Privacy Policy  

MWare (referred to as “The Company”, “we”, “us”, “our”) respect and acknowledge the
importance of protecting your personal information.



MWare is a “responsible person” in terms of the South African Protection of Personal
Information Act, 2013 (“POPIA“) and a “controller” in terms of the General Data Protection

Regulation (“EU GDPR”) 2016/679 of the European Union in that it determines the purpose and
the manner of processing of personal information.

MWare does not provide services intended for children and accordingly, we do not knowingly
collect personal information relating to children.

This Privacy Policy sets out how we will process your personal information in the ordinary
course of conducting our business and also applies to our website. Please ensure that you
read this Privacy Policy together with any other notifications that we may forward to you when
we are collecting or processing your personal information so that you are always fully
informed of how and why we are using your personal information. This Privacy Policy
supplements the other notices and is not intended to override them.

When you interact with us, you may provide us with personal information, or we may collect
personal information from you by law or under terms of a contract we have with you. You can
choose not to provide personal information when requested. However, without your requested
personal information, we may not be able to provide or continue to provide you with the
products or services offered by MWare or allow you full access to our websites. If you refuse,
we may have to cancel a product or service you have with us, but we will notify you if this is the
case.

We will only collect, use, store and transfer the minimum personal information that we deem
necessary to process for ordinary business purposes. Personal information we collect from you
may include:

• Personal Identifying Information (PII), i.e. your first names/s and surname, email address,
  phone number and other contact information.
• Company name.
• Log-in and account information for authentication purposes and account access.
• Your marketing preferences.
• Demographic data such as your gender, age, country, and preferred language.
• Data about how you and your PC or device interact with MWare, including web pages you
  visit when you use our websites and device, connectivity, and configuration data.

It is not standard practice for us to collect sensitive personal information about you, such as
information relating to your health, religion, political beliefs, race, or sexual orientation, except
with your express consent or unless we are required to do so by law.

If we link other data with your personal information as provided to us, we will treat that linked
data as personal information.

We may collect your personal information in a variety of ways when you interact with us,
including when:

• You engage us to provide our products and services.
• We respond to your inquiries and requests.
• As a result of communications between you and our representatives.
• We obtain feedback from you about our products and services.
• We conduct our administrative and business functions.
• You subscribe to our mailing lists and newsletters.
• We market our solutions and services to you.
• You access and use our websites.
• You apply for employment with us.

We may also collect your personal information from third party sources and third parties
including public databases, business partners with whom we offer co-branded services or
engage in joint marketing activities, and third parties that provide list enhancement or similar
services, to the extent that this is permitted by applicable law.

As you interact with our website, we may automatically collect technical data about your
equipment, browsing actions and patterns. We collect this personal information by using
cookies, server logs and other similar technologies. We may also receive technical data about
you if you visit other websites employing our cookies.



We will only use your personal information for the purposes for which we originally collected
it, unless we reasonably consider that we need to use it for another reason which is compatible
with the original purpose. If you wish to get an explanation as to how the processing for the
new purpose is compatible with the original purpose, please contact our Information Officer.

If we need to use your personal information for a purpose unrelated to the original purpose, we
will notify you and we will explain the legal basis which allows us to do so.



Please note that we may process your Personal information without your knowledge or
consent but only where this is required or permitted by law.

We may share your personal information for the purposes above with:



• Our affiliates and subsidiaries, if any, who are similarly bound by this Privacy Policy.
• Business partners, vendors, or contractors to provide requested services or facilitate
  transactions, including but not limited to processing of orders, assisting with sales-related
  activities or post-sales support, and providing customer support. It is important to note that
  any third parties with whom we share personal information are contractually required to
  implement appropriate data protection and security measures and are not permitted to
  process personal information for any purpose other than the purpose for which they are
  given access.
• In connection with, any joint venture, merger, sale of company assets, consolidation or
  restructuring, financing, or acquisition of all or a portion of our business by or to another
  company.
• In response to a request for information by a competent authority in accordance with, or
  required by any applicable law, regulation or legal process.
• Where necessary to comply with legal obligations, judicial proceedings, court orders or
  government orders.
• To protect the rights, property or safety of MWare, its business partners, you, or others, or
  as otherwise required by applicable law.
• Where you consent to the sharing of your personal information.

