Privacy Policy
Effective Date: 30 April 2025
Last Updated: 30 April 2025
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Introduction
Welcome to Algernon Innovations ("we," "us," or "our"). We are committed to protecting the privacy and security of your Personal Information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website (the "Site") or use our services, including Listen To Anything ("LTA") and any custom software development services (collectively, the "Services").
This Policy is drafted in accordance with the Protection of Personal Information Act, 4 of 2013 ("POPIA") of South Africa. By using our Services, you consent to the data practices described in this policy. If you do not agree with the terms of this privacy policy, please do not access the site or use the Services.
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Responsible Party
Algernon Innovations is the "Responsible Party" in terms of POPIA for the Personal Information we process via our Site and Services. Our contact details are provided at the end of this policy.
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Information We Collect
We may collect Personal Information directly from you, automatically through your use of our Services, or from third parties. "Personal Information" means information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person, as defined in POPIA.
3.1. Information You Provide Directly:
- Contact Information: Name, email address, phone number when you fill out forms, contact us, or register for an account.
- Account Information: Username, password, and other details required to set up and manage your account for services like LTA.
- Payment Information: While we may facilitate payments, we typically use third-party payment processors (e.g., PayStack). We do not directly store your full credit card details. The payment processors handle this data according to their privacy policies. We may receive transaction details (like transaction ID, amount, date) necessary for record-keeping.
- User Content (for LTA): Text, documents, or links you submit to be converted into audio. We process this content solely to provide the LTA service.
- Communication: Records and copies of your correspondence (including email addresses) if you contact us for support or inquiries.
3.2. Information Collected Automatically:
- Log Data: Internet protocol (IP) address, browser type and version, operating system, referring URLs, pages visited, date and time stamps.
- Usage Data: Information about how you interact with our Site and Services, such as features used, time spent on pages, clicks, and performance statistics.
- Cookies and Similar Technologies: We use cookies and similar tracking technologies (e.g., web beacons) to track activity on our Service and hold certain information. See our Cookie section below for more details.
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How We Use Your Information
We process your Personal Information for the following purposes based on lawful grounds permitted by POPIA:
- To Provide and Manage Services (Contractual Necessity): To operate the Site, provide LTA and other Services, create and manage your account, process transactions, and deliver requested information or products.
- To Communicate With You (Contractual Necessity / Legitimate Interest): To respond to your inquiries, provide customer support, send administrative information (e.g., updates to terms, security alerts), and provide service-related announcements.
- For Billing and Account Management (Contractual Necessity / Legal Obligation): To process payments, issue invoices, and manage your subscription or service agreement.
- To Improve Our Services (Legitimate Interest): To understand how users interact with our Services, analyze usage patterns, troubleshoot issues, gather feedback, and develop new features or improvements. We often use aggregated or anonymized data for this purpose.
- For Security and Fraud Prevention (Legitimate Interest / Legal Obligation): To monitor for and prevent fraudulent activity, security incidents, and abuse of our Services.
- For Legal Compliance (Legal Obligation): To comply with applicable laws, regulations, court orders, or legal processes.
- For Marketing (Consent / Legitimate Interest): To send you marketing communications about our products or services that may interest you, where permitted by law. You can opt-out of marketing communications at any time. We will obtain explicit consent where required by POPIA (e.g., for electronic direct marketing to non-customers).
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Lawful Basis for Processing
We rely on the following lawful bases under POPIA to process your Personal Information:
- Consent: Where you have given us explicit consent for specific processing activities (e.g., subscribing to marketing emails).
- Contractual Necessity: Where processing is necessary for the performance of a contract with you (e.g., providing the LTA service you subscribed to) or to take steps at your request before entering into a contract.
- Legal Obligation: Where processing is necessary for compliance with a legal obligation to which we are subject (e.g., tax laws, responding to legal requests).
- Legitimate Interests: Where processing is necessary for our legitimate interests or the legitimate interests of a third party, provided these interests are not overridden by your fundamental rights and freedoms (e.g., improving services, security monitoring).
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Sharing and Disclosure of Information
We do not sell your Personal Information. We may share your information with third parties ("Operators" under POPIA) only in the following circumstances:
- Service Providers / Operators: We engage third-party companies and individuals to perform services on our behalf (e.g., cloud hosting (Akamai), payment processing, data analytics, email delivery, customer support tools). These Operators have access to your Personal Information only to perform these tasks on our behalf and are obligated by contract and under POPIA not to disclose or use it for any other purpose.
