Introduction

At Trending Talent, we respect your privacy and take the protection of personal information very seriously. The purpose of this policy is to describe the way that we collect, store, use, and protect information that can be associated with you or another specific natural or juristic person and can be used to identify you or that person (personal information) or entity.

The purpose of this policy is to describe the way that we handle your personal information.

Please read the following Privacy Policy to understand what personal information you provide us with, how this information is processed and the purposes for which such processing is undertaken by Trending Talent.

Trending Talent are data controllers with respect to personal information about you that we receive from you and/or from our clients. We may also act as a data processor of your personal information in certain circumstances, in which case we will process personal information as described in this policy.

Applicable laws

Our privacy policy is written in line with the General Data Protection Regulation (GDPR), agreed upon by the European Parliament and Council in April 2016 and the Protection of Personal Information Act, 4 of 2013 (POPIA) and takes into consideration any other local laws and guidelines including Promotion of Access to Information Act,2 of 2000 (PAIA).

Acceptance and Consent

You must accept all the terms of this policy when you order our products/instruments or request/use our services. If you do not agree with anything in this policy, then you may not order our goods or request/use our services, instruments, or technology.

You may not order our goods or request/use our services, instruments, or technology if you do not accept this policy.

Deemed acceptance

By accepting this policy, you are deemed to have read, understood, accepted, and agreed to be bound by all of its terms.

Audience

This policy applies to you if you are:

• a visitor to our website; or
• a user of any kind on our portal; or
• a customer who has ordered or requested the goods or services that we provide.

This policy applies to you under certain circumstances.

Personal information

Personal information includes:

• certain information that we collect automatically when you visit our website.
• certain information collected on registration (see below)
• certain information collected on submission; and
• optional information that you provide to us voluntarily (see below)

but excludes:

• information that has been made anonymous so that it does not identify a specific person
• permanently de-identified information that does not relate or cannot be traced back to you specifically
• non-personal statistical information collected and compiled by us; and
• information that you have provided voluntarily in an open, public environment or forum including any blog, chat room, community, classifieds, or discussion board (because the information has been disclosed in a public forum, it is no longer confidential and does not constitute personal information subject to protection under this policy).

Personal information includes information we collect:

1. Automatically when you visit our website,
2. On registration,
3. On submission,
4. When completing questionnaires and tests on our portal, and
5. Provided by you voluntarily.

It excludes:

1. Anonymous,
2. De-identified,
3. Non-personal statistical, and
4. Other public information.

Common examples of the types of personal information which we may collect and process include your:

• identifying information - such as your name, date of birth, or identification number of any kind;
• contact information - such as your phone number or email address;
• address information - such as your physical or postal address; or
• demographic information - such as your gender or marital status.
• Sensitive personal information

Depending on the goods or services that you require, we may also collect sensitive personal information including your:

• financial information - such as your bank account details;
• sensitive demographic information - such as your race or ethnicity;
• medical information - such as information about your physical or mental health;
• sexual information - such as information about your sex life or sexual orientation;
• criminal information - such as information about your commission or alleged commission of any offence or about any related legal proceedings;
• employment information - including your membership of a trade union; and
• beliefs - including your political or religious beliefs.

Collection of Information

On registration

We collect certain information on registration when you register on our website. We will use this personal information to fulfill your account, provide additional services and information to you as we reasonably think appropriate, and for any other purposes set out in this policy.

• Once you register on our website and or portal, you will no longer be anonymous to us. You will provide us with certain personal information when you register on our website or portal.
• This personal information might include:
  • your name and surname
  • your email address
  • your telephone numbers
  • work attainments and documentation
  • your company name, company registration number, and VAT number;
  • your postal address or street address; and
  • your username and password.

On order or request

We collect certain information when you order our goods or request our services from us. When you order our goods, create a premium profile, or request our services from us, you will be asked to provide us with additional information on a voluntary basis (goods or services information).