It may be necessary for us to process, transfer and/or store your personal information in other
countries, either to carry out your instructions or for ordinary business purposes. These
countries may not have the same level of protection as is required by POPIA or the GDPR.
Where this is the case, we will only process your personal information with your consent. If
necessary, we will ask the party to whom we transfer your personal information to agree to our
privacy principles, associated policies and practices so that your personal information will be
protected to the same extent that it would have been had it been processed by us. Please
contact us if you want further information on the specific mechanism used by us when
transferring your Personal information out of South Africa or the European Economic Area.

MWare is committed to protecting your personal information from misuse, loss, unauthorised
access, modification, or disclosure by using a combination of physical, administrative, and
technical safeguards and contractually requiring that third parties to whom we disclose your
personal information do the same.



Whilst MWare makes every effort to secure its websites, you should note that the internet is
not completely secure; thus, when you submit or post personal information online, you should
be aware that MWare cannot guarantee the security of any personal information that you
submit or post online.

You can choose whether you wish to receive marketing communications from us by email,
social media platforms and/or phone. Even when you have agreed to this, you may opt out of
receiving future marketing materials from us at any time, as well as manage your
communication preferences by either following the unsubscribe instructions included in each
marketing email from us, or sending an email to info@mware.co.za, including your details and a
description of the marketing material you no longer wish to receive from us. We will comply
with your request as soon as is reasonably possible. If you opt out of receiving marketing
related communications from us, we may still send you administrative messages as part of
your ongoing use of our websites, solutions or services.

We do not provide your personal information to unaffiliated third parties for direct marketing
purposes or sell, rent, distribute or otherwise make personal information commercially
available to any third party.

Should you believe that any Personal Information we hold on you is incorrect or incomplete,
you have the ability to request to see this information, rectify it or have it deleted. Please
contact us.

In the event that you wish to complain about how we have handled your Personal Information,
please contact our Information Officer at erna@mware.co.za. Our Information Officer will then
look into your complaint and work with you to resolve the matter.

If you still feel that your Personal Information has not been handled appropriately according to
the law, you can contact the Regulator and file a complaint with them.

In order to access, correct, update, block or delete your personal information, you have the
right to:

• Request access to your personal information. This allows you to receive a copy of your
  personal information held by us and to check that we are lawfully processing it.
• Request correction of your personal information held by us. This allows you to have any of
  your incomplete or inaccurate information corrected, although we may need to verify the
  accuracy of the new information that you provide.
• Request erasure of your personal information. This allows you to request that we delete or
  remove your personal information where there is no justifiable reason for us to continue
  processing the information. In addition, you have the right to request us to delete or
  remove your personal information where you have successfully exercised your right to
  object to processing (see below), where we may have processed your information
  unlawfully or where we are required to erase your personal information in order to comply
  with a legal requirement. Please note that for specific legal reasons which will be
  communicated to you, we may not always be able to comply with your request of erasure.
• Object to processing of your personal information. You may object to our processing of
  your information where we are relying on a legitimate interest (or those of a third party) and
  there is something about your particular situation which makes you want to object to
  processing on this ground as you feel it impacts on your fundamental rights and freedoms.
  You also have the right to object where we are processing your personal information for
  direct marketing purposes. In some cases, we may be able to demonstrate that we have
  compelling legitimate grounds to process your information which overrides your rights and
  freedoms.
• Request restriction of processing of your personal information.
• This allows you to request
  that we suspend the processing of your personal information in the following scenarios:
• If you want us to establish the accuracy of the information.
• Where our use of the information is unlawful, but you do not want us to erase it.
• Where you need us to hold the information even if we no longer require it as you
  need it to establish, exercise or defend legal claims.
• You have objected to our use of your information, but we need to establish whether
  we have overriding legitimate grounds to use it.
• Request the transfer of your personal information to you or to a third party. We will
  provide you, or a nominated third party, with your personal information in a structured,
  commonly used, machine-readable format. Please note that this right only applies to
  automated information which you initially provided consent for us to use, or where we
  used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal
  information. However, this will not affect the lawfulness of any processing carried out
  before the withdrawal of your consent. If you withdraw your consent, we may not be able
  to provide certain products or services to you. We will advise you if this is the case at the
  time you withdraw your consent.
• No fee usually required: You will normally not have to pay a fee to access your personal
  information (or to exercise any of the other rights). However, we may charge a reasonable fee if
  your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to
  comply with your request in these circumstances.
• What we may need from you: We may need to request specific information from you to assist
  us to confirm your identity and ensure your right to access your personal information (or to
  exercise any of your other rights). This is a security measure to ensure that personal
  information is not disclosed to any person who has no right to receive it. We may also contact
  you to ask you for further information in relation to your request in order to speed up our
  response.
• Time limit to respond: We will endeavour to respond to all legitimate requests within 30 days.
  Occasionally it may take us longer than this if your request is particularly complex or if you
  have made a number of requests, in which case, we will notify you of the delay and keep you
  updated.

