1.1.This privacy policy (“Privacy Policy”) (as read together with the Terms) informs You of the policies of CongoVIP, in respect of the collection, use and disclosure of Your data.
1.2.All capitalized terms used herein shall, unless a contrary intention clearly appears, bear the same meaning given to such term in the Terms.
1.3. This Privacy Policy applies to every individual who accesses, visits or uses the Platform. By accessing, visiting or using the Platform, You accept and consent to the practices as described in this Privacy Policy, which includes without limitation, to consent for us to collect, use and disclose Your data.
1.4. This Privacy Policy should be read together with any other privacy notice or fair processing notice that We may provide on specific occasions when We are collecting or processing personal data. Accordingly, this Privacy Policy supplements the other privacy notices and is not intended to override them.
DATA COLLECTED
2.1. Data You provide us:
2.1.1.When you access or use the Platform, You may directly provide us with personal data which we may collect, such as:
2.1.1.1.Your name, title, e-mail address, username, password, phone number, location address (including proof of address), gender, marital status, place of birth, nationality, employer, job title, language preference, financial data, employment history;
2.1.1.2.Identification numbers issued by governmental bodies or agencies, such as your identity number, passport number, tax identification number;
2.1.1.3.Demographic information such as your address (including proof of address), preferences and interests;
2.1.1.4.Information relevant to the provision of our products and Services;
2.1.1.5.Information relevant to the procurement of products and services from Suppliers;
2.1.1.6.Bank account, billing, income or other financial information;
2.1.1.7.Special or sensitive personal information as defined in applicable data protection legislation; or
2.1.1.8Any other information that You may provide us.
2.1.2.Some examples of this include: creating an account, filling out forms, corresponding with us (e-mail, live-chat or otherwise), participating in events, competitions, promotions or surveys, requesting marketing information to be sent to you; giving us feedback, etc.
2.1.3.You are responsible for ensuring that the personal data that we hold about You is accurate and current. Accordingly, during Your relationship with us, You are required to keep us informed of any changes in respect of Your personal data.
2.2.Data automatically collected:When you access or use the Platform, certain data may be obtained automatically, such as (without limitation): Your IP address, username, password, device and connection information, browsing activity and use of our Platform, other information regarding Your visit on the Platform, cookies and other web technologies.
2.3.Data obtained from other sources:We may receive or collect data about You that is publicly available or available from Your use of any other Platform which is operated by us, our affiliates, partners or third party service providers from time to time.
DATA USE
3.1.We may use Your personal data for various purposes, such as to register You as a Member, provide our Services, news, relevant information, marketing, services, support and communications, respond to comments, live-chats, e-mails.
3.2.Personal data may also be used for purposes of billing and monitoring and analyzing usage, effectiveness, recommendations, suggestions, trends, activities, and for any other purpose for which the information was collected.
3.3.We may also use Your personal data where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Additionally, we may use Your personal data where we need to comply with a legal or regulatory obligation.
3.4.We may also use Your personal data to improve or develop our products and/or Services, and to personalize our products and make recommendations.
3.5.You have the right to opt-out of marketing messages at any time by contacting us.
3.6.We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
3.7.Your personal data may be processed without your knowledge and consent, in compliance with this Privacy Policy, where this is required or permitted by law.
COOKIES
4.1.The Platform uses cookies, which are text files containing unique data sent from a Platform server to a device to allow the Platform to identify each user when they access the Platform.
4.2.The purpose of the use of cookies on the Platform is to distinguish You from other users on the Platform in order to enhance Your experience when visiting the Platform, making the
Platform more user-friendly.
4.3.You may restrict or disable the use of cookies in Your browser settings. However please note that if You do so, You may not be able to access all or some parts of our Platform
(including its functions or services).
4.4.Please note that the Platform uses Google Analytics, as explained below, which in turn may use cookies to better understand user interactions on our Platform.
Please note that the Platform uses a third-party web analysis service provided by Google Inc. (“Google”) known as Google Analytics, which tracks and reports Platform traffic. Certain information (including your IP address) generated by the cookie is transmitted and stored by Google in order to produce reports on, inter alia, Your use of and activity on the Platform. Google may transfer such information to third parties, or as may be required in terms of applicable laws.
