BELVIGYN (PROPRIETARY) LIMITED

Privacy Policy

(Version 2.0 – Effective as of 1 November 2020 )

Please read these terms carefully when, using or accessing our Buzzer Service Platform(s) or mobile services or making use of any of the services offered by Buzzer (“Buzzer Services”) (“Buzzer”, “Us”, “We” “Our”).

This Privacy Policy forms part of the Buzzer Terms of Service and as such it applies to every person (“you”, “user(s)”,”he”, “she” “they”) who accesses or uses Buzzer’s online and/or mobile services, including any software, service, feature, product, program and element provided by or on behalf of Buzzer in connection with such services (collectively, the “Buzzer Service Platform (s)”) and including any products, programs, and services described in the Terms of Service.

introduction and PURPOSE OF the privacy POLICY

1. 1. Buzzer is in the business of marketing and selling community safety technology and services in defined territories and has conceptualised the products to service this market. In particular, the Buzzer Service Platform includes any or all of:
    1. the Buzzer community safety application, an application designed and built to provide civilians with an efficient way to inform control rooms of emergency response or safety incidents in a defined community (“the Community Safety App”)
    2. the monitor system, which is a system designed and built to provide professional and volunteer control rooms with an efficient channel to communicate with civilians (on Buzzer) and private, government and volunteer responders (“the Monitor System”); and
    3. the responder system, which is a mobile application designed and built to allow responders to work together and remain informed during incidents and operational cases (“the Responder System”).
  2. Buzzer respects your privacy and is committed to protecting the privacy of all users of the Buzzer Service Platform. We aim to utilise best practice when it comes to the collection and processing of all personal information.
  3. The Buzzer services can be accessed at www.buzzer.co.za or downloaded onto your mobile device from Google Play or I-Tunes Stores.
  4. All intellectual property (including our Service Platform) is currently owned and operated by Belvigyn (Pty) Limited, South Africa.
  5. This Privacy Policy describes the way we collect, store, use, and protect Personal Information which you submit to us, either through the Buzzer Service Platform, or other form of communication, whether digital or hard copy, in writing or verbally.
  6. Please read this Privacy Policy and the Terms of Service before using the Buzzer Service Platform or any of the services that we may offer.

ACCEPTANCE and consent

1. 1. You accept all the terms in this Privacy Policy, and our Terms of Service when you use the Buzzer Service Platform consent to us collecting, processing and storing the personal information as referred to in this Privacy Policy.
  2. The Buzzer Service Platforms are not for use by anyone under the age of 16. The Buzzer service is not directed to children or persons under 16 years old. Buzzer does not knowingly collect personally identifiable information from children under the age of 16. If you are under the age of sixteen, you must ask your parent or guardian for permission and assistance to use the Buzzer Service Platform. If we learn that we have collected Personal Information of a child under 16, we will take the appropriate steps to delete such information from our files as soon as possible. If you learn that a child has provided us with Personal Information in violation of this Privacy Policy, you can alert us at info@buzzer.co.za

Changes to this PRIVACY policy

1. 1. We may change the terms of this Privacy Policy from time to time in line with any changes that the law or our internal business operations require, without prior notice. It is your responsibility to consider the Privacy Policy each time you use the Buzzer Service Platform(s). If you do not agree with any terms of this Privacy policy, you must stop using the Buzzer Service Platform and uninstall the relevant application from your mobile device.

PRIVACY LAWS AND PROTECTING YOUR PERSONAL INFORMATION

1. 1. We will take the necessary steps to protect your privacy, including compliance with the Protection of Personal Information Act, 4 of 2013 (“POPI”), General Data Protection Regulations (GDPR) and all reasonable steps to be in compliance with the privacy laws of users outside of the EU and South Africa, where applicable.
  2. We have listed your rights that you have under data protection laws below:
    1. the RIGHT TO ACCESS – you can ask for copies of your personal data;
    2. the RIGHT TO RECTIFICATION – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
    3. the RIGHT TO ERASURE – you can ask us to erase your personal data;
    4. the RIGHT TO RESTRICT PROCESSING – you can ask use to restrict the processing of your personal data;
    5. the RIGHT TO OBJECT TO PROCESSING – you can object to the processing of your personal data;
    6. the RIGHT TO DATA PORTABILITY – you can ask that we transfer your personal data to another organisation or to you;
    7. the RIGHT TO COMPLAIN TO A SUPERVISORY AUTHORITY – you can complain about our processing of your personal data; and
    8. the RIGHT TO WITHDRAW CONSENT – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
  3. These rights are subject to certain limitations and exceptions.
  4. General Data Protection Regulation (GDPR) – You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

