We are Valgray (Pty) Ltd (Business registration number K2018522235) and this is our plan of action when it comes to protecting your privacy. 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).
Audience
This policy applies to you, if you are:
- a visitor to our website; or
- a customer who has ordered or requested the goods or services that we provide online.
Personal information
Personal information includes:
- certain information that we collect automatically when you visit our website;
- certain information collected on registration (see examples below);
- certain information collected on submission; and
- optional information that you provide to us voluntarily (see examples 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).
Common examples
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
- financial information – such as your bank account details.
Acceptance
Acceptance required
You must accept all the terms of this policy when you order our goods or request our services. If you do not agree with anything in this policy, then you may not order our goods or request our services.
Legal capacity
You may not access our website or order our goods or request our services if you are younger than 18 years old or do not have legal capacity to conclude legally binding contracts.
Deemed acceptance
By accepting this policy, you are deemed to have read, understood, accepted, and agreed to be bound by all of its terms.
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.
Changes
We may change the terms of this policy at any time by updating this web page. We will notify you of any changes by placing a notice in a prominent place on the website or by sending you an email detailing the changes that we have made and indicating the revision date. If you do not agree with the changes, then you must stop using the website and our goods or services. If you continue to use the website or our goods or services following notification of a change to the terms, the changed terms will apply to you and you will be deemed to have accepted those updated terms.
Collection
On registration
Once you register on our website, you will no longer be anonymous to us. You will provide us with certain personal information when you register on our website.
This personal information will include:
- your name and surname;
- your email address;
- your telephone number;
- your postal address or street address; and
- your username and password.
We will use this personal information to fulfil your account, provide additional services and information to you as we reasonably think appropriate, and for any other purposes set out in this policy.
On order or request
When you order our goods, or request our services from us, you will be asked to provide us with additional information on a voluntary basis (goods or services 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.
Note that a cookie file is not a virus!
These files serve a number of useful purposes for you, including:
- 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.
Web beacons
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. We use this information collected of our site and share it with our advertising platforms to carry out marketing initiatives. All the information that we share is encrypted and we make sure that our third-party service providers comply with relevant data protection laws. We may provide this information including identifiers that allow our advertising platforms to deliver targeted online advertising on social media and websites.
Optional details
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.
Purpose for collection
We may use or process any goods or services information, or optional information that you provide to us for the purposes that you indicated when you agreed to provide it to us. Processing includes gathering your personal information, disclosing it, and combining it with other personal information.
We generally collect and process your personal information for various purposes, including:
-
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.
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 or optional information.
Use
Our obligations
We may use your personal information to fulfil our obligations to you.
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.
Disclosure
Sharing
We may share your personal information with:
- an affiliate, in which case we will seek to require the affiliates to honour 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, or 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);
- other third parties who provide us with relevant services where appropriate (for example our couriers).
Regulators
We may disclose your personal information as required by law or governmental audit.
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.
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 in order 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 hosting company will host our website in a secure server environment that uses a firewall and other advanced security measures to prevent interference or access from outside intruders. We authorize access to personal information only for those employees who require it to fulfil their job responsibilities. We implement disaster recovery 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, emailing us, or phoning 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 will only retain your personal information for as long as it is necessary to fulfil 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.
Updating or removing
You may choose to correct or update the personal information you have submitted to us. Please contact us and we will assist you with any information updates.
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 nor can we be held responsible for the performance or non-performance of courier companies handling our shipments.
By using our website, you (the visitor) agree to allow third parties to process your IP address, in order to determine your location for the purpose of currency conversion. You also agree to have that currency stored in a session cookie in your browser (a temporary cookie which gets automatically removed when you close your browser). We do this in order for the selected currency to remain selected and consistent when browsing our website so that the prices can convert to your (the visitor) local currency.
Privacy Complaints Procedure
We respect your privacy and take the protection of personal data very seriously. These are the necessary steps to effectively and efficiently identify and report potential issues in how we have processed your personal data.
Types of complaints
You have a valid complaint if we are:
- unlawfully processing your personal information;
- failing to keep your personal information secure;
- misusing your personal information;
- keeping personal information about you for longer than is necessary;
- holding inaccurate personal information about you;
- unlawfully disclosing your personal information;
- collecting personal information for one reason and are using it for something else; or
- accessing your personal information without your authorization.
How to make a complaint
If you wish to complain about how we have processed your personal information, or how your complaint has been handled, please contact us at style@valgrayfordogs.com, with the following information:
- Full name of the person lodging the complaint;
- Contact details, such as email address and telephone number;
- How the personal data was collected (if known);
- All necessary information (such as your account number and what you think we have done incorrectly);
- The timeframe over which the suspected wrongdoing occurred (if known); and
- Any evidence in support of the complaint.
We will acknowledge receipt of your complaint within three business days. While we try to respond as promptly as possible, resolution times will vary depending on the nature of the complaint. We will liaise with our relevant departments to investigate your complaint and you will be notified of the outcome of your complaint as well as any action taken. If you are unhappy with how your complaint was handled, or the outcome of your complaint, then you may appeal by writing to us at style@valgrayfordogs.com, outlining your reasons.
Should you remain unhappy after the appeals process you may forward your complaint to the Information Regulator:
inforeg@justice.gov.za
The Information Regulator (South Africa), SALU Building, 316 Thabo Sehume Street, Pretoria
More information can be found at http://www.justice.gov.za/inforeg/
Abusive correspondence and complaints
We differentiate between people who make numerous complaints, because they think things have gone wrong, and people who are unreasonably being difficult. We do understand that sometimes complainants act in distress, and we will make a reasonable allowance for that. Abusive correspondence and behaviour that this policy does not cover include the following:
- Continuing to complain, even after we have advised you that there are insufficient or no grounds for your complaint or that we are not the appropriate body;
- Refusing to co-operate with our complaints process, without good reason, but still wanting your complaint to be resolved;
- Changing the basis of the complaint as inquiries are made and introducing trivial or irrelevant new information and expecting this to be taken into account and commented on;
- Submitting repeat complaints, after the complaint’s procedure has been completed essentially about the same issues, with minor variations which you then insist on being treated as new complaints and put through the full complaint’s procedure again; or
- Refusing to accept the outcome of the procedure after its conclusion, repeatedly arguing the point, complaining about the outcome, and denying that an adequate response has been given.
Note that if we determine that your correspondence or complaint is abusive, we will inform you of such a decision and of what action is being taken. We will ask you to change your behaviour and, if you fail to do so, we may impose restrictions on your correspondence. If your behaviour is so severe or extreme that it threatens our staff, we may consider other legal options.
Record keeping
We will retain adequate records of the details of the case and the action that has been taken.
By using our website, you (the visitor) agree to allow third parties to process your IP address, in order to determine your location for the purpose of currency conversion. You also agree to have that currency stored in a session cookie in your browser (a temporary cookie which gets automatically removed when you close your browser). We do this in order for the selected currency to remain selected and consistent when browsing our website so that the prices can convert to your (the visitor) local currency.