Our websites may contain links to sites and applications operated by third parties. We make no
representations or warranties in relation to the privacy practices of any third party site or
application, and we are not responsible for any third party content or privacy statements. Your
use of such sites and applications is subject to the relevant third party privacy statements.

Newsletter data

If you would like to receive our newsletter, we require a valid email address as well as
information that allows us to verify that you are the owner of the specified email address and
that you agree to receive this newsletter. No additional data is collected or is only collected on
a voluntary basis. We only use this data to send the requested information and do not pass it
on to third parties.

We will, therefore, process any data you enter onto the contact form only with your consent
per Art. 6 (1) (a) DSGVO. You can revoke consent to the storage of your data and email address
as well as their use for sending the newsletter at any time, e.g. through the “unsubscribe” link in
the newsletter. The data processed before we receive your request may still be legally
processed.

The data provided when registering for the newsletter will be used to distribute the newsletter
until you cancel your subscription when said data will be deleted. Data we have stored for
other purposes (e.g. email addresses for the members area) remain unaffected.

MailChimp

This website uses the services of MailChimp to send newsletters. This service is provided by
Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA.

MailChimp is a service which organizes and analyzes the distribution of newsletters. If you
provide data (e.g. your email address) to subscribe to our newsletter, it will be stored on
MailChimp servers in the USA.

MailChimp is certified under the EU-US Privacy Shield. The Privacy Shield is an agreement
between the European Union (EU) and the US to ensure compliance with European privacy
standards in the United States.

We use MailChimp to analyze our newsletter campaigns. When you open an email sent by
MailChimp, a file included in the email (called a web beacon) connects to MailChimp’s servers
in the United States. This allows us to determine if a newsletter message has been opened and
which links you click on. In addition, technical information is collected (e.g. time of retrieval, IP
address, browser type, and operating system). This information cannot be assigned to a
specific recipient. It is used exclusively for the statistical analysis of our newsletter campaigns.
The results of these analyses can be used to better tailor future newsletters to your interests.

If you do not want your usage of the newsletter to be analyzed by MailChimp, you will have to
unsubscribe from the newsletter. For this purpose, we provide a link in every newsletter we
send. You can also unsubscribe from the newsletter directly on the website.

Data processing is based on Art. 6 (1) (a) DSGVO. You may revoke your consent at any time by
unsubscribing to the newsletter. The data processed before we receive your request may still
be legally processed.

The data provided when registering for the newsletter will be used to distribute the newsletter
until you cancel your subscription when said data will be deleted from our servers and those of
MailChimp. Data we have stored for other purposes (e.g. email addresses for the members
area) remains unaffected.

For details, see the MailChimp privacy policy at https://mailchimp.com/legal/terms/.

YouTube

Our website uses plugins from YouTube, which is operated by Google. The operator of the
pages is YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA.

If you visit one of our pages featuring a YouTube plugin, a connection to the YouTube servers
is established. Here the YouTube server is informed about which of our pages you have visited.



