Privacy Policy

General

Section 14 of the Constitution of the Republic of South Africa, 1996, provides that everyone has the right to privacy. Furthermore, the Protection of Personal Information Act (POPI), 4 of 2013 reiterates that the right to privacy includes a right to protection against the unlawful collection, retention, dissemination and use of personal information.

Recidy hereby upholds your privacy and your trust very seriously. As a result, this privacy policy provides you with information about how we collect, use and disclose your personal information. Therefore, it is important to note that in terms of Section 18 of POPI, Recidy is obliged to provide the Data Subject with the following information when collecting personal information from the Data Subject.

1. About This Privacy Policy

This privacy policy applies when you visit or use our websites, apps and other services, including events, that refer or link to this privacy policy (each, a "Service"). This privacy policy may be supplemented by additional privacy statements, terms or notices provided to you.

Recidy owns or administers the Service and is the primary controller of your personal information provided to, or collected by or for, the Service.

Recidy will indicate within the registration processes of products and services and other registration forms what types of personal information are required and those that are requested. You may choose not to submit the requested information, but that may limit or prohibit the services that Recidy is able to provide to you.

2. Information We Collect

Recidy collects information about you in three ways: directly from your input, from third-party sources, and through automated technologies.

2.1 Data You Provide to Us

The types of personal information that we collect directly from you depends on how you interact with us and the Service, which may include:

• Contact details, such as your name, email address, postal address, social media handle, and phone number;
• Account login credentials, such as usernames and passwords, password hints and similar security information;
• Other account registration and profile information, such as job title, educational and professional background and qualifications, and photo;
• Payment information, such as a credit or debit card number;
• Comments, feedback and other information you provide to us, including search query data and questions or information you send to customer support; and/or
• Interests and communication preferences, including preferred language.

2.2 Data from Your Organization

Recidy may obtain personal information about you from the organization with which you are employed or affiliated in order to activate and manage your access to and use of the organization's subscription to the Service, including:

• Contact details, such as your name and organizational email address, postal address, and phone number;
• Other account registration information such as job title; and/or
• Organizational user ID

2.3 Data from Other Sources

Recidy also may obtain contact details and other information about you from our affiliates and from other third parties, including:

• Social networks when you grant permission to the Service to access your data on one or more networks;
• Service providers that help us determine a location in order to customize certain products to your location;
• Businesses with which we offer co-branded services or engage in joint marketing activities; and/or
• Publicly available sources and data suppliers from which we obtain data to validate or supplement the information we hold.

2.4 Data from Service Use, Including Cookies

The Service may automatically collect information about how you and your device interact with the Service, including:

• Computer, device and connection information, such as IP address, browser type and version, operating system and other software installed on your device, mobile platform and unique device identifier and other technical identifiers, error reports and performance data;
• Usage data, such as the features you used, the settings you selected, your URL click stream data, including date and time stamp and referring and exit pages, search terms you used, and pages you visited or searched for on the Service;
• For location-aware Services, the region, city or town where your device is located to provide you with more relevant content for where you are in the world.

Recidy collects this data through our servers and the use of cookies and other technologies. Cookies are small text files that can be read by a web server in the domain that put the cookie on your hard drive. We may use cookies and other technologies to store your preferences and settings, help you with signing in, provide targeted ads and analyse site operations. You can control cookies through your browser's settings and other tools. However, if you block certain cookies, you may not be able to register, login, or access certain parts or make full use of the Service.

3. How We Use Your Information

Depending on how you interact with us and the Service, we use your personal information to:

• Provide, activate and manage your access to and use of the Service;
• Process and fulfil a request, order, download, subscription or other transaction;
• Provide technical, product and other support and to help keep the Service working, safe and secure;
• Enhance and improve the Service and our other products, events, and services and to develop new products, services and benefits;
• Offer you customized content and other personalization to make the Service more relevant to your interests and geography;
• Respond to your requests, inquiries, comments and concerns;
• Notify you about changes, updates and other announcements related to the Service and our other products and services;
• Deliver targeted advertisements, promotional messages, notices and other information related to the Service and your interests;
• Provide you with promotional messages and other information about products, events and services of ours, our affiliates and third parties such as sponsors;
• Invite you to participate in user testing and surveys as well as drawings, sweepstakes, competitions and similar promotions;
• Identify usage trends and develop data analysis, including for purposes of research, audit, reporting and other business operations, including determining the effectiveness of our promotional campaigns and evaluating our business performance, or in other ways pursuant to a customer agreement; and/or
• Comply with our legal obligations, resolve disputes, and enforce our agreements.

