Sources of Personal Information Collected by EVG

Generally, the collection will occur when you submit a request on our website. By providing your personal information to us, either through our online submission form, or as an email or telephone enquiry, you will be deemed to have consented to your personal information being collected by us and used and disclosed in accordance with this Privacy Notice.
We also collect personal information you have made public from social media platforms and/or from third party suppliers such as blogs, forums and news sites who collect public online data.

We may also collect inferences about you from the personal information you make public as we may be able to determine certain information based on the information you place in the public domain. These inferences are drawn in two ways:

1. By using algorithms that analyse the data that you have posted on social platforms; and

2. Through manual analysis and modelling based on your observed engagement and interactions on social platforms

 
EVG may also use proprietary technology tools (including without limitation Optivid) to analyse publicly available information and engagement data relating to digital content on social media platforms (including platforms operated by Meta Platforms, Inc., such as Facebook and Instagram). These tools analyse engagement metrics and publicly available content interactions to assist our clients in understanding audience engagement and optimising digital content performance.

Whenever your personal information is collected by means of automated processing, we will take appropriate measures to protect your legitimate interests by:

• Providing you with an opportunity to make representations about any decision made on the basis of automated processing; and

• By providing you with sufficient information about the underlying logic of the automated processing of the information to enable you to make such representations  

 
When you submit an enquiry or contact us on behalf of another person or persons, you confirm that you have obtained the consent of such person or persons for us to process such information in terms of this Privacy Notice. You further confirm that you have made the other person or persons aware of this Privacy Notice.
 
You must let us know immediately if you become aware that your personal information has been provided to us without your consent or if you did not obtain the consent of another person or persons to provide us with their personal information.
 
Why Do We Collect Your Personal Information?

Subject to the terms of this Privacy Notice, we will use your personal information only for the purposes for which it was collected and agreed with you.

• To conclude or perform in terms of a contract.

• To comply with an obligation imposed by law on us as the responsible party.

• To protect your legitimate interests

• To pursue our legitimate interests

• If you have consented to the processing

Note: Our legitimate interests for processing personal information are to provide a service to our customers, which includes providing technology and related services that empowers our customers to ensure their marketing efforts reach their target audiences with much greater accuracy and impact, and with objectives that may include improving that customer’s own services or products to its end users. Our services allow our customers to reach a larger, more relevant, and a more engaged consumer audience, and to learn more about their competitors, and other information available on the internet that may be relevant to our customers. You can restrict access to such information through using the privacy settings available on the relevant social platforms at any time. This may include analysing publicly available social media engagement data using EVG’s analytics technologies to generate aggregated insights for customers relating to audience engagement, marketing effectiveness, and content performance.
 
We will only process your personal information for lawful purposes, and it may be used for the following purposes:

• to administer a service to you

• to make an appointment to see us

• to provide you with advice

• to respond to your enquiries and/or requests

 
We strive to maintain the quality, accuracy, and completeness of your personal information which we process. The quality of personal information degrades over time, and you can assist us by contacting us if there are any changes to your personal information or if you become aware that we have inaccurate personal information of you. We will not be held responsible for any losses arising from poor quality personal information which is inaccurate or incomplete, that is provided to us by yourself or person acting on your behalf.

Disclosure of Personal Information to Third Parties

EVG does not (without your consent)

• EVG does not sell or transfer personal information obtained from social media platforms in violation of the applicable platform policies. Where EVG processes information originating from social media platforms (including Meta platforms), such processing is conducted in accordance with the relevant platform terms and applicable data protection laws.

• We will also not indirectly transfer and of your public social data to any ad network, data broker or other advertising or monetization-related service.

• Put your public social data in a search engine or directory, or include web search functionality on our applications on social platforms

• Prefill any content in captions, comments, messages, or the user message parameter of posts

• Proxy, request or collect your username or passwords for social platforms

• Transfer your public social data to a data broker or sell your public social data

• Share your user IDs for social platforms with service providers who build or run any of our applications

We will also not disclose any personal information without your consent unless we reasonably believe that the disclosure is required in terms of an obligation imposed by law, if it is necessary for the proper performance of a public law duty by a public body or to protect your legitimate interest or the legitimate interest of us or a third party (for example, to prevent a threat to your or another’s health and safety).

