Privacy Policy

1. General principles for processing of personal data

In order to ensure that your personal data is processed correctly and with a suitable level of data protection, PNG has adopted the following processing principles:

• Personal data is processed lawfully, fairly and in a transparent manner.
• Personal data is collected only for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
• Personal data shall be adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.
• Personal data shall be accurate and, where necessary, kept up to date. Inaccurate or incomplete personal data will be rectified, erased, or further processing suspended.
• Personal data shall not be kept in a form which permits identification of the data subject for longer than is necessary for the purposes for which the data was collected or for which it is further processed.
• Personal data shall be processed in a manner that ensures appropriate security of the personal data.

PNG will always inform you of the collection and processing of your personal data unless we have a legitimate reason not to do so.

2. Types of personal data

We will collect and process your personal data in several ways when you engage with us via the various existing channels.

Some personal data is necessary to process in order for us to provide you with the services you have requested, and some personal data you may choose to provide voluntarily. We will always let you know which personal data is necessary and the consequences of not providing such data to us — for instance, that we may not be able to fully satisfy your request.

The personal data that we collect and process can generally be divided into the following categories:

• Contact information such as name, address, phone number, email address, job title, and place of work.
• Correspondence information that you provide when contacting us via online contact forms, email, or telephone.
• User information such as technical data regarding usage and viewing, including IP addresses, when you visit our website or applications.
• Application information, including your CV, in the event that you apply for a position with PNG. You will receive separate information regarding the processing of personal data when you submit your application.

As a general rule, PNG will not process any special categories of personal data about you unless you have provided your explicit consent, or we are required to do so in order to comply with applicable legislation.

3. Our purposes for processing your personal data

We only process your personal data in order to pursue a legitimate purpose. Generally, we will only process your personal data if:

• You have provided your consent to such processing; or
• The processing is necessary for the performance of a contract; or
• The processing is necessary for compliance with a legal obligation to which we are subject; or
• The processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, and such processing is not considered to be harmful to you.

We process your personal data for the following purposes:

• To provide you with services and information that you request from us.
• To administer our business relationships and negotiate and execute agreements.
• To provide general customer service and support.
• To understand how our website and services are used, and to evaluate and improve them.
• To communicate with you regarding various matters.
• To send you relevant technical or service-related communications where you have consented to receive these.

4. Cookies

We may use cookies on our website. The purposes for processing data collected through cookies are:

• To operate, improve and optimise the performance and user experience of the website and its services.
• To perform user analysis and to provide better and more relevant services.
• For statistical and analytical purposes.

5. Disclosure, transfer and making available personal data to recipients

Our disclosure and transfer of your personal data to recipients is kept to a minimum and is subject to the existence of an adequate level of data protection.

We may disclose or make personal data available to recipients under the following circumstances:

• Service providers who carry out services on our behalf, such as hosting, cloud computing, IT support, or other data processing activities. Such recipients are only permitted to process your personal data in accordance with our instructions, governed by a written data processing agreement.
• To establish, exercise or defend our legal rights.
• If you have provided your prior consent to the disclosure of your personal data to a specific recipient.
• In the event of any merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of PNG's business or assets.
• As set out in our cookie policy (section 4 above).

If your personal data is transferred to a recipient in a jurisdiction that does not ensure an adequate level of data protection, PNG will only make such a transfer in accordance with applicable data protection legislation, including the requirements of the Protection of Personal Information Act, 2013 (POPIA).

6. Automated individual decisions

We may use automated decision making based on your personal data. Automated decision making will only take place if the decision is:

• Necessary for entering into, or the performance of, a contract between you and PNG; or
• Authorised by applicable law, which also provides for suitable measures to safeguard your rights and legitimate interests; or
• Based on your explicit consent.

Where we use automated decision making, we will ensure that suitable security measures are implemented. Special categories of personal data will not be subject to automated decision making unless you have provided your explicit consent, or the processing is necessary for reasons of substantial public interest on the basis of applicable law.

7. Your consent

As noted above, some of our processing activities will be based on your consent. In such cases, you have the right to withdraw your consent at any time.

If you withdraw your consent, we will cease processing your personal data, unless and to the extent that continued processing or storage is permitted or required by applicable data protection legislation or other applicable laws and regulations.

Please note that the withdrawal of your consent will not affect the lawfulness of processing conducted prior to the withdrawal. As a consequence of withdrawing consent, we may not be able to satisfy your requests or provide you with certain services.

8. Data security

In order to safeguard your personal data, PNG has implemented appropriate technical and organisational measures to ensure a level of security appropriate to the risks represented by the processing and the nature of the personal data to be protected.

PNG has taken measures to protect personal data against accidental or unlawful destruction, accidental loss, alteration, unauthorised disclosure or access — in particular where the processing involves the transmission of personal data over a network — and against all other unlawful forms of processing.

9. Your rights

You have the right to access the personal data processed about you, subject to certain statutory exceptions. Furthermore, you may object to the collection and further processing of your personal data. You also have the right to have inaccurate personal data corrected, and you may request that we restrict the processing of your personal data.

We will delete or correct any information that is inaccurate or out of date by reason of the time elapsed since it was collected or by reason of any other information in our possession.

If you submit a written request, we will delete your personal data without undue delay, unless we have a legal basis to continue the processing — for example, where continued processing is necessary to establish, exercise, or defend a legal claim, or is necessary for the performance of a contract with you.

To exercise any of the rights described above, please contact us via the details set out in section 13.

When making such a request, please provide us with relevant information to identify you, including your full name and email address. We will respond to your request as soon as possible and within one month of receipt.

If you disagree with our processing of your personal data, you have the right to lodge a complaint with the Information Regulator of South Africa or your relevant local data protection authority.

10. Complaints

If you have any complaints about the processing of personal data carried out by PNG, please feel free to contact us at any time using the details below. We will review and assess your complaint and may contact you to obtain further information if required.

11. Links to other websites

Our website may contain links to other websites or integrated third-party sites. PNG is not responsible for the content of third-party websites, or for the practices of such companies regarding the collection of personal data. When you visit third-party websites, we encourage you to read the owners' policies on the protection of personal data and other relevant policies.

12. Changes to this Privacy Policy

PNG reserves the right to amend this Privacy Policy at any time due to changes in applicable legislation or in PNG's processes and practices. We will inform you of any material amendments to this policy. The most recent version of this policy will always be available on this page.

13. Contact information

If you have a request or question regarding the processing of your personal data, or this privacy policy in general, please contact us:

This policy is governed by and construed in accordance with the laws of the Republic of South Africa, including the Protection of Personal Information Act, 2013 (POPIA).