1.1. Fairbridges Wertheim Becker (“FWB”, “we”, “us” or “our”) is committed to protecting and respecting your privacy. This Policy describes how we collect and process your personally identifiable information (“Personal Information”).
1.2. Please do not provide us with any Personal Information if you do not agree with this Policy. Except in the circumstances indicated in this Policy relating to our collection of special Personal Information, we encourage you not to provide any special Personal Information to us.
1.3. Your provision of information to us is voluntary, although if you do not provide certain information to us you may not be able to engage effectively with us. By submitting your information to us, you agree and consent to our processing and transfer of your information in accordance with this Policy. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Policy.
2. Why we collect your information
Protecting your information is important to us and we would like to explain why we collect, store and use your information and assure you that we will keep your information confidential. We will only share your Personal Information when legally required to do so, if we need to do so in order to fulfil our agreement with you, you have provided your consent, it protects your or our legitimate interests or you have given us your consent to do so.
3. How We Collect Your Information
As you interact with us, you will likely provide information directly to us. We may collect information when you request information or our legal services from us, are established on our system as a supplier or vendor, use our website at www.fwbattorneys.com, use or interact with our social media platforms, apply for employment with us, complete online assessments or surveys or contact us via mail, telephone, email, the Website or electronic forms and otherwise through your dealings with us. We may also collect information about you from personal or trade references that you have identified to us. FWB may collect the information directly from you or from third parties (such as regulators, government authorities and registries, or from other third parties relating to the legal services we are providing you). In some instances, it is necessary for you to provide us with the information, so that we can provide you such legal services and in others it is optional.
4. Information We May Collect
We may collect the following information about you:
4.1. as applicable, your name, email address, a home, work, postal or other physical address, other contact information, marital status, trading name, registration number, ID number, VAT number, business details, bank details, education, qualifications, employment history, references and other information you provide to us;
4.2. certain special personal information such as gender and race which you provide to us when applying for employment with us;
4.3. details relating to the legal services you have requested from us, and any orders and transactions with us, including any personal information, financial information and any other information regarding the matter which we require in the representation and/or assistance of our clients;
4.4. information contained in correspondence between us;
4.5. information that you provide when filling in forms on the Website or when responding to surveys;
4.6. details of your visits to the Website (including but not limited to traffic data, IP address, location data, browser type, “visitor action pixels” from Facebook and other third-party tracking technologies, information collected via cookies and server logs); and
4.7. your image may be captured on CCTV cameras if you attend at our premises.
5. Where We Store Your Information
5.1. The information that we collect from you is stored in locked physical storage, on our secure servers or, in the case of supplier and vendor bank details, on our third-party banking platform.
5.2. We have reasonable and appropriate security measures in place to protect the information we hold and to prevent unlawful processing, unauthorised access and accidental loss, destruction or damage. The Website uses a secure socket layer (SSL) for authentication and private communications.
5.3. Unfortunately, the transmission of information via the internet or email is not completely secure. Although we will do our best to protect your information, we cannot guarantee the security of your information transmitted via the Website or email; any such transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
5.4. We retain your information for as long as needed or permitted considering the purposes for which it was obtained. The criteria used to determine our retention periods include but are not limited to the length of time we have an ongoing relationship with you and our legal obligations and legitimate business interests.
6. How We Use Your Information
6.1. We use information held about you in the following ways, where applicable:
– 6.1.1. to provide you with services requested and improve our services to you if you are a client;
– 6.1.2. to purchase goods and services from you if you are a supplier;
– 6.1.3. to consider any application you make to us for employment;
– 6.1.4. to comply with applicable laws and regulations;
– 6.1.5. to respond to your queries, manage our relationship with you, and inform you about our services;
– 6.1.6. to communicate with persons for our internal purposes;
– 6.1.7. to enable our internal operations;
– 6.1.8. to exercise and defend legal rights;
– 6.1.9. to ensure that content on the Website is presented in the most effective manner for you and for your computer and to efficiently administer and improve the Website;
– 6.1.10. to measure the effectiveness of our advertising for statistical and market research purposes;
– 6.1.11. to conduct research, although participation in surveys is voluntary;
– 6.1.12. to notify you about changes to our services or to verify the accuracy of the information we hold about you; and
– 6.1.13. to send you the information you might be interested in our various newsletters, which may relate to the marketing and promotion of FWB’s services, to which you can subscribe. You can unsubscribe from our newsletters at any time and thereafter we will not send them to you.
