Privacy Policy
This policy covers use and operation of the Political Advert Repository (“PAdRe”) website
(“the
Website”) which is operated, controlled and owned by Media Monitoring Africa
(“MMA”) on behalf of the
Electoral Commission (“IEC”) and any adverts uploaded to the website by
Political Parties (together, the
“Services”).
By signing on to receive the Services, you acknowledge that the Website is the
Intellectual Property of
MMA and is run and owned by MMA.
By signing on to receive the Services, you consent to Media
Monitoring Africa collecting and storing and
processing your personally identifying information (“PI”), on behalf of the IEC,
who will use the PI on
inter alia the following basis:-
-
to provide you with access to the Website and the associated Website services; and
-
in accordance with the provisions of this Privacy Policy as set out below.
MMA is a Non-Profit Trust registered in South Africa. It is our policy to respect your privacy
regarding
any information we may collect while operating the Services.
The IEC is South Africa's election management body, an independent organisation established under
chapter
nine of the Constitution. It conducts elections to the National Assembly, provincial
legislatures and
municipal councils.
The IEC and MMA take privacy seriously. In summary:
- we don’t collect personal information unless we truly need it;
- we don’t share personal information with anyone except to ensure that we can properly
process your
complaint, comply with the law and/or protect our rights;
- we don’t store personal information on our hosted servers unless required for the on-going
operation
of one of our Services. If you have questions about your personal data or this privacy
policy,
please contact us.
WEBSITE VISITORS
Like most website operators, MMA collects non-personally-identifying information of the sort that
web
browsers and servers typically make available, such as the browser type, language preference,
referring
site, and the date and time of each visitor request. MMA’s purpose in collecting non-personally
identifying information is to better understand how visitors use the Website. From time to time,
MMA may
release non-personally-identifying information in the aggregate, e.g., by publishing a report on
trends
in the usage of our Website.
MMA also collects potentially personally-identifying information like Internet Protocol (IP)
addresses
for logged in Users.
The User may visit the Website without providing any personal information. The Website servers
will in
such instances collect the IP address of the User computer, but not the email address or any
other
distinguishing information. This information is aggregated to measure the number of visits,
average time
spent at the Website, pages viewed, etc. MMA uses this information to determine use of the
Website, and
to improve content thereon. MMA assumes no obligation to protect this information, and may copy,
distribute or otherwise use such information without limitation.
For the purpose of this clause, “personal information” shall be defined as
detailed in the Protection of
Personal Information Act, No 4 of 2013.
EUROPEAN DATA PROTECTION LEGISLATION
In this Policy, "European Data Protection Legislation" means all applicable legislation relating
to data
protection in the European Economic Area ("EEA"), including the EU General Data Protection
Regulation
2016/679 ("GDPR") and all laws adapted under or replacing the GDPR. Where this Policy uses terms
specially defined in the GDPR, the GDPR definitions apply.
If the GDPR applies to you, your specific rights are listed at the end of this Policy.
GATHERING AND STORAGE OF PERSONALLY-IDENTIFYING INFORMATION
Certain visitors to the website choose to interact in ways that require MMA to gather
personally-identifying information. The amount and type of information that we gather depends on
the
nature of the interaction.
For example, we will require additional information regarding representatives of Political
Parties to
verify such representatives prior to allowing them i access to inter alia upload:-
- official party campaign advertisements to PAdRE;
- official party campaign podcasts released as part of campaigning for support;
- any and all official party communications relevant for purposes of storage in the PAdRE
repository.
(“Political Party Adverts”)
These representatives are identified based on details they registered with the IEC, including
name,
contact email address and contact phone number.
We collect, store and process such information on behalf of the IEC only insofar as is necessary
or
appropriate:-
- to communicate with you and to make sure that you actually exist (you are not a fraudster);
- to fulfil the purpose of your interaction with MMA or the IEC including but not limited to
uploading
and storing Political Party Adverts;
- comply with any legislation or regulation which requires us to collect the information;
MMA will be collecting and storing the Political Party Adverts that registered political parties
upload
for the purpose of providing public access to those adverts. MMA does not own the content of the
adverts, and it is the responsibility of the political parties to ensure that the adverts
uploaded are
correct and accurate.
MMA will be collecting and storing the content of each advert on behalf of the IEC for the
purpose of:
- providing public access to political adverts;
- analyzing and reporting on the political adverts uploaded both during the South African
National
election period, and thereafter.
MMA does not, however, warrant ownership of the content - that rests with the copyright holder
nor does
MMA warrant veracity of content of each advert submitted.
MMA does not disclose personally-identifying information other than as described below. And
visitors can
always refuse to supply personally-identifying information, with the caveat that it may prevent
them
from fully engaging in the complaint making process or other Website-related activities.
