Who we are
Our website address is: https://ajsglobal.com
PROTECTION OF PERSONAL INFORMATION ACT – POLICY DOCUMENT
- COLLECTION OF INFORMATION
1.1. As part of your interactions with SAJ Accounting Software Dealer Namibia (Pty) Ltd (referred to as “AJS”), AJS collects various data from you, both by you providing it directly, and automatically from, amongst other things, browsing AJS’s website. Your personal information may also be collected by AJS’s affiliated companies (collectively the “Group Companies”). This Policy Document explains how AJS and the Group Companies collect your data and what they can and cannot do with such information.
1.2. Personal information
1.2.1. Personal information includes:
18.104.22.168. certain information that AJS and the Group Companies collect automatically when you visit our website;
22.214.171.124. certain information collected on registration (see below);
126.96.36.199. certain information collected on submission; and
188.8.131.52. optional information that you provide to AJS and/or the Group Companies voluntarily (see below);
184.108.40.206. information that has been made anonymous so that it does not identify a specific person;
220.127.116.11. permanently de-identified information that does not relate or cannot be traced back to you specifically;
18.104.22.168. non-personal statistical information collected and compiled by AJS and/or the Group Companies; and
22.214.171.124. information that you have provided voluntarily in an open, public environment or forum including any blog, 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).
1.2.2. Sensitive personal information
Depending on the services required, AJS and the Group Companies may also collect sensitive personal information including your:
126.96.36.199. financial information – such as your bank account details;
188.8.131.52. biometric information – such as images of your face or fingerprints; and
184.108.40.206. historical conduct –such as payment defaults and credit bureau listings.
1.3. From Browsers
1.4.1. AJS and the Group Companies may place small text files called ‘cookies’ on your device when you visit this website. These files do not contain personal information, but they do contain a personal identifier allowing AJS and the Group Companies to associate your personal information with a certain device. These files serve a number of useful purposes for you, including:
220.127.116.11. granting you access to age restricted content;
18.104.22.168. tailoring our website’s functionality to you personally by allowing your preferences to be remembered;
22.214.171.124. improving how our website performs;
126.96.36.199. allowing third parties to provide services to our website; and
188.8.131.52. helping us deliver targeted advertising where appropriate in compliance with the applicable laws.
1.4.2. Your internet browser generally accepts cookies automatically, but you can often change this setting to stop accepting them. You can also delete cookies manually. However, no longer accepting cookies or deleting them will prevent you from accessing certain aspects of our website where cookies are necessary.
1.5. Third Party Cookies
1.6. Optional Details
You may also provide additional information to AJS and the Group Companies on a voluntary basis (optional information). This includes content or products that you decide to upload or download from our website or when you respond to surveys, order certain additional services, or otherwise use the optional features and functionality of our website.
1.7. Purpose of Collection
1.7.1. AJS and/or the Group Companies may use or process any services information, or optional information that you provide to them for the purposes that you indicated when you agreed to provide it to AJS and/or the Group Companies. Processing includes gathering your personal information, disclosing it, and combining it with other personal information. AJS and the Group Companies generally collect and process your personal information for various purposes, including:
184.108.40.206. services purposes – such as requests for and providing our services;
220.127.116.11. marketing purposes – such as pursuing lawful related marketing activities;
18.104.22.168. business purposes – such as internal audit, accounting, business planning, and joint ventures, disposals of business, other proposed and actual transactions as well the selling of personal information to third-parties in order to enable offerings of related products and services; and
22.214.171.124. legal purposes – such as handling claims, complying with regulations, or pursuing good governance.
1.7.2. We may use your usage information for the purposes described above and to:
126.96.36.199. remember your information so that you will not have to re-enter it during your visit or the next time you access our website;
188.8.131.52. monitor website usage metrics such as total number of visitors and pages accessed; and
184.108.40.206. track your entries, submissions, and status in any promotions or other activities in connection with your usage of the website.
1.8. Consent to Collection
1.8.1. We will obtain your consent to collect personal information:
220.127.116.11. in accordance with applicable law;
18.104.22.168. when you provide AJS and/or the Group Companies with any registration information or optional information voluntarily.
