PWA Privacy Policy

1.DEFINATIONS

Undefined terms in this Privacy Policy have the same definition as in our Terms of Service (“Terms”).
Property with Alton (Pty) Ltd, referred to as PWA.

2. PERSONAL INFORMATION WE COLLECT

2.1 Information needed to use the PWA Platform.

We collect personal information about you when you use the PWA Platform. With-out it, we may not be able to provide you with all services requested. This infor-mation includes:

  • Contact Information, Account, Profile Information. Such as your first name, last name, phone number, postal address, email address, date of birth, and profile photo, some of which will depend on the features you use.
  • Identity Verification and Payment Information. Such as images of your government issued ID (as permitted by applicable laws), your ID number or other verification information, bank account or payment account information.

2.2 Information you choose to give us.

You can choose to provide us with additional personal information. This information may include:

  • Additional Profile Information. Such as gender, preferred language(s), city, and personal description. Some of this information as indicated in your account settings is part of your public profile page and will be publicly visible.
  • Address Book Contact Information. Address book contacts you import or enter manually.
  • Other Information. Such as when you fill in a form, add information to your account, respond to surveys, post to community forums, participate in promotions, communicate with our customer care team and other employees, or share your experience with us. This may include health information if you choose to share it with us.

2.3 Information Automatically Collected by Using the PWA Platform and our Payment Services.

When you use the PWA Platform and Payment Services, we automatically collect personal information. This information may include:

  • Geo-location Information. Such as precise or approximate location determined from your IP address or mobile device’s GPS depending on your device settings. We may also collect this information when you’re not using the app if you enable this through your settings or device permissions.
  • Usage Information. Such as the pages or content you view, searches for Listings, jobs you have made, and other actions on the PWA Platform.
  • Log Data and Device Information. Such as details about how you’ve used the PWA Application(including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the PWA Platform. We may col-lect this information even if you haven’t created an PWA account or logged in.
  • Cookies and Similar Technologies as described in our Cookie Policy.
  • Payment Transaction Information. Such as payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address and other related transaction details.

2.4 Personal Information We Collect from Third Parties.

We collect personal information from other sources, such as:

  • Third-Party Services. If you link, connect, or login to the PWA Platform with a third party service (e.g. Google, Facebook, WeChat), you direct the service to send us infor-mation such as your registration, friends list, and profile information as con-trolled by that service or as authorised by you via your privacy settings at that service.
  • Background Information. We may obtain reports to the extent permitted by applicable laws and with your consent where required, we may obtain the local version of police, background or registered sex offender checks. We may use your information, including your full name and date of birth, to obtain such reports.
  • Enterprise Product Invitations and Account Management. Organisations that use our Enterprise products may submit personal infor-mation to facilitate account management and invitations to use enterprise products.
  • Other Sources. To the extent permitted by applicable law, we may receive additional infor-mation about you, such as references, demographic data or information to help detect fraud and safety issues from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results or fraud warnings from identity verification service providers for use in our fraud prevention and risk as-sessment efforts. We may receive information about you and your activities on and off the PWA Platform, or about your experiences and interactions from our partners. We may receive health information, including but not lim-ited to health information related to contagious diseases.

3. HOW WE USE INFORMATION WE COLLECT

3.1 Provide, Improve, and Develop the PWA Platform

We use personal information to:

  • enable you to access the PWA Platform and make and receive payments,
  • enable you to communicate with other suppliers,
  • perform analytics, debug and conduct research
  • provide customer service,
  • send you messages, updates, security alerts, and account notifications,
  • Personalise and customise your experience based on your interactions with the PWA Platform, your search and job history, your profile information and preferences, and other content you submit, and
  • enable your use of our enterprise products.

