Purpose of this policy – 1
Audience – 1
Personal information that we process – 2
We may use your personal information – 2
Collection via website – 2
Collection via mobile device – 4
Disclosure of personal information – 4
Accurate and up to date – 5
Retention of personal information – 5
Security of personal information – 5
Transfer of personal information outside south africa – 5
Updating, removing and opting-out – 5
Limitation – 6
Acceptance of terms – 6
Changes – 6
Enquiries – 6
1. This policy addresses the personal information and privacy issues that affect you. It describes the way we
collect, store, use, and protect information that can be associated with you or your business and that can
be used to identify you (“personal information”).
2. This policy applies to all visitors to our website including coupon users and potential clients/members of our
affiliates or partners (“you” and “your”). If you are a shareholder, employee, supplier or otherwise engaged
in work for us, a separate policy applies to you.
3. The categories and types of personal information that we may collect are:
3.1. When you make an enquiry, visit our premises, visit our website or register and activate a coupon:
3.1.1. your name, surname, address and telephone number that you provide or that is recorded
when you write to us, visit us, email us or call us;
3.1.2. company name, company registration number, and VAT number;
3.1.3. your social media details or related user accounts;
3.1.4. payment details, bank account(s) and credit card number(s).
3.1.5. unique information (such as identity/passport number)
3.1.6. additional information accessed through your interactions with us;
3.1.7. personal data gathered using cookies;
3.1.8. details of your visits to our website, including but not limited to traffic data, location data,
weblogs and other data;
3.1.9. any information necessary to enable Twilight Solutions to provide its services to you.
4. The categories and types of personal information that is excluded from this privacy policy are:
4.1. information that has been made anonymous so that it does not identify a specific person;
4.2. permanently de-identified information that does not relate or cannot be traced back to you
specifically; and
4.3. non-personal statistical information collected and compiled by us and information that you have
provided voluntarily in an open, public environment or forum including (without limitation) any blog,
social media account, chat room, community, classifieds or discussion board. Because the
information has been disclosed in a public forum, it is no longer confidential and does not constitute
personal information subject to protection under this policy.
5. to register and activate your coupon;
6. to send you administrative messages regarding the website via SMS, email, WhatsApp or any other method
of communication on record to you;
7. for marketing purposes, such as e-mails or SMS’ regarding news within Twilight Solutions and new deals,
coupons and services;
8. for targeted content in certain, specified instances directly or via third party service providers;
9. to enforce and collect on any agreement when you are in default or breach of the provisions thereof, such
as instituting legal proceedings against you;
10. to process payment instructions;
11. to comply with regulatory and compliance requirements; and
12. for any other related business purposes which may be deemed beneficial to you.
13. Collection on use
13.1. In order to provide the services to you, you may be asked to provide us with additional information
on a voluntary basis which we may process or refer to our affiliates, such as:
13.2. flight, hotel, card reservations;
13.3. real-time reporting details;
13.4. payment/card details.
14. Optional details
14.1. You may also provide additional information on a voluntary basis such as value-added services or
third-party services provided by our partners or affiliates or any further information you provide to us
(“optional information”). This includes content or products or when you enter competitions, take
advantage of promotions, respond to surveys, sign up and subscribe for certain additional services,
or otherwise use the optional features and functionality of the website.
15. Collection from browser
15.1. We automatically receive and record internet usage information on our server logs from your
browser, such as your Internet Protocol address (“IP address”), browsing habits, click patterns,
version of software installed, system type, screen resolutions, colour capabilities, plug-ins, language
settings, cookie preferences, search engine keywords, JavaScript enablement, the content and
pages that you access on the website, and the dates and times that you visit the website, paths
taken, and time spent on sites and pages within the website (“usage information”). Please note that
other websites visited before entering our website might place personal information within your URL
during a visit to it, and we have no control over such websites. Accordingly, a subsequent website
that collects URL information may log some personal information.
16. Cookies
16.1. When you access our website, we may send one or more cookies (small text files containing a string
of alphanumeric characters) to your computer to collect certain usage information. We use session
cookies (which disappear after you close your browser) and persistent cookies (which remain after
you close your browser and which can be removed manually) and may be used by your browser
on subsequent visits to our website. We use information gathered by cookies to improve the website.
16.2. Please note that some of our affiliates use their own cookies or widgets on our website. We have no
access to or control over them. Information collected by such cookies or widgets are governed by
the privacy policy of the company that created it.
17. Tracking Tools
17.1. Twilight Solutions uses third party tracking tools in order to improve your customer experience.
18. Web beacons
18.1. Our website may contain electronic image requests (called a “single-pixel gif” or “web beacon”
request) that allow us to count page views and to access cookies. Any electronic image viewed as
part of a web page (including an ad banner) can act as a web beacon. Our web beacons do not
collect, gather, monitor or share any of your personal information. We merely use them to compile
anonymous information about our website.
19. Recording calls
19.1. We may monitor and record telephone calls that you make to our switchboard in order for us to
provide various services to you.