1.8.2. To the extent that you object to AJS and/or either of the Group Companies processing your personal information, you can request that we no longer process your personal information by completing Form 1 of the regulations relating to the Protection of Personal Information Act 4 of 2013 (as amended) and submitting your form to us via email, alternatively by accessing your account online (if applicable), emailing us, or phoning us, notifying AJS and/or the Group Companies of your objection.
AJS and the Group Companies may use your personal information to fulfil our obligations and to provide services to you.
AJS and the Group Companies may share your personal information with:
3.1.1. other divisions or companies within the group of companies to which AJS or the Group Companies belong so as to provide joint content and services like registration, for transactions and customer support, to help detect and prevent potentially illegal acts and violations of its policies, and to guide decisions about its products, services, and communications (such divisions or companies will only use this information to send you marketing communications if you have requested their services);
3.1.3. AJS and the Group Companies’ service providers under contract who help provide certain services or 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 supply or services they perform for us and not for their own benefit);
3.1.4. credit bureaus to report account information, as permitted by law;
3.1.5. 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); and
3.1.6. other third parties who provide us with relevant services where appropriate.
We may disclose your personal information as required by law or governmental audit.
3.3. Law enforcement
We may disclose personal information if required:
3.3.1. by a subpoena or court order;
3.3.2. to comply with any law;
3.3.3. to protect the safety of any individual or the general public; and
3.3.4. to prevent violation of our customer relationship terms.
3.4. No selling
We will not sell personal information for purposes other than those related to the services which we provide. No personal information will be disclosed to any person, save for any third-party with whom we contract for the purposes of providing products and/or services related to the services provided by AJS and/or the Group Companies, as contemplated in this policy. We will only disclose personal information collected by AJS and the Group Companies during the ordinary course of their business and any third-party will provide similar products and services in the ordinary course of its business, which products and services are closely related.
3.5. Marketing purposes
We may disclose aggregate statistics (information about the customer population in general terms) about the personal information to advertisers or business partners.
AJS and the Group Companies will need to disclose personal information to their employees that require the personal information to do their jobs. These may include their responsible management, human resources, accounting, audit, compliance, information technology, or other personnel.
3.7. Change of ownership
If AJS or either of the Group Companies undergoes a change in ownership, or a merger with, acquisition by, or sale of assets to, another entity, AJS or either of the Group Companies may assign their rights to the personal information it processes to a successor, purchaser, or separate entity. AJS or either of the Group Companies will disclose the transfer on their website. If you are concerned about your personal information migrating to a new owner, you may request AJS or either of the Group Companies to delete your personal information.
We adhere to strict security protocols in respect of data protection laws. Our website and servers are hosted in a secure server environment that uses a firewall in addition to other advanced security measures aimed to prevent any interference or access from unwarranted outside third parties.
Access to any personal information is only authorised for employees who require such information in order to fulfil their employment responsibilities.
- ACCURACY OF INFORMATION
5.1. We aim to ensure that all personal information collected is accurate, complete and up to date as is necessary for the purposes defined in this policy. In order to maintain accurate information, AJS and/or either of the Group Companies may request that you update your information on our website.
5.2. Updating Information
You are able to review and update any personal information that may be held by us by accessing your account online (if applicable), emailing us, or phoning us, alternatively by completing Form 2 of the regulations relating to the Protection of Personal Information Act 4 of 2013 (as amended) and submitting the completed form to us via email. The identity of any person wishing to update any information is required to be verified prior to the granting of any access to the respective person’s account or making any changes to any personal information.
- RETENTION OF INFORMATION
6.1. Period of Retention
We will retain personal information for as long as we deem it necessary to do so in order to perform services in the ordinary course of our business, and for as long as retention of the record is required or authorised by law.
During the period of retention, AJS and the Group Companies will continue to abide by all their obligations stipulated in this policy.
6.3. AJS and the Group Companies reserve the right to retain information in physical or electronic records at their discretion.
- TRANSFER OF INFORMATION
We undertake not to transfer any personal information across any country border without prior written consent.
