Privacy Policy Statement
This Privacy Statement was published on 30 May 2021.
Spirotech Mining Services (Pty) Ltd is committed to protect and respect your privacy in compliance
with the Protection of Personal Information Act 4 of 2013 (POPIA). This privacy statement explains
when and why we collect personal information, how we use it, the conditions under which we may
disclose it to others, and how we keep it secure. This Privacy Statement applies to the use of our
products and to our sales, marketing, and customer contract fulfillment activities. It also applies to
individuals seeking a job at Spirotech Mining Services (Pty) Ltd.
Who are we?
Spirotech Mining Services (Pty) Ltd is a young entrepreneurial business that was established in 2016.
Our company’s headquarters are located in Krugersdorp, Gauteng. Spirotech Mining Services (Pty)
Ltd is committed to protecting the privacy of those who use its website, and the confidentiality of
any personal information or details submitted or provided to it by you. Deane O’Haughey is the
Information Officer on behalf of Spirotech Mining Services (Pty) Ltd and can be contacted by email at:
1) When do we collect personal data about you?
When you are using our online technology solutions:
● When you interact with us in person, through correspondence, by phone, by social media, or
through our website.
● When we collect personal information from other legitimate sources, such as third-party data
aggregators, public sources, or social networks. We only use this data if you have given your consent
to them to share your personal data with others.
● We may collect personal data if it is considered to be of legitimate interest and if this interest is
not overridden by your privacy interests. Before data is collected, we make sure an assessment is
made, ensuring that there is an established mutual interest between you and Spirotech Mining
Services (Pty) Ltd.
● We may collect information for market-specific reasons.
2. What type of information do we collect?
(a) If you contact us using one of our websites we may request and/or require further information
about you or your company, including, but not limited to, your name, your company’s name, address,
telephone and facsimile number, email address, and other identity and contact information.
(b) If you use our services, request quotes for products through our websites or otherwise, make use
of the websites, we may ask you to provide further information, including but not limited to technical
specifications, financial information, and other business-related information.
(c) When you visit our website, we may collect certain routing information such as Internet Protocol
address of your originating Internet Service Provider, and information provided by “cookies” stored
on your hard drive. Cookies are small data files containing a unique identifier so that we can
recognize you each time you return to our sites, and which keep track of the pages you view on the
website and which services you use.
(d) We may also collect aggregate information about the use of our website, including which pages
are most frequently visited, how many visitors we receive daily, and how long visitors stay on each page.
(e) We may also collect feedback, comments, and questions received from you in service-related
communication and activities, such as meetings, phone calls, documents, and emails. For our
websites and CRM technology, we may collect IP addresses and actions taken on the site.
(f) If you upload photos or videos, add posts or comments, etc. on our social media websites the
information can be read by anyone with access to these social media websites and used for purposes
over which Spirotech Mining Services (Pty) Ltd or you have no control. Therefore, Spirotech Mining
Services (Pty) Ltd is not responsible for any information you submit to social media platforms.
(g) If you apply for a job at Spirotech Mining Services (Pty) Ltd, we collect the data you provide during
the application process.
(h) Spirotech Mining Services (Pty) Ltd does not collect or process any special categories of personal
data, such as public unique identifiers or sensitive data. All this data is stored on our company’s
online drive.
3. Use of your personal information
Any personal information or details you provide to Spirotech Mining Services (Pty) Ltd on this
website will be treated and kept in confidence but may be used by Spirotech Mining Services (Pty)
Ltd in the following ways:
(a) Where you have provided your contact details to receive information from Spirotech Mining
Services (Pty) Ltd, we may use your contact information to let you know about the products or
services we offer (including online reports and newsletters) and about enhancements or changes to
the website. We may also use your data to enable Spirotech Mining Services (Pty) Ltd to respond to
complaints, or to form management decisions regarding the future development of its website.
(b) If you indicate your consent on the email submission page, Spirotech Mining Services (Pty) Ltd
may also use your personal data for future mailings in relation to the subject of interest that you
identified on the email contact page or the needs analysis page, in relation to support and/or new
products or services that may be relevant to you. You can unsubscribe from this at any time by
clicking on the “unsubscribe” link on any email we send to you or by contacting us at the details at
the end of this Notice.
(c) Where you have provided personal information for potential employment with Spirotech Mining
Services (Pty) Ltd, you agree that Spirotech Mining Services (Pty) Ltd, members of the Spirotech
Mining Services (Pty) Ltd or non-affiliated companies who perform support services on Spirotech
Mining Services (Pty) Ltd on behalf may use the information submitted on the Careers/Current
Vacancies page of this website to process your application. Spirotech Mining Services (Pty) Ltd may
also use your personal data to notify you of job openings within Spirotech Mining Services (Pty) Ltd
which may be of interest to you.
