Privacy Policy

SwitchTransact Privacy Policy

Last updated on April 25, 2021


For purposes of transparency, responsibility and accountability, the Privacy Policy following below, therefore, describes the Verge policies on the Collection, Use, and Disclosure of Personal Information, which information is stored and maintained on the Verge Electronic Usership Database, which in turn allows users access to the full use of the Verge’s interactive websites and mobile applications (the "Services").

In this context Verge is bound by, and adheres to, the stipulations of Section 14(d) of the Constitution of the Republic of South Africa, 1996 (Act 108 of 1996 as amended), and by the stipulations of specifically but not exclusively, of Chapter 3, and acknowledge and make ourselves subjected to the prescripts of Section 51, of the Protection of Personal Information Act, 2013 (Act 4 of 2013) (the PoPI Act), for as far as Verge may use or make available the Personal Information it collects from its users.

It is, therefore, a precondition that before being accepted as user of Verge, account applicants will at enrolment, explicitly consent to the collection, use, and possible disclosure of their Personal Information as described in this Privacy Policy.

The terms "we", "us", and "Verge" refer to the internet domain registered as switchtransact.com. Capitalized terms used but not defined in this Privacy Policy shall have the meanings ascribed to them in the Verge User Agreement (also “Terms and Conditions”) – see https://switchtransact.com/terms-and-conditions.

 

1. Secure Electronic Storage of Personal Information

In adherence to the stipulations of Section 19 of the PoPI Act (2013), the electronic database of the Verge is as secure as it can be humanly possibly be made with continuous industry relevant updates of software to enhance existing high level Verge security measures.  These same high level of security measures are taken by the Verge’s internationally renowned associates where Verge keeps and maintains its electronic database on nationally and internationally based electronic computer server systems world wide.

1,2       Verge follows generally accepted industry standards to protect the Personal Information submitted and in its possession, and especially those sections of Personal Information described as a “Unique Identifier” in the PoPI Act (2013), both during transmission and once Verge has received it. For example, when a user enters sensitive information through Verge Services, Verge encrypts that information using secure socket layer technology (SSL).  (see web address https://switchtransact.com signifying that all data contained therein is encrypted on the highest possible levels of electronic security).

1.3       Although Verge always makes good faith efforts to store Personal Information in a secure operating environment that is not open to the public, users should understand that there is no such thing as complete internet security, and Verge cannot guarantee that there will be no unintended disclosures of a user’s Personal Information. If Verge becomes aware that a user’s Personal Information has been disclosed in a manner not in accordance with this Privacy Policy, we will use reasonable efforts to notify the respective user or users of the nature and extent of the disclosure (to the extent we know that information) as soon as reasonably possible and as permitted by law.

1.4       In Email communications from users to Verge, additional Personal Information not originally collected, is frequently communicated inadvertently.  This kind of information will receive the same kind of security and level of protection by Verge as are afforded all Personal Information collected and kept by Verge.

1.5       MEMBERS ARE, HOWEVER, REMINDED THAT DESPITE THE Verge‘s COMPLIANCE WITH THE PRESCRIPT RE PROTECTION OF PERSONAL INFORMATION CONTAINED IN THE PoPI ACT, Verge CANNOT PROTECT A MEMBER’S PERSONAL INFORMATION IF THE MEMBER DOES NOT PERSONALLY TAKE CARE TO PROTECT SUCH PERSONAL INFORMATION FROM MISUSE DUE TO THE MEMBER’S USE OF OTHER WEB-BASED APPLICATIONS AND SERVICES OR DISCUSSION GROUPS S/HE MAY BE PART OF, OR PARTAKE IN, WHERE SUCH PERSONAL INFORMATION MAY OR COULD ALSO BECOME ACCESSIBLE.

2. Personal Information Collected

2.1       By creating an acount with Verge, you consent to the collection of the following Personal Information, which constitutes the only Personal Information Verge will collect in respect of user's info and kept stored on its electronic users database in order for Verge to render the services it has contracted to deliver to its clients (see Sections 10 and 13 of the PoPI Act [2013]).

2.2       Initials, First name & Surname

2.3       ID Number or Passport Number

2.4       Gender

2.5       Language

2.6       Date of Birth

2.7       Email address:

2.8       Postal address & Courier address.

2.9       Telephone numbers.

2.10     Electronic Location.

2.11     The Personal Information collected and stored by Verge thus complies with the stipulations of Sections 10 and 13 of the PoPI Act (2013).