Access to Information Manual
We respect your right of access to information. This document will help you exercise that right as required by section 51 of the Promotion to Access of Information Act 2 of 2000 (“PAIA”).
ACJUSA (Pty) Ltd and AJS South Africa, together with their group companies are the South African distributors for AJS Global Software Products, offering a variety of trusted software applications and software licenses for legal and corporate markets, including but not limited to accounting and bookkeeping management services, collection management solutions and products such as document automation. This is our ‘Access To Information Manual’. Its purpose is to help you access our information and any other information that we have.
PAIA requires us to make it available to you so that you:
• know what types of information we have; and
• can request access to it.
- Our details
Our details are as follows:
• Entity name: SAJ Accounting Software Dealer Namibia (Pty) Ltd
• Registration number: 2020/0440
• Physical address: 11B General Murtala, Muhammed Avenue, Eros, Windhoek, Namibia
• Information officer: Francois Horn
• Information officer email: email@example.com
• Contact email: firstname.lastname@example.org
• Website: www.ajsglobal.com
- Further guidance
If you would like further guidance on how you can get access to information under PAIA, you may contact the South African Human Rights Commission (“SAHRC”) to find out more information about PAIA. They have a guide in each official language of South Africa on how to exercise any right under PAIA. Their contact details are as follows:
• Phone number: 011 877 3825
• Fax number: 011 403 0625
• Postal address: Private Bag X2700, Houghton, 2041
• Physical address: Braampark Forum 3, 33 Hoofd Street, Braamfontein, Johannesburg
• Website: http://www.sahrc.org.za/index.php/understanding-paia
- Records we hold
We hold the following subjects and categories of records:
• Company records;
• Business records;
• Financial records;
• Insurance records;
• Personnel records;
• Policies and directives;
• Agreements or contracts;
• Regulatory documents;
• Published information;
• Customer information; and
• Reference materials.
4.1. Company records
Company records are all our records related to the incorporation and administration of our company. Some of them are available from the Companies and Intellectual Property Commission (CIPC).
• Memorandum of Incorporation – Automatically available from CIPC
• Directors’ names – Automatically available from CIPC
• Documents of incorporation – Automatically available from CIPC
• Minutes of board of directors’ meetings – Not automatically available
• Written resolutions – Not automatically available
• Records relating to appointment of directors, auditor, secretary, public officer, or other officers – Not automatically available
• Share register and other statutory registers – Not automatically available
• Other statutory records – Not automatically available
4.2. Business records
Business records include any documents that have economic value to the business.
• Operational records – Not automatically available
• Databases – Not automatically available
• Internal correspondence – Not automatically available
• Product records – Not automatically available
4.3. Financial records
Financial records are all our records related to our finances.
• Financial statements – Not automatically available (NDA required)
• Tax returns – Not automatically available
• Other documents relating to taxation of the company – Not automatically available
• Accounting records – Not automatically available
• Banking records – Not automatically available
• Banking details – Automatically available on request
• Banking details – Not automatically available
• Electronic banking records – Not automatically available
• Paid cheques – Not automatically available
• Asset register – Not automatically available
• Rental agreements – Not automatically available
• Invoices – Not automatically available
• Financial agreements – Not automatically available
4.4. Insurance records
Insurance records are all our records related to our insurable assets.
• Insurance policies held by the company – Not automatically available
• Register of all immovable property owned by the company – Not automatically available
4.5. Income tax records
Income tax records are all our records related to our income tax obligations.
• PAYE Records – Not automatically available
• Corporate tax records – Not automatically available
• Documents issued to employees for income tax purposes – Not automatically available
• Records of payments made to SARS on behalf of employees- Not automatically available
• VAT records – Not automatically available
• Regional Services Levies – Not automatically available
• Skills Development Levies – Not automatically available
• UIF – Not automatically available
• Workmen’s Compensation – Not automatically available
4.6. Personnel records
Personnel records are all our records about anyone who works for us, provides services to us, or provides services on our behalf and who receives or is entitled to receive remuneration, including our employees, contractors, and other personnel.
