STP Global

Privacy Policy

We are committed to maintaining the privacy, integrity and accuracy of your data by complying with all local and international regulations and requirements, and only request, capture and process the minimum amount of personal information required to effectively provide our products and services, as outlined in this privacy policy (“Policy”).

This Policy describes the types of information we may collect from you or that you may provide (“Personal Information”) on the website (“Website” or “Service”) and any of its related products and services (collectively, “Services”), and our practices for collecting, using, maintaining, protecting, and disclosing that Personal Information. It also describes the choices available to you regarding our use of your Personal Information and how you can access, update or delete it.

This Policy is a legally binding agreement between you (“User”, “you” or “your”) and STPGLOBAL (doing business as “”, “we”, “us” or “our”). If you are entering into this agreement on behalf of a business or other legal entity, you represent that you have the authority to bind such entity to this agreement, in which case the terms “User”, “you” or “your” shall refer to such entity. If you do not have such authority, or if you do not agree with the terms of this agreement, you must not accept this agreement and may not access and use the Website and Services.

By accessing and using the Website and Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Policy. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

Because we do business internationally and make use of the services of companies based in various parts of our modern interconnected world, the information contained in the following sections collectively explains how we treat your data as per the regulations set out in the POPIA, GDPR, CAN-SPAM and CCPA guidelines.

South African Protection of Personal Information Act 4 of 2013 (“POPI Act”)


As a registered business in South Africa, STPGLOBAL is required by law to keep plans and processes in place on how we process, store, and share your personal information. If you reside in South Africa, you have certain data protection rights recognised and protected in the South African Constitution and in the Protection of Personal Information Act 4 of 2013 (“POPI Act” or “POPIA”).

Under this act, as the end-user you have the right:

  1. to be notified about the collection and processing of your personal information and its intent,
  2. to request access to any personal information we may hold about you,
  • to request, where necessary, or subject to any statutory and contractual record-keeping requirements, that your personal information be corrected, or deleted when we are no longer authorized to retain such information,
  1. to object to the processing of your personal information,
  2. not to have your personal information processed for the purpose of direct marketing by means of unsolicited electronic communications,
  3. to not be subject to a decision which results in legal circumstances based solely on the basis of automated processing of your personal information,
  • to complain to the South African Information Regulator ( regarding any possible infringement of any of these rights, and,
  • to institute civil proceedings or effect judicial remedy.

Definitions as per the POPI Act

“Data Subject” means the person to whom the personal information relates and can be a natural or legal person.

“Personal Information” means information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person, including, but not limited to:

  • information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and the birth of the person;
  • information relating to the education or the medical, financial, criminal or employment history of the person;
  • any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier or other particular assignment to the person;
  • the biometric information of the person;
  • the personal opinions, views or preferences of the person;
  • correspondence sent by the person that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence;
  • the views or opinions of another individual about the person;
  • the name of the person if it appears with other personal information relating to the person or if the disclosure of the name itself would reveal information about the person; and
  • Personal information concerning a child.

“Third-Party” or “Third-Party Operator” means a person (natural or legal) who processes personal information for a responsible party in terms of a contract or mandate, without coming under the direct authority of that party.

Applications of this Policy

The obligations in this policy apply to STPGLOBAL, its management, staff members, and representatives. Any Third Parties to who we entrust personal information to are also bound by the terms of this policy and applies to all Personal Information gathered from Data Subjects.

Purpose of Collection

In order to meet our clients’ needs and deliver the high-quality products and services that STP Global is known for, we or a Third-Party Operator may require certain types of personal information, collected for explicitly defined purposes or reasons integral to the function, activity, or service that we or they render.

You can access and use the Website and Services without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual. If, however, you wish to use some of the features offered on the Website or Service, you may be asked to provide certain Personal Information (for example, your name and e-mail address on a contact form).

