1.1.1. our website, https://www.blanchard.co.za;
1.1.2. our social media properties;
1.1.3. our events, marketing and business development activities;
1.1.4. our business communications and other online and offline business interactions;
1.1.5. our professional services;
1.1.6. third party service providers, including analytics, advertising networks; search information, technical, payment and delivery services providers;
1.1.7. publicly available sources;
1.1.8. request/s for tenders, quotations, proposals and the like made by or to us;
1.1.9. the supply of products and services to us.
2. Purpose of this policy
2.1. BSA respects your privacy and is committed to protecting your personal information (as defined in applicable data protection legislation).
2.2. You warrant that you are lawfully entitled to provide personal information of any third party whose personal information you provide to BSA.
2.3. You indemnify the BSA against any loss, liability, damage or expense (including interest and penalties) suffered or incurred by BSA due to your provision of personal information of third parties to us in an unlawful manner.
3. How to contact our chief information officer
3.1. BSA has an information officer who oversees our data protection compliance. You can contact our chief information officer at:
Address: 1 Sangiro Street, Vorna Vallley, Midrand
E-mail address: email@example.com
Telephone number: +27 74 705 6532
4. Privacy and security
4.1. BSA has implemented reasonable technical and organisational measures to keep personal information secure and in compliance with applicable data protection laws.
4.2. You indemnify and hold BSA harmless from any loss, damages or injury that you may incur as a result of:
4.2.1. any security compromise of personal information to unauthorised persons; or
4.2.2. your acts or omissions during the provision of personal information to BSA.
5. Personal information which BSA may collect
BSA may collect the following personal information:
5.1. name, address (including proof of address), other contact details (e.g. email and telephone numbers), gender, marital status, date and place of birth, nationality, employer, job title, financial records and employment history, and family details, including their relationship to you;
5.2. identification numbers issued by government bodies or agencies, such as your identity number, passport number, tax identification number and driving licence number and company registration number;
5.3. demographic information such as your address, preferences and interests;
5.4. information relevant to the provision of our products and services;
5.5. information relevant to the procurement of products and services from suppliers;
5.6. bank account or payment card details, income or other financial information;
5.7. information that you provide to us as part of us providing products and services to you, which depends on the nature of your instructions to any employee or member of BSA;
5.8. special or sensitive personal information as defined in applicable data protection legislation, including information about your health, racial or ethnic origin, political opinions, religious or philosophical beliefs and trade union membership; your genetic and biometric information; information about your sex life;
5.9. relevant information as required by applicable laws, including anti-money laundering legislation and as part of our client onboarding procedures, including evidence of source of funds;
5.10. information you provide to us for the purposes of attending meetings and events, including dietary requirements which may reveal information about your health or religious beliefs;
5.11. identity data, contact data and special personal information from publicly available sources or third parties, service providers and the like who conduct screening on BSA’s clients or vendors for anti-money laundering purposes, or third parties with whom BSA hosts events.
6. Quality of information
BSA is obliged to keep personal information accurate and up to date. Please help us to do this by advising us of any changes to your personal information.
7. Purpose of processing of personal information
BSA may process the personal information it collects for a number of lawful purposes including:
7.1. to register you as a client of BSA;
7.2. to conduct sanctions screening against any list that BSA may in its sole discretion elect;
7.3. to comply with requirements under applicable laws;
7.4. to carry out services;
7.5. to carry out instructions provided to any employee or member of BSA for services;
7.6. to provide you with any other services, products or offerings that you may have requested or otherwise consented to, or which may be ancillary thereto, or associated therewith, and to notify you about changes to such services, products or offerings;
7.7. to manage marketing preferences;
7.8. to manage BSA’s relationship with you which may include:
7.8.1. notifying you about changes to BSA’s terms (including to this policy);
7.8.2. asking you to leave a review or take a survey;
7.8.3. assessing and dealing with complaints and requests;
7.8.4. managing payments, fees, charges and accounts (including collecting and recovering money owed to BSA);
7.9. to verify your identity or the identity of your beneficial owners;
7.10. to comply with lawful requests for information received from local or foreign law enforcement, government and tax collection agencies;
7.11. to comply with measures designed to protect or advance persons, or categories of persons, disadvantaged by unfair discrimination;
7.12. to monitor, keep record of and have access to all forms of correspondence or communications received by or sent from BSA or any of its employees, agents or contractors, including monitoring, recording and using as evidence, where applicable, all telephone and online communication software communications between us and you;
7.13. to detect and prevent fraud and money laundering and/or in the interest of security and crime prevention;
7.14. to administer and protect BSA’s business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
7.15. for operational, marketing, auditing, legal and record keeping requirements;
7.16. to conduct market research and provide you with information about BSA’s products or services from time to time via email, telephone or other means;
7.17. to deliver relevant website content and newsletters and other information to you (which may include direct marketing material);
7.18. to use data analytics to improve the BSA’s website, products/services, newsletters, customer relationships and experiences;
7.19. to make suggestions and recommendations to you about goods or services that may be of interest to you;
7.20. to disclose personal information to third parties for reasons set out in this policy or where it is not unlawful to do so;
7.21. to improve or evaluate the effectiveness of BSA’s business or products, services or offerings;
7.22. for submissions to awards and rankings agencies;
7.23. for purposes of material aimed to promote BSA;
7.24. to prevent and control any disease;
7.25. where you have unsubscribed from certain direct marketing communications, to take steps to implement your instruction;
7.26. to procure goods and services;
7.27. to respond to requests for quotations and tenders.