• List of employees – Not automatically available
• Employee personal information – Not automatically available
• Employee employment contracts – Not automatically available
• Employment policies and procedures – Not automatically available
• Employment Equity Plan – Not automatically available
• Medical aid records – Not automatically available
• Pension and provident fund records – Not automatically available
• Salaries of employees – Not automatically available
• Leave records – Not automatically available
• Internal evaluations – Not automatically available
• Disciplinary records – Not automatically available
• Disciplinary codes – Not automatically available
• Training records – Not automatically available
• Operating manuals – Not automatically available
• Personal records provided by personnel – Not automatically available
• Other statutory records – Not automatically available
• Related correspondence – Not automatically available
4.7. Policies and directives
Policies and directives include both internal and external documents.
• Internal relating to employees and the company – Not automatically available
• External relating to donors and other third parties – Not automatically available
• Information technology systems and documents – Not automatically available
4.8. Agreements or contracts
Agreements or contracts include the documents themselves and all related documents.
• Standard Agreements – Not automatically available
• Contracts concluded with customers – Not automatically available
• NDAs – Not automatically available
• Letters of Intent, MOUs – Not automatically available
• Third party contracts – Not automatically available
• Office management contracts – Not automatically available
• Supplier contracts – Not automatically available
4.9. Regulatory documents
Regulatory documents include any documents required to comply with any laws.
• Permits – Not automatically available
• Licences – Not automatically available
• Authorities – Not automatically available
4.10. Published information
Published information includes any document that we prepare and produce.
• External newsletters and circulars – Automatically available
• Internal newsletters and circulars – Not automatically available
• Information on the company published by third parties – Not automatically available
4.11. Customer information
Customer information includes any information about anyone that we provide services to, including our customers, leads, or prospects.
• Customer details – Not Automatically available
• Contact details of individuals within customers – Not automatically available
• Communications with customers – Not automatically available
• Sales records – Automatically available
• Transactional information – Not automatically available
• Marketing records – Not automatically available
4.12. Reference materials
Reference materials include any sources of information that we contribute to.
• Books – Not automatically available
• Newsletters and journals articles -Automatically available
• Magazines – Not automatically available
• Newspaper articles – Not automatically available
- Information we hold to comply with the law
We hold records for the purposes of PAIA in terms of the following main laws, among others:
• Basic Conditions of Employment Act 75 of 1997;
• Companies Act 61 of 1973;
• Companies Act 71 of 2008;
• Compensation for Occupational Injuries and Disease Act 130 of 1993;
• Consumer Protection Act 68 of 2008;
• Electronic Communications Act 36 of 2005;
• Electronic Communications and Transactions Act 25 of 2002;
• Employment Equity Act 55 of 1998;
• Financial Intelligence Centre Act 38 of 2001;
• Income Tax Act 58 of 1962;
• Labour Relations Act 66 of 1995;
• Occupational Health and Safety Act 85 of 1993;
• Private Security Industry Regulation Act 56 of 2001;
• Protection of Personal Information Act 4 of 2013;
• Skills Development Levies Act 9 of 1999;
• Unemployment Insurance Act 63 of 2001; and
• Value Added Tax Act 89 of 1991.
- How to request access
We have authorised and designated our information officer to deal with all matters relating to PAIA in order to comply with our obligations in terms of PAIA. To request access to a record, please complete Form C which is available from:
• the SAHRC website at http://www.sahrc.org.za/index.php/understanding-paia at this link: http://www.sahrc.org.za/home/21/files/Form%20C.doc%20August%202013.doc; or
• the Department of Justice and Constitutional Development website at www.justice.gov.za at this link: http://www.justice.gov.za/forms/paia/J752_paia_Form%20C.pdf.
Please submit the completed form to our information officer together with the relevant request fee, details here:http://www.sahrc.org.za/home/21/files/PAIA%20Notice%20on%20fees.pdfat our information officer’s email address, our physical address, or by fax in terms of our details provided above. Please ensure that the completed form:
• has enough information for the information officer to identify you, the requested records, and which form of access you require;
• specifies your email address, postal address, or fax number;
• describes the right that you seek to exercise or protect;
• explains why you need the requested record to exercise or protect that right;
• provides any other way you would like to be informed of our decision other than in writing; and
• provides proof of the capacity in which you are making the request if you are making it on behalf of someone else (we will decide whether this proof is satisfactory).
