EOH GROUP PRIVACY STATEMENT

The purpose of this document (“Privacy Statement”) is to inform the reader of how EOH Holdings Limited and all of its subsidiaries (“EOH” ) manages and processes (any operation or set of operations performed on data by any means such as collecting, recording, organization, storage, adaptation or alteration of personal information etc.) personal information. The manner in which EOH manages Personal Information (personal data, as defined in the data protection laws, includes, but is not limited to, names, postal address, email address, telephone number, date of birth etc.), is subject to the Electronic Communications and Transactions Act 25 of 2002; Protection of Personal Information Act 4 of 2013 and the European Union General Data Protection Regulations (“Data Protection Laws”).

When users (individuals who make use of any EOH websites and/or applications) interact with EOH, submit information to EOH, or sign up for any products and/or services offered by EOH, all personal information, which may be collected through our website or other channels, is treated as confidential and private. EOH manages the user’s personal information in the following ways:

By collecting personal information;
Using such personal information;
Sharing (amongst ourselves) the users personal information; and
Disclosing such personal information to EOH’s authorised service providers as well as relevant third parties in the manner set forth in this Privacy Statement.

EOH may from time to time update this document to ensure that it is consistent with future developments, industry trends and/or any changes in legal or regulatory requirements.

1. COLLECTION OF PERSONAL INFORMATION

1.1.1 Upon submission of an application form or other forms relating to any of EOH’s products and services;
1.1.2 When interacting with EOH’s customer service officers (via telephone calls, letters, face-to-face meetings and emails);
1.1.3 When making use of any EOH service i.e. Websites and/or applications;
1.1.4 Upon submission of a request for EOH to contact them, or request to be included in an email or other mailing lists;
1.1.5 When there is a response to EOH promotions, initiatives or to any request for additional Personal Data;
1.1.6 When contacted by or respond to EOH marketing representatives and customer service officers;
1.1.7 When EOH receives references from business partners and third parties;
1.1.8 When EOH seeks information from third parties in connection with the products and services applied for; and
1.1.9 Upon submitting Personal Information to EOH for any other reason.

1.2 When a user browses EOH Websites, it is generally done anonymously. EOH does not automatically collect Personal Information unless such information is provided or login credentials are used.

1.3 If EOH is provided with any Personal Information relating to a third party (e.g. information about a spouse, children, parents and/or employees), by submitting such information, a user confirms that the consent of the third party to provide EOH with such personal information has been obtained.

1.4 Users must ensure that all Personal information submitted to EOH is complete, accurate,
true and correct. Failure to do so may result in EOH’s inability to provide users with the
products and services requested.

2. PURPOSES FOR THE COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION

2.1.1 To respond to queries and requests;
2.1.2 To manage the administrative and business operations of EOH and comply with internal policies and procedures;
2.1.3 To facilitate business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Companies;
2.1.4 To match any Personal Information held, relating to any of the purposes listed herein;
2.1.5 To resolve complaints and handle requests and/or enquiries;
2.1.6 To prevent, detect, investigate a crime, analyse and manage commercial risks;
2.1.7 To provide media announcements and responses;
2.1.8 To monitor or record phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
2.1.9 For legal purposes (including but not limited to obtaining legal advice and dispute resolution);
2.1.10 To conduct investigations relating to disputes, billing, suspected illegal activities or fraud;
2.1.11 To meet or comply with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on EOH (including but not limited to responding to regulatory complaints, reporting to regulatory bodies and conducting audit checks, due diligence and investigations); and
2.1.12 For purposes which are reasonably related to the aforementioned.

2.2 In addition to the above, EOH collects, uses and discloses Personal Information of users for the following purposes:

2.2.1.1 Opening or continuation of accounts and establishing or providing users with the products and services subscribed to;
2.2.1.2 Facilitating the continuation or termination of user subscription to EOH products and services;
2.2.1.3 Facilitating the daily operation of the products and services (including but not limited to billing, customer service, customer verification, technical support, network maintenance and troubleshooting);
2.2.1.4 Facilitating third party services if purchased, obtained, administered or processed through EOH;
2.2.1.5 Managing and executing EOH service level agreements with users;
2.2.1.6 Processing of payment instructions, direct debit facilities and/or credit facilities requested by users;
2.2.1.7 Enforcement of repayment obligations (including but not limited to debt collection, filing of claims and retrieval of payments from losses made by service partners);
2.2.1.8 Administering and processing any insurance claims and payments arising under the respective policies;
2.2.1.9 Credit and internal risk management (including but not limited to performing credit checks and disclosures to law enforcement agencies);
2.2.1.10 Generation of internal reports (including but not limited to annual, operational and management reports);
2.2.1.11 Processing referral payments and commission fees to EOH’s external partners;
2.2.1.12 Administering fee adjustments, refunds and waivers;
2.2.1.13 Notifying users of their entitlements under loyalty and reward programmes with EOH;
2.2.1.14 Analysing user experience with EOH products and services so as to help us improve, review, develop and efficiently manage the products and services offered; and
2.2.1.15 For purposes which are reasonably related to the aforementioned.