personal AND NON-PERSONAL information

1. 1. Personal Information refers to any information that makes you identifiable as a specific individual and non-Personal Information refers to information which does not specifically identify you. When we refer to “personal information” or “information”, we refer to the statutory definition contained in the POPI.
  2. Personal Information includes; without limitation; your full name, surname, IP address, email address, age, race, gender, nationality, identity number, passport, photographs, contact details, history and location.

Collecting your personal information

1. 1. We collect information about you when you use Buzzer Service Platform interfaces and when you communicate with us.
  2. You provide us with different types of information in order for us to provide the Buzzer services, products and features to you.
  3. Buzzer may collect and store Personal Information from you in connection with:
    1. providing the Buzzer Service Platform or any other product which Buzzer offers;
    2. creation and maintenance of your user profile, account and verification of your profile;
    3. communicating with you about matters and updates regarding the Buzzer Service Platform;
    4. visits or browsing on our website or any of our application interface.
  4. When you register to become a Buzzer community member, you are required to provide us with:
    1. your name and surname;
    2. your e-mail address;
    3. your telephone contact details;
    4. your residential and/or work address
    5. By providing us with this information, you consent to us collecting and processing your Personal Information in order for you to make use of and to allow us to provide and optimise the Buzzer Service Platforms for you.
  5. Geolocation: We collect your unique user identifier and your location through GPS, WiFi, or wireless network triangulation in order to obtain your location for the purposes of providing the service. In particular:
    1. We collect the location of your designated “Places” to provide alerts when team members arrive and leave. If you turn off location sharing in one or more of your teams, we will not share your location with such teams; however, we will continue to collect your location information in order to provide the service for example, to provide our emergency services or to share your location with the other teams you continue to allow to see your location. We maintain location information only so long as it is reasonable to provide the Service and then delete location data tied to your personal information.
    2. We may maintain de-identified location data for a longer period of time in order to analyze aggregate trends and metrics.
    3. We may also share location information with third parties for research, and analytic purposes.
  6. Driving Event Data. We collect, and may use a third party to collect, sensory and motion data from your smartphone or mobile device, including information from the gyroscope, accelerometer, compass and Bluetooth, in order to calculate and detect driving events such as speeding, hard braking, crash detection and other events. We maintain sensory and motion data as long as it is required to provide the service and then delete or anonymize this data.
  7. Messages and User Content. We collect information when you message other members of your team through use of the Buzzer service. We will not retain any messages you send to us for longer than is necessary to provide the service or to resolve your query. Unless you request us not to, we may retain messages which you send us and we will only use this information in order to operate, maintain, and provide to you the features and functionality of the service and to communicate directly with you, such as to send you alerts on the movements of your team members, crime alerts in your neighborhood, etc. You can control your receipt of email and text alerts by visiting “settings” and “alert options” within the mobile app. We may also send you service-related emails (e.g., account verification, parental consent notification, order confirmations, change or updates to features of the service, technical and security notices). You may not opt-out of service-related e-mails.
  8. Social Media. When you interact with our platform interface through various social media, such as when you Like us on Facebook or post a comment to our Facebook page, we may receive information from the social network such as your profile information, profile picture, gender, user name, user ID associated with your social media account, age range, language, country, friends list, and any other information you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to the Buzzer Service Platform.

Information we collect automatically through the use of technology.

