• Midrand, Gauteng, South Africa
  • +27 67 231 7960
Paragon Business Consult

Privacy Policy

Last Updated: 28 June 2024

Welcome to Paragon Business Consult (Pty) Ltd

We (“Paragon Business Consult,” “we,” “our,” “us”) are dedicated to protecting your privacy and ensuring your personal information is handled safely and responsibly. This Privacy Policy outlines how we collect, use, disclose, and safeguard your information when you visit our website, use our services, or interact with us.

We value your privacy and aim to be transparent about how we manage your data. By using our website or services, you consent to the processing of your personal information by Paragon Business Consult (Pty) Ltd as described in this policy.

If you do not agree with our policies and practices, please discontinue using our website and services immediately.

Introduction

  1. Data Collection: We gather and use personal information when you visit our website and use our services.
  2. Respecting Your Rights: We respect your privacy rights and protect your data from unlawful collection, retention, sharing, and use
  3. Purpose of This Policy: This policy informs you about how we handle your data and protect your rights
  4. Ongoing Notification: This policy serves as ongoing notification of our data practices while you have an active account or use our services, including browsing our website
  5. Policy Updates and Legal Compliance: We may update this policy to reflect changes in the law or our data practices. Updates will be published on our website and will be effective from the publication date. This policy is governed by South African law and is part of our agreements with users whenever possible.

Privacy Policy Definitions for Paragon Business Consult

In this privacy policy, the following terms are defined as follows:

  1. Consent: Any voluntary, specific, and informed indication of a user’s wishes, signifying their agreement to the processing of their personal data.
  2. Direct Marketing: Approaching a data subject in person, by mail, or via electronic communication to promote or offer goods or services, either directly or indirectly.
  3. Information Officer: The designated Information Officer of Paragon Business Consult at any given time.
  4. Operator: An external third party contracted to process personal information on behalf of Paragon Business Consult.
  5. PAIA: The Promotion of Access to Information Act 2 of 2000.
  6. Personal Information: Any data that can identify a user, including but not limited to:
    • Information about gender, nationality, ethnic or social origin, age, language.
    • Email address, physical address, telephone number, location data, online identifiers.
    • Financial details such as banking information and invoices.
    • Personal opinions, views, or preferences.
      Private or confidential correspondence.
    • Special personal information, including health-related data.
    • The user’s name if it reveals additional personal information.
  7. POPIA: The Protection of Personal Information Act of 2013, along with any related regulations or codes of conduct.
  8. Processing: Any operation or set of operations performed on personal data, whether automated or not, including:
    • Collection, receipt, recording, organization, collation, storage, updating, modification, retrieval, alteration, consultation, or use.
    • Dissemination by transmission, distribution, or making available in any other form.
    • Merging, linking, restriction, degradation, erasure, or destruction of information.
  9. Special Personal Information: Data related to religious or philosophical beliefs, race, ethnic origin, trade union membership, political opinions, health, sex life, biometric information, or criminal behavior.
  10. Services: The services provided by Paragon Business Consult to any user.
  11. User: Any visitor or user of Paragon Business Consult’s website or application, or any associated content or services.
  12. The Website: The website or application accessible at https://paragonconsult.co.za

Responsible Party

Paragon Business Consult is the entity responsible for collecting and processing users’ personal information, and thus serves as the “responsible party” under this policy.

For any inquiries, you can reach us at:

  • Email: support@paragonbusinessconsult.com
  • Website: https://paragonbusinessconsult.com

From time to time, Paragon Business Consult may engage third-party service providers to carry out specific processing activities involving users’ personal information.

Personal information collected

Paragon Business Consult may collect the following types of personal information for various purposes:

  • Personal Information: This includes your name, date of birth, home language, address, account details, and email address.
  • Communication Records: Notes or recordings of your calls to our support center, emails you send, or other records of your interactions with us.
  • Account Information: Details such as product types, payment dates, top-up information, and other account-related data.
  • Financial Information: Bank account details for processing debit orders.

Providing personal information to Paragon Business Consult is voluntary. However, if you choose not to provide certain information, it may limit our ability to perform specific functions or comply with legal obligations, which could affect the completion or performance of contracts with you.

Certain laws, such as RICA and FICA, and related directives, may require or authorize Paragon Business Consult to collect your personal information.