DISCLOSURE OF INFORMATION
6.1.We may need to share your personal data with the following:
6.1.1.other companies within the CongoVIP group;
6.1.2.Suppliers, who may provide You with Services;
6.1.3.professional advisors, including but not limited to lawyers, consultants, bankers accountants, auditors, insurers who provide consultancy, banking, legal, insurance, accounting, auditing and other services;
6.1.4.governmental and regulatory authorities, if CongoVIP is legally obliged to do so;
6.1.5.third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, other businesses we may seek to acquire or merge with. Any new owners may use your personal data in accordance with this Privacy Policy.
6.2.Please note that “sharing” may include providing personal data to third parties for personalized advertising purposes.
6.3.The Platform, newsletters and/or events marketing pages may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share your personal information. CongoVIP does not control these third party websites and is not responsible for their privacy policies. When you leave the CongoVIP Platform, we encourage You to read all applicable privacy policies.
DATA SECURITY
7.1.We will take all reasonable precautions to safeguard your personal data and protect your privacy rights.
7.2.We limit access to Your personal data to those employees, agents, contractors and other third parties on a need to know basis. They will only process Your personal data on our instructions and they are subject to a duty of confidentiality.
7.3.We have put in place procedures to deal with any suspected personal data breach and will notify You and any applicable regulator of a breach where we are legally required to do so.
7.4.You indemnify and hold CongoVIP harmless from any loss, damages or injury that You may incur as a result of: (i) any security compromise of personal information to unauthorized persons; or (ii) Your acts or omissions during the provision of personal information to CongoVIP.
DATA RETENTION
8.1.We will only hold your personal data on our systems for as long as we deem it necessary to fulfill the purposes we collected it for, including but not limited to purposes of satisfying any legal, accounting, or reporting requirements.
8.2.In some circumstances we may anonymize Your personal data (so that it can no longer be associated with You) for research or statistical purposes in which case we may use this information indefinitely without further notice to You.
INTERNATIONAL AND TRANSBORDER TRANSFERS
9.1.We may need to share your personal data within the CongoVIP group, which may involve transferring your personal data across national boundaries, including to countries that do not have similar data protection laws to those where the personal data was collected.
9.2.If we transfer your personal data across national boundaries, we will make those transfers in compliance with applicable data protection laws.
YOUR LEGAL RIGHTS
Under certain circumstances, You may have rights under data protection laws in relation to your personal data, including:
10.1.request access – to Your personal data (commonly known as a “data subject access request”), which enables you to receive a copy of the personal data held by us about You;
10.2.request correction – of any incomplete or inaccurate personal data held by us about You, and to have any such personal data corrected. We may need to verify the accuracy of the new data You provide us;
10.3.request erasure – of personal data held by us about You, which allows you to request us to delete or remove your personal data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing your personal data, or where we have processed Your information unlawfully, or where we are required to erase your personal data to comply with applicable laws. Please note that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of request;
10.4.object to processing – of Your personal data, where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground, as you feel that it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. However, in some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
10.5.request restriction of processing – of Your personal data, which enables you to ask us to suspend the processing of your personal data in the following scenarios: (i) if you want us to establish the data’s accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) where you need us to hold the data even if we no longer require it, as you need it to establish, exercise or defend legal claims (provided that we have not already erased such data); or (iv) you have objected to our use of your personal data but we need to verify whether we have an overriding legitimate grounds to use it;
10.6.request to withdraw consent – if CongoVIP is relying on consent to process Your personal data. This does not affect the lawfulness of any processing carried out before you withdraw your consent. Please note that if You withdraw consent, CongoVIP may not be able to provide certain products or Services to You, as determined on a case-by-case basis.
COMPLAINTS
If you are not satisfied with CongoVIP’s use of your personal data or our response to any request by You to exercise your rights, of if You think we have breached any relevant data protection laws, You are encourage to immediately contact us. Should You remain dissatisfied, then You have the right to complain to the authority that supervises our processing of your personal data.
UPDATES TO PRIVACY POLICY
12.1.We reserve the right (but shall not be obliged), at our sole discretion, to modify, change or replace this Privacy Policy and any content contained on the Platform at any time.
12.2.Any such amendment will come into effect when published on the CongoVIP Platform and become part of any agree that you have with CongoVIP. You must ensure that you obtain the latest version of this Privacy Policy before any action is taken based hereon, and it is Your responsibility to check the CongoVIP Platform often
12.3.Your continued access or use of the Platform following any revision to the Privacy Policy shall be deemed to be your acceptance of such revised Privacy Policy, as may be amended or revised, and You provide all consents as stipulated in such revised Privacy Policy.
