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POPIA Section 18 Privacy Notice

As required by Section 18 of the Protection of Personal Information Act 4 of 2013 (POPIA)

1. Responsible Party

Name: Orbio (Pty) Ltd

Registration Number: [To be registered with CIPC]

Physical Address: Johannesburg, South Africa

Contact Email: info@orbio.co.za

Information Officer: dpo@orbio.co.za

2. Purpose of Collection

We collect and process your personal information for the following purposes:

To provide CRM and ITSM services
To manage customer relationships and support
To comply with legal and regulatory obligations
For internal business administration and analytics
To communicate with you about our products and services

3. Categories of Personal Information

We may collect the following categories of personal information:

Personal details: Name, surname, email address, phone number
Employment details: Job title, department, organisation
Technical data: IP address, browser information, device ID
Usage data: Service interactions, preferences, activity logs

4. Lawful Basis for Processing

We process your personal information based on the following lawful grounds under POPIA:

Consent: Where you have provided explicit consent
Contract: Where processing is necessary for the performance of a contract
Legal Obligation: Where required by South African law
Legitimate Interest: For our legitimate business interests

5. Data Recipients and Transfer

Your personal information may be shared with:

Our service providers and contractors (under confidentiality agreements)
Regulatory authorities when legally required
Business partners with your consent

Cross-border transfers: Your data is stored in South Africa with appropriate safeguards. We ensure adequate data protection for any cross-border transfers as required by POPIA Section 72.

6. Your Rights as a Data Subject

Under POPIA, you have the right to:

Access: Request details of personal information we hold about you
Correction: Request correction of inaccurate or outdated information
Deletion: Request deletion of your personal information
Objection: Object to processing of your personal information
Data Portability: Request your data in a structured, machine-readable format
Withdraw Consent: Withdraw consent at any time
Lodge a Complaint: Complain to the Information Regulator

7. Data Retention

We retain your personal information for as long as necessary to fulfil the purposes outlined in this notice, or as required by law. Default retention period is 7 years. After this period, your data will be securely deleted or anonymised.

8. Security Measures

We implement appropriate technical and organisational security measures to protect your personal information, including:

Encryption of data in transit and at rest
Access controls and role-based permissions
Regular security assessments
Staff training on data protection

9. How to Exercise Your Rights

To exercise any of your data subject rights, please contact us:

Email (DPO): dpo@orbio.co.za

Email (Information Officer): info@orbio.co.za

Phone: +27 (0) 11 000 0000

Address: Johannesburg, South Africa

Information Regulator (South Africa)

JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2017

Email: inforeg@justice.gov.za

Website: inforegulator.org.za

10. Collection of Information from Data Subject

We collect personal information directly from you, the data subject, where you:

Register for or use our CRM and ITSM services
Submit enquiries, support requests, or feedback
Complete forms or documentation
Communicate with us via email, phone, or our portal

We may also collect information from publicly available sources, business partners, or your organisation, in accordance with POPIA Section 13.

Mandatory vs Optional: Where collection is mandatory, you will be informed. Where optional, you may decline without impacting service quality where lawful.