Any third parties whom we share your personal information with to process such information on our behalf, are subject to data protection agreements or data protection notifications. These parties include our customers, internal third parties, content creation contractors, service providers, joint venture parties and analytics and search engine providers.

Processing the Information of Children

We do not generally process the personal information of children (natural person under the age of 18 for POPIA and natural person under the age of 18 for the GDPR).

We will only process the personal information of a child if the processing is –

• Carried out with the prior consent of a competent person (usually parent or guardian)

• Necessary for the establishment, exercise, or defence of a right or obligation in law

• Necessary to comply with an obligation of international public law.

• Of personal information which has been deliberately made public by the child with the consent of the competent person

If you are a competent person and are aware that your child or children have provided us with personal information, please contact us so that we may delete, de-identify or destroy the personal information. If we become aware that we have collected or processed the personal information of children without verification or the consent of a competent person, we will take steps to delete, de-identify or destroy the information.

Transborder Flow of Personal Information

In certain instances, we may disclose your personal information to third parties that are based in foreign countries.

The transfer of this information will only be completed if:

• the third party who is the recipient of the information is subject to a law, binding corporate rules or binding agreement which provide an adequate level of protection.

• You consent to such transfer.

• The transfer is necessary for the performance of a contract between you and us, or for the implementation of pre-contractual measures taken in response to a request from you.

• the transfer is necessary for the conclusion or performance of a contract concluded between us and the third party that is in your interest; or

• The transfer is for your benefit and

  • it is not reasonably practicable to obtain the consent of the data subject to that transfer; and

  • if it were reasonably practicable to obtain such consent, the data subject would be likely to give it.

 
Although we will take every precaution, it is possible that your personal information will be transferred to a third party in a foreign country that is in a jurisdiction where you will not be able to seek redress under POPIA and does not have an equivalent level of data protection as in your jurisdiction. We will not be held liable for how such third parties process your personal information.

Security

We are committed to protecting the security of personal information. While no security measures can guarantee against compromise, we use a variety of security technologies and procedures to help protect data from unauthorised access, use, or disclosure.
 
We hold your personal information in:

• Computer systems

• Electronic databases

• In hard copy or paper files

We have implemented and maintain appropriate technical and organisational measures to ensure a level of security appropriate to protect personal information and prevent:

• loss of, damage to or unauthorised destruction of personal information; and

• unlawful access to or processing of personal information.

Retention of Data

EVG will retain personal information only for as long as is necessary for the purposes set out in this Privacy Policy unless there is a valid technical, legal or business reason for it to be deleted, destroyed or de-identified.
 
We may keep some of your personal information:

• For as long as it is required by law

• If it is reasonably needed for lawful purposes related to our functions and activities; or

• If it is reasonably required for evidentiary purposes

Social Media Integrations

Our website uses social media features and widgets (such as “Like” and “Share” buttons/widgets). These are provided and operated by third parties and either hosted by a third party or hosted directly on our website.

These features may collect information such as the page you are visiting on our website, your IP address, and may set cookies to enable them to function correctly.
In some cases, EVG may process engagement data from social media platforms in order to analyse content performance or optimise digital content distribution. Such processing may be carried out using EVG’s proprietary analytics technology platforms and in accordance with the applicable platform terms and data protection requirements of those platforms.

If you are logged into your account with the third party that provides the features, they may be able to link the information about your visit to and use of our website to the social media account you hold with them. They may also record your interactions with the features they provide on our website.

The third party may send us information in line with their policies and personal information you have chosen to make available to them, and we may share information with the third-party for the purposes of serving targeted to you via their social media platform.

Your interactions with the features are governed by the Privacy Policy of the third party providing them. If you wish to learn more about the data protection practices of third-party companies that provide these features, you must read their Privacy Policy.


Direct Marketing Communications

We may communicate with you using email and other channels as part of our effort to market our products or services, administer or improve our products or services, or for other reasons not stated in this Privacy Policy. You can withdraw consent to receive such direct marketing communications, as permitted in the legislation.
 