The purpose of collecting your personal information may include, but is not limited to:

  • For our internal processes.
  • To provide an efficient service to our clients.
  • For supplier/third-party operator management.
  • To enable your use of our Services provided.
  • For relationship management with you and our other clients.
  • To send statements, invoices, and payment reminders to you, and collect payments from you.
  • To send you marketing or commercial communications to which you signed up for and/or have given explicit consent to receive.


Where you provide us with information, you agree to do so willingly and voluntarily and understand that we reasonably require the information to fulfil your requests, and to pursue both your legitimate interests as our client/prospective client as well as our own.

Your personal information is only allowed to be processed if you consent to the processing, including to the specific purposes for which the personal information is being collected, and you can withdraw your consent at any time by either automated means (for instance, by using the “Unsubscribe/Manage your Subscription” facility on any of our marketing emails) or by contacting our Information Officer using the details at the end of this document.

Information we may require

We do not collect information that is unnecessary or irrelevant for the purpose specified and only collect information from you with your consent for the purposes as stated throughout this policy, be that during virtual or in-person meetings, application forms, electronic media, ongoing interaction, via website cookies or any other means of digitally or physically giving valid consent.

Depending on the stated purpose, we generally collect the following Personal Information which may include, but is not limited to:

  • Names,
  • Contact details,
  • Email addresses,
  • Physical addresses,
  • Job position,
  • Company name,
  • Industry,
  • Testimonials,
  • Or any other personal information that you choose to send to us.

We may at times reasonably require additional information that is not mentioned above, and will inform users about the intended purpose whenever practicable, and what the consequences are if information, whether supplied voluntarily or mandatory, is not provided. Usually, if the information requested is not provided, we can only offer a limited service or no service at all. 

Privacy of Children

We do not knowingly collect any Personal Information from children under the age of 18. If you are under the age of 18, please do not submit any Personal Information through the Website and Services. If you have reason to believe that a child under the age of 18 has provided Personal Information to us through the Website and Services, please contact us to request that we delete that child’s Personal Information from our Services.

We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through the Website and Services without their permission. We also ask that all parents and legal guardians overseeing the care of children take the necessary precautions to ensure that their children are instructed to never give out Personal Information when online without their permission.

How we collect your information

We may receive and store any information you knowingly provide to us in various automated or manual ways to provide you with more information about our Services or when you agree to make use of our Services.

You can choose not to provide us with your Personal Information, but may therefore not be able to make use of or take advantage of some or all of the features on the Website or Service. Users who are uncertain about what information is mandatory are welcome to contact us.

Automatic collection of information

When you visit our Website, our Services may record information that your browser sends through automated means such as cookies, web beacons, or other similar information-gathering technologies.

This data may include information such as your device’s IP address, browser type, and version, operating system type and version, language preferences or the webpage you were visiting before you came to the Website and Services, pages of the Website and Services that you visit, the time spent on those pages, the information you search for on the Website, access times and dates, and other general usage statistics.

Information collected in such a way is used only to identify potential cases of abuse and establish statistical information regarding the usage and traffic of the Website and Services. This statistical information is not otherwise aggregated in such a way that would identify any particular User of the system.


This section covers the types of cookies we use, the information we collect using cookies and how that information is used. It also describes the choices available to you regarding accepting or declining the use of cookies, which can be interpreted as our Cookie Policy.

Our Website and Services may use cookies to help personalize your online experience. We may use cookies to collect, store, and track information for security and personalization, to operate the Website and Services, and for statistical purposes.

Please note that you have the ability to accept or decline cookies. Most web browsers automatically accept cookies by default, but you can modify your browser settings to decline cookies if you prefer.

Cookies are small pieces of data stored in text files saved on your computer or other devices when websites are loaded in a browser. They are widely used to remember you and your preferences, either for a single visit (through a “session cookie”) or for multiple repeat visits (using a “persistent cookie”).

Session cookies are temporary cookies that are used during the course of your visit to the Website, and they expire when you close the web browser.

Persistent cookies are used to remember your preferences within our Website and remain on your desktop or mobile device even after you close your browser or restart your computer. They ensure a consistent and efficient experience for you while visiting the Website and Services.

Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. If you choose to decline cookies, you may not be able to fully experience the features of the Website and/or our Services.

We may use some or all of the following types of cookies:

  • Necessary cookies, which are absolutely essential for the website to function properly. These cookies ensure basic functionalities and security features of the website, anonymously.
  • Functionality cookies, which help to perform certain functionalities like sharing the content of the website on social media platforms, collect feedback, and other third-party features.
  • Performance cookies, which are used to understand and analyze the key performance indexes of the website which help in delivering a better user experience for the visitors.
  • Analytics Cookies, which are used to understand how visitors interact with the website. These cookies help provide information on metrics such as the number of visitors, bounce rate, traffic source, etc.
  • Advertisement Cookies, which are used to provide visitors with relevant ads and marketing campaigns. These cookies track visitors across websites and collect information to provide customized ads.

Cookies may be set by the Website (“first-party cookies”), or by Third-Parties, such as those who serve content or provide advertising or analytics services on the Website (“third-party cookies”). These third parties can recognize you when you visit our website and also when you visit certain other websites.

Any data collected with these cookies will be used in accordance with the Privacy Policies of each individual Third-Party Operator or Service Provider we make use of, which you can explore via the links further down in this document.

If you are uncomfortable with these cookies or certain types of cookies, you can change your browser’s settings to delete cookies that have already been set and to not accept new cookies. Please note, however, that if you delete cookies or do not accept them when visiting our Website or using our Services, you might not be able to use some or all of the features of the Website or Services we offer.

Web Beacons or Tracking Pixels

Our emails may contain a “web beacon” (or “tracking pixel”) to tell us whether our emails are opened and verify any clicks through to links or advertisements within the email.

We may use this information for purposes including determining which of our marketing emails are more interesting to users and to query whether users who do not open our emails wish to continue receiving them.

The beacon/pixel will be deleted when you delete the email. If you do not wish the pixel to be downloaded to your device, you should read the email in plain text view or with images disabled.

Data Analytics

Our Website and Services may use Third-Party analytics tools that use cookies, web beacons, or other similar information-gathering technologies to collect standard internet activity and usage information. The information gathered is used to compile statistical reports on User activity such as how often Users visit our Website and Services, what pages they visit and for how long, etc. We use the information obtained from these analytics tools to monitor the performance of and improve our Website and Services.

Do Not Track signals

Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website. For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time. How browsers communicate the Do Not Track signal is not yet uniform. As a result, the Website and Services are not set up to interpret or respond to Do Not Track signals communicated by your browser.

Payment processing

In case of Services requiring payment, you may need to provide your payment method or account information, which will be used solely for processing payments. We may use third-party payment processors (“Payment Processors”, such as PayPal) to assist us in processing your payment information securely.

Payment Processors adhere to the latest security standards as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. Sensitive and private data exchange happens over an SSL-secured communication channel and is encrypted and protected with digital signatures, and the Website and Services are also in compliance with strict vulnerability standards in order to create as secure of an environment as possible for Users. We will share payment data with the Payment Processors only to the extent necessary for the purposes of processing your payments, refunding such payments, and dealing with complaints and queries related to such payments and refunds.

Please note that the Payment Processors may collect some Personal Information from you, which allows them to process your payments (such as your email address, billing address, credit card details, etc.) and handle all the steps in the payment process through their systems, including data collection and data processing. The Payment Processors’ use of your Personal Information is governed by their respective privacy policies which may or may not contain privacy protections as protective as this Policy. While we have made every reasonable effort to ensure the legitimacy and capability of such Payment Processors, we still suggest that you review their respective privacy policies before making use of their services.


We may permit certain third-party companies to help us tailor advertising that we think may be of interest to Users and to collect and use other data about User activities on the Website. These companies may deliver ads that might place cookies and otherwise track User behaviour.