2.12     The above stated Personal Information of users, which is collected and stored by Verge, is also in many instances, clearly not new information pertaining to an individual who has been using web-based services for a while, as such user’s Personal Information could already have been captured in one or other manner by a number of other Service Providers with which the specific user interacts with on the internet. 

2.13     Banking and/or other user specific financial information required for online payments are collected by the specific Service Provider rendering the service for Verge.  The Service Provider will enter into a separate contract with the user in order to render the specific service, and it is up to the user to authorise such Service Provider to store a user’s banking or financial information as the user sees fit.  Verge has nothing to do with these transactions a user enters into.

 

3. Personal Information Submitted by a Member

3.1       Verge may store the information a user submits in order for him/her to be able to use the Services. Verge uses this submitted information to fulfil a user’s requests, provide Service functionality, improve Service quality, personalize user’s experience, display relevant advertising, provide customer support, send messages to a user, back up our systems, allow for disaster recovery, and comply with stated legal obligations.

3.2       Account registration:  a user must provide a valid Email address at enrolment in order to sign up for an account through the Services (such an account is automatically created for a user at enrolment).  Once a user has signed up for a Verge account, s/he will start to receive Emails from Verge.  A user may manage his/her Email preferences and modify some of the information associated with his/her account on his/her personal profile – see https://client.switchtransact.com/login

3.3       A Verge user cannot opt out of electronically receiving required Verge administrative or legal notices via his/her provided Email address. If a user should feel that an unauthorized account has been created depicting his or her likeness, s/he can request its removal by sending email to [email protected]. In which case that account will be immediately deleted from the Verge electronic users database, without following the normal procedures mentioned in paragraph 11 below.

3.4       A person cannot sign up by logging into online accounts s/he may have with third party service providers.

3.5       Public Content:  Any information a user may reveal in a rating or review posting or other online discussion or forum is intentionally open to the public and is not in any way private. A user should think carefully before disclosing any Personal Information in any public forum.  Users do not have permission to disclose any Individually Identifiable Information re the Verge in any public forum. What a user has written may be seen and/or collected by third parties and may be used by others in ways Verge are unable to control or predict.

3.6       Contacts & messaging:  A user may invite friends, colleagues, businesses, and others whom s/he knows (collectively, “Associates”) to join the Services by providing the Verge contact information, either of the website address or via Facebook at Verge.natshoot.

3.7       Users are advised that when they send an invitation to connect to an Associate or another User, that Associate or User will have access to the user’s email address because it is displayed in the invitation. The invitation may also contain other Services Content about the user, such as name and photograph, to help the User or Associate identify who is sending the invitation. A user’s Verge connections will also have access to the user’s Email address. Users may thus not invite anyone s/he does do not know and trust, to connect with him/her.

3.8       All Personal Information electronically stored by Verge is strictly in the format provided and entered by users themselves and that data will not be changed by Verge without express request by a user in person (no such request through a third party will be given any attention or regulate any action by Verge).

3.9       Verge explicitly states that it at all times remains the responsibility of a user to ascertain that his/her contact details are up to date on the Verge electronic users databasis.  Verge will not be held responsible should any contact details of a user change and the user has not made provable effort to either personally change such detail on his/her profile page on his/her Personal Natshoot web page, or by sending an Email to request updating of personal contact details to [email protected].  

 

4. Information Provided on Behalf of Minors

4.1       In terms of the stipulations Sections 34 and 35 of the PoPI Act (2013), Verge does not collect Personal Information of minors other than such information being submitted by the minor’s parent or legal guardian.   

4.2       Verge does not allow account of minors under the age of 13 years, except if there are specific reasons why a parent or guardian of such a minor would want that minor to have account.  A written application and a communications procedure will be entered into with the parent of guardian of such a minor when application is made for such a minor to join Verge through his/her parent or guardian.

 4.3       If the user is a parent or legal guardian of a minor between the ages of 13 and 18 years, and needs to communicate with Verge on that minor’s behalf, users may, in compliance with the Terms of Use (User Agreement), use the Services on behalf of such minor child. Any Personal Information a user provides while using the Services on behalf of his/her minor will be treated as Personal Information as otherwise provided herein. 

4.4       If a user is under the age of 18, they should not, and have no permission to use the Services.  Enabling access to Email and Internet Services for minors remain the responsibility of parents or legal guardians of minors.

 

5. Electronic Activity & Use (Analytics Services)

5.1       Verge may collect and store information related to a user’s use of the electronic Services it renders, such as browser type, IP address, unique device identifier, requested URL, referring URL, browser language, the pages users view, and the date and time of users’ visits.  This in order to build a picture of where Verge can better its services to users and to remain relevant in the electronic communications era.