If you no longer wish to receive such correspondence, you may opt-out or UNSUBSCRIBE by clicking on the relevant link in any email communication you may have received. Further, you may express your communication preferences by:

• Contacting us by using the contact information in this Privacy Policy
   

Cookies, Device Data, and How it is Used

Cookies are small files that websites save to your hard disk or to your web browser’s memory. A cookie contains limited information, usually a unique identifier and the name of the website. When you use our website, we may use them to track how many times you have visited the website, to track the number of visitors to the website, your activity within the website, unique identifiers associated with your device, to store data you provide and to store technical information related to interactions with the website. Please see our Cookie Policy for further information.
 
We may automatically collect the following information about your use of the website through cookies, web beacons, and other technologies:

• Domain name.

• Browser type and operating system.

• Web pages you view.

• Links you click.

• IP address.

• Length of time to visit the website.

• Referring URL or the webpage that led you to the website.
   

We may also use session cookies, which are deleted when you close your browser, to store your user identification, to facilitate your movement around the website and other information useful in administering the session.
 
You may modify your browser settings to decline cookies or to notify you when a cookie is being placed on your computer or device. If you choose not to accept cookies, you may not be able to experience all the features of our website.
 
Your Rights

The Right to be Notified
 

• You have the right to be notified when your personal information has been accessed or acquired by an unauthorised person.

• When this occurs, we will notify the Information Regulator and you of the breach as soon as reasonably possible after discovering the breach.

• This will be communicated to you in one of the following ways:

• By mail (to last known address)

• By email (to last known email address)

• Placed in a prominent position on our website.

• Published in the news or media.

• As may be directed by the Information Regulator.

The Right to Establish Whether We Hold Your Personal Information and to Request Access to Such Information
 

• You have the right to be informed of whether we process personal information of you, receive a copy of such information and how we process your personal information.

• You can also request the above relating to any third parties.

• To do this, please use the contact details set out at the bottom of this Privacy Policy and specify what information you require.

• We will try and provide you with suitable means of accessing the requested information, where you are entitled to it.

• Note that you will be requested to provide identification before we can consider such requests.

• Requests for the personal information we hold will be done free of charge however a fee may apply for such information processed by third parties.

• There may be instances where we cannot grant access to your personal information. If we refuse access, we will give written reasons for the refusal.

T
he Right to Request Correction, Destruction or Deletion of Personal Information
 

• You may request us to correct or delete any information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or obtained illegally.

• If you believe that any personal information that we hold about you is excessive or has been unlawfully obtained or that we are no longer authorised to retain it, you may ask us to destroy or delete it.

• If we do not agree that there are grounds for action, you may ask us to add a note to the personal information stating that you disagree with it.

• We will require a copy of your identification document to confirm your identity before we will release this information.

• Once this is completed, we will notify you of such. The Right to Object to Processing in Certain Circumstances

• You may object at any time to the processing of your personal information in the prescribed form on reasonable grounds to your situation unless legislation prohibits such objection.

• You can object to the processing of your personal information for the purposes of direct marketing at any time.

The Right to Submit a Complaint to the Information Regulator
 

• Any person may submit a complaint to the Information Regulator alleging interference with the protection of the personal information of a data subject.

• Interference with the protection of personal information means:

  • Any breach of the 8 conditions for the lawful processing of personal information

  • Non-compliance with section 22 (notification of security compromise), 55 (duty of confidentiality), 69 (direct marketing), 70 (directories), 71 (automated decision making) or 72 (transborder flow of information)

  • A breach of the provisions of a code of conduct.

The Right to Institute Civil Proceedings
 

• You (or the Information Regulator at the request of yourself) may institute civil proceedings for damages against you for a breach which you deem to be interference with the protection of your personal information.

The Right to Restrict the Processing of Personal Information
 
We will restrict the processing of Personal Information in the following circumstances:

• You have contested the accuracy of personal information, for a period which enables us to verify the accuracy of the information,

• The processing is unlawful, and you oppose the destruction or deletion and request us to restrict it instead.

• You have requested us to transmit the personal data into another automated processing system.

All requests must be made in the prescribed manner and form. The various forms are available from the Information Regulator.