Social media features

Our Website and Services may include social media features such as the ability to visit our social media platforms or share a post to a social media, collectively “Social Media Features”. These Social Media Features may collect your IP address, what page you are visiting on our Website and Services, and may set a cookie to enable Social Media Features to function properly. Social Media Features are hosted either by their respective providers or directly on our Website and Services. Your interactions with these Social Media Features are governed by the Privacy Policy of their respective providers.

Email marketing

We offer electronic newsletters to which you may voluntarily subscribe at any time. We are committed to keeping your e-mail address confidential and will not disclose your email address to any third parties except as stated in this document or for the purposes of utilizing a third-party provider to send such emails. We will maintain the information sent via e-mail in accordance with applicable laws and regulations.

In compliance with the CAN-SPAM Act, all e-mails sent from us will clearly state who the e-mail is from and provide clear information on how to contact the sender. You may choose to change your preferences or stop receiving any marketing emails altogether by following the instructions included in the link on these emails or by contacting us. However, you may continue to receive essential transactional emails or other non-marketing communications from us, as necessary.

Access to and integrity of information

We take reasonable and routine steps to ensure that the information we collect is up to date and accurate and remind Users at the time of data collection and periodically through the use of our Services that they may request access to the information we have stored about them, or to update/request that we update or correct any information that may be outdated or incorrect. Information that does not need to be updated to fulfil the purpose for which it was collected will not be updated by us without the client’s express request.

You may at any time request and update or access your information by contacting our Information Officer using the details at the end of this document.

Security of Information and Regular Monitoring

We are committed to preventing unauthorised access, damage, loss of or destruction of your personal information and abide by the conditions for the lawful processing of your data as set out by the POPI Act by implementing and monitoring security measures as per industry standards and best practices, including regular policy reviews and GAP Analysis reviews, to ensure that:

  1. Your data is processed in a lawful and non-privacy-infringing way,
  2. Your data is processed only for the specific purpose as explicitly defined at the time of collection,
  3. If your data undergoes any additional processing, that is still in accordance with the original purpose that you gave their consent to,
  4. Your data is kept as complete, accurate and updated as possible by providing means to update it yourself, or by us, either routinely or on request,
  5. Documentation of our data processing operations are available to you on request,
  6. Your data will be kept confidential and not to disclose any personal information to third-party operators or service providers unless required by law or in the course of the proper performance of our/their duties to effectively provide our/their Services,
  7. You or the responsible party can exercise your/their rights, after providing adequate proof of identity and Power of Attorney where applicable, to have the ability to confirm the existence, access, correct and/or delete your data using the means prescribed in this document within a reasonable frame of time; at a prescribed fee, if any; and in a reasonable manner and format.

We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in our control and custody. However, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and the Website and Services cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by an unauthorised or malicious third party, despite best efforts.

As the security of Personal Information depends in part on the security of the device you use to communicate with us and the security you use to protect your credentials, please take appropriate measures to protect this information, including but not limited to, keeping your device’s operating system and security software up to date.

Retention periods

Unless no agreements, other laws or terms in this policy apply, stored personal information will be kept for no longer than necessary, or only until the purpose for which said information was collected has ultimately been fulfilled, or until the collected information has become obsolete, or for a retention period of one year after the information was finished being processed.

Personal Information data will be destroyed as soon as reasonably practicable, when the information is no longer necessary for the specified purpose it was collected for, or where the data subject withdraws consent in terms of this policy, or where the collected personal information is inaccurate, irrelevant, excessive, or incomplete, unless further retention is required by law or agreed to between the parties.

We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the expiration of the retention period.

Personal Information transfers to and from various countries

Due to the widespread use of cloud technology and how our modern interconnected digital world operates, it is accepted that Personal Information will almost always be transferred internationally, and possibly to multiple countries in some way or in some part, by the digital devices, products and services we all use every day.

While it is not always possible to pinpoint the exact location or country in which these cloud services are hosted or where their servers reside, the use of these services are required for us to provide our Services, to stay competitive in our industry and markets, and to keep up to date with the abilities and conveniences that technological innovation allows.

