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Privacy Policy

Version 2. 1 July 2021.

1. Introduction and Scope

Fraser Global Trading (Pty) Ltd respects the right to privacy and is committed to ensuring that personal information remains private and confidential. The purpose of this Privacy Policy is to describe how we collect, use, share and otherwise process the personal information of natural and juristic persons, referred to as data subjects. This Privacy Policy is applicable to customers who purchase our goods and/or employ our services, prospects who express an interest in our goods and/or our services and visitors to our website.

We invite you to carefully read this privacy policy which sets out the rights of data subjects and our legal obligations in terms of the Protection of Personal Information Act, 4 of 2013 (POPIA). If you do not agree with any of the practices set out in this Privacy Policy, please discontinue the use of our website, goods and services. Continued use of our website, goods and services will indicate acceptance of this Privacy Policy and provide consent for processing personal information, to the extent that such consent is required.

2. What personal information is collected?

Personal information is broadly defined in POPIA as “information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person”. This definition encompasses any information that allows for direct or indirect identification of an individual or organisation as the data subject.

2.1. Categories of Personal Information

The personal information that we collect falls into one or more of the following categories:

• Identity information: e.g. Name, identification number, organisation, registration number, job title
• Contact information: e.g. Delivery address, email address, telephone number, facsimile number
• Financial information: e.g. Billing address, payment information, credit references, creditworthiness
• Transaction information: e.g. Purchase and service history, project details, warranty information
• Technical information: e.g. IP address, browser, device, location, links clicked, web pages visited
• Marketing information: e.g. Enquiries, feedback on products/services, communication preferences

2.2. Special Personal Information

Special personal information is defined in POPIA as information relating to an individual's racial or ethnic origin, political or religious beliefs, membership of a trade union, criminal record, health, sexual orientation or preferences or biometrics. In certain circumstances we may be required to collect special personal information, such as body temperature and symptoms, in accordance with COVID-19 screening measures.

2.3. Public Information

Personal information shared in posts or comments on blogs, social media platforms and other public forums is not governed by this Privacy Policy. Once personal information is made publicly available, we cannot control whether it is read, collected or used by third-party organisations or individuals. Any information, correspondence, or files disclosed in the public domain is done at the data subject’s own risk, without any expectation of privacy.

2.4. Anonymised Information

The anonymised information that we collect from visitors to our website for statistical purposes does not constitute personal information in POPIA. It includes internet protocol (IP) address, device type, device model, browser type, browser version, location, language, pages visited, time and date of visit. It is derived from personal information but has been permanently “de-identified” so that it cannot be associated with a specific data subject.

3. How is personal information collected?

We obtain personal information from various sources depending on the context of our relationship or interaction with an individual or organisation. Personal information may be collected through direct interaction with data subjects, using automated tracking technologies and from third parties.

3.1. Sources of Personal Information

The personal information that we collect is obtained from one or more of the following sources:

• Enquiry, download and subscription forms submitted through our website
• Correspondence and files sent via email, messenger services or social media
• Telephonic consultations and online or in-person meetings with representatives
• Purchase orders, credit or operating lease applications and rental agreements
• Technical drawings, project checklists, production quality control logs, warranties
• Machinery installation checklists, completed job cards, operator training sessions
• Electronic or other enquiries referred to us from principal suppliers or customers
• Attendance records for trade shows, conferences, golf days and other events
• Subscriber open and click reports for email campaigns sent using Mailchimp
• Reports on website activity and paid search campaigns generated by Google

3.2. Cookies and Tracking Technologies

Cookies are small text files that are automatically sent to a computer or mobile device when a website is visited. We use cookies to record whether messages have been seen, store personal preferences, track website activity and display relevant online advertisements. Browser settings can be adjusted to refuse all cookies or to indicate when a cookie is being sent. However, if cookies are disabled, the functionality of our website may be affected.

Electronic image requests, also called single-pixel gifs or web beacon requests, are automatically placed in our email campaigns. We use web beacon requests to determine whether contacts on our mailing list have received and opened emails and whether links in the email have been clicked. In order to disable web beacon requests, email settings can be adjusted to disable HTML images or to display HTML emails in plain text format. Please note that this will affect the viewing of all images within HTML emails.

4. How is personal information used?

We process personal information on the legal basis of either (a) performing a contract to which the data subject is party, (b) protecting the legitimate interests of the data subject, (c) obtaining prior consent from the data subject, (d) pursuing our legitimate business interests or (e) complying with obligations imposed by the law or authorities.

Data subjects will be informed, prior to collection or as soon as reasonably practicable after collection, of the purposes for which personal information is collected and whether provision of personal information is mandatory or voluntary. Personal information will be processed for the purpose for which it is collected unless otherwise specified or permitted by the law.