If you are an administrator of an organization with a subscription to the Service, we will use your details to communicate with you about your organisation's subscription and related services. If you supply us contact information of your colleagues, we may contact those individuals with communications about the Service that may include reference to you.

4. Sharing of Your Information

4.1 Your Organization

If you access the Service through a subscription administered by your organization, your personal information and certain usage data gathered through the Service may be accessed by or shared with the administrators authorised by your organization for the purposes of usage analysis, subscription management and compliance, training course progress, performance and remediation, cost attribution and departmental budgeting.

4.2 Application Licensor

If you access a third-party application on the Service through a license agreement with the licensor of that application, personal information relevant to that third-party application may be shared with the licensor so that it can provide you access to the application, subject to the terms of its license agreement and privacy policy.

4.3 Our Group Companies and Service Providers

Dependent upon the Services provided, we share information with:

• Our affiliates, trading names and divisions within Recidy worldwide and certain AWS companies that provide technology, customer service and other shared services functions; and/or
• Our service providers, suppliers, agents and representatives, including but not limited to, payment processors, customer support, email service providers, event venues and service providers, IT service providers, marketing service providers, research providers, mailing houses and shipping agents;

to process the information as necessary to provide the Service, complete a transaction or fulfil your request or otherwise on our behalf based on our instructions and in compliance with this privacy policy and any other appropriate confidentiality and security measures.

4.4 Your Choices

• We may share your personal information with our affiliates and with sponsors, joint venture entities and other third parties, including entities for which we are acting as an agent, licensee, application host or publisher, that wish to send you information about their products and services that may be of interest to you, as determined by your choices in managing your communications preferences and other settings.
• The Service may let you post and share personal information, comments, materials and other content. Any such contributions that you disclose publicly may be collected and used by others. Please be careful when disclosing personal information in these public areas.

4.5 For Legal Reasons

We also will disclose your personal information if we have a good faith belief that such disclosure is necessary to:

• meet any applicable law, regulation, legal process or other legal obligation;
• detect, investigate and help prevent security, fraud or technical issues; and/or
• protect the rights, property or safety of Recidy, our users, employees or others; and
• as part of a corporate transaction, such as a transfer of assets to or an acquisition by or merger with another company.

5. Grounds for Processing

When we collect or otherwise process any personal information within the scope of applicable data protection laws, we do so:

• where necessary to provide the Service, fulfil a transaction or otherwise perform a contract with you or at your request prior to entering into a contract;
• where necessary for our compliance with applicable law or other legal obligation;
• where necessary for the performance of a task carried out in the public interest;
• where necessary to enable our customers to comply with their legal obligations;
• where applicable, with your consent; and/or
• where necessary to operate our business, protect the security of our systems, customers and users, detect or prevent fraud, or fulfil our other legitimate interests as described in sections 2-4 above, except where our interests are overridden by your privacy rights.

Where we rely on your consent to process personal information, you have the right to withdraw your consent at any time, and where we rely on legitimate interests, you may have the right to object to our processing.

6. Data Retention

Recidy retains your personal information for as long as necessary to provide the Service and fulfil the transactions you have requested, or for other essential purposes such as complying with our legal obligations, maintaining business and financial records, resolving disputes, maintaining security, detecting and preventing fraud and abuse, and enforcing our agreements. If you access the Service through a subscription administered or sponsored by your organization, we retain your organizational contact details after the termination of your organization's subscription to continue to communicate with you.

