OUR PILLARS OF PRIVACY
OUR PILLARS OF PRIVACY
We want you to know what and how information (including, without limitation, personal information) is collected when you interact with us through our retail stores, our call centers, associated entities, service providers, franchisees, apps, and websites.
We will offer you choices about how your information can be used by us and our trusted business partners.
We will take reasonable precautions to protect information we collect about you through our retail stores, our call centers, associated entities, service providers, franchisees, apps, and websites.
Browsing Information is information collected through cookies and web beacons to track what products you viewed and purchased online, what areas or pages you viewed on our websites, and other information about your browser and browsing behavior. We use browsing information to improve the design and content of our websites, to suggest content and products that we think may be relevant to you, and to help us learn things like what pages are most attractive to our visitors, what promotions visitors like to see, and to gauge the success of our advertising campaigns.
Interest-based advertising has become commonplace across the Web. It is the term we use for the activity that enables us to tailor ads to your interests and activities. Either we, or third-party advertising companies we work with, may look at your browsing activity, such as the types of content you access, ads you click on, and searches you conduct. We can then infer certain interests you have and place ads and offer you deals that meet your needs. Our goal for interest-based advertising is to show ads to people likely to be interested in the products we offer.
Personal Information (“PI”)
Any information of a personal nature by which you can be identified as an individual such as your name, postal address, email address, telephone number, home country, postal code, gender, age, and/or company name. In particular, we may collect and process the following information (which may include personal information) about you:
- information that you provide by filling in forms on our online retail store;
- information that we may ask you for if you enter any competition or promotion featured on our website or if you report a problem with our website;
- if you contact us, we may keep a record of that correspondence;
- we may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them;
- details of transactions you carry out through our online retail store and of the fulfilment of any contract you enter into with us;
- details of your visits to our online retail store (including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for billing purposes or otherwise) and the resources that you access; and
- during your visit to one of our retail stores, your registering with one of our loyalty programs, your participating in competitions that we run from time to time, and/or your use of any of our services.
Third-Party Advertising Companies
We allow certain companies to collect information from browsers of our websites to use to serve interest-based ads. These companies are usually third party ad servers, ad agencies, technology vendors or providers of sponsored content. Using cookies and web beacons, these companies collect data from a particular browser about web viewing behaviors over time and across unrelated websites and use such data to predict user preferences and to deliver advertisements to that browser which are calculated to target that browser’s predicted preferences.
Trusted Business Partners
When you visit our websites, web beacons will recognize specific cookies that have been placed on your browser. Web beacons can convey information that a browser with a recognized cookie has accessed a page or a certain part of a page on our websites, depending on where the web beacon is located on the websites. For example, a web beacon located on our purchase confirmation page will record that a browser with a recognized cookie accessed that page which means that we can conclude that the browser was used to purchase a product. The web beacon does not, however, tell us that you specifically (by reference to PI) have purchased a product because the cookie only identifies the browser and not you personally.
We use web beacons to suggest content and products that we think may be relevant to you, to measure the effectiveness of our advertising campaigns and to improve our websites by recognizing which pages are visited and whether those visits result in purchases. Web beacons also allow third-party advertising companies we work with to select and serve banner advertisements to your browser that you would be most likely to be interested in.
INFORMATION COLLECTED AND USED
What Information Do We Collect?
We collect PI at different touchpoints, including when you register with our websites or through one of our retail stores, register with one of our loyalty programs, participate in competitions that we run from time to time, enter into one of our retail stores, make a purchase in one of our retail stores or through our websites, or otherwise use any of our services. We combine PI we collect from you with other information we receive from you and from third parties such as our trusted business partners and social media platforms.
We automatically collect browsing information when you visit our websites, and use traffic counters when you enter our retail stores. This type of information is anonymous and is not linked to you personally. If for any reason this information is linked to information that can personally identify you, we’ll treat it as PI.
