Privacy Policy

1. INTRODUCTION
   1. All references to “the Company”, “Stormers Rugby”, “we”, “us” and “our” in this Privacy Policy are deemed to refer to Stormers Rugby Proprietary Limited, a company duly registered and incorporated with limited liability according to the laws of the Republic of South Africa (“South Africa”), with the registration number 2016/223694/07 and having its principal place of business at DHL STADIUM, Foyer E, Level 4, Fritz Sonnenberg Road, Cape Town, Western Cape, 8051.
   2. All references to “you”, “user” and “your” are deemed to refer to any user and/or visitor of the website and/or social media platforms, and other related URLs, its features and services.
   3. This Privacy Policy, together with our Terms and Conditions, sets out the basis on which any Personal Information (as defined in paragraph 2.2 below) that we collect from you, or that you provide to us, will be used, stored and processed by us.
   4. Stormers Rugby is the “responsible party” for purposes of applicable data protection legislation in respect of all Personal Information you submit to us when you use the digital platforms located at the domain names www.thestormers.com and/or www.wprugby.com and any other social media or digital platforms (including but not limited to Instagram, Twitter, LinkedIn and Facebook) (“the Platform(s)”), its features and/or services and/or where you otherwise communication with us.  Please see paragraph 9 below as it deals with Personal Information you submit to third-parties.
   5. All the provisions of this Privacy Policy are important, but please pay special attention to the parts that are in bold writing. These parts contain information about provisions that have special consequences on you and are only intended to bring such provisions to your attention.
   6. Stormers Rugby is committed to the protection of your privacy in respect of Personal Information collected by us when you interact with us by using the Platforms, and will ensure that Personal Information is collected and processed in line with the provisions of the Protection of Personal Information Act, No. 4 of 2013 (“POPI”).
   7. By continuing to use the Platforms, you represent and warrant that you are agreeing to this Privacy Policy, you provide us further with your express consent to process, collect, store, retain and to use your Personal Information in the manner and for the purposes set out in this Privacy Policy, and you consent to our collection of any changes or updates that you may provide to any information you provide that is collected by us. If you do not agree with this Privacy Policy or are concerned about any aspect as it relates to your Personal Information, please do not continue to use the Platforms, its services or otherwise interact with the Company.
   8. Where you provide us with Personal Information relating to a third-party data subject, you warrant that you have obtained all necessary consents from such data subject, including the data subject’s consent for you to share such Personal Information with the Company to process. We shall protect, store and process this Personal Information in the same manner and equal level of security as Personal Information about you.
2. INFORMATION WE MAY COLLECT FROM YOU
   1. When you use the Platforms, we may collect certain information that is not Personal Information such as your operating system, browser type, and Internet service provider (see paragraph 8.1 below for further details). 
   2. When accessed on the Platforms, we may also collect Personal Information that you provide to us. For purposes of this Privacy Policy, “Personal Information” shall mean any information of a personal nature by which you can be identified such as your name and surname, postal address, email address, telephone number, home country, postal code, your fax number, gender, age, date of birth, physical location, ID number, your image, financial details, and/or company name, business information and VAT number (as contemplated in POPI).
   3. We may collect, process and store the following information (which may include Personal Information) about you –
      1. information that you provide by filling in online feedback forms on the Platforms;
      2. information about your device software and hardware, including the unique internet mobile equipment identity (IMEI), number of your mobile telephone, the unique integrated circuit card identity (ICCID) number of your SIM cards in your device, your email address, personal internet protocol (“IP”) address;
      3. your geographic location information based on your mobile network operator’s tower details, GPS (Global Positioning System) and/or WIFI communications network location;
      4. the date and time, country and the IP address of the device from which you connect to our Platforms;
      5. information that we may ask you for if you report a problem with our Platforms;
      6. details of your visits to our Platforms (including, but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access); and
      7. if you contact us, we may keep a record of that correspondence.
   4. We may also collect information (which may include Personal Information) that our users provide, such as reviews and keyword searches.
   5. The supply of your Personal Information is voluntary; however, you acknowledge that we cannot make certain services available to you on the Platforms if you do not wish to supply such Personal Information.
