Surf’n’Curve (Pty.) Ltd.
Raffaello Gardelli, Mark Grinnell, Surf’n’Curve (Pty.) Ltd.
Surf’n’Curve (Pty.) Ltd.
419 Albert Road, 1st Floor
Salt River, 7925 Cape Town
Phone: +27 (21) 4482010, Mobile: +27 (0) 76 993 99 23
Types of processed data:
– Inventory data (e.g., names, addresses).
– contact information (e.g., e-mail, phone numbers).
– content data (e.g., text input, photographs, videos).
– usage data (e.g., websites visited, interest in content, access times).
– Meta / communication data (e.g., device information, IP addresses).
Categories of affected persons
Visitors and users of the online offer (hereinafter we refer to the affected persons as “users”).
Purpose of processing
– Provision of the online offer, its functions and contents.
– Answering contact requests and communicating with users.
– Safety measures.
– Reach Measurement / Marketing
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter the “data subject”); a natural person is considered as identifiable, which can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, to an identification number, to location data, to an online identifier (eg cookie) or to one or more special features, that express the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.
“Processing” means any process performed with or without the aid of automated procedures or any such process associated with personal data. The term goes far and includes virtually every handling of data.
“Pseudonymisation” means the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without additional information being provided, provided that such additional information is kept separate and subject to technical and organizational measures to ensure that the personal data not assigned to an identified or identifiable natural person.
“Profiling” means any kind of automated processing of personal data which involves the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular aspects relating to job performance, economic situation, health, personal To analyze or predict preferences, interests, reliability, behavior, whereabouts or relocation of that natural person.
“Responsible person” means the natural or legal person, public authority, body or body that decides, alone or in concert with others, on the purposes and means of processing personal data.
“Processor” means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller.
Relevant legal bases
In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing. Unless the legal basis in the data protection declaration is mentioned, the following applies: The legal basis for obtaining consent is Article 6 (1) lit. a and Art. 7 DSGVO, the legal basis for the processing for the performance of our services and the execution of contractual measures as well as the response to inquiries is Art. 6 (1) lit. b DSGVO, the legal basis for processing in order to fulfill our legal obligations is Art. 6 (1) lit. c DSGVO, and the legal basis for processing in order to safeguard our legitimate interests is Article 6 (1) lit. f DSGVO. In the event that vital interests of the data subject or any other natural person require the processing of personal data, Art. 6 (1) l
it. d DSGVO as legal basis.
We take into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different likelihood and severity of the risk to the rights and freedoms in accordance with Art. 32 GDPR of natural persons, appropriate technical and organizational measures to ensure a level of protection commensurate with the risk. Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to and access to the data Input, disclosure, securing availability and their separation. We have also set up procedures to ensure the enjoyment of data subject rights, data deletion and data vulnerability. Furthermore, we consider the protection of personal data already in the development, or selection of hardware, software and procedures, according to the principle of data protection through technology design and privacy-friendly default settings (Article 25 GDPR) .Collaboration with contract processors and third parties in the context of our processing Disclose data to other persons and companies (contract processors or third parties), transmit them to them or otherwise grant them access to the data, this is done only on the basis of a legal permission (eg if a transmission of data to third parties, such as payment service providers, acc. Article 6 (1) (b) DSGVO is required to fulfill the contract), you have consented to a legal obligation or on the basis of our legitimate interests (eg the use of agents, webhosters, etc.) based on data commissioning it so-called “contract processing contract”, this is done on the basis of Art. 28 GDPR. Transfers to third countries If we use data in a third country (i.e. outside of the European Union (EU) or the European Economic Area (EEA)) or in the context of the use of third party services or disclosure, or transmission of data to third parties, this will only be done if it is to fulfill our (pre) contractual Duties, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only in the presence of the special conditions of Art. 44 et seq. DSGVO. That the processing is e.g. on the basis of specific guarantees, such as the officially recognized level of data protection (eg for the US through the “Privacy Shield”) or the observance of officially recognized special contractual obligations (so-called “standard contractual clauses”.)
Rights of data subjects
You have the right to to ask for a confirmation as to whether the data in question are being processed and for information about this data as well as for further information and a copy of the data in accordance with Art. 15 GDPR. Art. 16 DSGVO the right to demand the completion of the data concerning you or the correction of the incorrect data concerning you. In accordance with Art. 17 GDPR you have the right to demand that the data in question be deleted immediately or alternatively as stipulated You have the right to demand that the data relating to you, which you have provided to us, be obtained in accordance with Art. 20 GDPR and request their transmission to other persons responsible. You have gem. Art. 77 DSGVO the right to file a complaint with the competent supervisory authority.
Right of withdrawal
You may object to the future processing of your data in accordance with Art. 21 GDPR at any time. The objection may in particular be made against processing for the purpose of direct advertising. Cookies and right of objection in the case of direct advertising
Deletion of data
We process the data of our clients in the context of our contractual services which include conceptual and strategic consulting, campaign planning, software and design development / consulting or maintenance, implementation of campaigns and processes / handling, server administration, data analysis / consulting services and training services Inventory data (eg, customer master data, such as names or addresses), contact data (eg, e-mail, telephone numbers), content data (eg, text inputs, photographs, videos), contract data (eg, subject matter, term), payment data (eg, bank details, payment history ), Usage and metadata (eg as part of the evaluation and success measurement of marketing measures). In principle, we do not process special categories of personal data, unless these are components of a commissioned processing. Those affected include our customers, prospects and their customers, users, website visitors or employees as well as third parties. The purpose of the processing is the provision of contract services, billing and our customer service. The legal basis of the processing results from Art. 6 para. 1 lit. b DSGVO (contractual services), Art. 6 para. 1 lit. f DSGVO (analysis, statistics, optimization, security measures). We process data that are necessary for the establishment and performance of the contractual services and indicate the necessity of their information. Disclosure to external parties will only be made if required by an order. When processing the data provided to us within the framework of an order, we act in accordance with the instructions of the client as well as with the legal requirements ner order processing gem. Art. 28 DSGVO and process the data for no other purpose than the order. We delete the data after expiration of statutory warranty and similar obligations. the necessity of keeping the data is checked every three years; in the case of legal archiving obligations, the deletion takes place after its expiry (6 years, pursuant to § 257 (1) HGB, 10 J, in accordance with § 147 (1) AO). In the case of data disclosed to us in the context of an order by the client, we delete the data according to the specifications of the order, in principle after the end of the order.
External payment service providers
When contacting us (eg by contact form, e-mail, telephone or via social media) the information of the user to process the contact request and their settlement acc. Art. 6 para. 1 lit. b) DSGVO processed. The information provided by the users can be stored in a Customer Relationship Management System (“CRM System”) or comparable request organization. We delete the requests, if these are no longer required. We check the necessity every two years; The archiving obligations also apply.
Hosting and e-mail delivery
The hosting services we use are used to provide the following services: infrastructure and platform services, computing capacity, storage and database services, e-mail, security and technical maintenance services, Hereby we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, prospects and visitors of this online offer based on our legitimate interests in an efficient and secure manner Provision of this online offer acc. Art. 6 para. 1 lit. f DSGVO i.V.m. Art. 28 DSGVO (conclusion of contract processing contract).
Collection of access data and log files
We, or our hosting provider, collects on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO Data on every access to the server on which this service is located (so-called server log files). The access data includes name of the retrieved web page, file, date and time of retrieval, amount of data transferred, message about successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider. Logfile information is stored for security reasons (eg to investigate abusive or fraudulent activities) for a maximum of 7 days and then deleted.
Social Media Online Sites
Incorporation of third-party services and content
Using Facebook Social Plugins