20. Purpose for collection of usage information
20.1. We may use any service information and optional information provided by you for such purposes
as indicated to you at the time you agree to provide such service information or optional
information. We may use your usage information for the purposes described above and to:
20.1.1. remember your information so that you will not have to re-enter it during your visit or the
next time you access the website;
20.1.2. monitor website usage metrics such as total number of visitors and pages accessed;
20.1.3. provide any services, which may be useful or beneficial to you; and
20.1.4. track your entries, submissions, and status in any promotions or other activities in
connection with your usage of the website.
21. If you’re using the mobile device, we may collect data that identifies settings and locations.
22. Sharing your information
22.1. We may share your personal information with:
22.1.1. Other divisions or companies within the group of companies to which we belong,
affiliates or service provides so as to provide joint content or services for transactions and
client support, to help detect and prevent potentially illegal acts and violations of our
policies, and to guide decisions about their products, services and communications.
22.1.2. An affiliate, in which case we will seek to require the affiliate to honour this privacy and
personal information policy which is in place purely to protect and service your rights
regarding identity, privacy and personal information in terms of POPIA, PAIA and rights
contained in the Bill of Rights;
22.1.3. Our service providers under contract who help with parts of our business operations
(including fraud prevention, bill collection, marketing, technology services). Our
contracts dictate that these service providers only use your information in connection
with the services they perform for us and not for their own benefit;
22.1.4. Banking partners as required by credit card association rules for inclusion on their list of
terminated merchants (in the event that you utilise the services to receive payments and
you meet their criteria).
23. In the process of various activities recorded in this policy we may receive a fee or compensation from third
parties, and you hereby consent and approve of our engagement in those activities.
24. Regulators:
24.1. We may disclose your personal information as required by law or governmental audit.
25. Law enforcement:
25.1. We may disclose personal information if required:
25.1.1. by a subpoena or court order;
25.1.2. to comply with any law;
25.1.3. to protect the safety of any individual or the general public; and
25.1.4. to prevent violation of our service terms.
26. Marketing purposes:
26.1. We may disclose aggregate statistics (information about the customer population in general terms)
about the personal information to business partners.
27. Employees:
27.1. We may need to disclose personal information to our employees that require the personal
information to do their jobs.
28. Change of ownership:
28.1. If we undergo a change in ownership, or a merger with, acquisition by, or sale of assets to, another
entity, we may assign our rights to the personal information we process to a successor, purchaser,
or separate entity. We will disclose the transfer on the website. If you are concerned about your
personal information migrating to a new owner, you may request us to delete your personal
information.
29. We will try to keep the personal information we collect as accurate, complete, and up to date as is
necessary for the purposes explicitly defined in this policy. From time to time, we will request you to update
your personal information via the website, SMS, or telephone. You are able to review or update any personal
information that we hold on you by emailing or phoning us. Please note that to better protect you and
safeguard your personal information, we take steps to verify your identity before making any corrections to
your personal information.
30. We will only retain your personal information for as long as we determine is necessary to fulfil the purposes
explicitly set out in this policy, unless:
30.1. retention of the record is required or authorised by law; or
30.2. you have consented to the retention of the record.
31. During the period of retention, we will continue to abide by our obligations. Unless explicitly directed
otherwise, your access of our website or use of our services is deemed consent to retain records of the
information outlined in this privacy and personal information policy.
32. We endeavour to protect your information. In this regard you have the following choices:
32.1. You can turn off cookies in your browser; or
32.2. You can opt-out of marketing communications with us by clicking on the unsubscribe link in any
marketing email that has been sent to you.
33. Generally, we use computer safeguards such as firewalls and data encryption to protect personal
information and we enforce physical access controls to our buildings and files. We authorize access to
personal information only for those employees who require it to fulfil their job responsibilities. Our website is
hosted in a secure server environment that uses a firewall and other advanced security measures to prevent
interference or access from outside intruders.
34. We may transmit or transfer personal information outside South Africa to a foreign country. Personal
information may be stored on servers located outside South Africa in a foreign country whose laws
protecting personal information may not be as stringent as the laws in South Africa. You consent to us
processing your personal information in a foreign country whose laws regarding processing of personal
information may be less stringent.
35. You may choose to correct or update the personal information you have submitted to us by contacting us
on the contact details provided on this website.
36. You can choose to opt-out of promotional messages.
37. We are not responsible for, give no warranties, nor make any representations in respect of the privacy
policies or practices of linked or any third-party websites.
38. You must accept all the terms of this policy when you visit our website or sign up for any of our services. If
you do not agree with anything in this policy, then you may not sign up for and use any of the services. You
may not access our website or use our services if you are younger than 18 years old or do not have legal
capacity to conclude legally binding contracts. By accepting this policy, you are deemed to have read,
understood, accepted, and agreed to be bound by all its terms.
39. We may change the terms of this policy at any time. Any changes will be placed in a prominent place on
the website or by email. If you do not agree with the change, you must stop using the services. If you
continue to use the services following notification of a change to the terms, the changed terms will apply
to you, and you will be deemed to have accepted such terms.
40. If you have any questions or concerns arising from this privacy and personal information policy or the way
in which we handle personal information, please contact us at info@twilightsolutions.co.za.