   6. We may use a third-party company to monitor website or social media platform traffic, which may, in some instances, store your information, including the Personal Information you submit to such third parties.
3. when will we process your personal information
   1. Your Personal Information may be requested, collected and processed at various locations and on various forms on the Platforms, including but not limited to, when:
      1. we require of you to submit certain information in order for you to register as a subscriber of the Company’s online community, including where you use our social media platforms;
      2. you complete online forms, including registration forms for newsletters and other e-mail communications;
      3. you access, use, refer to, view and/or make use of the Platforms or services available through the Platforms;
      4. you communicate or otherwise interact with us via the Platforms;
      5. you submit your Personal Information to us for any other reason; and
      6. you contact us, by email, feedback forms, site comments, telephonically or otherwise, with queries.
   2. We may also ask you to complete surveys that we use for market research and forecasting purposes, although you do not have to respond to them.
4. HOW YOUR INFORMATION IS USED AND DISCLOSED
   1. Stormers Rugby will only process your Personal Information in a manner that is adequate, relevant and not excessive in the circumstances. The processing of your Personal Information is done for a purpose compatible with the reason for which it was collected, unless agreed otherwise or as permitted by law.
   2. Please note that Stormers Rugby may process your Personal Information without your knowledge or consent, in compliance with applicable laws.
   3. In addition to the above, we may use the information, including the Personal Information, we hold about you for the following purposes –
      1. as a registered user to verify and keep a record of your identity;
      2. to create your subscription and user account and to ensure that it doesn’t duplicate an existing subscription and user account on the Platforms;
      3. as a subscriber, to send you notifications, newsletters, special offers, ticketing information and information about competitions;
      4. to maintain and update our subscriber or potential subscriber databases;
      5. to ensure that content from our Platforms are presented in the most effective manner for you and for your computer and/or mobile device;
      6. to monitor and analyse the conduct on the Platforms to ensure compliance with laws, reduce the likelihood of fraud and other risk-prevention purposes;
      7. in aggregate form, for internal business purposes such as generating statistics and developing our strategic and marketing plans;
      8. to provide you with information on our Platforms that you request from us or to contact you where you have consented to be contacted for a particular purpose;
      9. to allow you to participate in interactive features on our Platforms, when you choose to do so;
      10. to improve the Platforms, analyse trends and administer the Platforms, including requesting feedback on content;
      11. to carry out any contracts that may form between us; and
      12. to respond to any queries, you make;
      13. to enforce agreements and terms and conditions between us, monitor user activity, such as reviews and keyword searches, and to more effectively manage traffic on the Platforms;
      14. to diagnose and to assist you with technical difficulties and user support queries.
   4. We will not use your Personal Information for any purpose (other than as stated above) without your express consent.
   5. Except in terms of the other provisions of this Privacy Policy, we will not use or disclose your Personal Information to third parties without your consent, unless the use or disclosure is –
      1. required to comply with an obligation imposed by law on the Company and/or an order of court or legal process served on the Company; and/or
      2. disclosure is necessary to pursue the legitimate interests of the Company, its right or property and/or the legitimate interests of a third party to whom such Personal Information is supplied.
   6. We will be entitled to disclose your Personal Information to our affiliates, agents, advisors, employees, service providers, contractors, commercial partners, dealers and/or third-party service providers and suppliers to the extent that they need to know that information in order to process it for us/or to provide support services to us for data analytical purposes in order to develop, provide and to improve the services that may be offered to you, and/or to perform functions on our behalf. We will ensure that all such employees and/or third-party service providers having access to your Personal Information are bound by appropriate and legally binding confidentiality and non-use obligations in relation to your Personal Information.
   7. On rare occasions, we may be required to disclose your Personal Information due to legal or regulatory requirements. In such instances, we reserve the right to disclose your Personal Information as required to comply with our legal obligations, including but not limited to complying with court orders, warrants, subpoenas, service of process requirements or discovery requests.
   8. We may also disclose information about our users to law enforcement officers or others, in the good faith belief that such disclosure is reasonably necessary to enforce this Privacy Policy, respond to claims that any content violates the rights of third parties; or protect our legitimate interest, rights and/or property, or our personal safety or the personal safety of our users or the general public.