Purpose for Collection and Processing of Personal Information

Paragon Business Consult collects and processes personal information for specific, clearly defined, and lawful purposes related to its business functions or activities. These purposes include:

  • Contractual Obligations: To enter into or fulfill a contract with the user.
  • Legal Compliance: To adhere to legal requirements.
  • User Interests To protect the legitimate interests of the user, unless the user has objected in writing to specific processing activities on reasonable grounds.
  • Legitimate Interests: To pursue our own legitimate interests or those of a third party, unless the user has objected in writing to specific processing activities on reasonable grounds.
  • Direct Marketing: To process personal information for direct marketing purposes, but only if the user has opted in to receive such communications.
  • Customized Content: To customize and display content that may be of interest or benefit to the user.
  • Communication: To send content, including products, articles, listings, and advertisements, via email or other electronic media, provided the user has consented to such communications.
  • Interactive Features: To enable users to voluntarily participate in interactive features.
  • Notifications: To notify users about changes to the website or services.

If Paragon Business Consult intends to process a user’s personal information for any other purpose not listed or not automatically permitted by law, it will obtain the user’s written consent.

Paragon Business Consult will not sell a user’s personal information to any third party without the user’s prior written consent.

Collection Directly From The User

Paragon Business Consult endeavors to collect personal information directly from the user whenever possible. However, exceptions may occur in the following circumstances:

  • Public Records: When the information is available in a public record.
  • Consent: When the user has given written consent for us to collect information from another source.
  • Practicality: When it is more practical to obtain the information from another source.
  • No Prejudice: When collecting information from another source does not prejudice the user’s legitimate interests.
  • Legitimate Interests: When it is necessary to maintain our legitimate interests or those of a third party we intend to share the information with.
  • Purpose Prejudice: When collecting information directly from the user would compromise the purpose of collection.
  • Impracticality: When it is not reasonably practicable to collect information directly from the user.

If personal information is collected from a source other than the user, Paragon Business Consult will document the details of that source, including full names and contact information where applicable.

Paragon Business Consult may use cookies on its website to collect information in the following ways:

  • Through an iOS or Android application.
  • Via computer or mobile browser usage.
  • When users request additional services or information.
  • When users contact us to report issues with the website or services, or for any other reason.
  • When users complete forms on the website.from the user.

Users can visit the website without providing personal information. However, the website’s servers may still collect technical information for analytical purposes, technical maintenance, and content improvement. This information may include details of the user’s visit, such as IP address, operating system, browser type, location, and usage data. This information is aggregated and does not identify individual users.

Paragon Business Consult reserves the right to copy, distribute, or otherwise use such information without limitation.

Cookies

Cookies” are small text files transferred by a web server to a user’s hard drive and stored on their computer. These files collect information such as the user’s username, the date and time of visits, browsing history, and preferences.

Paragon Business Consult may use cookies on this website to:

  • Differentiate Users: Distinguish one user from another.
  • Session Memory: Remember the user’s last session when they return.
  • Audience Metrics: Estimate audience size and usage patterns.
  • Preference Storage: Store information about user preferences to customize the website and content accordingly.
  • Search Efficiency: Speed up searches on the website.

These provisions apply only to cookies used by Paragon Business Consult. Third-party service providers may also use cookies on the website, but Paragon Business Consult neither controls nor accesses these cookies and bears no responsibility for them.

Users have the right and ability to accept or decline cookies through their web browser settings, regardless of whether they are logged in as a member or visiting casually. However, declining cookies may restrict access to certain features of the website.

General Conditions For Processing Personal Information

  1. Legal Compliance: Paragon Business Consult (hereinafter “The Company”) is committed to adhering to all applicable laws, regulations, and contractual obligations when handling personal information.

  2. Fair and Reasonable Processing: The Company pledges to process personal information in a manner that is fair and reasonable. This means collecting, using, and storing information in ways that individuals would reasonably expect and that align with ethical standards.

  3. Respect for Privacy: The Company prioritizes the privacy rights of individuals. Whenever possible, alternative methods that pose no risk to privacy will be employed to achieve our goals. If less intrusive methods exist, The Company will opt for those.

  4. Relevance and Necessity: The Company ensures that all collected and processed personal information remains relevant and necessary for the stated purposes. Information collected will always be adequate and not excessive, serving only to fulfill the identified objectives.