By making use of our Website or Services, or those integrations of our Third-Party Operators or Service Providers, you give us consent to transfer your Personal Information across borders in the following ways, but not limited to:

  • Cloud server services and facilitators for communication, such as Outlook, Zoom or WhatsApp.
  • Cloud services for data file storage, such as OneDrive or Google Drive.
  • Bulk email communication service providers, such as Mail Chimp.
  • Other Third-Party services integral to the storage and management of your information or the delivery of our Services, such as a CRM database/platform.

Sharing of information with Third-Parties and Service Providers

Depending on the requested Services or as necessary to complete any transaction or provide the Services we offer, we may share your information with the trusted subsidiaries and joint venture partners, affiliates, contracted companies, and or service providers (collectively, “Service Providers”) we rely upon to assist in the operation of the Website and our Services and whose privacy policies are consistent with ours or who agree to abide by our policies with respect to Personal Information. We will not share any information with unaffiliated or unauthorized third parties.

Service Providers are not authorized to use or disclose your information except as necessary to perform their duties, fulfil their services to us or on our behalf, or to comply with legal requirements. Service Providers are given the information they need only in order to perform their designated functions, and we do not authorize them to use or disclose any of the provided information for their own marketing or any other purposes.

As mentioned in other parts of this policy, we may share and disclose your information to the following categories of Service Providers:

  • Communication and collaboration services
  • Data analytics services
  • Data storage services
  • Sales and marketing services

Our staff are regularly reminded that they have a confidentiality obligation towards data subjects who hold a Right to Privacy under the Constitution, and neither we nor our staff will disclose your information to a third party unless:

  • If required or permitted by law, such as to comply with a subpoena or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
  • In the event we go through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your Personal Information may be among the assets transferred.

Links to other resources

Our Website and Services may contain links to other resources that are not owned or controlled by us. Please be aware that we are not responsible for the data practices of such other resources or third parties. We encourage you to be aware when you leave the Website and Services and to read the Privacy Policies of each and every external resource that may or may not collect Personal Information.

Data Breach Management

An event that has caused or can potentially cause damage to our organisation’s assets, reputation and/or personnel which includes our customers and any other Personal Information we process, store or share, is deemed a Data Breach.

Where there are reasonable grounds to suspect that Users’ Personal Information has been disclosed to unauthorised third parties as a result of external activity, including, but not limited to:

  • The illegitimate use of our systems for the processing, storage or sharing of data by any person,
  • The transfer of personal information to persons who are not entitled to receive that information,
  • The loss or theft of personal and/or classified data and information via any means, for example hacking, attempted hacking, theft or loss of devices,
  • Unauthorised changes to personal information via our system hardware or software,
  • Unauthorised disruption or denial of service to our system,

we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement and regulatory authorities.

In the event of a data breach, we will make efforts to notify affected individuals and the regulator as soon as reasonably possible after the breach is discovered, if we believe that there is a risk of harm to the User as a result of the breach, or if notice is otherwise required by law, by:

  • Sending an email to the data subject’s last known email address;
  • Or placing a notice in a prominent position on our Website or in the delivery of our Services;
  • Or as may be directed by the Regulator;

and including enough information so that the affected parties can take the necessary measures by:

  • Providing a description of the possible consequences of the breach;
  • Providing a description of the measures that we intend to take or have taken to address the breach;
  • To mitigate the possible adverse effects of the breach; and
  • If known to us, the identity of the unauthorized person who may have accessed or acquired the personal information in question.

Any data breaches experienced by Third Party Operators or Service Providers must be reported to us or the relevant responsible party as soon as possible.