3.2 Create and Maintain a Trusted and Safer Environment.

We use personal information to:

  • detect and prevent fraud, spam, abuse, security and safety incidents, and other harmful activity,
  • study and combat discrimination
  • conduct security investigations and risk assessments,
  • verify or authenticate information provided by you,
  • conduct checks against databases and other information sources, including background or police checks,
  • comply with our legal obligations, protect the health and well-being of our customers, suppliers, suppliers’ employees and employees of the public,
  • resolve disputes with our suppliers,
  • enforce our agreements with third parties,
  • comply with law, respond to legal requests, prevent harm and protect our rights (see section 4.5)
  • we may conduct profiling based on your interactions with the PWA Platform, your profile information and other content you submit to PWA, and infor-mation obtained from third parties. In limited cases, automated processes could restrict or suspend access to the PWA Platform if such processes de-tect activity that we think poses a safety or other risk to PWA, our community, or third parties. If you would like to challenge the decisioning based on the automated process, please contact us via the Contact Information section be-low.

3.3 Provide, Personalise, Measure, and Improve our Advertising and Marketing.

We may use personal information to:

  • send you promotional messages, marketing, advertising, and other infor-mation based on your preferences and social media advertising through so-cial media Applications,
  • Personalise, measure, and improve our advertising,
  • administer referral programs, rewards, surveys, contests, or other promotional activities or events sponsored or managed by PWA or its third-party partners,
  • analyse characteristics and preferences to send you promotional messages, marketing, advertising and other information that we think might be of inter-est to you, and
  • invite you to events and relevant opportunities.

3.4 Provide Payment services.

Personal information is used to enable or authorise third parties to use Payment Services:

  • Detect and prevent money laundering, fraud, abuse, security incidents
  • Conduct security investigations and risk assessments.
  • Comply with legal obligations (such as anti-money laundering regulations).
  • Enforce the Payment Terms and other payment policies.
  • With your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your prefer-ences.
  • Provide and improve the Payment Services.

4. SHARING & DISCLOSURE

4.1 Sharing With Your Consent or at Your Direction.

Where you provide consent, we share your information as described at the time of consent, such as when authorising a third-party platform or website to access your PWA account or participating in promotional activities by PWA partners or third par-ties.

Where permissible with applicable law, we may use certain information about you, such as your email address, de-identify it, and share it with social media Platforms, to generate leads, drive traffic to PWA or otherwise promote our products and ser-vices.

4.2 Sharing Between Employees.

To help facilitate jobs or other interactions between Employees, we may need to share certain information such as:

  • When a job request is made or dispute is submitted, certain information may be shared between customer(s) and suppliers, including profile, name, names of any additional customers, cancellation history, review information, age of customer (unless prohibited by applicable law), dispute outcome (when applicable) and other information you choose to share and submit. When a job is confirmed, additional information is shared to assist with coor-dinating the job, like profile photo and phone number. When you as a sup-plier have a confirmed job, certain information is shared with the Customer (and the additional customers they invite, if applicable) to coordinate the job, such as your profile, full name, phone number, and listing address.
  • When you as a Supplier invite another Employee to supply with you, you au-thorise that person to access and update your information and Employee Content, including but not limited to certain information like your full name, phone number, site address, calendar, listing information, listing photos, and email address.
  • When you as a Customer invite additional customers to a job, your full name, job dates, Supplier name, listing details, the site address, and other related information will be shared with each additional customer.

4.3 Information You Publish in Profiles, Listings, and other Public Information.

You can make certain information publicly visible to others, such as:

  • Your public profile page, which includes your profile photo, first name, de-scription, and city.
  • Listing pages that include information such as the address or experience’s approximate or precise location description, calendar availability, profile pho-to, aggregated demand information (like page views over a period of time), and additional information you choose to share.
  • Reviews, ratings and other public feedback
  • Content in a community or discussion forum, blog or social media post.

We may display parts of your public profile and other content you make available to the public like listing details on third-party sites, applications and apps.

Information you share publicly on the PWA Platform may be indexed through third-party search engines. In some cases, you may opt-out of this feature in your ac-count settings.

4.4 Supplier Service Providers

Suppliers may use third-party services to help manage or deliver their services, such as cleaning services or locksmiths. Suppliers may use features on the PWA Platform to share information about the Customer (like job start and job end dates, customer name, customer phone number) with such third-party service providers.