6.2. Please also note that we also receive and store standard information from you of a non-identifiable nature, which is information that is received when you interact with the Site regarding your internet connection and online services. We may use such information to track movements on the Site and improve the Site and online services. Such information will include the URL you came from, IP address, domain type, browser type, country your device is located in, and any search terms you entered on our website. This information will not identify you unless combined with Personal Information and we do not use Personal Information in this process.
6.3. Furthermore, we do not knowingly collect Personal Information of children without the consent of a parent or guardian.
7. Disclosure / Transfer Of Your Information
7.1. We generally do not disclose your information to third parties, however, it may be necessary from time to time to make your information available to third parties (such as legal and regulatory authorities, advocates, courts, accountants, auditors, professional advisers, sub-contractors or providers of products and services).
7.2. We may disclose your information to the extent necessary to enforce our Letter of Engagement or any agreement with you, to provide services to our clients, to comply with a legal obligation or to protect the rights, property, or safety of us or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
7.3. We use Google Analytics to collect traffic statistics for the Website and this information is shared with Google. You can opt out of Google Analytics by installing the Google Analytics opt-out browser add-on. For more information, please visit the Google Privacy Terms.
8. Your Rights
8.1. You have the following rights in relation to the information we hold about you:
– 8.1.1. the right to access information held about you;
– 8.1.2. the right to request the correction of your information; we strive to maintain accurate information so if it is determined that your information is not accurate, we will work quickly to correct it;
– 8.1.3. the right to opt-out of marketing communications;
– 8.1.4. the right to request the deletion of your information, in which case we will use reasonable efforts to delete your information.
8.2. For your protection, we may only implement requests with respect to the information associated with the details you provide to us and we may need to verify your identity before implementing your request. We will respond to your request as required by applicable laws as soon as reasonably practicable.
8.3. Please note that we retain backup systems, which are essential to the operation of our business. If we are not able to delete residual copies from our systems or from our backup systems, your information will continue to be protected as required under this Policy.
9. How do We Protect Your Personal Information?
9.1. We take all reasonable and appropriate measures to ensure that your Personal Information is safeguarded and secure. We have reasonable standards of technology and operational security in place to attempt to prevent loss or misuse of any Personal Information. Any of our authorised employees who are responsible for the maintenance of any special Personal Information as defined by the Protection of Personal Information Act (No. 4 of 2013) (hereinafter “POPIA”) submitted by you are requested to maintain the confidentiality of such information unless you have expressed to us otherwise.
9.2. Whenever we commission other organisations to provide support services to us, we will bind them to our privacy policies as far as they may be required to have access to our customer’s personal information to perform such services. Our Website may contain links to or from other sites. While we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content or the security or privacy practices employed by other sites. We recommend that you always read the privacy and security statements on such sites.
9.3. When we will disclose personal information without consent. We will not disclose personal information to anyone outside the organisation or organisations who provide services to us without your permission unless:
– 9.3.1. we are compelled to do so by law or in terms of a court order;
– 9.3.2. it is in the public interest to do so;
– 9.3.3. it is necessary to protect our rights.
9.4. However, no system is perfect unfortunately and we cannot guarantee absolute security despite our best efforts. In the event that there is a privacy breach, we have to let you know unless we are obligated by law not to do so.
10. What are Cookies and How We Use Them
10.2. Cookies are not computer programs and do not run on a computer as programs do. The cookies located on our Website cannot gather information or function on their own. They cannot collect any personal information about you or your machine and cannot gather data or information about what you do on the Internet. Cookies merely enable us to provide a more valuable online experience to you. While you can set up your Internet browser to disable cookie technology, we do not recommend that you do this since some parts of this Website and our online services may not function properly, or at all.
11. Marketing: Mail, email, or SMS promotions
Provided that you have agreed to this, we may use your personal or other information to send you information on new services that may be of interest to you and from time to time will mail, email or SMS information to you about us, our products and services, or our partners and their products or services. If you do not wish to continue receiving this information you may contact us and we will remove you from our mailing list.
12. The General Data Protection Regulations
The principles set out in this Policy are also aimed at compliance with the EU General Data Protection Regulations, to the extent applicable.
13. Changes to this Policy
We will periodically review our privacy practices, which are subject to change. Any changes we may make to this Policy in the future will be posted on this page.
For the purpose of the Protection of Personal Information Act (4 of 2013), the responsible person is Fairbridges Wertheim Becker. Please contact our Information Officer at email@example.com if you have questions regarding this Policy or our privacy practices, if you would like to review, correct, update or delete the information we hold about you, if you would like to object to or withdraw your consent to our use of your information or if you would like to opt-out of marketing communications.
15. Details of authorities
If you wish to report a complaint regarding your Personal Information that we hold if you are unhappy that we have not addressed your concerns satisfactorily, you can contact the Information Regulator at: