment processing: When you buy something from us, we ask you to provide your name, contact information, and credit card information or other payment account information. When you submit your card information, we store the name and address of the cardholder, the expiry date and the last four digits of the credit card number. We do not store the actual credit card number. For quick processing of future payments, if you have given us your approval, we may store your credit card information or other payment information in an encrypted format in the secured servers of our Payment Gateway Service Providers.
iv.
Testimonials: When you authorize us to post testimonials about our products and services on websites, we may include your name and other personal information in the testimonial. You will be given an opportunity to review and approve the testimonial before we post it. If you wish to update or delete your testimonial, you can contact us at www.centrax.co.za
v.
Interactions with Centrax Systems: We may record, analyze and use your interactions with us, including email, telephone, and chat conversations with our sales and customer support professionals, for improving our interactions with you and other customers.
Information that we collect automatically:
i.
Information from browsers, devices and servers: When you visit our websites, we collect information that web browsers, mobile devices and servers make available, such as the internet protocol address, browser type, language preference, time zone, referring URL, date and time of access, operating system, mobile device manufacturer and mobile network information.
ii.
Information from first party cookies and tracking technologies: We use temporary and permanent cookies to identify users of our services and to enhance user experience. We also use cookies, beacons, tags, scripts, and other similar technologies to identify visitors, track website navigation, gather demographic information about visitors and users, understand email campaign effectiveness and for targeted visitor and user engagement by tracking your activities on our websites.
iii.
Information from application logs and mobile analytics: We collect information about your use of our products, services and mobile applications from application logs and in-house usage analytics tools, and use it to understand how your business use and needs can improve our products. This information includes clicks, scrolls, features accessed, access time and frequency, errors generated, performance data, storage utilized, user settings and configurations, and devices used to access and their locations.
Information that we collect from third parties:
i.
Signups using federated authentication service providers: You can log in to Centrax Systems using supported federated authentication service providers such as LinkedIn, Microsoft and Google. These services will authenticate your identity and give you the option to share certain personal information with us, such as your name and email address.
ii.
Referrals: If someone has referred any of our products or services to you through any of our referral programs, that person may have provided us your name, email address and other personal information. You may contact us at sales@centrax.co.za to request that we remove your information from our database. If you provide us information about another person, or if another person gives us your information, we will only use that information for the specific reason for which it was provided to us.
iii.
Information from our reselling partners and service providers: If you contact any of our reselling partners, or otherwise express interest in any of our products or services to them, the reselling partner may pass your name, email address, company name and other information to Centrax Systems. Centrax Systems may also receive information about you from review sites if you comment on any review of our products and services, and from other third-party service providers that we engage for marketing our products and services.
1. Purposes for using information
In addition to the purposes mentioned above, we may use your information for the following purposes:
• To communicate with you (such as through email) about products that you have downloaded and services that you have signed up for,
changes to this Privacy Policy, changes to the Terms of Service, or important notices;
• To keep you posted on new products and services, upcoming events,
offers, promotions and other information that we think will be of interest to you;
• To ask you to participate in surveys, or to solicit feedback on our products and services;
• To set up and maintain your account,
and to do all other things required for providing our services,
such as enabling collaboration, providing website and mail hosting, and backing up and restoring your data;
• To provide customer support, and to analyse and improve our interactions with customers;
• To detect and prevent fraudulent transactions and other illegal activities,
to report spam, and to protect the rights and interests of Centrax Systems, Centrax Systems users,
third parties and the public;
• To update, expand and analyse our records, identify new customers,
and provide products and services that may be of interest to you;
• To analyse trends, administer our websites, and track visitor navigations
on our websites to understand what visitors are looking for and to better help them;
• To monitor and improve marketing campaigns and make suggestions relevant to the user.
Legal bases for collecting and using information
Legal processing bases applicable to Centrax Systems:
If you are an individual from South Africa, our legal basis for information collection and use
depends on the personal information concerned and the context in which we collect it.
Most of our information collection and processing activities are typically based on:
(i) contractual necessity,
(ii) one or more legitimate interests of Centrax Systems or a third party permitted by POPIA that are not overridden by your data protection interests, or
(iii) your consent. Sometimes, we may be legally required to collect your information, or may need your personal information to protect your legitimate interests.
Withdrawal of consent:
Where we rely on your consent as the legal basis,
you have the right to withdraw your consent at any time,
but this will not affect any processing that has already taken place.
Your choice in information use:
Opt out of non-essential electronic communications: You may opt out of receiving newsletters and other non-essential messages by using the ‘unsubscribe’ function included in all such messages. However, you will
continue to receive notices and essential transactional emails.
Disable cookies: You can disable browser cookies before visiting our websites. However, if you do so, you may not be able to use certain features of the websites properly.