4.5 Complying with Law, Responding to Legal Requests, Preventing Harm and Protecting our Rights.

We may disclose your information to courts, law enforcement, governmental or pub-lic authorities, tax authorities, or authorised third parties, if and to the extent we are required or permitted to do so by law or where disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with a valid legal request or to respond to claims asserted against PWA, (iii) to respond to a valid legal request re-lating to a criminal investigation to address alleged or suspected illegal activity, or to respond to or address any other activity that may expose us, you, or any other of our users to legal or regulatory liability (more information on PWA’s Law Enforcement Guidelines, (iv) to enforce and administer our agreements with suppliers, or (v) to protect the rights, property or personal safety of PWA, its suppliers, or employees of the public. For example, if permitted due to the foregoing circumstances, supplier tax information may be shared with tax authorities or other governmental agencies.

Where appropriate, we may notify suppliers about legal requests unless: (i) provid-ing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon or harm to PWA, our Employees, or expose PWA to a claim of ob-struction of justice.

For jurisdictions where PWA facilitates the collection and remittance of taxes where legally permissible according to applicable law, we may disclose suppliers’ and cus-tomers’ information about transactions, jobs with taxes to the applicable tax authori-ty, such as supplier and customer names, Listing addresses, job dates and amounts, tax identification number(s), the amount of taxes received (or due) by suppliers from customers, and contact information.

In jurisdictions where PWA facilitates or requires a registration, notification, permit, or license platform of a supplier with a local governmental authority through PWA in accordance with local law, we may share information of participating suppliers with the relevant authority, both during the platform process and, periodically thereafter, such as the supplier’s full name and contact details, address, tax identification number, listing details, and number of jobs booked.

4.6 Programs with Managers and Owners.

We may share personal information of suppliers and customers such as job infor-mation, and information related to compliance with applicable laws such as short-term jobs, consulting companies, and/or business owners, in order to facilitate pro-grams with business owners. For example, customer job and personal information, including customer contact information, may be shared with the supplier manage-ment of the service to facilitate supplying services, compliance with applicable laws, security, billing, and other services.

4.7 Supplier Information Provided to PWA for Customers Jobs.

If a job is designated as being for business or work purpose and (1) is made by a customer affiliated with an enterprise, (2) the enterprise is enrolled in PWA for work, we may disclose information related to the job to the enterprise (e.g., name of the supplier, job address, job dates, Listing details, etc.) to the extent necessary for the adequate performance of PWA’s contract with the enterprise and to provide the ser-vices. At the request of the enterprise or the customer, we may also share this in-formation with third parties engaged by the enterprise to provide support services.

4.8 Service Providers.

We share personal information with affiliated and unaffiliated service providers to help us run our business, including service providers that help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background or police checks, fraud prevention, and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of the PWA Services through third-party applications and software tools (e.g. through the integration with our APIs), (vi) provide customer ser-vice, advertising, or payments services, (vii) process, handle or assess insurance claims or similar claims, or (viii) facilitate non-profit and charitable activities con-sistent with PWA’s mission. These providers are contractually bound to protect your personal information and have access to your personal information to perform these tasks.

4.9 Business Transfers.

If PWA undertakes or is involved in any merger, acquisition, reorganisation, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will noti-fy you before your personal information is transferred and becomes subject to a dif-ferent privacy policy.

4.10 Corporate Affiliates.

To support us in providing, integrating, promoting and improving the PWA Platform, Payment Services, and our affiliates’ services, we may share personal information within our corporate family of companies that are related by common ownership or control. Some examples are:

  • Sharing with PWA. Even if your country of residence is not the South Africa your information will be shared with PWA, which provides the technical infrastructure for the PWA Platform.
  • Sharing with PWA Payments. In order to facilitate payments on or through the PWA Platform, certain infor-mation will be shared with the relevant PWA Payments entity.

5. OTHER IMPORTANT INFORMATION

5.1 Analysing your Communications.

We may review, scan, or analyse your communications on the PWA Platform for reasons outlined in the “How We Use Information We Collect” section of this policy, including fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, and customer support purposes. For ex-ample, as part of our fraud prevention efforts, we scan and analyse messages to mask contact information and references to other sites. In some cases, we may also scan, review, or analyse messages to debug, improve, and expand job offerings. We use automated methods where reasonably possible. Occasionally we may need to manually review communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyse your messaging communications to send third-party marketing messages to you and we will not sell reviews or analyses of these com-munications.

