At hoola modern Agency, including our trading divisions, hoola modern and hoola social, we are committed to safeguarding the privacy of your personal information and data.
51, 6th Avenue
Who does this policy apply to?
This Policy applies to all data subjects (persons, whether a natural or juristic person, to whom personal information relates) (“you”, “your”), who’s personal information we collect, regardless of the country where you live or work.
What does this policy cover?
This policy describes how hoola modern Agency which owns and operates hoola modern and hoola social (collectively referred to as “we”, “our” or “us”) will make use of your data on the hoola modern Agency websites and during your interaction with hoola modern Agency online and offline, including the completion of a survey for hoola modern Agency, data we may process in connection with the running of competitions or online games, data we may process if you attend our events, data we may handle if you supply or partner with hoola modern Agency or data we use to send you direct marketing.
It also describes your data protection rights, including a right to object to some of the processing which hoola modern Agency carries out. More information about your rights, and how to exercise them, is set out in the “What rights do I have?” section.
Summary of how we use your data
• We use your personal data to allow you to use the features in our content, to administer your online and offline relationships with us, to manage the safety and security of our events, to comply with hoola modern Agency’s legal obligations and to provide you with our news and developments. Some of this information will be provided by you, and others will be generated by hoola modern Agency or provided by third parties.
• Our websites may provide interactive features that engage with social media sites, such as but not limited to, Facebook and Twitter. If you use these features, these sites will send us personal data about you.
• Where we rely on your consent, such as for direct marketing purposes, or to place cookies, you can withdraw this consent at any time.
What information do we collect?
We collect and process personal data about you when you interact with us and our websites, when we carry out market research and when you enter our competitions or participate in our online games. This data will typically be provided directly by you and may include information you provide on registration or in the process of a purchase, such as your name, address, email address, and marketing preferences. The details being provided by you will be made clear in forms you complete or will be provided directly by you in surveys, in entering competitions or in volunteering information in communications or content you provide us.
What information do we generate or receive from third parties?
We may generate or collect information about you ourselves. In an online context, much of this is set out in our Cookies Policy. In an offline context, we may particularly collect information about you where you are an employee of a supplier, stakeholder or other entity with whom we communicate, or where you attend an event organised by hoola modern Agency. Sometimes, we receive information about you from third parties. For example, if you login to a site or app using Facebook Connect you will be asked if you wish to share information from your Facebook account with us. If you use a “like” or a “share” button for a feature on our sites or apps, then the third party will share information with us. If you participate in activities on non-hoola modern Agency sites or apps – such as participating in a Facebook application – you may allow us to have access to personal data held by Facebook, or other site or app owners.
We sometimes will receive relevant information from third party sites. We may also obtain information about you from third party demographics providers, which we may use to help us better understand our users and send them appropriate offers and information.
If we provide online services to a child where we need parental consent for this, we may ask for a parent’s email address, in order to ask for consent. Where you are participating in a hoola modern Agency event or competition, we may receive information about you from another team member or official responsible for entering you or your team into our competition. This will typically involve, but is not limited to, basic biographical information, including your contact email address.
How do we use this information, and what is the legal basis for this use?
We process this personal data for the following purposes:
• To fulfil a contract, or take steps linked to a contract: this is relevant where you make a purchase from us or enter a competition or online game we run. This includes:
o verifying your identity;
o receiving confirmation of payment (where relevant);
o communicating with you;
o administering the competition (where relevant); and
o providing customer services and arranging the delivery or other provision of products, prizes or services. (where relevant)
• As required by hoola modern Agency to conduct our business and pursue our legitimate interests, in particular:
o we will use your information to provide products and services you have requested and to respond to any comments or complaints you may send us;
o we monitor use of our websites and online services, and use your information to help us monitor, improve and protect our content, services and websites, both online and offline;
o we use information you provide to personalise our website, games, or services for you;
o we process data you provide when you enter into a hoola modern Agency event or competition so that we can administer that competition, communicate with you and ensure eligibility. If this involves sensitive personal data, such as information about disability used to ensure eligibility for a disabled competition, we do this to ensure the integrity of our competition; o we use information you provide as well as information which we have collected about you to investigate any complaints received from you or from others, about our website and competition venues or our products or services;
o we will use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation); and
o we use data of some individuals to invite them to take part in market research.