5. PROTECTION OF YOUR PERSONAL INFORMATION
   1. We recognize that protecting your privacy is important to you. For this reason, we are committed to protecting the Personal Information you provide in a variety of ways.
   2. We will –
      1. treat your Personal Information as strictly confidential;
      2. take appropriate technical and organizational measures to ensure that your Personal Information is kept secure and is protected against unauthorized or unlawful processing, accidental loss, destruction or damage, alteration, disclosure or access;
      3. promptly notify you if we become aware of any unauthorized use, disclosure or processing of your personal information;
      4. provide you with reasonable evidence of our compliance with our obligations under this Privacy Policy on reasonable notice and request; and
      5. upon your request, promptly return or destroy any and all of your Personal Information in our possession or control.
   3. We may keep Personal Information for as long as you continue to access and use the Platforms, content, services and/or subscribe to any features available on or through the Platforms or for as long as reasonably necessary or until you contact us and ask us to destroy the retained information if it is no longer required for the purposes for which it was collected or required by us in terms of any applicable law.
6. STORAGE AND SECURITY OF YOUR PERSONAL INFORMATION
   1. We will take appropriate reasonable technical and organisational measures to protect your Personal Information, and we will use technology that will help us to do this, however, the transmission of information via the internet is never completely secure and we cannot guarantee the security of your information transmitted to our Platforms and we cannot accept any liability for the safeguards and security measures implemented by you and/or your internet service provider. Any transmission of your information to our Platforms are entirely at your own risk and we will not be liable for any loss, claim and/or damage arising from any unauthorised access, disclosure, misuse, loss, alteration or destruction of your Personal Information. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
   2. We store your Personal Information on our servers or on the servers of our third party service providers, such as IT systems or hosting service providers. In this event, we will ensure that we have entered into written contracts that require such third party service providers to secure the integrity and confidentiality of Personal Information in its possession by taking appropriate, reasonable technical and organisational measures.
   3. We may, from time to time, transfer, store or host your Personal Information on servers outside of South Africa.  We will at all times ensure that appropriate security safeguards are in place to secure and protect such Personal Information held in another country or that the service provider acts at all times in compliance with applicable privacy laws. Where required under applicable laws we will take measures to ensure that Personal Information handled in other countries will receive at least the same level of protection as it is given in this Privacy Policy.
7. Communications
   1. When you subscribe as a subscriber, we may communicate with you via the Personal Information provided by yourself (such as telephone numbers or email addresses) for the purposes of announcements and the provisions of further information which you find useful, including information about services you may be interested in and the like.
   2. Notwithstanding the generality of the above, we may from time-to-time email newsletters to you, which newsletters will contain information which you may find useful, including information about special offers, ticketing information and information about competitions which you may be interested in.
   3. You may contact us at any time (in any manner, whether telephonically, electronically, in writing or in person) should you wish to unsubscribe from any of the above general communications.  Please note that it is not possible to unsubscribe from communications specific to agreements entered into with us.
8. COOKIES AND OTHER INFORMATION
   1. The Platforms utilise first and third-party cookies. We may collect information about your computer (including tablets, smart phones etc.), including where available, your operating system, browser type, third-party software installed on your device, installation and uninstallation rates, the language of your device and computers manufacturer, screen size and model of the device and any other technical information for system administration and to report aggregate information to our advertisers.
   2. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.
   3. We may use cookies to manage our users’ sessions and to store preferences (like keeping a user lodged in), tracking information, and language selection. “Cookies” are small text files transferred by a web server to your hard drive and thereafter stored on your computer. The types of information a Cookie collects include the date and time you visited the Platforms (to the extent applicable), your browsing history, your preferences, and your username.
   4. In some instances, our third-party service providers may use Cookies on the Platforms (to the extent applicable). We cannot control, or access Cookies used by third-party service providers. This Privacy Policy covers only Cookies used by us, and not any Cookies used by third parties.
   5. Cookies enable us to –
      1. estimate our Platforms’ audience size and usage pattern;
      2. store information about your preferences, which allows us to customize the Platforms according to your individual interests;
      3. speed up your searches; and
      4. recognize you when you return to the Platforms.
