What is personal information?
8 Personal information refers to private information about an identifiable person, such as your name and surname, gender, age, date of birth, contact details (e.g. your home address, postal address, e-mail address or phone number), physical location, ID number and your image (such as a private photograph on a social networking site).
9 Other information which might be “personal” information may include:
How we collect your personal information
10 We collect your personal information in four ways, namely:
Active collection of personal information from you
11 Some areas of our site may require you to submit certain information in order for you to register for certain services or benefit from specified features, such as when you register on the site, request to receive any newsletters or similar subscriptions or tips/pointers, or participate in a particular activity, such as a game, promotional competition or other promotion (collectively referred to as the “value added services”). If you contact us, we may keep a record of that correspondence.
12 If you want to take advantage of any of our site sharing features, we will ask you to create a publicly visible profile, indicating, for example, your username, e-mail address and, if you so wish, your photo.
13 Our site may also collect personal information from you by asking you specific questions and by permitting you to communicate directly with us, for example via e-mail, feedback forms, site comments and forums.
14 In these situations, we will:
15 The information we may actively collect from you may include your:
Passive collection of personal information from your device
16 We passively collect some of your personal information from the device which you use to access and navigate through our site, using various technological means.
17 One of the key ways in which we collect information passively is using server logs to collect and maintain log information (see paragraph 9.2 above).
19 A cookie is a small piece of data (an alphanumeric identifier) which our computer system transfers to your device through your web browser when you visit our site and which is stored in your web browser. When you visit the site again, the cookie allows the site to recognise your browser. Cookies may store user preferences and other information.
20 Cookies also enable us to analyse usage of our site, diagnose problems with our server, aggregate and report information, ensure our records are complete, accurate and up to date, determine the fastest route for your computer to use in connecting with our site, and better administer and improve the site, recognise you when you next access our site to remember your preferences and to tailor our services to you, manage and target advertising on our site, as well as to compile aggregate information about your access to and use of our site. This information can be used to enhance the content of our site and make it more user-friendly, as well as to give you a more personalised experience.
22 The information which we may passively collect from your device may include your identifying information, contact details, device and device event information, site activity information, log information, telephony log information, location information, unique application numbers (see paragraph 9 above) and any other information which you permit us, from time to time, to passively collect from your device.
Passive collection of personal information from social networking sites (with your permission)
23 We may allow you to log onto our site, or create a profile on our site, by using Facebook Connect or another social networking site authentication option.
24 By collecting information from social networking sites we enable you to enrich your profile on our site, your game-play and your social experience by enabling you to share your information (e.g. posts, photos, videos, contacts, etc) which is stored on that site without you having to actively give us all that information – all you need to do is login using your username and password and give us your permission to access and use that information.
25 There are two kinds of information which we collect from social networking sites, namely basic information and extended information.
(i) Basic information
26 Basic information is information which you have put on a social networking site which you have made public in accordance with your privacy settings on the relevant social networking site.
27 This could include your name and surname, username or user-ID number, your profile picture or its URL, your e-mail address, the physical location of your device, your gender, your date of birth, and any other information which you have decided to share publically (i.e. the information which you have put on your social networking site profile for anyone to see).
28 We will access your basic information from a social networking site only:
(ii) Extended information
29 Extended information is information which you have put on a social networking site over and above the basic information. This could include your additional identifying information and contact details, biographical information, educational history, personal preferences, religion, your “friends” or contacts on the social networking site, your “likes” and “dislikes”, information you have “shared” (e.g. comments on, or shared content on, your or your friend's Facebook “wall”), your recommendations to your friends or other social networking site contacts, your game scores and rankings, and any other information which you have put on, or actions you have done, on a social networking site (e.g. the information on your Facebook “wall”, your game score predictions, or the trophies you've won on our games), and any other information which you permit us, from time to time, to passively collect from a social networking site.
30 We will collect from the relevant social networking site your extended information only if and to the extent that you give us permission to do so.
31 You can decide the layers of extended information which you want to share with us and manage it either through our site or the relevant social networking site (e.g. you might decide, depending on your personal preferences, to allow us to post on your wall when you win a game or to send a notification to your Facebook friends on your behalf.
32 We may offer you the ability to import your address book contacts or to manually enter third parties' contact details in order to populate your invite list on our site (“your contacts”). You may authorise us to send your communications to your contacts on your behalf (e.g. to send your contact an e-mail or notification from you or on your behalf inviting him/her to join your online game sports pool).
33 Each application on our site will have its own default privacy setting. You can manage your settings at the time of giving us your permission or at any time thereafter by clicking on “My profile” on our site or on the relevant social networking site, or in any other manner which we make available on our site from time to time.
34 Your permission will expire if you do not access our site for a period of 60 continuous days. If it expires, you will need to refresh it when you next log in to our site.
35 We only receive information from social networking sites – we do not give them access to any of your personal information.