1. 1. When you visit our website or use our mobile app, we and our business partners may collect certain information about your computer or device through technology such as cookies, web beacons, log files, or other tracking/recording tools. The information we collect through the use of tracking technologies includes, but is not limited to, IP address, browser information, referring/exit pages and URLs, click stream data and information about how you interact with links on the website, mobile app, or Service, domain names, landing pages, page views, cookie data that allows us to uniquely identify your browser and track your browsing behavior on our site, mobile device type, mobile device IDs or other persistent identifiers, and location data collected from your mobile device. Some or all of this data may be combined with other personally identifying information described above. When you access our Service by or through a mobile device, we may receive or collect and store a unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google Ad ID, or Windows Advertising ID or other identifier), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g. latitude and/or longitude), WiFi location or similar information regarding the location of your mobile device. We use this information to:
    1. remember information so that you will not have to re-enter it during your visit or the next time you visit our website or mobile application;
    2. Provide custom, personalized content and information, including advertising relating to the service;
    3. track your location and movements in order to provide the service;
    4. monitor aggregate metrics such as total number of visitors, users, traffic, and demographic patterns;
    5. diagnose or fix technology problems reported by our Users or engineers that are associated with certain IP addresses or User IDs, and Automatically update our mobile application on your system and related devices.
  2. We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Service. These tools collect information sent by your browser or mobile device, including the pages you visit, your use of third party applications, and other information that assists us in analyzing and improving the Service. Although we do our best to honor the privacy preferences of our Users, we are not able to respond to “Do Not Track” signals from your browser at this time.
  3. Please note that third parties who advertise on the Buzzer Service Platform(s) may also use cookies, but we do not have access to, or control over them, and therefore cannot take responsibility for them.
  4. We use Google Analytics. Google Analytics gathers information about the use of our Buzzer Service Platform(s) by means of cookies. The information gathered is used to create reports about the use of our Buzzer Service Platform(s). You can find out more about Google’s use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google’s privacy policy at https://policies.google.com/privacy

PURPOSE, UseS AND DISCLOSURE of information

1. 1. Personal Information which you provide to us will only be used for the purposes listed in this Privacy Policy and the Terms of Use.
  2. Buzzer may use your Personal Information to:
    1. provide the Buzzer Service and/or any other products and services to you, which may necessitate sharing your Personal Information with third party service providers solely for the purpose of providing and enhancing the functionality and efficacy of the Buzzer Services. Such third parties include law enforcement, security and surveillance, emergency medical and armed response service providers. These third parties will only have access to your Personal Information in order to respond to an incident. manage its relationship with you and third-party service providers;
    2. communicate with you about the Buzzer Service and any other products, services or support offered by us and to send communications in connection these services and products only;
    3. provide support to you in respect of the Buzzer service;
    4. provide personalised offers relating to the Buzzer service;
    5. measure the performance of our marketing initiatives;
    6. allow you to participate in competitions and surveys;
    7. answer enquiries, provide information, support or advice about the Buzzer service and any new products or services offered;
    8. assess and improve the performance and operation of the Buzzer Service Platform(s);
    9. prevent and detect security threats, fraud or other malicious activity;
    10. process and respond to any complaint made by you.
  3. Buzzer will not sell, rent or otherwise disclose your Personal Information to any third party without your express consent, provided that, by using the Buzzer Service Platform(s) and/or subscribing to the Buzzer Service, you provide your express and informed consent for Buzzer to disclose your Personal Information to third parties as follows:
    1. to third party companies employed by us to provide services which enable the Buzzer Service Platforms to function including,: Buzzer Service Platform(s) hosting, administration, maintenance and development. These companies require access to your Personal Information to perform their functions and not for any other purposes;
    2. to third party companies or entities with which Buzzer contracts, whether directly or indirectly, to provide the Buzzer service where such companies or entities require access to your Personal Information to perform their own regulatory functions and not for any other purposes;
    3. to transfer Buzzer’s user database/s, including Personal information contained therein, to any third party who acquires all or substantially all of the assets or shares in Buzzer;
    4. to governmental agencies, exchanges and other regulatory or self-regulatory organisations if Buzzer is required to do so by law or if Buzzer believes that such action is necessary to comply with the law or with any legal process;
    5. to protect and defend Buzzer’s rights and property;
    6. to prevent fraud, abuse, misuse or unauthorised use of the Buzzer Service Platform(s);
    7. to protect the personal safety or property of the users of the Buzzer service or the public (if you provide false or deceptive information about yourself or misrepresent yourself as being someone else, we will disclose such information to the appropriate regulatory bodies and commercial entities); and
    8. if applicable, to personalise your experience on the Buzzer Service Platform(s), to help you log on in future and to continue to use the Buzzer Service Platform(s), to reply to queries you might have, to provide you with support and to help Buzzer select services or materials for inclusion on the Buzzer Service Platform(s) which may be of interest to you. .
  4. The Buzzer Service Platform(s) may connect to various social media sites or apps, including Facebook, Twitter, LinkedIn, Instagram and Google+. If you want to use our Buzzer Service Platform(s) for social media integration, including to create user profiles and login functionality, we will share your information with the relevant social media sites or apps. Any information or content that you voluntarily post to the website or to our Facebook page will automatically be available to the public. We may publicly post your reviews and comments online on our website or mobile application, or link your reviews to third party websites. We are not responsible for the practices employed by websites or services linked to or from the Service, nor the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies. Please read over those rules and policies before proceeding.
  5. We may transmit or transfer Personal Information to countries outside of South Africa.
  6. Across the EU, we will endeavour to ensure compliance with the General Data Protection Regulation (GDPR) and should you believe we are in contravention of the GDPR, you may contact our Information Officer at keri@buzzer.co.za and we will ensure that we revert within 48 hours of your correspondence.
  7. WE RESERVE THE RIGHT TO SHARE NON-PERSONAL, NON-INDIVIDUAL INFORMATION IN AGGREGATE FORM WITH THIRD PARTIES FOR BUSINESS PURPOSES, FOR EXAMPLE WITH BUSINESS ASSOCIATES AND PARTNERS. YOU WILL NOT BE IDENTIFIABLE FROM SUCH DATA AS SUCH. Buzzer is not responsible and cannot be held liable for the privacy practices of such third parties.
  8. Demographic and statistical information about user behaviour may be collected and used to analyse the popularity and effectiveness of the Buzzer Service Platform(s). Any disclosure of this information will be in aggregate form and will not identify individual users.
2. QUALITY AND PROTECTION OF YOUR INFORMATION
  1. You are responsible for the accuracy of the information submitted to us and for ensuring that it is up-to-date, complete and accurate. It is your duty to maintain your profile and the details of the Personal Information which you provide to us.
  2. You may modify your account information, update or amend your personal information, or change your password at any time by logging in to your account. You can also stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, parental consent notification, order confirmations, change or updates to features of the Service, technical and security notices). If you have any questions about reviewing or modifying your account information, you can contact us directly at info@buzzer.co.za
  3. Buzzer will take all reasonable measures to prevent the destruction, unlawful access and loss of Personal Information including establishing appropriate physical, electronic and managerial procedures to safeguard the Personal Information collected from you. This helps prevent unauthorised access, maintains data accuracy and ensures that Personal Information is used correctly. In order to carry out these security procedures, Buzzer will ask for proof of identity before Personal Information is disclosed to you:
  4. Please contact Buzzer by phone or email if you:
    1. require access to any of your Personal Information which is being held by Buzzer;
    2. wish to notify Buzzer of any change, modification or correction to your Personal Information which you are unable to change for yourself;
    3. would like to have your Personal Information removed from our records;
    4. believe that someone is impersonating or otherwise unlawfully using your login details or your account.
  5. While every effort will be made to adopt appropriate security procedures to help prevent unauthorised access to your Personal Information, Buzzer will not be liable for any attempt to hack or crack or otherwise gain access to any of your Personal Information on servers owned and maintained by or on behalf of Buzzer.

HOW BUZZER STORES INFORMATION COLLECTED FROM YOU

1. 1. Information, including your Personal Information is stored on the Google Cloud platform.
  2. Information is held for as long as you maintain a profile with Buzzer (until you request us to delete it) or as long as may be legally required.
  3. Information which you provide to us will be stored electronically and/or in hard copy, with reasonable security measures protecting this information. However, please note that we work with third party contractors, some of which host and operate certain features of the Buzzer Service Platform(s). Therefore, information that Buzzer collects from you may be collected in or transferred to a destination outside South Africa, including in Israel or the United States or any other such region as deemed appropriate from time to time and/or may be processed by employees/independent contractors operating outside South Africa who work for or are contracted to Buzzer. By submitting Personal Information to us, you agree to the transfer, storage and processing of your Personal Information as set out in this Privacy Policy. Buzzer will take all steps reasonably necessary to ensure that your data and Personal Information is treated securely and in accordance with this Privacy Policy.

CONCERNS AND SECURITY BREACH

1. We will report any security breach to the Information Regulator in South Africa, and the GDPR regulatory body (if applicable) and to the individuals or companies involved. If you want to report any concerns about our privacy practices or if you suspect any breach regarding your information, kindly notify us by sending an email to keri@buzzer.co.za