Data protection rights under the GDPR

If you are a resident of the European Economic Area (“EEA”), you have certain data protection rights and we aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information, as described below and in other parts of this Policy. If you wish to be informed what Personal Information we hold about you and if you want it to be removed from our systems, please contact us using the information at the end of this Policy. In certain circumstances, you have the following data protection rights:

  1. You have the right to withdraw consent where you have previously given your consent to the processing of your Personal Information. To the extent that the legal basis for our processing of your Personal Information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
  2. You have the right to learn if your Personal Information is being processed by us, obtain disclosure regarding certain aspects of the processing, and obtain a copy of your Personal Information undergoing processing.
  • You have the right to verify the accuracy of your information and ask for it to be updated or corrected. You also have the right to request us to complete the Personal Information you believe is incomplete.
  1. You have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent. Where Personal Information is processed for the public interest, in the exercise of an official authority vested in us, or for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to your particular situation to justify the objection. You must know that, however, should your Personal Information be processed for direct marketing purposes, you can object to that processing at any time without providing any justification. To learn whether we are processing Personal Information for direct marketing purposes, you may refer to the relevant sections of this Policy.
  2. You have the right, under certain circumstances, to restrict the processing of your Personal Information. These circumstances include: the accuracy of your Personal Information is contested by you and we must verify its accuracy; the processing is unlawful, but you oppose the erasure of your Personal Information and request the restriction of its use instead; we no longer need your Personal Information for the purposes of the processing, but you require it to establish, exercise or defend your legal claims; you have objected to processing pending the verification of whether our legitimate grounds override your legitimate grounds. Where processing has been restricted, such Personal Information will be marked accordingly and, with the exception of storage, will be processed only with your consent or for the establishment, to exercise or in defence of legal claims, for the protection of the rights of another natural, or legal person or for reasons of important public interest.
  3. You have the right, under certain circumstances, to request the erasure of your Personal Information from our records. These circumstances include: the Personal Information is no longer necessary in relation to the purposes for which it was collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data has been unlawfully processed. However, there are exclusions of the right to erasure such as where processing is necessary for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, to exercise or in defence of legal claims.
  • You have the right to request and receive your Personal Information that you have provided to us in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance from us, provided that such transmission does not adversely affect the rights and freedoms of others.
  • You have the right to complain to a data protection authority about our collection and use of your Personal Information. If you are not satisfied with the outcome of your complaint directly with us, you have the right to lodge a complaint with your local data protection authority. For more information, please contact your local data protection authority in the EEA. This provision is applicable provided that your Personal Information is processed by automated means and that the processing is based on your consent, on a contract which you are part of, or on pre-contractual obligations thereof.

Use and processing of collected information

We act as a data controller and a data processor in terms of the GDPR when handling Personal Information, unless we have entered into a data processing agreement with you in which case you would be the data controller and we would be the data processor.

Our role may also differ depending on the specific situation involving Personal Information. We act in the capacity of a data controller when we ask you to submit your Personal Information that is necessary to ensure your access and use of the Website and Services. In such instances, we are a data controller because we determine the purposes and means of the processing of Personal Information and we comply with data controllers’ obligations set forth in the GDPR.

We act in the capacity of a data processor in situations when you submit Personal Information through the Website and Services. We do not own, control, or make decisions about the submitted Personal Information, and such Personal Information is processed only in accordance with your instructions. In such instances, the User providing Personal Information acts as a data controller in terms of the GDPR.

In order to make the Website and Services available to you, or to meet a legal obligation, we may need to collect and use certain Personal Information. If you do not provide the information that we request, we may not be able to provide you with the requested products or services. Any of the information we collect from you may be used for the following purposes, but not limited to:

  • Delivering products or services;
  • Improving products and services;
  • Sending administrative information;
  • Sending marketing and promotional communications;
  • Sending product and service updates;
  • Responding to inquiries and offer support;
  • Requesting user feedback;
  • Improving user experience;
  • Posting customer testimonials;
  • Delivering targeted advertising;
  • Administering prize draws and competitions;
  • Enforcing terms and conditions and policies;
  • Protecting from abuse and malicious users;
  • Responding to legal requests and prevent harm; and
  • Running and operating the Website and Services.