(d) The information you provide on the application form will be kept on file by Spirotech Mining
Services (Pty) Ltd in our CV management system for a period of twelve (12) months from the date of
submission. If after that period no job has been matched to the information you provided, your
personal information will be deleted from our database.
4. With whom do we share your personal information?
(a) We may provide the information we collect about you and your company, including your email
address or other identifying information, to our Affiliates and third parties, including manufacturers,
suppliers, or others involved in the distribution chain to provide the products or services that have
been requested. We may provide aggregate statistics about visitors, website transactions, or other
website activity.
(b) We may disclose information about you or your company if we have a good faith belief that we
are required to do so by law or legal process; to respond to claims, or to protect your vital interests
or the vital interest of others.
5. How long do we keep this information about you?
We keep information in line with our data retention schedule which provides that no personal data is
retained for a period longer than is necessary for the particular business purpose unless we are
required to retain the personal information to meet our legal and regulatory requirements. In all
cases our need to use your personal information will be assessed on a regular basis and information
that is no longer required will be securely deleted.
This means that we may retain your personal data for a reasonable period of time after your last
interaction with us. When the personal data that we have collected is no longer required, we will delete it securely. We may process data for statistical purposes, but in such cases, data will be anonymized.
6. Data subject rights
In some circumstances, the Protection of Personal Information grants you certain rights in relation to
your data. These rights are detailed below along with details of how we will respond in
circumstances where these rights apply.
Subject access requests:
You may have the right to access particular personal data that we hold about you. This is referred to
as a subject access request. In circumstances where these rights apply, we will respond promptly, and
certainly within one month from the point of receiving the request and all necessary information
from you.
Our formal response will include details of the personal data we hold about you, including
the following:
– Sources from which we acquired the information;
– The purposes for processing the information; and
– Persons or entities with whom we have shared the information.
Right to rectification
You may have the right to the rectification of any inaccurate personal data we hold concerning you.
Taking into account the purposes of the processing, you may have the right to have incomplete
personal data completed, including providing a supplementary statement.
Right to erasure
You may have the right to the erasure of your personal data without undue delay.
Right to restriction of processing
You may have the right to restrict the processing of your personal data where one of the following
applies:
a) your personal data is inaccurate; the processing is unlawful and you oppose to the erasure of the
personal data;
b) you have objected to us processing your personal data whilst we verify whether there are
legitimate grounds for the processing activity.
Notification obligation regarding rectification or erasure of personal data or restriction of processing
Where we rectify, erase, or restrict the processing of any personal data, we will notify any third
parties to whom we have shared the personal information unless this is impossible or involves
disproportionate effort.
Right to data portability
You may have the right to receive your personal data in a structured, commonly used and
machine-readable format for transmission to another data controller.
Right to object
You may have the right to object, at any time, to the processing of your personal data, including any
personal profiling: unless this relates to processing that is necessary for a task carried out in the
public interest or an exercise of official authority vested in us. In this circumstance, we will cease
processing your personal data unless we can demonstrate compelling legitimate grounds for the
processing.
Right to not be subject to decisions based solely on automated processing
We do not carry out any automated processing, which may lead to an automated decision based on
your personal data.
Accuracy of information
In order to provide excellent customer service, we must hold accurate personal data about you. We
take reasonable steps to ensure the accuracy of any personal data or sensitive information we
obtain. We ensure that the source of any personal data or sensitive information is clear and we
carefully consider any challenges to the accuracy of the information. We also consider when it is
necessary to update the information, such as name or address changes and you can help us by
informing us of these when they occur.
Use of sub-contractors (processors and sub-processors)
We may use sub-contractors to process personal data on our behalf, and we are responsible for
making sure they commit themselves to adhere to this Privacy Policy and applicable data protection
legislation by signing a Data Processing Agreement.
Changes to this Privacy Statement
Spirotech Mining Services (Pty) Ltd reserves the right to amend this Privacy Statement at any time.
The applicable version will always be found on our websites. We encourage you to check this Privacy
Statement occasionally to ensure that you are happy with any changes.
If we make changes that significantly alter our privacy practices, we will notify you by email or post a
notice on our websites prior to the change taking effect.
Your right to complain with a supervisory authority
If you are unhappy with how your personal data has been processed, you may, in the first instance,
contact
Deane O’Haughey
Tel: 010 600 2160
Cell: 082 529 0834
Email: deane@spiroms.co.za
Jolandie Lamprecht
Cell: 083 410 4442
If you remain dissatisfied, then you have the right to apply directly to your national supervisory
authority for a decision. The supervisory authorities can be contacted at:
complaints.IR@justice.gov.za
Signed on behalf of Spirotech Mining Services (Pty) Ltd
—————–
D O’Haughey
Managing Director