  5. Purpose Limitation: Personal information will be processed strictly for the purposes for which it was collected. If the same goals can be achieved without processing personal information, The Company will refrain from such processing.

  6. Proportionality: The Company will apply processing activities that are proportionate to the intended purpose. Only the least privacy-invasive measures necessary to achieve the desired outcomes will be used.

  7. Balancing Interests: In processing personal information, The Company will ensure that users’ rights and interests are not unduly compromised. Any potential infringement of privacy rights will be justified by a significant and legitimate interest of The Company, ensuring minimal impact on user privacy.

  8. Data Retention: The Company retains the right to store personal information indefinitely unless the user objects. Upon achieving the purpose for collecting the information, The Company will delete or destroy the data unless otherwise directed by the user in writing or as required by law.

  9. Cessation of Processing: Once the original purpose for processing personal information is fulfilled, The Company will cease using the data. Should there be no further legitimate need to retain the information, it will be securely deleted or anonymized.

  10. User Rights and Transparency: The Company is committed to transparency in its data processing activities. Users will be informed of their rights, including the right to access, correct, and delete their personal information. The Company will ensure that users can exercise these rights easily and without undue delay.

  11. Security Measures: The Company employs robust security measures to protect personal information from unauthorized access, alteration, or destruction. Regular reviews and updates to security protocols ensure the continuous protection of user data.

  12. Continuous Improvement: The Company is dedicated to continuously improving its privacy practices. Regular audits and user feedback are integral to refining our data protection measures and ensuring compliance with the highest standards.

By adopting these principles, Paragon Business Consult aims to foster a trusted relationship with its users, ensuring their personal information is handled with the utmost care and respect.

Disclosure and sharing Personal Information

Sharing of Personal Information

  1. Third-Party Processing: Paragon Business Consult (hereinafter “The Company”) may share certain personal information with third-party operators who perform processing activities on behalf of The Company. This may occur in the course of providing content or services, or for concluding or performing any services or transactions with a user.

  2. Prior Notification: Users will be notified of the information shared and the categories of third-party operators with whom it is shared before any such sharing occurs. This ensures transparency and allows users to understand who will handle their personal data.

  3. Consent for Sharing: By using our services, you consent to The Company sharing your personal information with the following operators:

  4. Business Transfers: In the event of a reorganization or sale of The Company, personal information held about users may be transferred to the new organization. Users will be notified of such transfers and the associated implications for their personal data.

  5. Aggregated Information: The Company may share aggregated information about users and their usage patterns. This information will be de-identified, ensuring that individual users’ personal information is not disclosed.

  6. Express Consent: Except as stated in this policy, The Company will not share a user’s personal information with any third parties without obtaining the user’s express consent.

By adhering to these principles, Paragon Business Consult ensures that personal information is shared responsibly and transparently, safeguarding the privacy and trust of our users.

User rights in relation to the processing of their personal information

Rights in Relation to the Processing of Personal Information

Users of Paragon Business Consult (hereinafter “The Company”) have the following rights concerning the processing of their personal information:

  1. Access and Correction: Users have the right to access any personal information held by The Company about them. Additionally, users have the right to request the correction of any inaccurate or outdated personal information.
  2. Right to Object: Users have the right to object to the processing of their personal information. This includes the right to withdraw consent previously given for processing activities.
  3. Lodging Complaints: Users have the right to lodge a complaint with the Information Regulator if they believe their rights have been infringed upon. Complaints can be submitted through the Information Regulator’s website: Information Regulator.

By recognizing and facilitating these rights, Paragon Business Consult is committed to ensuring that users have control over their personal information and can engage with our services with confidence and transparency.

Further Processing

Paragon Business Consult (hereinafter “The Company”) commits to processing personal information solely for the purposes previously specified to the user. Any deviation from these specified purposes will occur only under the following circumstances:

  1. User Consent: Further processing will be conducted if the user has explicitly consented to such actions.

  2. Contractual Rights and Obligations: Further processing is permissible if it is necessary for exercising contractual rights or fulfilling obligations between The Company and the user.

  3. Compatibility with Original Purpose: Further processing activities that are linked to or compatible with the original purpose are allowed.

  4. Legal and Regulatory Requirements: –
    • Further processing is necessary for the prevention, detection, investigation, prosecution, and punishment of an offence.
    • Processing is required to enforce any law.
    • Further processing is essential for conducting legal proceedings in any court or tribunal, whether these proceedings have commenced or are reasonably anticipated.
  5. Protection of Life or Health: Further processing is necessary to prevent or mitigate a serious and imminent threat to the life or health of the user or another individual.