   6. You have the ability to either accept, block or to restrict the use of Cookies on your computer and/or mobile device, whether you are registered with us or not. Typically, you can configure your browser to block or restrict Cookies. However, you hereby agree that if you block or restrict Cookies when using the Platforms, you may limit your access to certain features of the Platforms (to the extent applicable). For example, you may have difficulty using certain interactive features of the Platforms (to the extent applicable).
9. THIRD PARTIES
   1. We may use third-party service providers to monitor our users’ interests. In addition, the Platforms contain links to third-party websites, social media platforms, products and/or services.
   2. We are not responsible for the content of these third-party websites and social media platforms or for the security of your Personal Information when you use the third-party websites and social media platforms. These third-party service providers and third-party websites and/or social media platforms may have their own privacy policies governing the storage and retention of your Personal Information that you may be subject to. They may also collect information that is not Personal Information such as your browser specification, or operating system.
   3. If you click on the links to, from or advertised on the Platforms to third-party websites or social media platforms this Privacy Policy does not govern Personal Information provided to, stored on, or used by these third-party providers and third-party websites and/or social media platforms. You accept that there may be risks when you use such third party websites and/or social media platforms, and you do so at your own risk. We recommend that when you enter a third party’s website and/or social media platforms, you review its privacy policy as it relates to how such third parties collect, process, store and protect your Personal Information.
   4. You agree that the Company is not liable for any of the following –
      1. the content, security, operation, use, accuracy or completeness of any such third-party websites and/or social media platforms; or the products or services that may be offered or obtained through them; or the accuracy, completeness, or reliability of any information obtained from a third-party website and/or social media platforms;
      2. the ownership or right of use of any licensor of any software provided through any third-party website and/or social media platforms;
      3. any content featured on third-party websites that are accessed through the links found on the Platforms;
      4. any failure or problem that affects the products or services of a third-party website and/or social media platforms, for example any telecommunication service provider, internet service provider, electricity supplier, local or other authority;
      5. loss or damages suffered when visiting third party websites and/or social media platforms by following a link to that website and/or social media platforms from the Platforms.
10. GENERAL
    1. You warrant that all information (including Personal Information) that you provide to us is accurate, truthful and current information, and not to impersonate or misrepresent any person or entity or falsely state or otherwise misrepresent your affiliation with anyone or anything. Failure to adhere to this requirement will entitle the Company, inter alia, to terminate your use of the Platforms.
    2. You acknowledge that we may verify your identity and your Personal Information through an automated email verification process and/or with third party service providers.
    3. You may request access to the Personal Information which we collect from you, including to rectify the information, or object to its processing by sending an email to us at Gavin@stormers.co.za. You also have the right to lodge a complaint with the information regulator if you think we are in breach of any applicable data protection legislation.
    4. You may access, remove, review, and/or make changes to Personal Information that you have provided to us. We may also send you any legally required notifications and other notifications, including but not limited to, service related notices or notices regarding a change to any of our policies. For example, we may send you a notice regarding server problems or scheduled maintenance to the Platforms. 
    5. If this Privacy Policy or any provision in this Privacy Policy is regulated by or subject to the POPI, or other data protection legislation it is not intended that any provision of this Privacy Policy contravenes any provision of POPI or other data protection legislation. Therefore, all provisions of this Privacy Policy must be treated as being qualified, to the extent necessary, to ensure that the provisions of POPI or other data protection legislation are complied with.
11. NOTIFICATION OF CHANGES

We reserve the right to change this Privacy Policy from time to time, and in our sole discretion. We may send you a notice regarding material changes to this Privacy Policy, but we encourage you to frequently check this Privacy Policy for any changes. Your continued use of the Platforms after any change in this Privacy Policy will constitute your acceptance of such changes.

1. CHILDREN

The site is not intended for children and we do not knowingly collect or intend to collect Personal Information of children. If you are under the age of 18 (eighteen) years do not use our Platforms without the consent of your parent or legal guardian.

1. HOW TO CONTACT US

If you have any questions about this Privacy Policy, please contact us at mailto: Gavin@stormers.co.za with “Privacy Policy” in the subject line.