Privacy Policy

1. Introduction.
   • We are committed to protecting personal information and this privacy statement describes why and how we collect and use personal information and provides information about your rights in relation to personal information.
   • This Privacy Policy applies to Personal Information provided to us, by participants in our procurement process. We may use personal information provided to us for any of the purposes described in this privacy statement or as otherwise stated at the point of collection.
   • In this privacy statement, we refer to information about you or information that identifies you as “Personal Information” and refer to the handling, collecting, protecting, or storing of you personal information as “processing” such personal information.
   • We process personal information for numerous purposes and we are committed to being transparent about why and how we process personal information.
     
     
2. Personal Information Collected
   • During our engagement with entities in our procurement process we may collect the following information from our suppliers:-
     
     Name, Identity Number, Registration Number, Gender, Contact Details, Addresses, Tax and Vat Reference Numbers, Transaction History With Suppliers, Service Level Agreements, History Of Telephonic Conversations, Formal Communication, Bank Account Numbers, Training and Educational History.
     
     Special Personal Information: Race and Ethnic Origin
     
     
3. Purpose for Processing
   We collect Personal Information from suppliers with the sole purpose of administering, managing and developing our businesses, services, and more specifically our procurement process
   
   
4. Legal Grounds For Processing Personal Information
   • To comply with laws and other measures designed to protect or advance persons, or categories of persons, disadvantaged by unfair discrimination, which forms the basis for our processing personal information relating to race, ethnic origin and gender for example. The Broad-Based Black Economic Empowerment act 53 of 2003 and The Employment Equity act, No. 55 of 1998; and
   • To protect legitimate interest of our suppliers; and
   • To pursue the legitimate interests of Soft-Ice cc; and
   • To carry out actions for the conclusion or performance of a contract to which the supplier is party
   • Processing complies with an obligation imposed by law on the entity including but not limited to the Value Added Tax Act, No. 89 of 1991 and the Income Tax act, No. 58 of 1962
     
     
5. Retention
   Personal Information collected in our procurement process is either retained in Electronic Format or in “Hard Copies”. Hard Copies are retained under the supervision of the entity’s finance department in lockable cabinets or rooms with restricted access. Electronic copies of the Personal information are retained in accordance with our Information Resources Policy.
   
   
6. Destruction 
   Personal Information will be destroyed by the ordinary deletion in the case of electronic records or utilizing shredding or incineration in respect of hard copies.
   
   
7. Further Processing
   Further processing of Personal Information, which is not compatible with the original purpose for which it was collected, shall not be allowed without the Supplier’s consent.
   
   
8. Transfer of Personal Information
   • Cross-border transfers
     Processing of the Personal Information of our suppliers in the procurement process may require the entity to engage in Cross-Border Transfers of Personal Information, which will mostly be limited to cloud storage facilities and online software accounting systems that may be operated from outside the borders of the Republic of South Africa. Soft Ice cc shall however ensure that cross-border processors comply with the general requirements in respect of our third-party Processors Policy.
   • Third-Party Processors
     Soft Ice cc may disclose or transfer the Personal Information we collect/process to third- party contractors, subcontractors and/or their subsidiaries and affiliates, in providing its services in running and manging identity management, payroll systems, website hosting and management, information analysis, remote software, backup, security and cloud storage services.
     
     Third-Party Processors will be obliged to:-
     • Always process the information only with the knowledge or authorization of the Entity; and
     • Treat information which comes to their knowledge as confidential and not disclose it; and
     • Immediately notify the Entity in the event that there are reasonable grounds to believe that the personal information of a supplier has been accessed or acquired by any unauthorized person
       
       Soft Ice CC shall obtain the necessary undertaking/certificate that the Third Party processors will adhere to these requirements, save in the event of third-party that meet international standards of personal information protection such as Google, Dropbox and Microsoft One-Drive.
       
       
9. Disclosure of Personal Information
   We may disclose personal information under the following circumstances:
   • To professional advisors, for example, law firms as necessary to establish, exercise, or defend our legal rights and obtain advice in connection with the running of our business. Personal Information may be shared with these advisors as necessary in connection with the services they have been engaged to provide.
   • When explicitly requested to do so by our suppliers;
   • To law enforcement, regulatory, and other government agencies and professional bodies, as required by and/or in accordance with applicable and regulation. We may also review and use your personal information to determine whether the disclosure is required or permitted.
     
     
10. Processing by Means of Information Technology
    The processing of Personal Information by means of computers, mobile services, networks, and servers are safeguarded in terms of our Information Resources Policy which provides for the creation and maintenance  of backup facilities and procedures, the installation of and regular updating of Anti-Virus and Firewall Software and by subjecting our employees to a stringent Fair Use Policy in respect of our Information Resources.
    
    
11. Processing by Employees
    Soft Ice CC implemented a generally accepted standard of security as far as our employees are concerned through training, a Human Resources Policy, confidentiality agreements, and awareness programs.
    
    
12. Your Legal Rights in Relation to Personal Information
    You are generally entitled to :-
    • Request the entity to confirm , free of charge , whether or not the entity holds any personal information about you; and
    • Request the record or a description of the personal information held by the entity about you; and
    • Request the entity to correct or delete personal information about you in its possession or under its control that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or obtained unlawfully; and
    • Withdraw your consent for processing of your personal information at any time if the processing was dependant on only your initial consent; and
    • Request that personal information be destroyed or deleted, subject thereto that the entity is no longer authorized to retain the information in terms of section 14 of the Protection of Personal Information Act; and
    • Be informed as to the purpose and method of processing your personal information.
    • Restrict the processing of your personal information:-
      • For a period to allow for the verification of the accuracy of such information where you contested the accuracy thereof;
      • If your personal information has been unlawfully processed and your request the restriction of processing instead of deletion;
      • Your personal information is no longer necessary in relation to the purpose for which it was initially collected and processed but the personal information is required by you to establish , exercise, or defend legal claims; or
      • For a period of time in order to grant us the opportunity to verify whether the legitimate grounds relied on by us, take preference over your interests, in the situation where you have objected to processing based on it being necessary for the pursuit of a legitimate interest identified by us.
    • The right to object to the processing of your personal information where:-
      • Processing was based on protecting your legitimate interest
      • The legal justification for processing is necessary for a legitimate interest by us or a third party; or
      • The processing is for direct marketing purposes.

Log  a complaint with the Information Regulator in respect of your personal information , which complaint can be directed at The Information Regulator , JD House, 27 Stiemans Street, Braamfontein, Johannesburg, 2001 or at [email protected]