- Legal Requirements: We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court, government agency, or the Information Regulator).
- Business Transfers: If we are involved in a merger, acquisition, or asset sale, your Personal Information may be transferred as part of that transaction. We will provide notice before your Personal Information is transferred and becomes subject to a different privacy policy.
- Protection of Rights: We may disclose information where we believe it necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms and Conditions, or as evidence in litigation.
- With Your Consent: We may share your information for other purposes with your explicit consent.
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Data Security
We implement reasonable technical and organizational security measures designed to protect the security of any Personal Information we process, in compliance with POPIA. However, please remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
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Data Retention
We will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). Generally, this means we retain account information while your account is active and for a reasonable period afterward to comply with legal obligations, resolve disputes, and enforce our agreements. User Content submitted to LTA is typically processed and stored only as long as needed to provide the service and may be deleted sooner according to service settings or upon account deletion. We may retain aggregated or anonymized data indefinitely for analytical purposes.
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International Data Transfers
Your information, including Personal Information, may be processed and maintained on computers located outside of South Africa where the data protection laws may differ. We strive to host primary services within South Africa where possible. However, some of our third-party service providers (Operators) may be located internationally.
If we transfer your Personal Information outside of South Africa, we will ensure that adequate safeguards are in place as required by POPIA. This may include transferring data to countries deemed to have adequate data protection laws by South Africa, using Standard Contractual Clauses approved for international transfers, obtaining your explicit consent, or relying on Binding Corporate Rules where applicable.
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Your Data Subject Rights under POPIA
As a data subject in South Africa, you have the following rights regarding your Personal Information:
- Right of Access: You have the right to request confirmation of whether we hold Personal Information about you and to request access to that information.
- Right to Rectification: You have the right to request correction of inaccurate or incomplete Personal Information.
- Right to Erasure ('Right to be Forgotten'): You have the right to request the deletion or destruction of your Personal Information under certain conditions (e.g., if it's no longer necessary for the purpose collected, consent is withdrawn, or processing is unlawful).
- Right to Restrict Processing: You have the right to request the restriction of processing of your Personal Information under certain circumstances (e.g., while verifying accuracy, if processing is unlawful but you oppose erasure).
- Right to Object: You have the right to object to the processing of your Personal Information based on our legitimate interests or for direct marketing purposes.
- Right to Data Portability: Where processing is based on consent or contract and carried out by automated means, you may have the right to receive your Personal Information in a structured, commonly used, machine-readable format.
- Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time.
- Right to Complain: You have the right to lodge a complaint with the South African Information Regulator if you believe your rights under POPIA have been infringed.
To exercise any of these rights (except complaining to the Regulator), please contact our Information Officer using the details provided in the "Contact Us" section below. We may need to verify your identity before processing your request.
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Cookies and Tracking Technologies
We use cookies and similar tracking technologies to collect and track information about your usage of our Site and Services and store certain information. Cookies are small data files stored on your device. We use them for various purposes such as ensuring the Site functions correctly, remembering your preferences, analyzing performance, and potentially for marketing.
The types of cookies we may use include essential cookies (necessary for site function), performance/analytics cookies (help us understand usage), and functionality cookies (remember choices).
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
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Children's Privacy
Our Services are not intended for use by children under the age of 18. We do not knowingly collect Personal Information from children under 18. If you become aware that a child has provided us with Personal Information without parental consent, please contact us. If we become aware that we have collected Personal Information from a child under 18 without verification of parental consent, we take steps to remove that information from our servers.
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Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any significant changes by posting the new Privacy Policy on this page and updating the "Last Updated" date. We encourage you to review this Privacy Policy periodically for any changes. Changes are effective when they are posted on this page.
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Contact Us / Information Officer
If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or need to contact our designated Information Officer, please contact us at:
Email: hi@algernoninnovations.com
Via Website: Our contact page
The designated Information Officer is Boyd Kane.
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Information Regulator (South Africa)
If you have unresolved concerns, you have the right to complain to the Information Regulator of South Africa:
The Information Regulator (South Africa)
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
P.O. Box 31533, Braamfontein, Johannesburg, 2017
Complaints email: complaints.IR@justice.gov.za
General enquiries email: inforeg@justice.gov.za
Website: https://www.justice.gov.za/inforeg/