2.3.1.1 For analytics and tracking, including facilitating the sale of analytical data;
2.3.1.2 To conduct market research and surveys to enable EOH to understand and determine customer location, preferences and demographics in order to develop special offers and marketing programmes in relation to EOH products and services, and to improve our service delivery and customer experience;
2.3.1.3 To provide additional products, services and benefits to users, which include promotions, loyalty and reward programmes from EOH;
2.3.1.4 To match Personal Information with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of products and services by EOH;
2.3.1.5 For leads generation and management of marketing EOH’s products and services;
2.3.1.6 To administer contests, competitions and marketing campaigns, and personalize user experience;
2.3.1.7 To communicate advertisements involving details of EOH’s products and services, special offers and rewards, either to general customers, or to communicate advertisements which EOH has identified as being of interest to specific users (this includes but is not limited to upselling, cross selling and telemarketing);
2.3.1.8 To organise promotional events and corporate social responsibility projects; and
2.3.1.9 For purposes which are reasonably related to the aforementioned.

2.6 Once EOH receives confirmation that a user wishes to withdraw consent for marketing or promotional materials/communication, it may take up to 30 (thirty) working days for the withdrawal to be reflected on the system. Therefore, users may continue to receive marketing or promotional materials/communication during that period of time. In may be noted that even upon withdrawal of consent for the receipt of marketing or promotional materials, EOH may still contact users for other purposes in relation to the products and services held by users or subscriptions to EOH.

3. PROCESSING OF PERSONAL INFORMATION

3.2.1 EOH will only collect Personal Information for a purpose consistent with the purpose for which it is required. The specific purpose for which information is collected will be apparent from the context in which it is requested.
3.2.2 EOH will only process Personal Information in a manner that is adequate, relevant and not excessive in the context of the purpose for which it is processed.
3.2.3 Personal Information will only be processed for a purpose compatible with that for which it was collected, unless the user has agreed to an alternative purpose in writing or EOH is permitted in terms of national legislation of general application dealing primarily with the protection of Personal Information.
3.2.4 EOH will keep a record of all Personal Information collected and the specific purpose for which it was collected for a period of 1 (one) year from the date on which it was last used.
3.2.5 EOH will not disclose user Personal Information relating to any third party, unless prior written consent from the user is obtained, or where EOH is required to do so by law.
3.2.6 If Personal Information is released with consent of the user, EOH will retain a record of the information released, the third party to which it was released, the reason for the release and the date of release, for a period of 1 (one) year from the date on which it was last used.
3.2.7 EOH will destroy or delete any Personal Information that is no longer needed by EOH for the purpose it was initially collected, or subsequently processed.

4. DISCLOSURE OF PERSONAL INFORMATION

4.1.1 EOH’s related corporations and employees to provide content, products and services to address user questions and requests in relation to customer accounts, subscription and billing arrangements with EOH as well as products and services;
4.1.2 Companies providing services relating to insurance and consultancy to EOH;
4.1.3 Agents, contractors or third party service providers who provide operational services to EOH, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security or other services to EOH;
4.1.4 Vendors or third party service providers in connection with marketing promotions and services offered by EOH;
4.1.5 Other telecommunications, content or other service providers to facilitate their provision of content or services, or for interconnection, inter-operability, system operation and maintenance and billing between service providers;
4.1.6 Collection and repossession agencies in relation to the enforcement of repayment obligations for debts;
4.1.7 Credit bureaus for the purpose of preparing credit reports or evaluation of creditworthiness;
4.1.8 External banks, credit card companies and their respective service providers;
4.1.9 EOH’s professional advisers such as auditors and lawyers;
4.1.10 Relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and
4.1.11 Any other party to whom users authorise EOH to disclose Personal Information to.

5. USE OF COOKIES

5.1.1 To enable certain features and functions on websites, e.g. remembering user-id, favourite channel selections, browsing and other service preferences;
5.1.2 To build up a profile of how users experience the website;
5.1.3 To improve the efficiency of EOH’s website;
5.1.4 To administer services to users and advertisers; and
5.1.5 To establish usage statistics.

5.3 Advertisements on the EOH website may be provided by third party advertisers and their agencies. These may generate cookies to track how many people have seen a particular advertisement (or use the services of third parties to do this), and to track how many people have seen it more than once. EOH does not control these third parties and their cookie policies. Should users have any questions about EOH’s Data Privacy Policy, they may contact EOH.

6. QUERIES

6.3 If a user withdraws their consent to any or all use of Personal Information, depending on the nature of such a request, EOH may not be in a position to continue to provide its products and services to users. In addition, EOH may not administer any contractual relationship in place, which in turn may also result in the termination of any agreements with EOH, and may result in the user being in breach of contractual obligations or undertakings. EOH’s legal rights and remedies in such event are expressly reserved.

7. GOVERNING LAW

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EOH GROUP PRIVACY STATEMENT