7. Locations of Processing

Your personal information may be stored and processed in your region or another country where Recidy, its affiliates and their service providers maintain servers and facilities, including South Africa and the United States. We take steps, including through contracts, intended to ensure that the information continues to be protected wherever it is located in a manner consistent with the standards of protection required under applicable law.

Recidy is a division of Amazon Web Services (AWS) Inc which is a subsidiary of Amazon.com, Inc. Amazon.com is a registered trademark of Amazon.com. Amazon Web Services, Inc. is located in the United States, and our affiliated companies are located throughout the world. Depending on the scope of your interactions with AWS Offerings, your personal information may be stored in or accessed from multiple countries, including the United States. Whenever we transfer personal information to other jurisdictions, we will ensure that the information is transferred in accordance with this Privacy Notice and as permitted by applicable data protection laws. The AWS follows the European Commission regulations with regard to the Treaty on the Functioning of the European Union. Therefore, the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) and in particular Article 45(3) thereof, sets out the rules for the transfer of personal data from controllers or processors in the Union to third countries and international organisations to the extent that such transfers fall within its scope of application.

Amazon Web Services, Inc. participates in the EU-US Data Privacy Framework, the UK Extension to the EU-US Data Privacy Framework, and the Swiss-US Data Privacy Framework.

8. Data Security

We implement technical and organizational measures to seek to ensure a level of security appropriate to the risk to the personal information we process. These measures are aimed at ensuring the integrity, confidentiality, and availability of personal information.

9. Children's Privacy

We do not knowingly collect information from children under the age of 14 or target the Service to children under 14.

10. Your Communications Preferences

You can customise and manage your communications preferences and other settings when you register with the Service, by updating your account features and preferences, by using the "opt-out" mechanisms such as "unsubscribe" or other means provided within the communications that you receive, or by contacting us. We reserve the right to notify you of changes or updates to the Service whenever necessary.

11. Accessing and Updating Your Information

11.1 Your Account

The Service may allow registered users to directly access and review their account information and make corrections or updates upon login at any time. Keeping such information up to date is the responsibility of the user. Registered users may also close their account directly through the Service or by contacting the Service's customer support.

11.2 Your Rights

You may have the right under applicable privacy and data protection laws to request free of charge:

• access to your personal information;
• rectification or deletion of your personal information;
• restriction of our processing of your personal information, or to object to our processing; and
• portability of your personal information.

If you wish to exercise these rights, please submit your request in writing via our privacy centre. We will respond to your request consistent with applicable laws. To protect your privacy and security, we may require you to verify your identity.

12. Changes

We will update this privacy policy from time to time. Any changes will be posted on this page with an updated revision date. If we make any material changes, we will provide notice through the Service or by other means.

13. Contact

If you have any concerns regarding this privacy policy or our processing of your information, please contact us at info@recidy.com with a thorough description, and we will try to resolve the issue for you.

For any prospective or current customers of Recidy, our contact address is: info@recidy.com

The Recidy legal details for specific jurisdictions including the European Economic Area, the UK and Switzerland, are determined in South African jurisdiction for purposes of data protection representation for our businesses that are processing personal data within the European scope. If you interact with Recidy offerings on behalf of or through your organization, then your personal information may also be subject to your organization's privacy practices, and you should direct privacy inquiries to your organization. You may also lodge a complaint to a data protection authority in the applicable jurisdiction.

14. Supplementary Notices

14.1 Authors / Contributors

Where we contract with you to produce content for any of our services, such as to write books, legal analysis, reviews, guidance or legal opinion for dissemination to our subscribers, we will process some personal information about you. Such information includes:

• name, organization, and contact details;
• professional experience, role, practice area, affiliations and subject expertise;
• professional biography or profile produced or approved by you, including your image, likeness or voice, which may be published within our services and made available to our subscribers alongside any content produced by you for Recidy;
• financial information in order to facilitate payments for works produced;
• editorial and reviewer commentary and feedback as part of peer review; and
• administration information such as author work progress updates.

The above information is processed in order to facilitate the publication of the work and to administer, manage and fulfil our contract with you.

