PRIVACY AND PROTECTION OF PERSONAL INFORMATION POLICY
Last updated April 2019
This Privacy and Protection of Personal Information Policy sets out the manner in which Thumbtribe complies with
data protection legislation such as the Protection of Personal Information Act of 2013 (POPIA), with specific
Your rights in respect of your personal information and how you can exercise these.
Personal information collected by Thumbtribe.
The manner in which this information is handled and stored.
Circumstances in which your personal information will be shared with third parties.
Deletion of personal information.
If you have any questions about this Policy or the way in which your personal information is handled and
processed, please contact us by sending email to firstname.lastname@example.org
Note that provision of services may require that you use a third-party website, platform or application which
will have its own applicable policy relating to the protection of personal information, which you should always
Please also note that – in addition to this Policy – specific products and services may have further terms and
conditions which you will be required to review and consent to.
Collection of personal information
Personal information can be generally defined as information that can be directly or indirectly used to identify
an individual, whether it is collected online or offline.
When we collect and use your personal data we will inform you beforehand (for example, through this policy) and,
where appropriate, request your consent in respect of more sensitive forms of personal information.
Where appropriate, we will ask for your consent to process the personal data. Where you have given consent for
processing activities, you have the right to withdraw your consent at any time.
Thumbtribe collects personal information for the purpose of offering the services and products it and its
partners make available to consumers in South Africa. Personal information is collected where:
You provide it to us through your usage of our products and services and when you sign up for a product
or service or otherwise interact with us or our products and services. This could include your name,
contact details and credit card information.
technologies. This could include your Internet Protocol (IP) address, browser version, location, device
ID, your history of interaction with the product or service and information required for fraud
prevention and the maintenance of a product or service. Cookies tell us which parts of our websites you
visited, help us measure the effectiveness of ads and web searches, and give us insights into user
behaviour, so that we can improve our communications and products.
It is lawfully sourced from a third party, such as where an item is “liked” on a third-party platform,
where our services are offered jointly with a third party or where you interact with our advertising on
a third-party site or platform.
Personal information may also be used for the purpose of marketing these services and products, based on site,
platform or application usage and combined with other information in order to maintain and improve our services
How do we use personal information?
We collect, process and share personal information for the specific and limited purpose of providing our
products and services as well as marketing these. This may include:
Facilitating ordering and distribution of products and services;
Building and maintaining customer profiles based on usage and personal information collected;
Complaints handling; and
Provision of targeted marketing, communications, products and services.
Additionally, Unilever processes your personal data also using automated means. An automated decision is a
decision which is made solely by automatic means, where no humans are involved in the decision-making process
related to your personal data.
Sharing of personal information
Thumbtribe will only share personal information with third-party service providers where sharing of personal
information is required to provide our products and services – including marketing of products and services -
subject to such service providers agreeing to be bound by POPIA and to process this personal information in
accordance with this Policy.
We will also share personal information to comply with a legal obligation or where we believe disclosure is
required by applicable law.
Where personal information is transferred outside of South Africa for processing this will only be done where
data protection in the relevant country is at least of an equivalent level to that offered in South Africa and
subject to the recipient agreeing to process personal information in accordance with this Policy.
Security of personal information
Thumbtribe utilises industry-standard security measures and processes to ensure that personal information stored
by it is secure and its integrity maintained.
Deletion of personal information
We will keep your personal data for as long as we need it for the purpose it is being processed for. For
example, where you make a purchase online with us we will keep the data related to your purchase, so we can
perform the specific contract you have entered and after that, we will keep the personal data for a period which
enables us to handle or respond to any complaints, queries or concerns relating to the purchase.
Your data may also be retained so that we can continue to improve your experience with us and to ensure that you
receive any loyalty rewards which are due to you.
We retain the identifiable data we collect directly for targeting purposes for as little time as possible, after
which we employ measures to permanently delete it.
We will actively review the personal data we hold and delete it securely, or in some cases anonymise it, when
there is no longer a legal, business or consumer need for it to be retained.
the IP address from which you access the site
the type of browser and operating system used to access the site
the date and time of your access to the site
the pages you visit
the address of the website from which you accessed the sites.
Cookies are small text files that our server sends to the user’s browser when the user visits the site.
You can delete cookies at any time or you can set your browser to reject or disable cookies. If you choose to
disable cookies certain functions on the site may not work correctly.
from cookies to personalise content and ads, to provide social media features and to analyse the browsing habits
of visitors to our site, including the number of visitors, what sort of content is popular, and the technology
When a user revisits the site, we may recognise the user by the cookie and customise the user’s experience
We share information about your use of our site with our social media, advertising and analytics partners who
may combine it with other information that you’ve provided to them or that they’ve collected from your use of
Review of this Policy
This Policy will be reviewed from time to time. Any amendments made will be brought to your attention so that
you can review these.