If you’re logged in to your YouTube account, YouTube allows you to associate your browsing
behavior directly with your personal profile. You can prevent this by logging out of your
YouTube account.

YouTube is used to help make our website appealing. This constitutes a justified interest
pursuant to Art. 6 (1) (f) DSGVO.

Further information about handling user data, can be found in the data protection declaration
of YouTube under https://policies.google.com/privacy.

Vimeo

Our website uses features provided by the Vimeo video portal. This service is provided by
Vimeo Inc., 555 West 18th Street, New York, New York 10011, USA.

If you visit one of our pages featuring a Vimeo plugin, a connection to the Vimeo servers is
established. Here the Vimeo server is informed about which of our pages you have visited. In
addition, Vimeo will receive your IP address. This also applies if you are not logged in to Vimeo
when you visit our website or do not have a Vimeo account. The information is transmitted to a
Vimeo server in the US, where it is stored.

If you are logged in to your Vimeo account, Vimeo allows you to associate your browsing
behavior directly with your personal profile. You can prevent this by logging out of your Vimeo
account.

For more information on how to handle user data, please refer to the Vimeo Privacy Policy at
https://vimeo.com/privacy.

Google Web Fonts

For uniform representation of fonts, this page uses web fonts provided by Google. When you
open a page, your browser loads the required web fonts into your browser cache to display
texts and fonts correctly.

For this purpose your browser has to establish a direct connection to Google servers. Google
thus becomes aware that our web page was accessed via your IP address. The use of Google
Web fonts is done in the interest of a uniform and attractive presentation of our website. This
constitutes a justified interest pursuant to Art. 6 (1) (f) DSGVO.

If your browser does not support web fonts, a standard font is used by your computer.

Further information about handling user data, can be found at
https://developers.google.com/fonts/faq and in Google’s privacy policy at
https://policies.google.com/privacy.

Google Maps

This site uses the Google Maps map service via an API. It is operated by Google Inc., 1600
Amphitheatre Parkway, Mountain View, CA 94043, USA.

To use Google Maps, it is necessary to save your IP address. This information is generally
transmitted to a Google server in the USA and stored there. The provider of this site has no
influence on this data transfer.

The use of Google Maps is in the interest of making our website appealing and to facilitate the
location of places specified by us on the website. This constitutes a justified interest pursuant
to Art. 6 (1) (f) DSGVO.

Further information about handling user data, can be found in the data protection declaration
of Google at https://policies.google.com/privacy.

We retain your personal information for only as long as is necessary to fulfil the purposes for
which it was collected, or to comply with legal obligations, resolve disputes, protect our assets,
or enforce agreements. Depending on the purpose, retention periods will vary.

Any Personal Information held by us for marketing and service update notifications will be kept
by us until such time that you notify us that you no longer wish to receive these notifications.

The criteria we use to determine retention periods, excluding marketing and service
notifications, include whether:

• We are under a legal, contractual, or other obligation to retain personal information
  including pursuant to data retention laws, as part of an investigation or for litigation
  purposes.
• Personal information is needed to provide our solutions and services business including
  performance improvement and to maintain accurate business and financial records.
• There are automated means to enable you to access and delete your personal information
  at any time. We will generally retain personal information for a shorter period of time,
  where this is not the case.
• The personal information is Special PII in which event we will generally retain this for a
  shorter period of time.
• You have consented to us retaining your personal information for a longer retention period,
  in which case, we will retain personal information in line with your consent.

We may update this Privacy Policy from time to time. Any updates of this Policy will be posted
on the MWare website together with an updated revision date. Unless otherwise stated, any
new Privacy Policy will supersede the previous Policy.

We have appointed an Information Officer who is responsible for overseeing questions in
relation to this Privacy Policy. If you have any questions about how your personal information is
handled by MWare, you have a privacy concern or you wish to make a complaint, please
contact us addressing the Information Officer at erna@mware.co.za.

MWare keeps this Privacy Policy under regular review and places updates on our web page,
alternatively the updates can be requested from our Information Officer. This document was
updated on 1 July 2021 and is presently version 1 (one).



The Information Officer is the owner of this document, who checks and, if necessary, updates
the document at least once a year.