Privacy and Cookie Policy

Jelico (Pty) Ltd]

  1. 1 Introduction
  1. 1.1 Jelico (“the Company”) is a private company duly incorporated in accordance with the laws of South Africa. 
  1. 1.2 The Company is committed to maintaining the privacy and security of customers’, suppliers’, associates and any data subjects’ personal information, which includes information that identifies or relates specifically to a person such as, but not limited to, their names, email address and physical address, mobile phone numbers, date of birth, any medical related information and gender (“customer information“). For purposes hereof, customer information includes any personal information of third parties that a user may submit to the Company on behalf of such third party (for example, the personal information of the user’s employees or partners). 
  1. 1.3 The Company is committed to comply with the Protection of Personal Information Act (“POPIA”) and the General Data Protection Regulation (“GDPR”) applicable to EU Citizens.
  1. 1.4 The Company also receives third party suppliers’ personal information and is committed to maintaining the privacy and security of such third-party suppliers (“suppliers’ information“).
  1. 1.5 The security of such customer information submitted by a customer (or allowing another person to do so on your behalf) and suppliers’ information submitted to the Company (including via the Company website (known herein as “the website“)) is dealt with as set out in this policy (“policy“), read together with the applicable Section 18 Consent available on the Website.
  1. 1.6 This policy sets out the following:
    1. 1.6.1 What customer information and suppliers’ information the Company collects and holds;
    2. 1.6.2 Why the Company collects that information;
    3. 1.6.3 To whom the Company discloses customer information and/or suppliers’ information to;
  1. 1.6.4 How long the Company holds customer information and/or supplier information for;
  2. 1.6.5 How the Company safeguards customer information and suppliers information;
  3. 1.6.6 Transfer of customer information and/or suppliers information inside and outside South Africa;
  4. 1.6.7 Customers’ and suppliers’ rights to access and correct such information;
  5. 1.6.8 The Cookies policy of the Company;
  6. 1.6.9 Changes to this policy;
  7. 1.6.10 How to contact the Company.
  1. 1.7 By using the Company website and providing personal information, the customer and/or supplier agrees to the terms and conditions stated in this policy and consents to the Company collecting, using and disclosing customer information and/or supplier information as detailed in this policy.
  1. 1.8 Should a user not agree with this policy (or any part), please do not provide such personal information to the Company. Withholding of personal information may affect the services the Company can provide.
  1. 1.9 Any term used in this policy that does not have a specifically defined definition must be interpreted in accordance with the use thereof and definition given thereto in POPIA. 
  1. 2 What customer information and suppliers’ information the Company collects and holds
  1. 2.1 Where practical, the Company will collect customer information directly from the customer and/or supplier. This will normally take place when you deal with the Company directly, by emailing the Company, when visiting this website, telephonic conversation, by visiting the Company’s premises or any other way of communication and connection with the Company.
  1. 2.2 We may also collect customer information directly from the customer, when the customer subscribes to receive marketing material and/or when requesting information from the Company.
  1. 2.3 Should the customer directly submit a request for a quotation and/or information via this website and/or to the Company via email, or request to be part of the Company mailing list, the customer is indicating that he/she has read this policy and is willing for the Company to deal with such customer’s customer information as set out in this policy.
  1. 2.4 In some cases, customer are represented by a third party. In this instance it may be necessary for the Company to collect customer information from such a third party. In such instances, we understand that the third party has the customer’s consent for providing the Company with the customer information, and the customer has consented to the Company processing the customer information as set out in this policy. Should it be necessary as solely determined by the Company, the Company may request a copy of such customer consent.
  1. 2.5 Should a customer become aware that customer information has been provided to the Company by a third party without the customer’s consent, please let the Company know immediately by emailing the Company on [email protected] 
  1. 2.6 the Company may require the following customer information from a customer in order to facilitate requests and to provide services to the customer:
    1. 2.6.1 name;
    2. 2.6.2 physical/residential address;
    3. 2.6.3 email address;
    4. 2.6.4 Identity/passport details and numbers;
    5. 2.6.5 mobile phone number;
    6. 2.6.6 gender;
    7. 2.6.7 date of birth;
    8. 2.6.8 dietary requirements;
    9. 2.6.9 medical and health information;
    10. 2.6.10 credit card details, including card number, CVV number and expiry date;
    11. 2.6.11 emergency contact details (next of kin), used solely for emergency purposes;
    12. 2.6.12 any and all company information affiliated with the customer i.e. company registration number, company addresses, company contact details and company directors;
    13. 2.6.13 any other information required by us, suppliers and contractors in order to provide customers with accurate assistance;
  1. 2.7 By providing the emergency contact details of a next of kin, the customer, is acknowledging and representing to the Company that the emergency contact has read this policy and consents to the Company dealing with their personal information as set out in this policy.
  1. 2.8 In some instances, it may be necessary for the Company to collect sensitive customer information. Sensitive customer information includes racial or ethnic origin, religious beliefs or affiliations, criminal record and health information (i.e. pregnancy).
  1. 2.9 the Company’s only collects sensitive customer information when it is reasonably required for purposes of delivering the requested services. 
  1. 2.10 By providing sensitive customer information to the Company’s the customer (or allowing another person to do so on the customer’s behalf), is indicating that he/she has read this policy and consents for the Company’s to deal with such customer’s sensitive customer information as set out in this policy.
  1. 2.11 the Company’s has also entered into contracts with third party operators who process customer information and/or supplier information on behalf of the Company’s. In circumstances where a third-party operator may provide services to the Company’s whereby such operators would need to access customer information and/or supplier information, such operators enter into an agreement to uphold the Company’s privacy undertakings as set in this policy.
  1. 3 Why the Company collects that information and how information is used