Processing your Personal Information depends on how you interact with the Website and Services, where you are located in the world and if one of the following applies: (i) you have given your consent for one or more specific purposes; this, however, does not apply, whenever the processing of Personal Information is subject to California Consumer Privacy Act or European data protection law; (ii) provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof; (iii) processing is necessary for compliance with a legal obligation to which you are subject; (iv) processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; (v) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party. We may also combine or aggregate some of your Personal Information in order to better serve you and to improve and update our Website and Services.

We rely on the following legal bases as defined in the GDPR upon which we collect and process your Personal Information:

  • User’s consent
  • Performance of a contract
  • Our own legitimate interests

Note that under some legislations we may be allowed to process information until you object to such processing by opting out, without having to rely on consent or any other of the legal bases above. In any case, we will be happy to clarify the specific legal basis that applies to the processing, and in particular, whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

You are entitled to learn about the legal basis of information transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by us to safeguard your information. If any such transfer takes place, you can find out more by checking the relevant sections of this Policy or inquire with us using the information provided in the contact section at the end of this document.

California privacy rights

Users residing in California are afforded certain additional rights with respect to their Personal Information under the California Consumer Privacy Act (“CCPA”) to California residents.

As described in the relevant parts of this Policy, we may have collected the categories of Personal Information listed below in the past twelve (12) months from California residents:

  • Personal identifiers (such as email address, phone number, etc)
  • Internet or other electronic network activity

In addition to the rights, as explained in this Policy, California residents who provide Personal Information as defined in the statute to obtain Services for personal, family, or household use are entitled to request and obtain from us, once a calendar year, information about the categories and specific pieces of Personal Information we have collected and disclosed.

Furthermore, California residents have the right to request deletion of their Personal Information or opt-out of the sale of their Personal Information which may include selling, disclosing, or transferring Personal Information to another business or a third party for monetary or other valuable consideration. To do so, simply contact us using the details at the end of this document.

Changes and amendments

We reserve the right to modify this Policy or its terms related to the Website and Services at any time, at our discretion. When we do, we will revise the updated date at the bottom of this page. We may also provide notice to you in other ways at our discretion, such as through the contact information you have provided.

An updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the Website and Services after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected.

Acceptance of this policy

You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Website and Services and submitting your information you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use our Website and Services.

Contacting us

If you have any questions regarding the information we may hold about you or if you wish to exercise your rights, or if you have any other questions, concerns, or complaints regarding this Policy, we encourage you to contact our Information Officer using the details below.

Our Information Officer is responsible for:

  • Ensuring information policies are reviewed, monitored, up to date and sufficient;
  • Ensuring an Impact Assessment is done as and when deemed necessary;
  • Handling complaints or requests made in terms of this policy;
  • Supporting this policy with relevant documentation;
  • Ensuring POPI training or awareness is conducted;
  • Backing up data;
  • Reporting incidents and allocating security responsibilities; and
  • Any other relevant information-related duty or responsibility.

Please note that we may ask you to verify your identity before responding to such requests. Your request must provide sufficient information that allows us to verify that you are the person you are claiming to be or that you are the authorized representative of such a person. If we receive your request from an authorized representative, we may request evidence that you have provided such an authorized representative with power of attorney or that the authorized representative otherwise has valid written authority to submit requests on your behalf.

You must include sufficient details to allow us to properly understand the request and respond to it. We cannot respond to your request or provide you with Personal Information unless we first verify your identity or authority to make such a request and confirm that the Personal Information relates to you.

There are also certain prescribed forms by POPIA to be used when interacting with data subjects which can be requested from our Information Officer, including:

  • Form 1 – Objection to the processing of personal information
  • Form 2 – Request for correction or deletion of personal information or destruction or deletion of record of personal information
  • Form 4 – Request for data subject’s consent to process personal information for Direct Marketing

STPGLOBAL’s Information Officer:

Dirk Brouwer

We will attempt to resolve complaints and disputes and make every reasonable effort to honour your wish to exercise your rights as quickly as possible and within the timescales provided by applicable data protection laws.

STPGLOBAL Privacy Policy V1, last updated on July 8, 2023.