When completing job applications

We collect certain information when you complete job applications on our website or portal. This information might include but is not limited to:

• Skills
• Knowledge
• Qualification
• Experience
• Career history
• Medical history

When completing assessments

We collect certain information when you complete assessments on our website or portal. This information might include but is not limited to:

• Work strengths
• Skills and abilities
• Motivation and culture
• Strategic capability
• Career interested and motivation
• Other information related to work engagement, performance and retention

From browser

We collect certain information from your web browser, including your Internet usage information when you visit our website. We automatically receive and record Internet usage information on our server logs from your browser, such as your Internet Protocol address (IP address), browsing habits, click patterns, version of software installed, system type, screen resolutions, colour capabilities, plug-ins, language settings, cookie preferences, search engine keywords, JavaScript enablement, the content and pages that you access on the website, and the dates and times that you visit the website, paths taken, and time spent on sites and pages within the website (usage information). Please note that other websites visited before entering our website might place personal information within your URL during a visit to it, and we have no control over such websites. Accordingly, a subsequent website that collects URL information may log some personal information.

Cookies

We may place small text files called 'cookies' on your device when you visit our website. These files do not contain personal information, but they do contain a personal identifier allowing us to associate your personal information with a certain device. These files serve a number of useful purposes including:

• granting you access to age restricted content;

• tailoring our website's functionality to you personally by letting us remember your preferences;

• improving how our website performs;

• allowing third parties to provide services to our website; and

• helping us deliver targeted advertising where appropriate in compliance with the applicable laws.

Your internet browser generally accepts cookies automatically, but you can often change this setting to stop accepting them. You can also delete cookies manually. However, no longer accepting cookies or deleting them will prevent you from accessing certain aspects of our website where cookies are necessary. Many websites use cookies and you can find out more about them at www.allaboutcookies.org. We collect certain information from cookies that we may send to your computer to try and give you a personalised experience.

Third party cookies

Some of our business partners use their own cookies or widgets on our website. We have no access to or control over them. Information collected by any of those cookies or widgets is governed by the privacy policy of the company that created it, and not by us.

Web beacons

We collect certain information from web beacons on our website to compile anonymous information about our website. Our website may contain electronic image requests (called a single-pixel gif or web beacon request) that allow us to count page views and to access cookies. Any electronic image viewed as part of a web page (including an ad banner) can act as a web beacon. Our web beacons do not collect, gather, monitor, or share any of your personal information. We merely use them to compile anonymous information about our website.

Optional details

We collect certain optional information, that you provide when you upload or download content from our website or when you enter competitions, take advantage of promotions, respond to surveys, or register and subscribe for certain additional goods or services. You may also provide additional information to us on a voluntary basis (optional information). This includes content or products that you decide to upload or download from our website or when you enter competitions, take advantage of promotions, respond to surveys, order certain additional goods or services, or otherwise use the optional features and functionality of our website.

Recording calls

We may monitor and record any telephone calls that you make to us, unless you specifically request us not to.

Your obligations

You may only send us your own personal information or the information of another data subject where you have their permission to do so.

For what purposes do we process personal information about you?

We are committed to keeping your personal information confidential and secure. The way in which we use your personal information will depend upon your user rights based on your or your company’s work pr study objectives in accessing our services, instruments, and technology in the specific below areas:

• Recruitment
• Assessment
• Engagement including performance and development management
• Retention

Legal bases for processing your personal information

We must have a legal basis to process your personal information. In most cases, the legal basis will be one of the following:

• to fulfil our contractual obligations to Clients; for example, provide recruitment, assessment, engagement and retention data for client talent management purposes and to ensure that invoices are paid correctly;
• to comply with our legal obligations;
• to meet our legitimate interests; for example, to provide the Services, to conduct analysis that help us to improve our Services, to ensure that any complaints or concerns can be promptly dealt with, and to ensure our records are kept up to date and accurate; and
• goods or services purposes - such as collecting orders or requests for and providing our goods or services;
• marketing purposes - such as pursuing lawful related marketing activities;
• business purposes - such as internal audit, accounting, business planning, and joint ventures, disposals of business, or other proposed and actual transactions; and
• legal purposes - such as handling claims, complying with regulations, or pursuing good governance.
• We may use your usage information for the purposes described above and to:
  • remember your information so that you will not have to re-enter it during your visit or the next time you access the website;
  • monitor website usage metrics such as total number of visitors and pages accessed; and
  • track your entries, submissions, and status in any promotions or other activities in connection with your usage of the website.
  • We may use any of your personal information that you provide to us for the purposes that you indicated when you agreed to provide it to us.
• Your consent, you have the right to withdraw your consent at any time by contacting using the avenues provided in the portal and /or using the contact details below.

Consent to collection

We will obtain your consent to collect personal information:

• In accordance with applicable law;
• When you provide us with any registration information, submit job applications and partake in assessment exercises or provide optional information;
• We will get your consent to collect your personal information in accordance with applicable law when you provide us with it.

Messages and updates

We may send administrative messages and email updates to you about the website. In some cases, we may also send you primarily promotional messages. You can choose to opt-out of promotional messages.

We may use your information to send you administrative messages and email updates to you regarding the website and for marketing purposes where lawful.

Targeted content

While you are logged into the website, we may display targeted adverts and other relevant information based on your personal information. In a completely automated process, computers process personal information and match it to adverts or related information. We never share personal information with any advertiser, unless you specifically provide us with your consent to do so. Advertisers receive a record of the total number of impressions and clicks for each advert. They do not receive any personal information. If you click on an advert, we may send a referring URL to the advertiser's website identifying that a customer is visiting from the website. We do not send personal information to advertisers with the referring URL. Once you are on the advertiser's website, however, the advertiser is able to collect your personal information. We may use your information for targeted content in certain, specified instances.

Disclosure

We may share your personal information with:

• our clients for the purposes as stated in this policy and based on your profile status and preferences
• other divisions or companies within the group of companies to which we belong so as to provide joint content and services like registration, for transactions and customer support, to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about our products, services, and communications (they will only use this information to send you marketing communications if you have requested their goods or services);
• an affiliate, in which case we will seek to require the affiliates to honor this privacy policy;
• our goods or services providers under contract who help provide certain goods or services or help with parts of our business operations, including fraud prevention, bill collection, marketing, technology services (our contracts dictate that these goods or services providers only use your information in connection with the goods or services they supply or services they perform for us and not for their own benefit);
• credit bureaus to report account information, as permitted by law;
• banking partners as required by credit card association rules for inclusion on their list of terminated merchants (in the event that you utilise the services to receive payments and you meet their criteria); and
• other third parties who provide us with relevant services where appropriate.
• We may share your personal information with third parties for the purposes of fulfilling our obligations to you among other purposes.
• Regulators
• We may disclose your personal information as required by law or governmental audits.

Law enforcement

We may disclose personal information if required:

• by a subpoena or court order;
• to comply with any law;
• to protect the safety of any individual or the general public; and
• to prevent violation of our customer relationship terms.
• We may disclose personal information to third parties if required for legal reasons.
• No selling
• We will not sell personal information. No personal information will be disclosed to anyone except as provided in this privacy policy.

Marketing purposes

We may disclose aggregate statistics (information about the customer population in general terms) about the personal information to advertisers or business partners.

Employees

We may need to disclose personal information to our employees that require the personal information to do their jobs. These include our responsible management, human resources, accounting, audit, compliance, information technology, or other personnel.

Change of ownership

If we undergo a change in ownership, or a merger with, acquisition by, or sale of assets to, another entity, we may assign our rights to the personal information we process to a successor, purchaser, or separate entity. We will disclose the transfer on the website. If you are concerned about your personal information migrating to a new owner, you may request us to delete your personal information.