• Where you give us consent:
o we will send you direct marketing in relation to our relevant products and services, or other products and services provided by us and carefully selected partners and sponsors;
o we place cookies and use similar technologies in accordance with our Cookies Policy (see below) and the information provided to you when those technologies are used; and
o on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.
• For purposes which are required by law:
o where we are required to hold or collect personal data to meet legal requirements on us.
o where we need parental consent to provide online services to children under 16. However, most of our websites are not designed for children under 16 and most of our services do not require consent; and
o where in response to requests by government or law enforcement authorities conducting an investigation.
Withdrawing consent or otherwise objecting to direct marketing
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.
What cookies and/or tracking technologies does hoola modern Agency?
When you visit one of our websites, we may also collect, process and use information about you and your use of the website, including any forums you visit and how you arrived at our site. Such information may be collected through “traffic data” and may entail the use of “cookies” or other tracking technologies, IP addresses or other numeric codes used to identify your computer. For more information on Cookies please click on the link to our Cookies Policy [see below].
Apple iOS and Android Devices
By accessing a hoola modern Agency application from these devices you consent to cookies being stored to your device (and other tracking technologies being used to read data from your device) for the following purposes: keeping you logged in, ensuring that an appropriate version of content is presented, analytics and advertising. Many of these cookies and technologies are essential to the operation of the application. It is not currently possible to opt out or remove these cookies (or prevent use of these technologies) from the device without deleting the application.
Who will we share this data with, where and when?
We will share appropriate data with third party providers as necessary to manage our processes.
Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.
Personal data will also be shared with third party service providers, who will process it on behalf of hoola modern Agency for the purposes identified above. Such third parties include providers of website hosting, security services, maintenance, call centre operations and identity checking. Some of our suppliers may be separate data controllers, such as market research organisations, and may provide you with their own privacy notice where appropriate.
What rights do I have?
You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format.
In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where it would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and in the Data Protection Act 2018. We will inform you of relevant exemptions we rely upon when responding to any request you make.
To exercise any of these rights, you can get in touch with us – or our data protection officer – using the details set out below. If you have unresolved concerns, you have the right to complain to a data protection authority where you live, work or where you believe a breach may have occurred. This likely to be the Information Regulators Office in South Africa. Data that is mandatory is indicated on relevant forms that you complete. Where provision of data is mandatory, if relevant data is not provided, then we will not be able to fulfil your requests to register, make a purchase or otherwise engage with Mandela Bay Development Agency. All other provision of your information is optional.
How do I get in touch with you, or your data protection officer?
We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch at firstname.lastname@example.org or by writing to: hoola modern Agency , 51, 6th Avenue, Walmer, Port Elizabeth, 6065
How long will you retain my data?
Where we process data in connection with your registration to use hoola modern Agency sites, we do this for as long as you are an active user of our sites. Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future. Where we process personal data in connection with performing a contract, online game or for a competition, we keep the data for 7 years from your last interaction with us or from when the contract ends.
What is a Cookie?
Information may be sent to your computer in the form of an Internet “cookie” to allow our servers to monitor your requirements. The cookie is stored on your computer. Our server may request that your computer return a cookie to it.
These return cookies do not contain any information supplied by you or any personally identifiable information about you.
Such measures are necessary to allow hoola modern Agency to measure the usability of the systems, which will help to continually improve user experience of our websites. Your browser software should however enable you to block cookies if you wish to. For more information about cookies, please visit http://www.allaboutcookies.org/.
Strictly Necessary Cookies
These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for, like shopping baskets or e-billing, cannot be provided.
These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.
These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide you with local weather reports or traffic news by storing in a cookie the region in which you are currently located.
These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
Targeting or Advertising Cookies
These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
hoola modern Agency uses Google Analytics, a web analytics service provided by Google. Google Analytics collects first party cookies, which are text files placed on your computer to collect standard internet log information and visitor behaviour. This information is sent to Google and is used to evaluate how our website is being used. This enables us to more accurately engage in remarketing, report on demographics and interests as well as any other statistical purposes.
Google Display Network Impression Reporting
Integrated services that require Google Analytics to collect data for advertising purposes, including the collection of data via advertising cookies and identifiers. A full list of cookies used by Google Analytics and explanations on how these work are available on the Google code website.
How to disable cookies
You can stop cookies being downloaded on to your computer by selecting the appropriate settings on your browser. However please note that if you do this you may not be able to use the full functionality of this website.
There is more information about cookies, including how to delete them on the website aboutcookies.org. You may also opt out of being tracked by Google Analytics.