Oju Privacy Policy

Introduction

In this Privacy Policy, “we”, “our” or “us” refers to Oju Holdings (Pty) Ltd, a South African company registered in terms of the Company Laws of the Republic of South Africa under registration number 2013/072216/07.

Oju respects your constitutional rights to privacy and data protection. Accordingly, we believe in protecting the Personal Information you provide to us and the Service Use Data we collect from you (as detailed in the Oju T’s & C’s) when you use our Services. Oju will use its best commercial endeavours to only use or disclose your Personal Information and/or Service Use Data in the manner stated in this policy, the Oju Ts & Cs and as authorised by you. It is our intention that through the application of this Privacy Policy your Personal Information and the Service Use Data will be protected from being dealt with in any manner that is inconsistent with the applicable privacy and data protection laws of the Republic of South Africa.

The use of our Services (being the OjuChat mobile app, the website www.oju.world or any third-party platforms through which our Services are provided or are accessible) involves the processing of your Personal Information and Service Use Data, so it’s very important that you understand how this occurs and how you can control it.

Our Privacy Policy explains:

• What Personal Information and Service Use Data we collect from you and how we collect it;
• How we use and disclose your Personal Information and Service Use Data; and
• How to access and update your Personal Information.

By registering with us and using our Services you agree to this Privacy Policy and furthermore, you consent to the handling of your Personal Information and Service Use Data as set out in this Privacy Policy. If you do not agree with this Privacy Policy please do not register with us and if you have registered, please do not use our Services.

If you have any questions regarding this Privacy Policy please email us on ojuholdings@gmail.com

Service Use Age Restrictions

Our Services are not intended for use by children. A “Child” is defined in the South African Children’s Act 38 of 2005 as “a person under the age of 18 years.”

Any person under the age of eighteen (18) years of age MAY NOT make use of our Services.

We do not knowingly collect Personal Information from any children. If you are or become aware that we have collected Personal Information from a Child, you have a duty to email ojuholdings@gmail.com and provide us with the necessary details so that we can investigate the matter and take immediate action.

Sensitive personal information

The European Union General Data Protection Regulation defines the following personal data as being considered “sensitive” and is subject to specific processing conditions:

• personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs;
• trade-union membership;
• genetic data, biometric data processed solely to identify a human being;
• health-related data;
• data concerning a person’s sex life or sexual orientation.

In some jurisdictions there may be personal information in addition to the above which is considered to be sensitive and is subject to stricter regulation than other types of personal information. Before communicating any personal information of a sensitive nature within OjuChat, consider whether it is appropriate to do so.

Also remember that sensitive personal information can be communicated or revealed to third parties through the posting of personal photographs of, for example, your work place, school, place of worship, holidays or social activities.

By you posting any personal information of a sensitive nature within OjuChat, you are consenting to such personal information being available within the controls you have selected (for example, available to the audience of users you select as being capable of viewing your post or profile personal information).

By registering with us and using our Services you agree to the processing of your Personal Information and Service Use Data in accordance with this Privacy Policy.

When you access and use certain Service features you will be asked to agree to the processing of your Personal Information in specific ways (for example, when you follow a third-party account, you are asked if you agree to the transfer of your Personal Information to a third-party). You can find information on how to control your preferences and the use of your Personal Information via your account on the OjuChat App in the setting section. For certain Personal Information, you may withdraw your consent to the processing of that Personal Information in accordance with this Privacy Policy.

Scope and application of this Privacy Policy

• This Privacy Policy applies to the Services.
• Any definitions used in this Privacy Policy have the same meaning as the equivalent defined terms in the Oju Ts & Cs.
• This Privacy Policy does not apply to Personal Information that you choose to disclose or submit to:
  1. services other than Oju (such as other products or services supplied or operated by us or our affiliates) and that do not expressly state that this Privacy Policy applies; or
  2. any third-party services (including any third-party websites) that you may access through Oju.

If you are using OjuChat on behalf of a third-party legal entity (your “Organisation”), you agree to notify your Organisation’s relevant individual owners, shareholders, directors, officers, managers, employees and other relevant individuals whose Personal Information we collect or you provide to us from time to time (“Connected Persons”) of the collection of their Personal Information and you agree to obtain your Connected Persons’ consent to the processing of their Personal Information in accordance with this Privacy Policy. When this Privacy Policy refers to “you” or “your” this includes you and any Connected Persons. If you or any Connected Persons would like to request your Personal Information be removed from our database, written request to this effect should be made and submitted to ojuholdings@gmail.com

Types of information or data that we collect from you and from your use of our Services and which we process

We collect the following information from you and through your use of our Services:

• Personal Information
• Shared Personal Information
• Service Use Data

Personal Information YOU give us

Personal Information will be collected directly from you when you register for our Services. This Personal Information is necessary for us to provide you with our Services, to provide you with Customer Services, to enable us to answer any queries or solve any technical problems you may have and for us to forward information regarding our Services to you. For example, when you sign up and register to use our Services, we will require you to provide us with certain Personal Information such as your name, a user name, your South African identity number, your mobile number, email address, billing information and account password.

