Last updated: 24/05/2018

This Privacy Policy describes the policies and procedures of SANNA – South African National Naturist Association and its partners – on the collection, use and disclosure of your information.

For the sake of brevity, ‘SANNA’ and its partners will be referred to as ‘SANNA’ in this document.

This Privacy Policy does not apply to information our customers may process when using our services.

—

Privacy and security are of utmost importance to SANNA and we strive to ensure that our technical and organizational measures in place respect your data protection rights.

COLLECTION OF PERSONAL DATA
“Personal data” refers to any information relating to an identifiable individual or his or her personal identity.

Personal data is collected on our website by SANNA and its partners.

The personally identifiable information that SANNA and its partners may collect from you when registering for an account includes: first and last name, postal address, phone number, email and IP address.

Your registrant information will be needed for the following purposes:

• provision of our services to you;
• prevention of fraudulent transactions;
• billing/invoicing operations;
• provision of a sales/technical support service;
• maintenance of your account with us;
• dispute resolution cases;
• enforcement of our Terms of Service, or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency;
• collection of aggregate statistics about use of our services;
• direct marketing;
• Much of the data collected is aggregated or statistical data about how individuals use our Services, and is not linked to any personal data, but to the extent it is itself personal data, or is linked or linkable to personal data, we treat it accordingly.

SANNA will NOT send you any unsolicited information, including emails, except as mentioned hereby.

New customers will receive a welcome email containing information about the features provided by the Service, as well as CP (Control Panel) and login details.

SANNA may also send system notifications upon need, related to any upgrade, maintenance or other service issues concerning your hosting account.

If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide. We may also receive a confirmation when you open an email from us.

SANNA will keep your personally identifiable information private and will NOT share it with any unauthorized third parties.

When you use our services, we may collect information about your engagement with and utilization of our services, such as processor and memory usage, storage capacity, navigation of our services, and system-level metrics. We use this data to operate the services, maintain and improve the performance and utilization of the services, develop new features, protect the security and safety of our services and our customers, and provide customer support. We also use this data to develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our business.

LEGAL BASIS FOR PROCESSING OF PERSONAL DATA
We collect personal information from you only when:

• we need your personal information to perform a contract with you (e.g. to deliver the services you have requested), or,
• the processing is in our legitimate interests and not overridden by your rights

We have a legitimate interest in operating our services and communicating with you as necessary to provide these services, for example when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities.

Please note that in most cases, if you do not submit the requested information, SANNA will not be able to provide the requested service to you.

In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need that information to protect your vital interests or those of some other person’s.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

ACCESS TO YOUR PERSONAL DATA
You may access and update your personal Information at any time from your My Profile – > My Account section, and/or My Profile – > Click gears icon -> Edit Profile section.

SECURITY OF YOUR PERSONAL DATA
SANNA is committed to protecting the security of member and potential member or website customer collected personal information. To do so, we use technical security measures to prevent the loss, misuse, alternation or unauthorized disclosure of information under our control. We use security measures including and not limited to: physical, electronic and managerial procedures to safeguard and secure the information we collect online. However, please keep in mind that the Internet cannot be guaranteed to be 100% secure.

If SANNA learns of a security system breach, we may attempt to notify you and send you any available protective information to the email address that you have provided to us or by posting a notice in your CP.

SHARING YOUR PERSONAL DATA WITH THIRD PARTIES
We will only share your information under the following circumstances:

1. Service Providers
   We may share information with third-party service providers that provide services on our behalf and to provide you with information relevant to you such as service upgrades.
2. As Required By Law and Similar Disclosures
   We may share information to (i) satisfy any applicable law, regulation, legal process, or governmental request; (ii) enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof; (iii) detect, prevent, or otherwise address fraud, security, or technical issues; (iv) respond to your requests; or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

THIRD-PARTY SERVICES
You may access other third-party services through our services, for example by clicking on links to those third-party services from within our services. We are not responsible for the privacy policies and/or practices of these third-party services, and we encourage you to carefully review their privacy policies.

PRIVACY OF YOUR PAYMENT DETAILS
We use third party payment processing companies who collect and store financial information, such as your payment method (valid credit card number, type, expiration date or other financial information), and their use and storage of that information is governed by the payment processors’ applicable terms of service and privacy policy. Collected billing information is used for the purposes of processing payments and fraud detection.

We do not store your financial account information on our systems; however, we have access to, and may retain, subscriber information through our third-party payment processor.

All PayFast transactions are subject to the PayFast Privacy Policy.

ACCOUNT PRIVACY
We consider your registration data and the content of all your messages private and confidential. The header of the messages that you send will contain your name (e-mail address) and Internet Protocol (IP) address. We will not intentionally monitor or disclose any of your e-mail content or registration data unless we are required to do so:

• to enforce these Terms and Conditions,
• by law,
• to defend ourselves in any legal action,
• to protect our property.

Since your password is essential for protecting your privacy, we encourage you to NOT share it with anyone and change it frequently. Additionally, you agree to respect the privacy and confidentiality of others.

AGE RESTRICTIONS
We offer services only to people who are 18+. Our services are not targeted to, intended to be consumed by or designed to entice individuals under the age of 18. If we learn that we have collected the personal information of a child under the age of 18, we will take steps to delete that information as soon as possible.