• If you do not use the standard form, we may:
• reject the request due to lack of procedural compliance;
• refuse it if you do not provide sufficient information; or
• delay it.
- Grounds for refusal
We may have to refuse you access to certain records in terms of PAIA to protect:
• someone else’s privacy;
• another company’s commercial information;
• someone else’s confidential information;
• the safety of individuals and property;
• records privileged from production in legal proceedings; or
• research information.
We will notify you in writing whether your request has been approved or denied within 30 calendar days after we have received a completed request for access form. If we cannot find any requested record or it does not exist, then we will notify you by way of affidavit that it is not possible to give access to that particular record.
- How we will give you access
We will evaluate and consider all requests to us in terms of PAIA. If we approve your request for access to our records, then we will decide how to provide access to you – unless you have asked for access in a specific form. Publication of this manual does not give rise to any rights to access information records, except in terms of PAIA.
- How much it will cost you
You must pay us a request fee as required by law when submitting a request for access to information. The prescribed fees are as set out in the Fee Schedule which is available from http://www.sahrc.org.za/index.php/understanding-paiaat this link: http://www.sahrc.org.za/home/21/files/PAIA%20Notice%20on%20fees.pdf.
You must pay us the fees before we will hand over any information. You may have to pay a further access fee if we grant the request for any time that has exceeded the prescribed hours to search and prepare the record for disclosure.
- How we process and protect personal information
We process the personal information by various methods, but mainly through capturing personal information of customers and sometimes its authorised users, who provide such information when offering our services and products.
10.1. Categories of people
We process the personal information of the following categories of people:
• customers utilising our services and/or products;
• prospects or leads;
• recruiters providing services related to employees;
• contractors, vendors, or suppliers;
• debtors and creditors; and
• directors and shareholders.
We process the personal information to:
• supply our services;
• better understand our data subjects’ needs when doing so;
• keep our data subject records up-to-date;
• manage employees in general;
• manage supplier contracts in general;
• manage customers in general;
• manage customer credit in general;
• market to customers;
• enforce debts;
• market services to prospects; and
• process customer requests or complaints.
We generally collect and process personal information for our customers for various purposes including:
• to help provide better, more satisfying services to our customers when utilising our products and services;
• to help improve or alter specific or general services provided by us;
• to receive and/or provide feedback from/to customers and our service providers;
• to ensure that our services are paid for and that neither we, our service providers, customers or other clients are defrauded or the victims of illicit activity; or
• better market our services and products.
10.3. Categories of personal information
We process many different categories of personal information, including:
• contact details, such as phone numbers, physical and postal addresses, and email addresses;
• personal details, such as names and ages;
• demographic details, such as races and age groups;
• biometric information;
• account numbers;
• background information;
• contract information;
• credit information;
• market intelligence information; and
• debt and debtor information.
10.4. Third-party disclosures
We give the following people personal information that we process in the ordinary course of business to fulfil our obligations to our clients and member agencies:
• contractors, vendors, or suppliers;
• agents, distributors, or other resellers;
• operators, other responsible parties, or co-responsible parties; and
• third-party vendors (such as software developers) to help us maintain our services.
We secure our data by maintaining reasonable measures to protect personal information from loss, misuse, and unauthorized access, disclosure, alteration and destruction. We also take reasonable steps to keep personal information accurate, current, complete, and reliable for its intended use.
- Other prescribed information
The Minister of Justice and Constitutional Development has not made any regulations prescribing any other information that needs to appear in this manual.
- Availability of this Manual
This manual is available in English and will be available on our website, and at our company offices. The manual is also electronically available on our website at: https://www.ajsglobal.com
- Updates to this Manual
This manual will be updated whenever we make material changes to the current information.
Date of Compilation: 01/07/2021
Date of Revision: 09/06/2022