the Company collects the above information about the customer and/or supplier solely for the following purposes:

  1. 3.1 Providing related products, services and event information to you and to carry out your requests;
  1. 3.2 to fulfil a customer’s particular requests and to enable the Company to invoice the customer for fees payable to the Company and/or the supplier;
  1. 3.3 to improve customer service;
  1. 3.4 to improve the Company’s website (the Company’s strives to improve its website offerings based on the information and feedback received from customers and suppliers); and/or
  1. 3.5 Conduct credit reference search, if needed;
  1. 3.6 Confirming, verifying and updating your details;
  1. 3.7 For the detection and prevention of fraud, crime, money laundering or other malpractice;
  1. 3.8 For audit and record keeping purposes;
  1. 3.9 We also collect and process personal information for marketing purposes to ensure our products and services remain applicable to you and potential customers;
  1. 3.10 to comply with applicable laws;
  1. 3.11 For purpose of this policy, customers (also referred to as you) include potential and existing customers.
  1. 3.12 Section 11 of POPIA prescribes that personal information may only be processes if certain conditions are met which are listed below along with supporting information for processing of personal information:
  1. 3.12.1 Customers consents to the processing – consent is obtained from you during the introductory stage of our relationship either verbally, written or tacitly;
  1. 3.12.2 The processing is necessary – in order to deliver products and services to you, certain personal information is required. Processing is furthermore necessary to conclude a contract between the parties;
  1. 3.12.3 Processing protects a legitimate interest of the data subject – We needs to collect and process personal data in order to provide you with information regarding our required service and products. You will benefit from having their aircraft details updated and in an accessible format as a value-added service from us.
  1. 4 To whom the Company discloses customer information and/or suppliers’ information to
  1. 4.1 the Company’s collects customer information for its own purposes (i.e. to issue a quotation, provide goods and services, etc) and for the suppliers which provide the goods or services to the Company. 
  1. 4.2 By providing customer information to the Company, the customer (or allowing another person to do so on the customer’s behalf), is indicating that he/she has read this policy and consents for the Company sharing customer information with the suppliers to enable service delivery.
  1. 4.3 the Company discloses customer information to its suppliers. the Company’s only discloses certain customer information to the suppliers to enable the supplier to deliver the good and services which the customer has selected and purchased.
  1. 4.4 the Company does not exercise control over the supplier’s privacy policies and each customer should refer to the privacy policy of any such supplier to see how such supplier protects a customer’s privacy.
  1. 4.5 the Company also discloses the suppliers information to customers. the Company only discloses supplier information to the customers to enable the customer to know the details of their goods/services which the customer has selected and purchased.
  1. 4.6 In addition, the Company will only disclose customer information and supplier information if:
  1. 4.6.1 required by applicable law;
  1. 4.6.2 the Company has a public duty to disclose the information;
  1. 4.6.3 the Company’s legitimate interests require disclosure or the customer’s and/or the supplier’s legitimate interests require disclosure; or
  1. 4.6.4 the customer and/or the supplier has agreed that the Company may disclose his/her customer information or supplier information (as the case may be), including but not limited to marketing communications.
  1. 5 Legal bases for processing for EEA users:
  1. 5.1 If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have a legal basis for doing so under the GDPR. The legal basis depends on the Services you use and how you use them. This means we collect and use your information only where:
  1. 5.1.1 We need to provide you the services, including to operate the services, provide customer support and personalised features and to protect the safety and security of the services provided by us;
  2. 5.1.2 It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests;
  3. 5.1.3 You give us consent to do so for a specific purpose; or
  4. 5.1.4 We needs to process your data to comply with a legal obligation.
  1. 5.2 If you have consented to the use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use through, in some cases, this may mean no longer using the Services. 
  1. 6 How long the Company holds customer information and/or supplier information for

the Company retains the customer information and/or supplier information while the services/goods are being provided and/or the account is in existence in respect of a customer, or for the purposes of after sales support, or for as long as is necessary if legally required even after the services are completed and/or  account is fully paid.