Optional Information: You can choose not to provide optional profile information such as your photo.You can also delete or change your optional profile information. You can always choose not to fill in non-mandatory fields when you submit any form linked to our websites.
Your choice in information use:
Opt out of non-essential electronic communications: We do not sell any personal information. We share your information only in the ways that are described in this Privacy Policy,and only with parties who adopt appropriate confidentiality and security measures.
Employees and independent contractors: Employees and independent contractors of Centrax Systems have access to the information covered in Part I on a need-to-know basis.We require all employees and independent contractors of Centrax Systems to follow this Privacy Policy for personal information that we share with them.
Third-party service providers: We may need to share your personal information and aggregated or de-identified information with third-party service providers thatwe engage, such as marketing and advertising partners, event organizers,web analytics providers and payment processors. These service providers are authorized to use your personal information only as necessary to provide these services to us.
Other cases: Other scenarios in which we may share the same information covered under Parts I and II are described in Part III.
Your rights with respect to information we hold about you as a responsible party.
You have the following rights with respect to information that Centrax Systems holds about you.
Right to access:You have the right to confirm if we process yourpersonal information, and access (and obtain a copy of, if required)the categories of personal information that we hold about you, including the information's source, purpose and period of processing,
and the persons to whom the information is shared.
Your rights with respect to information we hold about you as a responsible party. You have the following rights with respect to information that Centrax Systems holds about you. You have the right to update the information we hold about youor to correct any inaccuracies.
Based on the purpose for which weuse your information, you can instruct us to add supplemental information about you in our database.
Right to restriction of processing: You may also have the right to request to restrict the use of your information in certain circumstances, such as when you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right to data portability: You have the right to transfer your information to a third party in a structured, commonly used and machine-readable format, in circumstances where the information is processed with your consent or by automated means.
Right to object: You have the right to object to the use of your information in certain circumstances, such as the use of your personal information for direct marketing.
Right to complain: You have the right to complain to the Information Regulator if you have any grievance against the way we collect, use or share your information.
Retention of information
We retain your personal information for as long as it is required for the purposes stated in this Privacy Policy. Sometimes, we may retain your information for longer periods as permitted orrequired by law, such as to maintain suppression lists, prevent abuse,if required in connection with a legal claim or proceeding, to enforceour agreements, for tax, accounting, or to comply with other legal obligations.When we no longer have a legitimate need to process your information, we will delete or anonymize your information from our active databases. We will also securely store the information and isolate it from further processing on backup discs until deletion is possible.
Part II – Information that Centrax Systems processes on your behalf as an operator
Information entrusted to Centrax Systems and purpose
Information provided in connection with services: You may entrust information that you or your organization (“you”) control, to Centrax Systems in connection with use of our services or for requesting technical support for our products. This includes information regarding your customers and your employees (if you are a responsible party) or data that you hold and use on behalf of another person for a specific purpose, such as a customer to whom you provide services (if you are an operator). The data may either be stored on our servers when you use our services, or transferred or shared to us as part of a request for technical support or other services.
Information from mobile devices: When you elect to allow it, some of our mobile applications have accessto the camera, call history, contact information, photo library, and other information stored on your mobile device. Our applications require such access to provide their services. Similarly, when you elect to provide access, location-based information is also collected for purposes including, but not limited to, locating nearby contacts or setting location-based reminders. This information will be exclusively shared with our mapping providers and will be used only for mapping user locations. You may disable the mobile application's access to this information at any time by editing the settings on your mobile device. The data stored on your mobile device and their location information to which the mobile applications have access will be used in the context of the mobile application, and transferred to and associated with your account in the corresponding services (in which case the data will be stored on our servers) or products (in which case the data will remain with you unless you share it with us).(All the information entrusted to Centrax Systems is collectively termed “service data”)
Ownership and control of your service data.
We recognize that you own your service data. We provide you complete control of your service data by providing you the ability to
(i) access your service data,
(ii) share your service data through supported third-party integrations, and
(iii) request export or deletion of your service data.
How we use service data.
We process your service data with your knowledge or when you provide us instructions through the various modules of our services. For example, when you generate an invoice,information such as the name and address of your customer will be used to generate the invoice; and when you use our campaign management service for email marketing, the email addresses of the persons on your mailing list will be used for sending the emails.
Who we share service data with?
Centrax Systems and third-party sub-processors: In order to provide services and technical support for our products,the contracting entity within the Centrax Systems engages other group entities and third parties.
