1. PURPOSE OF THE PRIVACY NOTICE
This privacy notice explains how we collect, use, and process your personal information through your use of our Sporting Post website, including any information you may provide through this Sporting Post website when you register an account with us. We will ensure that the personal information we collect from yourself is protected and processed carefully and responsibly. It is important that you read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your information. This privacy notice supplements other notices, the Standard Terms and Conditions, and privacy policies and is not intended to override them.

2. WHO IT APPLIES TO
This notice applies to any person (natural or juristic), whose information is either loaded on our Sporting Post website. We may need to update this privacy notice periodically and encourage you to check our privacy notice regularly so that you remain up to date on how we process and protect your personal information. If you have any questions about this notice, please email us at [email protected]

3. WHAT PERSONAL INFORMATION WE COLLECT AND GENERATE
Personal information means any information about a natural or legal person from which that person can be identified. It does not include information where the identity has been removed (anonymous information). We collect the personal information we require to register you as a customer and to communicate with you.

3.1. The following is the information we collect:

• First name;
• Last name; and
• Email address.

3.2. We generate information about you in the form of:

• Customer account and related profile; and
• Subscriptions email service.

As a general rule, we do not collect any special categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric information).

4. WHEN AND WHY WE COLLECT AND PROCESS YOUR PERSONAL INFORMATION

4.1. We process your personal information to meet our contractual obligations with you, as well as collect and use your personal information for the following purposes:

• Registering an account with us;
• Subscription email service;
• To reply to you when you contact us for support; or
• To investigate and resolve your query, complaint, or request.

4.2. In some instances, we process your personal information because it is in our or your legitimate interest to do so. For example:

• We may monitor our premises with CCTV cameras to ensure your and our safety; or
• We may record your details (name/company name, identity number, contact number, and vehicle registration number) upon the entrance to any of our premises to ensure your safety and our safety.

4.3. We are legally required to collect and process certain information, including:

• To identify and validate our customers and for purposes related to the prevention of financial crime, including sanctions screening, monitoring of anti-money laundering and financing of terrorist activities;
• To report suspicious activity on your account to the relevant authorities; or
• To report to other governmental agencies, for example, the South African Revenue Service.

When you register an account with Winning Media Proprietary Limited for the Sporting Post website, you can choose if you want to receive promotional material from us. We may send you information about our services, products, and promotional activities via the communication channels you selected. You can unsubscribe at any time by following the unsubscribe link or by contacting us.

5. CHILDREN’S INFORMATION
All information about minors will require parents and/or a legal guardian’s consent for processing. This applies to anyone under the age of 18 years. We do not knowingly collect the personal information of persons under the age of 18 years.

6. WE ONLY SHARE YOUR INFORMATION WITH OTHERS WE TRUST
We only use service providers we trust and who have agreed to keep your personal information secure and confidential and to only use it for the purposes for which we shared it with them. We use/may use service providers to assist with the following:

• Communication with you;
• Verification of your identity;
• Verification of your address; and
• Monitoring the effectiveness of our services to you;

Some of the service providers that we use may be located in other countries. These countries may not have the same levels of protection of personal information as South Africa, in which case the foreign service providers must undertake to protect the personal information of our customers to the same level that we do. We provide for appropriate safeguards by means of contracts between us and our foreign service providers. By using our website, you agree to not being notified of details regarding the level of protection afforded to your information in the relevant country/countries. We may be required to share your personal information with external auditors, internal auditors, professional accountants, professional advisors, South African Revenue Services, other regulatory and law enforcement bodies.

7. REASONABLE STEPS TAKEN TO SAFEGUARD YOUR PERSONAL INFORMATION
We take reasonable steps to protect your personal information against the following:

• Loss;
• Interference;
• Unauthorized access;
• Use;
• Modification;
• Disclosure; or
• Other misuse.

These steps include password protection for electronic files, securing paper files, and physical access restrictions. We will continuously review our security controls and processes to ensure that security risks are identified and addressed. If something should happen, we will take the necessary steps to minimize the threat to your privacy, and we will let you know if your personal information has been compromised. We will also let you know how you can help minimize the impact of a breach.

8. WE DO NOT KEEP YOUR PERSONAL INFORMATION LONGER THAN WE NEED TO
We will not keep your personal information longer than we need to unless we are legally required to do so. We take legal requirements, contractual obligations, and the expectations and requirements of our customers into account when we determine how long we should retain information. When we no longer need your personal information, we will securely delete or destroy it in line with the Protection of Personal Information Act (POPIA) requirements.

9. CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
We keep our privacy notice under regular review and, therefore, encourage you to check our privacy notice regularly so that you remain up to date on how we process and protect your personal information. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

10. IF YOU FAIL TO PROVIDE PERSONAL INFORMATION
Where we need to collect personal information by law or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to process your credit application. In this case, we may not then be in a position to provide the product or service you may require from us, but we will notify you if this is the case at the time.

11. ACCESS AND CORRECTION OF PERSONAL INFORMATION
You have the right to:

• Be notified that your personal information is being collected;
• Be notified of security compromises where reasonable grounds exist for us to believe that your personal information has been accessed or acquired by an unauthorized person;
• Ask us what we know about you and request access to such information; ask what personal information was sent to our service providers or any other third party;
• Ask us to update, correct or delete any out-of-date or incorrect personal information we hold about you; where it is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully;
• Unsubscribe from any direct marketing communications we may send you and object to the processing of your personal information;
• Request us to delete or remove your personal information where there is no good reason for us continuing to process, although this will be subject to Winning Media Proprietary Limited requiring the information for legal and legitimate reasons;
• Request restrictions on processing of your personal information;
• Withdraw your consent at any time where we are relying on consent to process your personal information;
• Submit a complaint to the Information Regulator. You have the right to submit a complaint to the Information Regulator regarding an alleged interference with the protection of your personal information. However, please note that until POPIA is in force, the Information Regulator does not have the power to enforce your protection under POPIA;

You can request access to the personal information we hold about you or correct your personal information. It can take us up to 21 days to respond to your request due to procedures that we are required to follow. In certain cases, we may require proof of your identity and sometimes changes to your personal information may be subject to additional requirements such as valid proof of residence.

Please see below our contact details for our information officers:

NAME	Mr Suren Rampersadh	Mrs Chanelle Beukes Mr Rowan Cross Mr Adheesh Maharaj
TITLE	Information Officer	Deputy Information Officers
EMAIL ADDRESS	[email protected]
CONTACT NUMBER	087 353 8930
POSTAL ADDRESS	PO Box 74234, Rochdale Park, 4034
PHYSICAL ADDRESS	6 Tetford Circle, Umhlanga, Durban, 4320
WEBSITE	www.sportingpost.co.za

12. DOCUMENT METADATA

Document number:	POPI3
Document version:	V1
Document approval by:	POPIA Committee
Document approval date:	01 July 2021
Document owner:	Adheesh Maharaj
Document author(s):	Adheesh Maharaj
Last updated:	1 July 2021
Next review date:	September 2021