5.2       Verge may also use third party analytics services in connection with the Services. For example, Verge may use services to record mouse clicks, mouse movements, scrolling activity, and/or clicks, as well as any text that users type into the Services (collectively, “Traffic Data”). These analytics services will not collect Personal Information which users do not voluntarily enter (see Verge User Agreement - https://switchtransact.com/terms-and-conditions) .

5.3       These services will not track users’ browsing habits across websites which do not use their services. Verge will use the information collected from these services to find usability problems and to make its Services easier to use. These recordings will never identify users or their accounts.   Verge only records anonymous user information, and stops such recording before a person signs-in or creates an account. Should Verge decide to use any third party analytics services that track or collect Personal Information, Verge will always provide users with advance notice and a user is then free to op out of such a process.

 

6. Cookies and Similar Mechanisms

6.1       “Cookies” are small computer files that are transferred to a user’s computer hard drive that contain information such as user ID, user preferences, lists of pages visited and activities conducted while browsing the Services. At the user’s option and own responsibility (and possible to his/her own expense), a user may block cookies or delete cookies from his/her hard drive. However, by disabling cookies, users may not have access to the entire set of features of the Services 

6.2       Please see the complete Verge Cookie Policy here:  https://switchtransact.com/cookie-policy

 

7. Third Parties

7.1       Verge does not rent, share, sell or trade Personal Information or users’ Demographic Data with third parties for marketing purposes.

7.2       Service Providers:  Verge, however, has to share Personal Information and Traffic Data with its business partners who assist Verge by performing core services (such as hosting, bulk Emails, online payments, fulfilment, or data storage and security) related to Verge operation of the Services and/or by making certain interactive tools available to Verge users. Those business partners shall be, and are, bound to uphold the same standards of security and confidentiality that Verge has promised to users in this Privacy Policy, and they will only use specific Contact Data and other Personal Information to carry out their specific business obligations to Verge and to provide users’ requested services.

7.3       Business Transfers:  Verge may from time to time have to share information of or about users with subsidiaries, joint ventures, or other companies under common control, in which case Verge will require them to honour this Privacy Policy. If another company acquires Verge or all, or substantially all, of its assets, that company will possess the same information, and will assume the rights and obligations with respect to that information as described in this Privacy Policy, unless Verge notifies users otherwise.

7.4       Links:  The Services may contain links to unaffiliated third party websites. Except as set forth herein, Verge does not share users’ Personal Information with them, and are not responsible for their privacy practices. Verge suggests that users read the privacy policies on all such third party websites.

7.5       Trans-border information flow:  Verge stores backups of its System on servers in specifically European countries for sake of security and for sake of effectiveness of such services rendered by international service providers.  This Verge procedure complies with the prescripts of Section 72(1)(d) and 72(1)(e) of the PoPI Act (2013).

 

8. Use and Disclosure of Users’ Personal Information

8.1       Customization and Contact:   The objective of collecting Personal Information from users is to provide an efficient, meaningful, and customized experience. For example, Verge can use Personal Information to: (a) help make the Services easier for users to use by not having to enter information more than once; (b) help users to quickly find information and services; (c) help Verge to create content that is most relevant to users; and (d) alert users to new information and Services offered by Verge.

8.2       Verge may use users’ Contact Data to send users information about Verge or on Verge products or Services, to contact users when necessary, including to remind users of upcoming or follow-up appointments, and in conjunction with users’ use of certain interactive tools.  Verge may use users’ Demographic Data or Traffic Data to customize and tailor users’ experience on the Services, in Emails and in other communications, displaying content that Verge thinks users might be interested in and according to users’ preferences.

8.3       Due to the nature of the administrative procedures employed by Verge, all Verge  personnel have access to users’ Personal Information on the Verge electronic users database.  Verge personnel all subscribe to high ethical standards in respect of the content of this policy document, and are bound by a non-disclosure clause in their employment contracts re the possible disclosure of any Verge electronic information to third parties and are liable in instances of transgression of that clause. 

 

9. Duration of Retention of Personal Information

9.1       Once a person has been accepted as a user of Verge, his/her Personal Information collected at enrolment as identified under paragraph 2 above, will be stored in the format provided by the user for as long as the person remains a paid-up user, unless the user changes the contact details on his/her Personal Natshoot web page, or requests Verge to do so on his/her behalf.  This in order for the Verge to be able to continuously render the contracted services to the user which s/he had joined and paid the Association for.