8. Direct marketing
You have the right to object to receiving direct marketing (opt out) at any time by unsubscribing here: mailto: firstname.lastname@example.org , or on any of our platforms.
9. Disclosure of Personal Information
BSA may, as we may deem necessary for any one or more of the purposes set out in this policy or other lawful purposes, transfer personal information to third parties or service providers, including to:
9.1. service providers acting as operators or processors or responsible parties or controllers who provide information technology and system administration services;
9.2. professional advisors acting as operators or processors or responsible parties or controllers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance, accounting and other services;
9.3. service providers and the like who conduct screening on BSA’s clients (or their beneficial owners) or suppliers for anti-money laundering purposes;
9.4. regulators and other authorities if BSA is legally obliged to do so, or if instructed by you to do so, for purposes of preventing, detecting and reporting fraud and criminal activities, the identifying of the proceeds of unlawful activities and the combatting of crime;
9.5. any person if BSA is under a duty to disclose or share personal information in order to comply with any applicable laws, or to protect the rights, property or safety of any member of BSA, other clients or other third parties, or the reputation of BSA;
9.6. your agent or any other person acting on your behalf, or an introducer;
9.7. tracing agents, sheriffs and the like;
9.8. various awards and rankings agencies;
9.9. clients and prospective clients for purposes of rendering services, proposals, quotations, tenders and the like; and
9.10. a third party/parties whom BSA may choose to sell, transfer or merge parts of BSA’s business or assets. Alternatively, BSA may seek to acquire other businesses or merge with them. If a change happens to BSA’s business, then the new owners may use personal information in the same way as set out in this policy.
10. Access to, correction and deletion of personal information
Under certain circumstances, you may have some or all of the rights set out below under the data protection laws that may be applicable in relation to your personal information which BSA holds.
10.1. Request access to personal information (commonly known as a “Data Subject access request”), including the right to receive a copy of the personal information.
10.2. Request correction of any incomplete or inaccurate personal information.
10.3. Request erasure of personal information if BSA is not authorised to process the personal information.
10.4. Object to processing of personal information, if BSA is relying on its legitimate interest (or those of a third party) to process the personal information, but as a result of your particular situation such processing impacts on your fundamental rights and freedoms.
10.5. Request restriction of processing of personal information whilst a complaint is being investigated.
10.6. Withdraw consent at any time if BSA is relying on consent to process personal information. If you withdraw your consent, BSA may not be able to provide certain products or services to you. This will be considered on a case-by case basis.
11. Electronic and website link
11.1. BSA’s website, newsletters and/or events marketing pages may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share your personal information.
11.2. BSA does not control these third-party websites and is not responsible for their privacy policies. When you leave the BSA’s website, we encourage you to read all applicable privacy policies.
If you are not satisfied with the BSA’s use of your personal information or our response to any request by you to exercise your rights, or if you think that we have breached any relevant data protection laws, you are encouraged to contact our Chief Information Officer at the contact details set out above or the relevant information officer set out in the applicable countryspecific schedule to this policy, if applicable. Should you remain dissatisfied, then you have the right to complain to the authority that supervises our processing of your personal information.
13. Latest Version
13.1. BSA keeps this policy under regular review and may amend this policy from time to time.
13.2. Any such amendment will come into effect when published on the BSA website and become part of any agreement that you have with BSA.
13.3. You must ensure that you obtain the latest version of this policy before any action is taken based hereon. It is your responsibility to check the BSA website often.