Shared Personal Data

OjuChat enables certain Personal Data to be shared publicly with your OjuChat contacts and other Service Users. At any time you can hide your profile from public view and search by unchecking “allow find by phone number or Oju ID” in your account settings. This means that other users of Oju will not be able to find you. We refer to this type of personal data above as “Shared Personal Data”. Shared Personal Data will remain publicly-available for so long as you or a User that has shared such personal data retains it. Even after you delete Shared Personal Data, it may still be separately cached, copied or stored by, or remain public through, other Users or third parties who are not affiliated with and not controlled by us.

Where you have requested that we delete your Personal Data that we have made public and there are grounds for deletion, we will use reasonable steps try to tell others that are displaying your Personal Data or providing links to your Personal Data, to delete it as well.

Please consider carefully what you post and communicate through our Services. In some instances, you may control what access the wider public has to your Shared Personal Data via our privacy settings.

Service Use Data

We collect Service Use Data as a consequence of your use of our Services. This may include both Personal Information and Non-personal Information such as your:

1. location;
2. mobile number;
3. mobile network service provider;
4. frequency of use of our Customer Services;
5. amount of data used.

When you use or access our Services or our Customer Services (including when you visit our website), we may collect information about the services that you use and how you use them. In addition, as a registered User you may provide us with information about your use of Customer Services.

This information may include the following:

• we might set and access one or more cookies (small text files containing a string of alphanumeric characters) on your computer. Cookies will be used to store limited session related information so that Users can access and use our website. You can change your browser settings to, for example, accept or reject cookies. Please review your web browser “Help” file to learn the proper way to modify your cookie settings.
• we might automatically receive and log information about User activities on the Oju applications that User browsers send or from User mobile devices. Such information may include Internet Protocol (“IP”) address, browser type, device-specific information (such as your device model, unique device identifiers, operating system, version and mobile network information), device event information, web requests, browser language, referring / exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, features used, and one or more Oju cookies that may uniquely identify a User’s browser.
• we might maintain usage data which is collected from Users to assist us in debugging the system or addressing other problems in our Services. This usage data may include such information as you request, the date and time of your request, size of the communication and cookies as well as User side data such as connect times, connect failures and performance problems.

Use of information and data

Personal Information and Service User Data that is collected by us is used only for the purposes for which it is collected or for such other secondary purposes that are related to the primary purposes, unless we disclose other uses in this Privacy Policy or at the time of collection.

We collect and use your Personal Information primarily for the following purposes:

• we use your personally identifiable, registration, profile and Service Use Data to operate, maintain and provide to you all of the features and functionality of the Services. In addition, copies of correspondence received by us from you, that may contain Personal Information are stored as archives for record-keeping and back-up purposes.
• we use your personally identifiable and certain Non-personal Data (such as anonymous log file information) to track and analyse your preferences and trends, in order to improve the quality and design of our Services and to create new features, promotions, functionality and services.
• we use unique identifiers and log file information to: (a) identify and remember your device and account so that you will not have to re-enter your account details during your visit or the next time you visit our Services; (b) provide custom and personalised content, advertisements and information; (c) monitor the effectiveness of our Services or marketing campaigns; and (d) monitor aggregate usage metrics.
• we use your mobile number from time-to-time for non-marketing administrative purposes such as sending privacy or security related notices, notifying you of major Service changes or for other customer service purposes.
• we may use the data collected to provide anonymous reporting for internal and external clients, for auditing and analysis in order to maintain and protect our Services or to ensure the technical functionality of our service and network.

We collect and use Service Use Data for the following purposes:

• we use User personally identifiable information such as telephone numbers, registration, profile, and usage information to operate, maintain, and provide Users with the range of features and functionality of our Services.
• we use Service Use Data to determine pricing of our Services for particular Users,
• we use Service Use Data to conduct market analysis of Users and determine user trends.
• we may use non-personally identifiable Service Use Data for the purposes of target advertising, which enables us to personalise and serve advertisements specifically to End-Users and their interests. We do not disclose the identity of End-Users in this process to our third-party advertising partners unless End-Users provide express permission to do so. We may also provide our advertising partners with information about the performance of its advertisements to enable them to better understand their customers. If we intend to use your use Personal Information for direct marketing purposes, we will ensure that you are clearly notified of your right to and how to, opt-out from receiving such direct marketing.