4.1. Purposes for Collection

The personal information that we collect is processed for one or more of the following purposes:

• Responding to enquiries and requests for quotations, information or marketing literature
• Developing customised solutions or packages for specific production or project requirements
• Entering into contracts or fulfilling our contractual obligations to provide products and services
• Processing orders, administering customer accounts and credit facilities and maintaining records
• Complying with legal or regulatory obligations such as preventing fraud, conducting audits etc.
• Provision of technical services/support including consultations, training, installations and repairs
• Sending administrative notices regarding stock takes, price increases, service interruptions etc.
• Sending communications such as updates, information and special offers on products and services
• Evaluating and improving our products, services, customer experience, website and promotions

4.2. Objections and Opting Out

Data subjects are entitled to withhold or withdraw their consent for the processing of personal information at any time, subject to the applicable limitations and exceptions. If failure to collect or process the required information prevents us from complying with our contractual or legal obligations, we reserve the right to discontinue our relationship or interaction with the data subject in question.

Data subjects who receive electronic marketing communications may opt-out at any time by clicking the “unsubscribe” link in emails or by submitting an opt-out request using the email address provided in the “Questions and Concerns” section below. Please note that communications relating to orders and billing are considered transactional and necessary for administering customer accounts, therefore customers cannot opt-out of these.

5. Is personal information shared with third parties?

Personal information will not be sold to third parties or disclosed except as outlined in this Privacy Policy.

5.1. Employees and Partners

In the course of our operations, it will be necessary for us to disclose personal information to employees in management, accounting, sales, marketing and technical positions in order to perform certain tasks. It will also be necessary to disclose personal information to third parties such as our goods suppliers and service providers to administer transportation, marketing, support, administration, auditing or information technology (IT) services on our behalf.

5.2. International Transfers

Due to the nature of our activities, personal information that we receive is processed at our offices in the Republic of South Africa and transferred to third parties located within the country as well as in Britain, the European Union, the Middle East and the United States of America. Data protection laws may differ in these regions but we will always ensure that the information is adequately protected and processed in accordance with this Privacy Policy.

5.3. Law Enforcement

In certain circumstances, disclosure of personal information to government officials, law enforcement officials or private parties may be required in response to legal requests, including search warrants, court orders or subpoenas. We may disclose personal information in order to (a) comply with the applicable law or regulation, (b) prevent or stop illegal or unethical activities from occurring or (c) protect the legal rights of an individual or organisation.

5.4. Third-Party Websites

We may provide hyperlinks to third-party websites including those of our goods suppliers, service providers, industry associations and social media platforms. Third-party websites are not governed by this Privacy Policy as we have no control over the content, data processing methods or privacy policies and cannot accept any responsibility for their use. We strongly advise that data subjects review the privacy policies of each website visited before submitting any personal information.

6. How long is personal information stored?

We will retain personal information for the minimum period necessary to fulfil the purposes set out in this Privacy Policy. Personal information is retained for as long as there is a legitimate business need to do so, unless a longer retention period is required by law i.e., for historical reference and tax purposes. Once the applicable retention period has ended, hard copies will be destroyed and soft copies will be deleted or removed from our databases.

7. How is personal information protected?

7.1. Security Safeguards

Taking into account the risks involved in processing personal information, we implement and maintain appropriate technical and organisational measures to protect against loss, damage, misuse and unintentional or unlawful alteration, destruction or disclosure. We store personal information in a manner that protects it from unauthorised access or interference by third parties. Our security safeguards include password protection, access control, network security systems, regular data back-ups, staff training and non-disclosure and confidentiality agreements.

7.2. Encryption of Data

We strive to protect personal information submitted via online forms using Secure Sockets Layer (SSL) certificates installed on the web server. The “https” in our web address and the padlock icon in the address bar indicate that a secure connection to our website has been established. However, no method of transmission via the internet is completely secure and we cannot ensure or warrant the security of personal information transferred online.

7.3. Security Breaches

In the event that we suspect or are informed of a security breach which compromises the integrity or confidentiality of personal information, it will be reported to the relevant regulatory authority. Data subjects whose personal information is involved in the breach will be notified and afforded the opportunity to put measures in place that provide protection against the potential consequences.

8. What rights do data subjects have?

Under POPIA data subjects have the following legal rights relating to the processing of personal information:

• The right to be informed what personal information is collected and the purpose for which it is collected
• The right to access personal information that has been collected and to be provided with a copy thereof
• The right to request that inaccurate or incomplete personal information on file be corrected or updated
• The right to be forgotten i.e., the right to request that personal information on file be deleted or destroyed
• The right to object to or restrict the processing of personal information for a particular purpose or purposes
• The right not to be subject to automated decision-making based on automated processing or profiling
• The right to be notified if personal information is accessed or acquired by an unauthorised party
• The right to lodge a complaint with the data protection authority regarding privacy concerns

9. Questions and Concerns

Should you have questions or concerns regarding this Privacy Policy, the processing of your personal information or your legal rights, please contact our Information Officer by sending an email to marketing@fgtrading.co.za or phoning +27 (0) 11 450 0263. If data subjects would like to access the personal information that we have on file they are entitled to do so by making a “subject access request”. In order to safeguard personal information please note that you will be required to verify your identity before access is granted. Requests can be made free of charge but administrative fees will be applicable for substantial and/or excessive requests.

10. Changes to This Privacy Policy

FG Trading reserves the right to amend this Privacy Policy in accordance with changes in legislation and technological or organisational developments which may affect how we process Personal Information. Any amendments will be published here with the effective date indicated at the top of the page. We recommend that you visit our website periodically to review the latest version of the policy.