Active Line (Pty) Ltd (“Active Line”, “we”, “us” or “our” as the context may require) is a telecommunication and connectivity provider. Active Line cares about how your personal information is used and is committed to respecting your privacy and helping protect your information.

This Privacy Policy will explain how Active Line uses personal data from you when you use any of our electronic platforms and facilities, including our website, social media, telephone, and/or email (“Active Line’s Electronic Facilities”) or our services, what information we collect about you, and the corresponding rights and obligations arising in connection therewith.

It is important to note that this Privacy Policy has been drafted in compliance with the Protection of Personal Information Act, 4 of 2013 (“the POPI Act”).

PLEASE READ THIS DOCUMENT BEFORE YOU MAKE USE OF ACTIVE LINE’S ELECTRONIC FACILITIES OR SERVICES OR PROVIDE US WITH ANY PERSONAL INFORMATION. BY PROVIDING ACTIVE LINE WITH YOUR PERSONAL INFORMATION, YOU AGREE THAT YOU HAVE READ AND UNDERSTOOD THIS PRIVACY POLICY, AND CONSENT TO ACTIVE LINE PROCESSING YOUR PERSONAL INFORMATION, WHICH WE UNDERTAKE TO PROCESS STRICLTY IN ACCORDANCE WITH THE TERMS OF THIS PRIVACY POLICY.

What data do we collect?

Active Line collects the following data:

• Personal identification information (name, email address, physical address and/or telephone number/s).
• The products and/or services in respect of which you have indicated an interest.

How do we collect your data?

You directly provide Active Line with most of the data we collect. We collect data and process data when you:

• Complete the Contact form on our website.
• Submit a query or request via Active Line’s Electronic Facilities.
• Enter into an agreement with us.
• Voluntarily complete a client survey or provide feedback on any of our message boards or via email.
• Use or view our website via your browser’s cookies.
• Request us to contact you regarding your interest in our products and/or services, via a third party.

How will we use your data?

Active Line collects your data so that it can inter alia:

• Assist you with your query or request.
• Contact you in response to your request or query.
• Process any order/s placed with us.
• Arrange delivery of products ordered.
• Process any return of products.
• Improve the quality of our services.
• Recover unpaid sums and/or any other amount due to us.
• Proceed with debt collection.
• Identify other products and/or services which may be of interest to you and informing you of such.

Active Line reserves the right to send your data to credit bureaux for purposes of assessing your credit risk. Active Line may base decisions on information obtained from credit bureaux.

In order to correctly handle any query or request, and to perform the abovementioned functions, Active Line may from time to time share your data with its staff, which will only be done on a need-to-know basis; and with its operators including service providers and agents who perform services on behalf of Active Line which will similarly be done on a need-to-know basis, and in terms of an agreement.

Conditions for Lawful Processing

In terms of section 5 of the POPI Act, a data subject has the right to have his, her or its personal information processed in accordance with the conditions for lawful processing. Active Line would like to assure you of its commitment to processing personal information lawfully, and particularly in accordance with the POPI Act. To this end, we wish to make sure that you are aware of the conditions for lawful processing,[1] and have summarised them[2] here:

• Accountability – Active Line must ensure that the conditions set out below, and all the measures that give effect to such conditions, are complied with at the time of the determination of the purpose and means of the processing of personal information and during the processing itself.
• Processing Limitation – Personal information must be processed lawfully, and in a reasonable manner that does not infringe on your privacy as data subject. Personal information may only be processed if, given the purpose for which it is processed, is adequate, relevant and not excessive. Furthermore, personal information may only be processed if the data subject consents to the processing; processing is necessary to carry out actions for the conclusion or performance of a contract to which the data subject is party; processing complies with an obligation imposed by law on Active Line; processing protects a legitimate interest of yours; processing is necessary for the proper performance of a public law duty by a public body; or processing is necessary for pursuing the legitimate interests of Active Line or of a third party to whom the information is supplied.[3] The personal information must be collected directly from you, subject to certain exceptions.[4]
• Purpose Specification – personal information must be collected for a specific, explicitly defined and lawful purpose related to a function or activity of Active Line. The records of personal information must not be retained any longer than is necessary for achieving the purposes for which the information was collected or subsequently processed.[5]
• Further Processing Limitation – further processing of personal information must be compatible with the purpose for which it was collected.
• Information Quality – Active Line must take reasonable steps to ensure that the personal information is complete, accurate, not misleading, and updated.
• Openness – Active Line must maintain documentation of all processing operations under its responsibility. In this regard, please refer to the Manual available on our website or at our reception.
• Security Safeguards – Active Line must secure the integrity and confidentiality of personal information in our possession by taking reasonable measures to prevent loss of, damage to or unauthorised destruction of personal information, and unlawful access to or processing of personal information. To this end, please refer to the Security Measures document on our website or at our reception.
• Data Subject Participation – You have the right to request Active Line to confirm whether or not it holds personal information about you and request the record or description of personal information held by Active Line. You may request that we correct or delete inaccurate, excessive, misleading or unlawfully obtained information about you.