Employees and independent contractors: We may provide access to your service data to our employees and individuals who are independent contractors of Centrax Systems involved in providing the services (collectively our “employees”) so that they can:
(i) identify, analyse and resolve errors,
ii) manually verify emails reported as spam to improve spam detection, or
(iii) manually verify scanned images that you submit to us to verify the accuracy of optical character recognition. We ensure that access by our employees to your service data is restricted to specific individuals, andis logged and audited. Our employees will also have access to data that you knowingly share with us for technical supportor to import data into our products or services. We communicate our privacy and security guidelines to our employees and strictly enforce privacy safe guards within the Centrax Systems.
Collaborators and other users: Some of our products or services allow you to collaborate with other users or third parties. Initiating collaboration may enable other collaborators to view some or all of your profile information. For example, when you edit a document that you have shared with other persons for collaboration, your name and profile picture will be displayed next to your edits to allow your collaborators to know that you made those edits.
Third-party integrations you have enabled: Most of our products and services support integrations with third-party products and services. If you choose to enable any third-party integrations, you may be allowing the third party to access your service information and personal information about you.We encourage you to review the privacy practices of the third-party services and products before you enable integrations with them.
Other cases: Other scenarios in which we may share information that are common to information covered under Parts I and II are described in Part III.
Retention of information:
We hold the data in your account as long as you choose to use Centrax Systems Services. Once you terminate your Centrax Systems user account, your data will eventually get deleted from active database during the next clean-up that occurs once in 6 months. The data deleted from active database will be deleted from backups after 3 months.
Data subject requests:
If you believe that we store, use or process your information on behalf of one of our customers, please contact the customer if you would like to access, rectify, erase,restrict or object to processing, or export your personal data. We will extend our support to our customer in responding to your request within a reasonable timeframe.
Part III - General
Children’s personal information:
Our products and services are not directed to individuals under 18. Centrax Systems does not knowingly collect personal information from children who are under 18 years of age. If we become aware that a child under 18 has provided us with personal information, we will take steps to delete such information.If you believe that a child under 18 years has provided personal information to us,please write to Centrax Systems with the details, and we will take the necessary steps to delete the information we hold about that child.
Children’s personal information:
We have appointed an Information Officer to oversee our management of your personal information in accordance with this Privacy Policy. If you have any questions or concerns about our privacy practices with respect to your personal information, you can reach out to our Information Officer by sending an email to Centrax Systems
www.centraxdigital.com.
Locations and international transfers:
Apart from the recipients mentioned under "Who we share your data with" under Part II of this Privacy Policy,we share your personal information and service data with relevant entities in the Centrax Systems and other operators engaged by Centrax Systems. By accessing or using our products and services or otherwise providing personal information or service data to us, you consent to the processing, transfer, and storage of your personal information or Service Data within the countries where Centrax Systems operates. Such transfer is subject to a group company agreement that imposes data protection obligations on all the entities that process your personal information as required by applicable data protection laws.
Data processing agreement:
To enable you to be compliant with thedata protection obligations under the POPIA,we are prepared to sign a data processing agreement that is compliant with POPIA. You can request data processing agreement from Centrax Systems by sending an email to Centrax Systems. Once we get your request, we'll forward a copy of the data processing agreement to you for your signature.
Do Not Track (DNT) requests:
Some internet browsers have enabled 'Do Not Track'(DNT) features, which send out a signal (called the DNT signal) to the websites that you visit indicating that you don't wish to be tracked. Currently, there is no standard that governs what websites can or should do when they receive these signals. For now,we do not take action in response to these signals.
Disclosures in compliance with legal obligations:
We may be required by law to preserve or disclose your personal information and service data to comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements.
Enforcement of our rights:
We may disclose personal information and service data to a third party if we believe that such disclosure is necessary for preventing fraud, investigating any suspected illegal activity, enforcing our agreements or policies, or protecting the safety of our users.
Business Transfers:
We do not intend to sell our business.However, in the unlikely event that we sell our business or get acquired or merged, we will ensure that the acquiring entity is legally bound to honour our commitments to you. We will notify you via email or through a prominent notice on our website of any change in ownership or in the uses of your personal information and service data. We will also notify you about any choices you may have regarding your personal information and service data.
Compliance with this Privacy Policy:
We make every effort, including periodic reviews,to ensure that personal information you provide is used in conformity with this Privacy Policy. If you have any concerns about our adherence to this Privacy Policy orthe manner in which your personal information is used, kindly write to us Centrax Systems. We'll contact you, and if required, coordinate with the appropriate regulatory authorities to effectively address your concerns.
General Provisions:
Centrax Systems holds the right to make changes to this Privacy Policy, and we will publish it through our website:
www.centraxdigital.com By providing your information you agree to the terms and conditions set forth herein, therefore,if you do not wish that Centrax collects your personal information, please refrain from providing it.
Data Retention:
When you engage with Centrax Systems via our website, we will retain your Personal Information for our records unless and until you explicitly ask us to delete this information.