5.2 Linking Third-Party Accounts.

You can link your PWA account with certain third-party services like social net-works. Your contacts on these third-party services are referred to as “Friends.” When you direct the data sharing by creating this link:

  • some of the information provided to us from linking accounts may be pub-lished on your public profile,
  • your activities on the PWA Platform may be displayed to your Friends on the PWA Platform and/or that third-party service,
  • a link to your public profile on that third-party service may be included in your PWA public profile,
  • other PWA users may be able to see any Friends that you may have in com-mon with them, or that you are a Friend of their Friend if applicable,
  • other PWA users may be able to see any schools, hometowns or other groups you have in common with them as listed on your linked social net-working service,
  • information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes, and
  • publication and display of information that you provide to the PWA Platform through this linkage is subject to your settings and authorisations on the PWA Platform and the third-party service.

5.3 Third-Party Partners & Integrations.

Parts of PWA may link to third-party services, not owned or controlled by PWA, such as Google Maps/Earth. Use of these services is subject to the privacy policies of those providers, such as Google Maps/Earth Additional Terms of Use, Google Privacy Policy(see here for more information on how Google uses information), and Citi Privacy Policy. PWA does not own or control these third parties and when you interact with them you are providing your information to them.

6. YOUR RIGHTS

You can exercise any of the rights described in this section consistent with applica-ble law. Please note that we may ask you to verify your identity and request before taking further action on your request.

6.1 Managing Your Information.

You can access and update some of your personal information through your Ac-count settings. If you connected your PWA Account to a third-party service, like Fa-cebook or Google, you can change your settings and unlink from that service in your Account settings. You are responsible for keeping your personal information up to date.

6.2 Data Access and Portability.

In some jurisdictions, applicable law may entitle you to request certain copies of your personal information or information about how we handle your personal in-formation, request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format, and/or request that we transmit this information to another service provider (where technically feasible).

6.3 Data Erasure.

In certain jurisdictions, you can request that your personal information be deleted. Please note that if you request the erasure of your personal information:

  • We may retain your personal information as necessary for our legitimate business interests, such as prevention of money laundering, fraud detection and prevention, and enhancing safety. For example, if we suspend an PWA Account for fraud or safety reasons, we may retain information from that PWA Account to prevent that Employee from opening a new PWA Account in the future.
  • We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, PWA payments may keep in-formation for tax, legal reporting and auditing obligations. Records of personal information will not be retained any longer than necessary for achieving the purpose for which the information was collected or subsequently processed, in terms of the POPI Act.
  • Information you have shared with others (e.g.Reviews, forum postings) will continue to be publicly visible on PWA, even after your PWA Account is can-celled. However, attribution of such information to you will be removed. Some copies of your information (e.g., log records) will remain in our database, but are disassociated from personal identifiers.
  • Because we take measures to protect data from accidental or malicious loss and destruction, residual copies of your personal information may not be re-moved from our backup systems for a limited period of time.

7. SECURITY

While no organisation can guarantee perfect security, we are continuously imple-menting and updating administrative, technical, and physical security measures to help protect your information against unauthorised access, loss, destruction, or al-teration. The consumer is required to be notified of any breach of security, in terms of the POPI Act.

8. CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time in accordance with ap-plicable law. If we do so, we will post the revised Privacy Policy and update the “Last Updated” date at the top. In case of material changes, we will also provide you with notice of the modification by email at least thirty (30) days before the effective date. If you disagree with the revised Privacy Policy, you can cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes ef-fective, your continued access to or use of the PWA Platform will be subject to the revised Privacy Policy.

9. CONTACT INFORMATION AND RESPONSIBLE PWA ENTITIES

For questions or complaints about this Privacy Policy or PWA’s handling of person-al information contact PWA (Pty) Ltd, Blackbrick 2-015, 25 Fredman Drive, Sandown, South Africa, 2031.