We may also use your Personal Information and Service User Data:

• to respond to court orders, subpoenas, legal process, enforceable governmental requests, to establish or defend against legal claims or exercise our legal rights.
• where we reasonably believe it is necessary to use such information to detect, investigate, prevent, or address illegal activities, fraud, security or technical issues, or potential threats to the safety of any person or violations of the Oju Ts & Cs or to protect our rights, property or safety as required or permitted by law.

Disclosure

We may disclose your Personal Information and Service Use Data in the following circumstances:

• where we have your explicit consent to do so;
• to respond to court orders, subpoenas, legal process, enforceable governmental requests, to establish or defend against legal claims or exercise our legal rights;
• where we believe it is necessary to access, use, preserve or disclose such information to detect, investigate, prevent or address illegal activities, fraud, security or technical issues, potential threats to the safety of any person or violations of Oju Ts & Cs or to protect the rights, property or safety of Oju as required or permitted by law;
• we may provide information to our related bodies corporate or other trusted businesses or persons who work on behalf or with us including our professional advisors, such as our lawyers or auditors. Where information is disclosed to our related bodies corporate, that related body corporate will use the information in compliance with Oju Ts & Cs including this Privacy Policy;
• we may disclose User telephone numbers to telecommunications providers for the purposes of obtaining and providing zero-rating and reverse billing arrangements for Users via Customer applications on our platform;
• we will take reasonable steps to ensure that our contracts with third parties include requirements for those third parties to comply with the requirements of the applicable South African privacy legislation.
• we may disclose your Personal Information to overseas recipients such as companies in our corporate group or affiliates or third parties that assist in the conduct of our Services.

Please be aware that the privacy laws in other countries might not be the same as in South Africa. However, where we do disclose your Personal Information to overseas third-parties, we will take such steps as are reasonable to ensure that your Personal Information is handled in accordance with Oju Ts & Cs including this Privacy Policy.

We may also disclose aggregate, anonymous log file and usage information in reports to interested third parties to assist those parties in understanding the usage patterns and performance results of certain advertisements, content, services, promotions or features, or to provide you a better user experience. For example, we may provide aggregate-level reports to an advertising partner for the purpose of showing delivery and performance statistics of a specific advertising campaign. Such information will be de-identified.

Security of your Personal Information

We strive to ensure the security, integrity and privacy of Personal Information collected and held by us and we review and update our security measures constantly in light of current technologies.

We use a variety of security technologies and procedures for the purpose of preventing loss, misuse, unauthorised access or disclosure of Personal Information, for example, we use encryption technology (such as SSL) to protect certain sensitive information (such as Location Data) provided by you to us (Service Use Data).

Despite our efforts, no data security measures can guarantee 100% security at all times. We do not warrant nor guarantee the security of Oju or any Personal Information you provide to us.

Quality of your Personal Information

We take such steps as are reasonable, in the circumstances, to ensure that the Personal Information we process is accurate, complete, and current. However, it is ultimately up to you to update or correct your Personal Information whenever necessary.

Access to Personal Information and Correction

You may request access to your Personal Information that is held by us.

If, at any time, you discover that Personal Information held by us is incorrect, you may contact us to have the information corrected and we will correct our records as soon as reasonably possible.

You can contact us about your Personal Information by sending an email to ojuholdings@gmail.com

Third Parties

Our Ts & Cs, including this Privacy Policy, only applies to Oju. It does not apply to any other company or organisation, including those whose products or services are available in or via our Services. These third parties are not under our control and we cannot accept responsibility or liability for their conduct. Before disclosing your Personal Information to third parties (for example, through an app made available using our Services), we advise you to examine that third party’s terms and conditions of use and their privacy policy.

Changes to our Privacy Policy

We may from time to time amend this Privacy Policy.

Whenever we make any changes to this Privacy Policy that are important for you to know about, we will post the updated Privacy Policy at this link and notify you via the update notes of the app stores.

Communication with us

All communication relating to these Ts & Cs and our Privacy Policy should be directed to ojuholdings@gmail.com. Your communication will receive priority attention.

Communication from us

We will periodically send you service-related announcements when we consider it necessary to do so (such as when we temporarily suspend our Services for maintenance, security, privacy or administrative-related communications). We will send such announcements to your email address or via SMS. You may not opt-out of these service-related announcements, which are not promotional in nature and used solely to protect your account and keep you informed of important changes to Oju.