How do we store your data?

Active Line securely stores your data at 7 Drome Road, Formain, Johannesburg, Gauteng, South Africa, 2090.

The security measures that have been implemented are far-reaching, and include (but are not limited to):

• Physical Security
• Server security
• Restrictions on Access
• Security by design
• Security objectives established
• Guidelines published on how to achieve these objectives
• Adoption of an overall security management strategy
• Policies on key security mechanisms implemented in both everyday work and server security.

The totality of the security measures is demonstrated in the Security Measure document. Alternatively, you may request a copy from our Information Officer.

Active Line will keep your personal identification information, and product preferences until our services and/or communication is no longer required. The default position is to delete your personal data 180 days after either the expiry of your contract with Active Line or your latest interaction with us via Active Line’s Electronic Facilities. Once this time period has expired, we will delete your data by shredding and dumping any hard copies of data and destroying the applicable hard drives.

Otherwise, where you have provided data in any of the other circumstances listed under the abovementioned paragraph headed How will we use your data?, it will be deleted once our services and/or communication are no longer required. The data will be deleted in the same way as described above.

Marketing

• Active Line would like to send you information about services of ours that we think you may be interested in.
• If you have agreed to receive marketing, you can always opt out at a later date.
• You have the right at any time to stop Active Line from contacting you for marketing purposes.
• If you no longer wish to be contacted for marketing purposes, let us know via the opt-out feature found in the marketing communication, or via email.

What are cookies?

Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. When you visit our website, we will collect information from you automatically through cookies or similar technology.

For further information, visit https://www.allaboutcookies.org/.

How do we use cookies?

Active Line uses cookies in a range of ways to improve your experience on our website, including:

• Keeping you signed in on the relevant portal, service, or programme.
• Understanding how you use our website.

What types of cookies do we use?

There are a number of different types of cookies, however, our website uses:

• Functionality – Active Line uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
• Advertising – Active Line uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, devices, and your IP address. Active Line reserves the right to share limited aspects of this data with third parties for advertising purposes. We reserve the right to share online data collected through cookies with our advertising partners. This means that when you visit another website, you could be shown advertising based on your browsing patterns on our website.

How to manage cookies

You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

Privacy policies of other websites

Our website may contain links to other websites. Our Privacy Policy applies only to our website, so if you click on a link to another website, you should read their privacy policy.

How to contact us

If you have any questions about Active Line’s privacy policy, the data we hold on you, or you would like to exercise one of your rights as a data subject, please do not hesitate to contact our information officer, Patricia Mandindi, via one of the following channels:

Email: patricia@activeline.co.za    

Telephone: +27 10 065 0853

Registered Post: 7 Drome Road, Formain, Lyndhurst, Gauteng, South Africa, 2090

Marked for the attention of Information Officer, Patricia Mandindi.

Information Regulator

To lodge a complaint pertaining to alleged violations of protection of personal information, you are free to contact the Information Regulator:

Address: 33 Hoofd Street, Forum III, 3^rd Floor Braampark, Braamfontein, Johannesburg, 2017

Post: P.O. Box 31533, Braamfontein, Johannesburg, 2017

Email: inforeg@justice.gov.za

Changes to our privacy policy

Active Line reserves the right to and may from time to time update this Privacy Policy. Any revision will be published on Active Line’s website.

Accordingly, you are advised to visit and re-read this Privacy Policy on a regular basis.

This Privacy Policy was last updated in March 2023.

[1] Clause 4 of the POPI Act.

[2] While the conditions for lawful processing are all addressed in this document, our summary is intended for informative purposes only. It must not be construed as legal advice or a comprehensive analysis and must not be relied on as such. Where it comes to enforcing your rights, or drafting your own Privacy Policy, independent legal advice by a POPI Act expert is strongly advised.

[3] For further information, refer to section 11 of the POPI Act.

[4] For exceptions, refer to section 12(2) of the POPI Act.

[5] For more information, refer to section 14 of the POPI Act.