Passive collection of personal information from our affiliates and third party service providers
36 We collect some personal information passively from our affiliates and third party service providers, purely to supplement information which you have already agreed to give us, to supplement your user profile on our site and to help you and your friends connect.
Why we collect your personal information and how we use it
37 We use the information we collect to provide, maintain, and improve our services, to develop new ones, and to protect us, our services and our users. We constantly strive to improve our users' experience, and so we also use the information we collect in order to offer you information and content which is more appropriately tailored for you.
38 We may collect and use your personal information to:
39 We will get your permission before collecting or using your personal information for any other purpose.
Compulsory/optional information and consequences of not sharing it with us
40 Only the following information is compulsory: Your e-mail address and username. In order to access any of the value added services you will need to identify yourself as a MultiChoice subscriber with a SmartCard number of a living person (not a bot).
41 All other information is optional. If you do not agree to share your compulsory information with us, then you will not be able to make full use of the features that are offered to registered users. If you do not agree to share your optional information with us, then you may not be able to enjoy all of the site features and functionality.
Retention of your personal information
42 We retain all personal information which we collect from you (except for the information referred to in paragraph 43 below) unless there is a valid technical, legal or business reason for us to delete, destroy or de identify it (“retained information”).
43 We will not retain the following information if you ask us not to -
In this situation, our site will prompt you with a “do not store” option. If you select “do not store” then we will use the relevant information temporarily for the required purpose and then delete, destroy or de-identify it. If you permit us to retain it, we will use it only in line with your permissions and, subject to paragraphs 48 to 50 below, we will not disclose it to any third party without your permission.
44 We may keep all retained information for as long as you continue to access our site and for three years thereafter. Subject to paragraph 45 below:
45.1 we are required by law, a code of conduct or a contract with you to keep it;
46 We store all retained information on our servers in South Africa. Please see paragraphs 59 to 61 below regarding our security measures.
Disclosure of your personal information
48 We may disclose your personal information to:
49 We may use your personal information to compile profiles for statistical purposes and may freely trade with such profiles and statistical data, provided that the profiles or statistical data cannot be linked back to you by a third party.
50 We will get your permission before disclosing your personal information to any third party for any other purpose.
Accuracy of your personal information
51 We are careful to ensure that your personal information is accurate, complete, not misleading, and up to date. Please let us know if, to your knowledge, any information we have about you is incorrect, incomplete, misleading or out of date, by notifying us at the contact details set out in paragraph 67 below. We will take reasonable steps to correct or update the relevant information accordingly having regard to the purpose for which the information was collected or used.
52 If you contest the accuracy of your personal information, we may elect to verify its accuracy and, if we do so, we may restrict the processing of the contested information for a reasonable period while we verify its accuracy.
53 When you register on the site you may choose whether to receive marketing communications from us. You may also manage it in your privacy settings on our site.
54 You may refuse to accept, require us to discontinue, or pre-emptively block any approach or communications from us if that approach or communication is primarily for the purpose of direct marketing (“direct marketing communications”).
55 You may opt out of receiving direct marketing communications from us:
56 If you have opted out in accordance with clause 55, we will:
57 You may (in terms of the Consumer Protection Act, 2008) register a pre emptive block against direct marketing communications. If you do so, we will not send you direct marketing communications unless you have expressly consented to receiving direct marketing communications from us.
58 We will not send you direct marketing communications at home at any period during which it is prohibited by law to do so, unless you have expressly or implicitly requested or agreed otherwise.
59 Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information in the course of its transmission. Once we have received your information, we will store some of it on our servers and use strict procedures and security features to try to prevent unauthorised access to it.
60 We take reasonable technical and organisational measures to secure the integrity of retained information, using accepted technological standards to –
61 In particular:
Linking to third party sites
62 We are not responsible for the privacy practices of a third party site to which there may be a link on our site or to which you may log in from our site (e.g. integrated social networking services).
64 In certain instances we will give you the option to manage some of your privacy settings on integrated social networking sites from our sites (e.g. to enable you to determine which of your personal information you would like to share via our site).
Changes to this policy
What you can do to protect your personal information
66 People have different privacy concerns. Our goal is to be clear about what information we collect so that you can make meaningful choices about what you make available. For example, you may -
Queries and complaints
68 If you contact us we may ask you to verify your identity before we can act on your request.
69 Please note that we may reject requests that are vexatious or frivolous, unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or which would be disproportionately impractical to address.
Resolution of disputes
70 If we receive a complaint from you we will use our best endeavours to resolve it.
72 Such arbitration proceedings must be conducted in Johannesburg in English.
73 The arbitration ruling will be final and the unsuccessful party will pay the costs of the successful party on an attorney and own client scale.
74 The expedited rules of the Arbitration Foundation of South Africa may be downloaded from the following site: http://www.arbitration.co.za.