  6. Research and Statistical Purposes: Further processing is required for historical, statistical, or research purposes, provided that it serves the public interest and adheres to data protection principles.

Notification of Additional Purposes

If The Company intends to process personal information for purposes not previously specified, it will ensure that the user is notified of these new purposes. This notification will include the potential consequences of the intended further processing for the user.

By adhering to these guidelines, Paragon Business Consult ensures that personal information is processed responsibly, transparently, and in accordance with user expectations and legal requirements.

Accuracy, correctness and completeness of personal information.

Paragon Business Consult (hereinafter “The Company”) is committed to maintaining the accuracy and completeness of the personal information it holds about its users. The following steps and guidelines outline the process for ensuring and correcting the accuracy of this information:

  1. Maintaining Accurate Information: The Company will take all reasonably practicable steps to ensure that the personal information it retains about users is complete, accurate, not misleading, and updated as necessary.

  2. User Responsibility: If a user becomes aware of any personal information in The Company’s custody that is incorrect, inaccurate, or needs updating, the user should submit a written request to The Company’s information officer at popi@paragonconsult.co.za to correct or update the relevant information.

  3. Contesting Information Accuracy: If a user contests the accuracy of any personal information being used by The Company, The Company will immediately stop using that information until its accuracy has been verified, provided it is reasonably practicable to do so.

  4. Adherence to Correction Requests: The Company reserves the right to adhere to a user’s request for correction or updating of personal information only if the change will result in the information being correct and accurate.

By following these policies, Paragon Business Consult ensures that the personal information it processes is reliable and up-to-date, maintaining the trust and confidence of its users.

Security safeguards.

Paragon Business Consult (hereinafter “The Company”) is dedicated to safeguarding the personal information in its custody against any loss, damage, unauthorized destruction, or access. The following measures and protocols outline our commitment to data protection:

  1. Risk Management and Security Safeguards: The Company continually identifies and documents any risks to the personal information it holds. Appropriate security safeguards are in place to mitigate these risks and ensure the protection of personal data.

  2. Third-Party Operator Obligations: The Company includes stringent data protection clauses in contracts with third-party operators who process personal information on its behalf. These obligations include:

    • Authorization: Operators must not process any personal information without The Company’s knowledge and authority.
    • Confidentiality: Operators must treat all personal information as confidential and must not disclose it to any unauthorized third parties.
    • Security Measures: Operators must establish and maintain security measures that are equivalent to or exceed those employed by The Company.
    • Breach Notification: Operators must notify The Company immediately if there are reasonable grounds to believe that any personal information has been leaked or accessed by unauthorized persons.
    • International Compliance: If an operator is located in another country, it must comply with the data protection laws of that country and provide verification of compliance.
    • Legal Disclosures: Operators legally obliged to disclose any personal information must notify The Company beforehand to enable The Company and/or individual users to protect their rights if necessary.

  3. Data Backup and Recovery: The Company ensures that all personal information on its systems is properly backed up. Backup copies are stored separately from live files to prevent data loss or unauthorized access in case of system failures or breaches.

By implementing these measures, Paragon Business Consult ensures robust protection of personal information, maintaining the privacy and trust of its users.

Notification of breach of security

Paragon Business Consult (hereinafter “The Company”) is committed to promptly addressing any security breaches involving personal information. The following procedures outline our response in the event of a data breach:

  1. Immediate Identification and Notification: If personal information about a user is inadvertently leaked or if The Company’s security is unlawfully breached by an unauthorized party, The Company will immediately identify the users who may be affected by the breach.
  2. User Contact: The Company will contact the affected users at their last known email address, contact details, or by the quickest means possible. This ensures timely communication and allows users to take swift action.

  3. Providing Information and Guidance
    • The Company will provide sufficient information to the affected users to enable them to take necessary protective measures against the potential consequences of the compromise. This includes:
      • Detailed information about the nature of the breach.
      • Steps the user can take to protect themselves.
      • Potential consequences that may arise from the breach.
      • Contact information for further assistance and support.

By adhering to this policy, Paragon Business Consult ensures that users are promptly informed and adequately supported in the event of a security breach, helping to mitigate potential risks and maintain user trust.