You may choose not to be contacted by Recidy to produce content for us by contacting us via the communications that you receive from our content development teams, or via the contact details provided within this policy.

14.2 Jurisdiction-Specific Notices

Our business changes constantly, and our Privacy Notice may also change. You should check our website frequently to see recent changes. You can see the date on which the latest version of this Privacy Notice was posted. Unless stated otherwise, our current Privacy Notice applies to all personal information we have about you and your account. We stand behind the promises we make, however, and will never materially change our policies and practices to make them less protective of personal information collected in the past without informing affected customers and giving them a choice.

Fees and Payment for Services

1. Subscription Fees and Billing

The basic Services for this app may be charged on a subscription fee or transaction fees, as set out either on the registration process or on our website from time to time (Fees). It is important to further note that the Subscriptions are automatically charged each billing period (whether weekly, monthly, annually, or any period specified), and you may be charged no earlier than 24 hours before the beginning of each billing period as follows:

(a) Trial Periods

When you subscribe to content for a price, you may receive access to the subscription benefits at no charge for a specified trial period, after which you will be charged until you cancel your subscription. To avoid being charged, you must cancel before the end of the trial period. Once you cancel your trial, you will immediately lose access to the content and any subscription privileges unless otherwise specified. Access to such trial periods may be limited to a certain number of trials for each user during a given period, or other restrictions.

(b) Cancellations

You may cancel a subscription at any time before the end of the applicable billing period as described accordingly and the cancellation will apply to the next period. For example, if you purchase a monthly subscription, you may cancel that subscription at any time during any month of the subscription, and the subscription will be cancelled at the end of your then-current billing period. You will not receive a refund for the current billing period, except as otherwise provided in the terms of use (for example where content is defective).

(c) Price Increases

When you purchase a subscription, you will initially be charged at the rate applicable at the time of your agreement to subscribe. If the price of the subscription increases later, Recidy will notify you. The increase will apply to the next payment due from you after the notice, provided that you have been given at least 30 days' prior notice before the charge is made. If you are given less than 30 days' prior notice, the price increase will not apply until the payment after the next payment due. If you do not wish to pay the increased price for a subscription, you may cancel the subscription as described in the cancellations section of these Terms, and you will not be charged further amounts for the subscription, provided you have notified us before the end of the current billing period. Where Recidy increases the price of a subscription and consent is required, Recidy may cancel your subscription unless you agree to the new price. If your subscription is cancelled and you later decide to re-subscribe, you will be charged at the then current subscription rate.

2. Taxes

Recidy fees are quoted exclusive of taxes such as sales tax, value added tax and goods and services tax (collectively, taxes). Where taxes are payable on some or all of the services, we will add the taxes to your invoice and you must pay us such additional amounts in respect of taxes, at the applicable rate, at the same time as you pay the Fees.

3. Refund Policy

First time subscribers may claim a refund within 30 days of their initial subscription date. Agents or subscribers via an agent are not eligible.

4. Payment Methods

In terms of payment of services, Recidy accepts payments for the services through a credit card or debit card; by a way of electronic funds transfer into the bank account of Recidy; or by entering a credential related to a loyalty programme.

5. Electronic Fund Transfer Payment Terms

If you make payment for any Recidy services by way of electronic funds transfer, please note that:

• a) You must make payment of the full amount for the services as displayed on the Website terms;
• b) The reference number for the services as displayed on the Website;
• c) For purposes of this clause, payment shall only be deemed to have been made on the date and time at which you provide to Recidy by way of email, suitable proof of payment of the full amount for the relevant services as displayed on the Website; and
• d) The full amount for the Services as displayed on the Website, in South African Rands, clears and is irrevocably released into the bank account of Recidy within 3 (three) days of the date on which you have initiated the relevant Service;
• e) Furthermore, it is important to note that any services subscribed will automatically be cancelled if Recidy does not receive the payment in its bank account within the stipulated timeframe. For the avoidance of doubt, you shall have no claim of any nature against Recidy arising, whether directly or indirectly, from such cancellation.