9.2       The full Paragraph 2 disclosed Personal Information of users provided at enrolment will be stored for a maximum of two years after the last date on which the user had to update his/her account, should the user default on payment of account fees.  After two years of not updating account with the Association, a user’s Surname, Initials and ID number will permanently remain on the Verge database for future reference should that person one day again apply for account. All other Personal Information the Verge has in possession re that user will be permanently deleted from the Verge electronic users database (see 9.4 below).

9.3       The Surname, Initials and ID number of a user who’s account of Verge terminates for whatever reason, will permanently remain on the Verge database for future reference should that person one day again apply for account (or for administrative purposes should such a user pass away).  All other Personal Information the Verge has in possession re that user will be permanently deleted from the Verge electronic users database (see 9.4 below).

9.4       The Verge electronic account database, however, retains the references of all official Verge documents issued and linked to any user at any time in the past for possible management of liability issues, and to protect Verge against fraudulent transactions entered into by non-active former users on strength of Verge documentation issued at the time the user was on the electronic users database marked as an active user of the Association.

 

10. Change in Control

10.1     Verge may have to disclose users’ Personal Information and other information provided, to a third party as part of a sale of the assets of Verge, a subsidiary or division of Verge, or as the result of a change in control of Verge. Any third party to which Verge transfers or sells Verge’s assets will have the right to continue to use the Personal Information and other information users had provided to Verge.  Such third parties will, however, still strictly be bound by, and have to honour the commitments Verge has made towards users in its Privacy Policy as this Policy may be updated from time to time.

 

11. Changing and Deleting Personal Information (To be read with paragraph 9)

11.1     As a registered User of the Services, a user may modify some of the Personal Information s/he had included in his/her profile or change his/her username by logging in and accessing his/her Natshoot account. 

11.2     On resignation from the Association by a user or by taking action as described in paragraph 9.2 and 9.3, Verge will use all commercially reasonable efforts to delete a user’s account and the Personal Information in a user’s profile; however, it may be impossible to remove a user’s account without some residual information being retained on the Verge system.

11.3     When a user’s account is deleted, s/he understands that removed Content may well persist in backup copies for a reasonable period of time (but will not be available to others). Furthermore, to the extent that Content about users have been shared with others, or other Users have independently uploaded and/or retained Content about a user, such Content may also remain on the Services.

11.4     For example, while Verge will remove a user’s account profile and the ability for others to contact a user through the Services or access a user’s Personal Information, some Content about a user may be retained in the individual pages for groups or businesses a user could have contacted through the Services or outside of the Services.

11.5     Registered users who wish to close their account with Verge, for whatever reason, should send such a request for removal by sending an Email to [email protected].

 

12. Relevant Technical Aspects of the Verge Users Database

12.1    For safety reasons data is hosted on a cloud environment and not on a shared server. This server is not shared with other website but dedicated to the Verge system.

12.2    There is no public access to a user's data, a user or system admin must log in to access a user's data. A system admin can only be access the data through an SSL encrypted connection with a private and public key that is unique to a users computer. 

12.3    Passwords are encrypted and hashed with a salt and can not be decrypted.

12.4    Cookies used for authentication are encrypted.

12.5    Data backups are encrypted

12.6    Cross site request forgery prevention is implemented on authentication pages

12.7    Log in forms are throttled to only 3 tries per minute to prevent brute force attacks

 

13. Complaints Process

13.1     If users have any comments, concerns or questions about this Privacy Policy, please send an Email with full details to [email protected].

13.2     Users consent to resolve in Gauteng North, any dispute that a user may have with Verge regarding the execution or results of the procedures described of this Policy Document.

13.3     If users would want to lodge complaints against the manner in which the Verge manages and secures its electronic account database, based on reasonable and factual grounds, they must  please contact the independent Information Regulator, appointed in terms of Section 39 of the PoPI Act (2013).

13.4     Users may also send complaints via an Email with full details to [email protected] so that the complaint can be investigated and immediate mitigations set into motion to rectify the problem should the complaint be proven to be true.

13.5     Users further consent to resolve in Gauteng North, any dispute that a user may have with Verge regarding the execution or results of the procedures described of this Policy Document.

 

14. Updates and Changes to Privacy Policy

14.1     Verge may revise this Privacy Policy from time to time. The most current version of the Privacy Policy will govern the Verge use of its users’ Personal Information and other information, which policy will be located at https://switchtransact.com/privacy-policy .

14.2     If Verge makes any changes to this Privacy Policy, users will be notified by Email or by posting a notice on or through the Services. By continuing to access or use the Services after those changes become effective, users by default agree to be bound by the revised Verge Privacy Policy unless they explicitly state that they do not consent to it, by sending an Email directed at [email protected] with reasons why they cannot agree with the changes.

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