If you know of or have reason to believe that anyone under the age of 16 has provided us with any personal data, please contact us.

LOG FILES
We use IP addresses to analyze trends, administer our site and servers, track access, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information. It is possible that personal information about a customer may be included in the log files due to the normal functions of IP addresses and Web browsing.

COOKIES
We use different cookies on our website to make it as useful to you as possible. Cookies are small text files that we put on your computer or mobile device to tell us what you want to use on our site but they do not tell us who you are.

Here you can learn more about cookies and how to control or delete them.

Here are the cookies that we use on our site:

1. Essential cookies
   We use a cookie to remember your login for you and what you’ve put in the shop cart. Also, we set a cookie to help you choose a preferred font size for using the site. These cookies we consider essential for the operation of our website.
2. External web services
   We use an external live chat service (using cookies to remember your session name) to deliver real time support to you should you want to.
3. Analytics
   We use Google Analytics and Facebook cookies to monitor visitor activity on our website. No personally identifying data is included in this type of reporting. We do not share information about this analysis with any third parties.

Visitors can opt out of Google’s advertising tracking cookie or install a browser plugin to opt out of all Google Analytics tracking software. More information about Facebook’s analytics cookie is available here.

We assume you are happy with this usage of cookies on this website. If you are not happy, then you should either not use this site, or delete the cookies (you can check out how to do that according to your browser here), or browse the site using your browser’s anonymous usage setting (named “Incognito” in Chrome, “InPrivate” for Internet Explorer, “Private Browsing” in Firefox and Safari etc.).

We currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser.

Please remember that if you choose to delete the cookies or use the browser anonymously, you may find that certain sections of this website do not work properly.

YOUR RIGHTS UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)

If you are a resident of the European Economic Area (EEA), you have the following data protection rights:

• Managing Your Information
  You may access and update some of your information through the “Change Contact Details” section in the CP. If you have chosen to connect your account to a third-party application like Facebook, Google or Twitter, you can change your settings and remove permission for the app from the “Linked Social Accounts” section in the CP. You are responsible for keeping your personal information up to date.
• Rectification of Inaccurate or Incomplete Information
  You have the right to ask us to correct any inaccurate or incomplete personal information concerning you if you cannot update it yourself from within your account.
• Data Access and Portability
  In some jurisdictions, the applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
• Opt-out of marketing communications
  You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you.
• Data Retention and Erasure
  We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide the contracted services to you, you can request that we erase your personal information and close your account. Please note that if you request the erasure of your personal information:

We may retain some of your personal information so as to detect and prevent fraud and enhance safety. For example, if we suspend an account for security reasons, we may retain certain information from that account to prevent that customer from opening a new account in the future.

We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting and auditing purposes.

Because we maintain our platform to protect it from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

In cases where fraudulent or otherwise illegal activity has been deemed to have occurred as determined by law enforcement or management, the information may remain in our database indefinitely in order to help facilitate the prevention of repeated abuse in the future from the offending party.

Withdrawing Consent and Restriction of Processing
If you have provided your consent to the processing of your personal information, you may withdraw it at any time by sending us a communication specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing and pending the verification whether the SANNA’s legitimate grounds override your own.

Objection to Processing
In some jurisdictions, applicable law may entitle you to require us not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing, we will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.

By default, customers do receive any system updates, such as the newsletters, invoices and service email notifications. Customers cannot opt out of possibly receiving important system notifications, since the latter are deemed necessary for the performance of our contractual obligations to you.

Lodging Complaints
If you want to make a complaint about the way we are processing your data, you can contact us.

You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

—

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

INTERNATIONAL TRANSFERS OF INFORMATION WE COLLECT
We collect information globally and primarily store that information in the United States. We transfer, process and store your information outside of your country of residence. Whenever we transfer your information, we take steps to protect it.

To facilitate our global operations, we transfer information to the United States and allow access to that information from countries in which we and associated companies have operations for the purposes described in this policy. These countries may not have equivalent privacy and data protection laws, certainly not equivalent to the laws of many of the countries where our customers and users are based. When we share information about you, we make use of standard contractual data protection clauses, which have been approved by the European Commission.

A copy of your personal data will also be stored in the data center you have selected when signing up for our services. This is done so that SANNA can deliver the contracted service in the location specified by the customer.

COMPLIANCE WITH LAWS AND LAW ENFORCEMENT
SANNA cooperates with government and law enforcement officials to enforce and comply with the law. We will disclose any information about Users upon valid request by government or law officials as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including without limitation subpoenas), to protect your property and rights, or the property and rights of a third party, to protect the safety of the public or any person, or stop activity we consider illegal or unethical.

CHANGES TO PRIVACY POLICY
Any changes to our Privacy Policy will be placed here and will supersede this version of our Policy. We will take reasonable steps to draw your attention to any changes in our Policy. However, to be on the safe side, we suggest that you read this document each time you use the website to ensure that it still meets with your approval.

CONTACT US
If you have any questions about our Privacy Policy, or if you want to know what information we have collected about you, please use our Contact Us form.