You do not have to provide us with any PI, however if you do not do so we may not be able to provide you with the products, services or benefits you have requested.
All information that you share about yourself, whether PI or not, in a public open forum – on a social network, in user-generated content elements of our website, etc. will be considered public information for the purposes of this policy. Although we appreciate your input, and at times ask for it, it is better to not post it if you aren’t comfortable with it being public.
Who Collects Information?
We collect information from you when you interact with us through our retail stores, call centers, associated entities, service providers, franchisees, apps or our websites. We may also collect information about you from third parties, such as through social media platforms or our trusted business partners who also collect information from you on our behalf in the course of helping us operate our websites and provide services of interest to you. We may collect your PI from other individuals who choose to share your PI with us. We also permit third-party advertising companies to collect your browsing information as well to provide ads on our behalf that are tailored to your interests. See the “Interest Based Advertising Section below for more information on interest-based ads and your choices regarding your information.
In general, collection of your PI, browsing information and information you post or provide may vary across our stores and websites depending on their purpose, functionality or unique aspects.
Use and Sharing of Collected Information
- We use your PI to:
- complete transactions and otherwise facilitate your shopping experience including deliveries of our products;
- offer you information and promotional material about our products and services.
- respond to any queries, comments, complaints, or other communications you have with us
- facilitate your participation in our loyalty programs;
- facilitate your participation in competitions, special offers, and promotions.
- We use your browsing information to help us analyze our websites, consumer behaviour and our services and offerings.
- We use your browsing and shopping information to provide you with interest-based advertising.
- We may use information you post in public areas (whether a third party social network, or in user-generated content elements of our websites) to provide you with an interactive social media experience that brings aspects of your social networking community to our websites.
- We may use all the above information for administrative purposes, including planning, development, procurement, loss prevention, and quality control.
- We may use your PI as well as de-identified information for analytic purposes.
We may share PI and browsing information :
- within our family of brands and with businesses controlling, controlled by, or under common control with LSSA;
- with our service providers, including deliveries, couriers, internet service providers, IT system administrators, promotions companies, marketing consultants, mailing houses, payment processors and other third party suppliers with whom we have business relationships;
- with our consultants and professional advisors;
- with our call centers, associated entities, franchisees, wholesale partners or resellers.
These parties have their own privacy policies which governs the way that they deal with PI.
If you are a candidate for employment with us, we may collect other information as further set out in our application forms or during the recruitment and selection process including interviews. This may include information relating to your employment history, working eligibility rights, suitability for the role you are applying for, and your referee details.
Storage of your Personal Information
CHOICES REGARDING YOUR INFORMATION
With your PI — like the information you give us to fulfill an order or sign up for an offer or competition – we will always give you the right to change or correct your information and the choice of not receiving marketing from us again. There are several ways you can control our use of any submitted PI in connection with promotional communications.
When you set up an account, or click on “Sign In” on the website, you may access, correct or update your choices and settings. If your personal details change, such as your address or phone number, please update them through your online account or contact us through the contact information provided on the relevant website for assistance.
If you receive email marketing communications from us on behalf of any of our brands and want to opt out of receiving such communications in the future from that brand, you can opt out by clicking the “Unsubscribe” link at the bottom of the promotional email.
At your written request, we will provide you with a copy of any PI which we hold about you, unless an exception under local law applies. We may charge a fee for retrieving this information, in which case we will inform you of the fee and obtain your agreement to that fee before providing the information. If you would like to do so, please contact us. If you cannot correct your PI through your account, or have any difficulty managing your communication preferences, please contact us and we will take reasonable steps to correct that information unless an exemption under local law applies.
Please be aware that some of the user content that you provide to us and which appears on our websites (such as photos you submit to participate in competitions) may be stored and controlled by third party providers. While we will take reasonable steps to comply with your requests in relation to your PI, in some limited cases this may not be possible. If so, we will try to provide you with the details of the appropriate third party provider so you may contact them directly.
Our systems do not recognize browser “Do Not Track” signals, but several of the third-party advertising companies who utilize cookies on our websites to provide interest-based advertising enable you to opt out of those practices. If you would like to learn more about interest-based advertising and see what choices you may have about how companies use your information, please go to http://aboutads.info/choices/ or http://www.networkadvertising.org/choices/. We do not operate or control these sites, and are not responsible for the opt-out choices available there. The only way to fully opt-out of online tracking is to adjust your browser settings to reject cookies or to notify you when a cookie is set. Please remember, even if you opt out of interest-based advertising on or through http://www.networkadvertising.org these sites and other opt out sites or services you may still receive marketing material from us, as interest-based ads are only one form of advertising. You may opt out of receiving any marketing material from us as set out above.
Finally, it is important to note that in most cases opting out drops an “opt-out cookie” on your browser. As a result, if you delete, block or otherwise restrict cookies or use a different computer or browser, you’ll need to renew your opt-out choice.
Interacting with Social Media on our Websites
Social media provides tools that many of our customers use and enjoy, and we include links to various social media platforms on our websites. If you interact with these social media tools through our websites, your experience on those social media sites will be governed by the privacy and other policies of those sites. The privacy settings you have chosen on those sites will determine the degree to which your information is made public. We encourage you to choose your privacy settings on those sites accordingly.
Additional privacy policies may apply where we conduct certain promotions and make special offers. You should always check to see whether additional privacy provisions apply.
Our websites are intended for users who are 18 years old or older. We do not knowingly collect PII from children under the age of 18. If we become aware that we have inadvertently received PII from a child under the age of 18, we will delete such information from our records.
We keep your PI confidential and we require, by contract, that each of our trusted business partners who may have access to any such PI keep it confidential and have the necessary security safeguards in place. Our trusted business partners, in turn, may share information with their own service providers pursuant to similar confidentiality restrictions.
We will not sell, trade, or otherwise transfer any of your PI to any other outside parties without getting your consent first. “Outside parties” do not include companies owned by LSSA or our trusted business partners who help operate and provide services on our websites.
Of course, to the extent we reasonably believe that a disclosure is required by law, to enforce our websites policies, or to protect your or others’ rights, property or safety, we reserve the right to do so.
Safeguarding Your PI
By sharing information with us, you acknowledge and agree that data transmissions are never completely private or secure. You understand that any message or information you send to us may be read or intercepted by others and you do so at your own risk, even if there is a special notice that a particular transmission (for example, credit card information) is encrypted. Nonetheless, we maintain security measures in accordance with applicable data protection and privacy laws, regulations and industry practices to protection the PI you provide to us against accidental, unlawful or unauthorized use or disclosure.
When you register at our websites, or confirm an account or membership information that you have opened in one of our retail stores, we ask you to set up a password that you can use to access your information. If you are provided with an auto-generated password as part of the registration process, we ask you to change your password upon your first login. If you want to cancel your password or change it, or something happens to your password, click on “Sign In” from the relevant website, and you may access, correct or update your choices and settings from within your account, or contact us through the contact information provided on the relevant website for assistance.
Disclosure to other countries
Please be aware that your PI, browsing information, and communications may be transferred to and maintained on servers or databases located outside South Africa. We may also disclose PII to our associated entities, call centers, wholesale partners, resellers, affiliates and service providers which are located including Singapore, the Netherlands, United States of America and India.
The laws in these countries may not be as protective of your privacy as those in your location. By providing your PII to us, you are agreeing to the collection, use, transfer, and disclosure of your PII, browsing information to those countries, and that communications will be governed by the applicable laws in those countries and accordingly your PI may not receive the same protections that it would in South Africa. You may request us not to transfer your PI to the countries listed above, but if you do so we may not be able to provide the services or products you have requested from us.
Contact Us Regarding Your Information
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