Cross border transfers of personal information.

  1. User Consent: Users consent to the transfer of their personal information, including special personal information, across national borders.

  2. Purpose of Transfers: Transfers may occur for storage or if it serves The Company’s or a third party’s legitimate interests, even to countries without similar data protection laws.

  3. Safeguards: The Company will ensure appropriate measures to protect personal information during such transfers.

By following this policy, Paragon Business Consult ensures that users are informed and consent to transborder data transfers while maintaining data protection standards.

Retention of information

  1. Indefinite Retention: Users consent to The Company keeping records of their personal information for an indefinite period.

  2. User Objection: If a user objects, The Company will cease retaining the records unless legally entitled or required to keep them.

By adhering to this policy, Paragon Business Consult ensures clarity on data retention practices while respecting user preferences and legal obligations.

Returning, destroying or deleting personal information

  1. Destruction or Deletion: When The Company is no longer authorized to retain personal information, it will ensure the information is permanently destroyed or deleted as soon as reasonably practicable.

  2. Return or Transfer: If requested in writing by the user, The Company will return the information to the user or transfer it to a third party.

By following this policy, Paragon Business Consult ensures proper handling of personal information when retention is no longer authorized.

Consent.

  1. Voluntary Consent: The user consents to the processing of their personal information in accordance with the provisions outlined in this privacy policy.

  2. Acknowledgment and Understanding: The user acknowledges and agrees that their consent is voluntary and has been given after reading and understanding this privacy policy, particularly concerning:
    • The types of personal information, including special personal information, to be processed.
    • The specific processing activities that will be undertaken.The specific purpose(s) for which the information will be processed.
    • The potential consequences for the user resulting from such processing.

  3. Withdrawal of Consent: If a user wishes to withdraw any consent previously given, they must notify The Company’s information officer in writing.

By adhering to this policy, Paragon Business Consult ensures that user consent is obtained transparently and can be withdrawn in accordance with user preferences.

How to request the removal of your information.

Process for Requesting Removal

  1. Direct Request Process: Users can request the removal of certain information by emailing support@paragonconsult.co.za.

  2. Steps to Request Removal:
    • Log into your email account.
    • Address your email to support@paragonconsult.co.za.
    • Provide the following details:
      • Full name
      • Contact information
      • Specific information to be removed (e.g., first name, surname, email address, cellphone number, company name, ID number, addresses, payment details)
      • Specify if you wish to remove Personal Information, Payment Details, or both.

  3. Active Product/Service Disclaimer: If you have an active product/service with us, you cannot request the removal of personal or payment information necessary for continued service provision.

  4. Review Process: The request will be forwarded to Paragon Business Consult’s dedicated POPI team.Each request will be reviewed on a case-by-case basis.The POPI team will contact you to communicate the outcome of your request.

  5. Outcome Notification: Please note that not every request will necessarily result in the removal of the requested information. Decision outcomes will be communicated to you promptly.

By following this policy, Paragon Business Consult facilitates the process for users to request the removal of their personal information while ensuring compliance with applicable legal and operational requirements.

Choice of law.

This privacy policy of Paragon Business Consult (hereinafter “The Company”) shall be governed and interpreted in accordance with the laws of the Republic of South Africa.

By specifying the governing law, Paragon Business Consult ensures that this privacy policy is aligned with legal principles and requirements applicable in South Africa.

Amendment of this privacy policy

  1. Modification Rights: The Company reserves the right to change, update, add, remove, or amend any provisions of this privacy policy at any time.

  2. Effective Date: Changes, updates, additions, removals, or amendments to this privacy policy will be effective from the date of their publication on the Paragon Business Consult website.

  3. User Responsibility: It is the user’s responsibility to periodically check this privacy policy for any changes, updates, additions, removals, or amendments.

  4. Acceptance of Changes: The user’s continued use of this website following any changes to this privacy policy will constitute acceptance of and agreement to abide by the revised policy.

By outlining these terms, Paragon Business Consult ensures transparency and user awareness regarding updates to its privacy policy, maintaining compliance and user trust.

Contact.

For more information regarding your rights to privacy or the information processing activities of Paragon Business Consult, please contact us directly at support@paragonconsult.co.za.

This contact information ensures accessibility for users seeking clarification or assistance concerning their privacy rights and data processing activities by Paragon Business Consult.

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