Security

We take the security of personal information very seriously and always do our best to comply with applicable data protection laws. Our technology platform is hosted in a secure server environment that uses a firewall and other advanced security measures to prevent interference or access from outside intruders. All our data is encrypted and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities. We implement disaster recover procedures where appropriate.

Accurate and up to date

We will try to keep the personal information we collect as accurate, complete, and up to date as is necessary for the purposes defined in this policy. From time to time, we may request you to update your personal information on the website. You are able to review or update any personal information that we hold on you by accessing your account online or emailing us. Please note that in order to better protect you and safeguard your personal information, we take steps to verify your identity before granting you access to your account or making any corrections to your personal information.

Retention

We retain the User’s non-updated personal information (including test results) for a period of 24 months, after which time we may anonymize the data and use it for research purposes. We will also anonymize data at the request of the Client or the Participant. If the Participant requests their data to be anonymized, we will first inform the Client who requested the Assessment be made available to the Participant.

We retain Clients' personal information for as long as we maintain a relationship with Clients, and then for a reasonable period of time that allows us to assist with any queries, requests, or complaints regarding the Assessments and/or the Services, to commence or defend legal claims, and to comply with our regulatory obligations (including record retention obligations). For this purpose, we take our lead from the SAICA Retention Policy of April 2016 as its guide to the retention of records, aligned to the various applicable South African legislative acts.

We will only retain your personal information for as long as it is necessary to fulfill the purposes explicitly set out in this policy, unless:

• retention of the record is required or authorized by law; or
• you have consented to the retention of the record.
• During the period of retention, we will continue to abide by our non-disclosure obligations and will not share or sell your personal information.

We may retain your personal information in physical or electronic records at our discretion.

Transfer to another country

We may transmit or transfer personal information outside of the country in which it was collected to a foreign country and process it in that country. Personal information may be stored on servers located outside the country in which it was collected in a foreign country whose laws protecting personal information may not be as stringent as the laws in the country in which it was collected. You consent to us processing your personal information in a foreign country whose laws regarding the processing of personal information may be less stringent.

Updating or removing

You may choose to correct or update the personal information you have submitted to us, by clicking the relevant menu on any of the pages on our website or contacting us by email.

Limitation

We are not responsible for, give no warranties, nor make any representations in respect of the privacy policies or practices of linked or any third party websites.

Your rights

You are entitled to see the personal information that we hold about you. You may ask us to make any necessary changes to ensure that personal information about you is accurate and kept up to date. You will not have the right to make changes to the Assessment Data, however, as this would undermine the accuracy and value of the Assessment data.

If you would like:

• any further information about the personal information that we collect, the purposes for which we collect it and how we protect it;
• a copy of the information we hold about you;
• to verify the information we hold about you;
• to anonymize your personal information;
• to object to our use of your personal information;
• to restrict our use of your personal information; or
• to receive your personal information in a usable electronic format and transmit it to a third party (right to data portability),

then please request these services in our portal, or Email us at support@trending-talent.com

Enquiries

If you have any questions or concerns arising from this privacy policy or the way in which we handle personal information, please contact the Information Officer:

Information Officer: Joe Pieterse Email: joe@trending-talent.com Deputy Officer: Mike Cross Email: mike@trending-talent.com

Physical Address: V&A Waterfront, Dock Side Junction, Waterfront, Cape Town, 8001

If any complaints relating to Personal Information in terms of POPIA, these can be logged directly with the Information Regulator (South Africa): inforeg@justice.gov.za https://www.justice.gov.za/inforeg/

Changes to our Privacy Policy

We may update this Privacy Policy from time to time. The updated Privacy Policy will be published on our Website and, where appropriate, notified to you by email. You should refer to the Privacy Policy from time to time in order to keep yourself up to date with regard to the way we process your personal information.

Trending Talent Privacy Policy Version 2.2 (last updated June 2021)