  1. 7 How the Company safeguards customer information and suppliers information
  1. 7.1 the Company is dedicated to safeguarding information and as such takes reasonable safety measures to protect customer information and supplier information and prevent the misuse of such information, as supplied to the Company.
  1. 7.2 the Company implements a variety of security measures to maintain the safety of customer and supplier information. the Company offers the use of a secure server. All supplied sensitive information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our payment gateway providers database, only to be accessible by those authorized with special access rights to such systems. Such authorized personnel are required to keep the information confidential.
  1. 7.3 Where the Company provides hyperlinks to any third-party internet websites, such links are not an endorsement by the Company of any products or services in such websites. the Company has not verified the truth or accuracy of any content of such websites. If a customer uses such hyperlinks the customer does so entirely at the customer’s own risk and we accept no responsibility or liability for the content, use or availability of such websites. This website may also contain material provided by third parties and we accept no responsibility or liability for the accuracy of such material.
  1. 7.4 If the customer uses a hyperlink to a third-party website, please note that these websites have their own privacy policies and use of cookies. We do not accept responsibility for customer information provided to a third-party website.
  1. 8 Transfer of customer information and/or suppliers information inside and outside South Africa
  1. 8.1 The customer information and/or supplier information that the Company collects may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who works for the Company or one of the Company’s operators. By submitting customer information to the Company (on this website or otherwise), the customer, hereby consents to the transfer of their customer information both inside and outside the European Union and/or South Africa.
  1. 8.2 Unfortunately, the transmission of information via the Internet is not completely secure. the Company will do its best to protect customer information submitted to it via the website, but cannot guarantee the security of data transmitted to the website; any transmission is at your own risk.
  1. 9 Customers’ and suppliers’ rights to access and correct such information
  1. 9.1 The customer or supplier has a right to request access to their information that the Company holds in respect of such customer or supplier.
  1. 9.2 Should any customer or supplier request access to customer information or supplier information the Company holds in respect of such customer or supplier respectively, or if the customer or supplier wishes to update or correct any of its information held by the Company, the customer or supplier (as the case may be) can contact the Company to update and correct their information themselves by emailing [email protected]
  1. 10 The Cookies policy of the Company
  1. 10.1 the Company reserves the right to use “cookies” when a user visits the website.
  1. 10.2 A “cookie” is a small text file that is downloaded onto an electronic device, when a user of the electronic device accesses a website, such as this website. It allows the website to recognize that user’s device and store some information about the user’s preferences or past actions.
  1. 10.2.1 Transient cookies or site functionality cookies: Such cookies only exist for the duration of the customer’s website visit and are deleted on exit. They recognize customers;
  1. 10.2.2 as a customer moves between pages, for example, these cookies allow customers to navigate the website and use the Company features;
  1. 10.2.3 Persistent cookies: These cookies stay on a customer’s device until they expire or are deleted. These cookies often store and re-enter customer’s login information, so customers don’t need to remember membership details
  1. 10.2.4 Site analytics cookies: These cookies allow the Company to measure and analyze how the Company’s customers use the website, to improve both its functionality and customer experience.
  1. 10.2.5 Targeting or advertising cookies: Such cookies are used to deliver advertisements relevant to customers and/or suppliers. They also limit the number of times that customers and/or suppliers see an advertisement and helps the Company measure the effectiveness of the Company’s marketing campaigns.
  1. 10.3 the Company reserves the right to use cookies for the following purposes:
  1. 10.3.1 store details of customer marketing, customer preferences to enhance customers journey through the website;
  1. 10.3.2 from time to time, the information gathered through this site will be used to notify you about products and services that we think will be of interest to you, unless you inform us in writing that you are not interested in receiving communications in this regard; and
  1. 10.3.3 evaluate the website in respect of advertising and promotional effectiveness.
  1. 10.4 To enable or disable cookies, follow the instructions provided by your browser (usually located within the ‘Help’, ‘Tools’ or ‘Edit’ facility) or contact the Company.
  1. 11 Changes to this policy
  1. 11.1 the Company reserves the right, in its sole discretion, to amend this policy at any time by posting the amended policy on our website. Unless otherwise stated, the current version will apply each time a user accesses our website.
  1. 11.2 Users agree to review this policy whenever users visit the website for any such amendments.
  1. 11.3 Save as expressly provided to the contrary in this policy, the amended version of this policy shall supersede and replace all previous versions thereof.
  1. 12 How to contact the Company

Should a user wish to contact the Company regarding the customer information that it holds in respect of the customer, the way in which customer information is being used, or this policy, please contact the Company at [email protected]jelico.co.za 

Date of Policy:[30/06/2021]

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