AGGREGATED STATISTICS
MMA may collect statistics about the interaction of visitors with the Website. MMA may display
this
information publicly or provide it to others. However, MMA does not disclose
personally-identifying
information other than as described below.
PROTECTION OF CERTAIN PERSONALLY-IDENTIFYING INFORMATION
MMA and the IEC will not rent or sell potentially personally-identifying and
personally-identifying
information to anyone.
MMA and the IEC will only disclose potentially personally-identifying and personally-identifying
information to those of our employees, contractors and affiliated organizations that: -
- need to know the information to provide the Services available at our Website or store the
personal
information and complaints; and
-
that have agreed not to disclose it to others.
- Other than to our employees, contractors and affiliated organizations, as described above,
we
disclose potentially personally-identifying and personally-identifying information only in
response
to a subpoena, court order or other governmental request, or when we believe in good faith
that
disclosure is reasonably necessary to protect our property or rights, or the property or
rights of
third parties or the public at large;
- We take all measures reasonably necessary to protect against the unauthorized access, use,
alteration or destruction of potentially personally-identifying and personally-identifying
information.
YOUR RIGHTS:
You have:
The right to access: You have the right to obtain information about the processing of your
personal data
and a copy of your personal data that MMA and the IEC store.
The right to rectify your data: You have the right to request that MMA and/or the IEC update your
personal data if it is inaccurate or incomplete.
The right to request data erasure: You have the right to have your personal information erased
from the
MMA and/or IEC files if the data is no longer necessary for the purpose for which it was
collected, you
withdraw your consent and no other legal basis for our processing your data exists, or your
fundamental
rights to data privacy and protection outweigh our legitimate interest in continuing our
processing.
The right to restrict or object to processing: You have the right to restrict or object to our
processing
if we are processing your data based on legitimate interests or performance of a task in the
public
interest as an exercise of official authority (including profiling) or processing your data for
purposes
of scientific or historical research and statistics.
The right to lodge a complaint: If you think we have processed your personal information unfairly
or
unlawfully, or we have not complied with your rights under law, you have the right to complain
to a
national data protection authority, the Information Regulator. Contact details for data
protection
authorities are available here.
COOKIES
A cookie is a string of information that a website stores on a visitor’s computer, and that the
visitor’s
browser provides to the website each time the visitor returns. The Website uses cookies to help
us
identify and track visitors, their usage of the Website, and their Website access preferences.
Visitors
who do not wish to have cookies placed on their computers should set their browsers to refuse
cookies
before using the Website, with the drawback that certain features of the Website may not
function
properly without the aid of cookies.
CERTAIN USERS RIGHTS UNDER GDPR
If you are a resident of the EEA or Switzerland, the following applies for purposes of processing
and
legal basis for processing personal information:
As explained above, we process personal information in various ways depending upon your use of
the
Services.
We process personal information on the following legal bases:
- with your consent;
- as necessary to perform the Services; and
- as necessary for our legitimate interests in providing services where those interests do not
override your fundamental rights and freedom related to data privacy.
Individual Rights: If you are a resident of the EEA or Switzerland, you have certain rights under
the
GDPR. To verify your identity, we might need you to provide us with PI prior to accessing any
records
containing information about you.
The right to access: You have the right to obtain information about our processing of your
personal data
and a copy of your personal data that we store.
The right to rectify your data: You have the right to request that we update your personal data
if it is
inaccurate or incomplete.
The right to request data erasure: You have the right to have your personal information erased
from our
files if the data is no longer necessary for the purpose for which it was collected, you
withdraw your
consent and no other legal basis for our processing your data exists, or your fundamental rights
to data
privacy and protection outweigh our legitimate interest in continuing our processing.
The right to restrict or object to processing: You have the right to restrict or object to our
processing
if we are processing your data based on legitimate interests or performance of a task in the
public
interest as an exercise of official authority (including profiling) or processing your data for
purposes
of scientific or historical research and statistics.
The right to lodge a complaint: If you think we have processed your personal information unfairly
or
unlawfully, or we have not complied with your rights under GDPR, you have the right to complain
to a
national data protection authority. Contact details for data protection authorities are
available here.
To submit any request to us under the GDPR, please contact us at the address in the next
paragraph for
more information.
CONTACT DETAILS AND PRIVACY POLICY CHANGES
Although most changes are likely to be minor, we may change our privacy policy from time to time
at our
sole discretion. We encourage visitors to check this page frequently for any changes to the
privacy
policy. Your continued use of our Website after any change in this privacy policy will
constitute your
acceptance of such change.
Should you wish to lodge a complaint or enforce your rights in terms of this Privacy Policy,
please
contact the Data Protection Officer:
Name: William Bird
Title: Director
Organisation: Media Monitoring Africa
Email: info@mma.org.za