1. Introduction

GIMTRAC is a registered company that specialises in the manufacturing of sports goods. The legal entity information is available on the website www.gimtrac.co.za The company has been in existence for 40 years and has a footprint not only in South Africa but also in many African countries.

2. Definitions

In this document references to GIMTRAC and its subsidiary divisions includes the steel / metal, wood, PVC , apparel and administrative sections.

“ Process “ means how GIMTRAC acquires, stores, uses, makes available , updates,  discloses or otherwise deals with information of staff, service providers  and customers’ personal information.

As a general rule, GIMTRAC will only process a service provider and a customer’s personal information if this is required to deliver or provide a solution to a customer. GIMTRAC respects the customers’ privacy and will treat their personal information confidentially at all times.

Personal information of staff members will similarly only be used to benefit of the company and with the permission of the staff member(s ). 

3. Purpose of the Document

This document outlines how GIMTRAC undertakes to collect, use and store personal information of staff, service providers and customers. It also outlines service providers and customers’ privacy rights and how the law protects these rights. GIMTRAC adheres to general principles in accordance with applicable privacy laws. GIMTRAC will change this document content from time to time if required to do so by law or by its business practices. If such change is required staff, service providers and customers will be allowed a reasonable time to raise objections before the change is made. The latest version of this document will be displayed on the company’s website. www.gimtrac.co.za

4. Responsible Party and Operator

5. Personal Information

Personal information refers to any information that identifies an individual person ( juristic entity ) or specifically relates to an individual. Personal information includes but is not limited to:

• Employment history and current employment status
• Gender or sex
• Biometric information
• Marital status
• National origin
• Financial history
• Age, language, education, birth, race. 
• Financial information such as banking, income, obligations, expenses, account transactions, etc.
• Identifying numbers such as passport, id, account numbers.
• Information on your location, physical address, work address, home address.
•  Social media profiles.
• Health related information such as medical history, mental health, disability, preferences and opinions.
• Confidential correspondence.
• Religion, belief, conscience, culture.

6. Processing Personal Information

GIMTRAC may process service providers, customer’s and or/ staff members personal information for the following reasons:

• To open manage and maintain service providers and customers’ accounts.
• To communicate with service providers and customers regarding their needs, instructions and requests.
• To meet record keeping obligations
• To conduct market related research
• To perform all duties regarding staff care
• To manage the work areas in the factory
• To ensure that staff receive all benefits that they are entitled to
• To manage payroll administration
• To manage staff benefits and affiliations.
• For training purposes.
• To manage health related processes
• For customer satisfaction surveys.
• For marketing purposes.
• To fulfil reporting requirements and information requests.
• To process invoices and payment procedures.
• To detect and report theft, corruption and other crimes.

7. Obtaining Personal Information About Service Providers, Staff and Customers

GIMTRAC collects personal information of service providers, customers and staff from:

• Service providers, customers and staff themselves
• Through social media platforms
• Through email messages
•  Through advertising and marketing campaigns
• From third parties
• From public sources such as newspapers, company registers and online search engines.
• People the service provider, customer or staff member has authorised to share their personal information or a medical practitioner.
• Regulatory and law enforcement agencies if so required.
• Qualification information providers

8. Sharing Customers and Staff Members Personal Information

GIMTRAC will only share customer and staff members personal information under the following conditions:

• If the individual has consented to this
• If it is required by the law.
• If it is necessary to protect the service provider, customer or staff member
• In order to conclude a contract or service level agreement
• For payroll, UIF, MIBFA or any other related staff activity
• For medical reasons if so required.
• For marketing purposes

9. The Use of Customers and Staff Members Information for Marketing Purposes

GIMTRAC will use customers personal information to:

• Market products to them.
• Inform them of new products.
• Provide information regarding special opportunities and stock price reduction sales.
• Inform them of additional services.
• Staff information may be used in marketing activities of the company, with their permission.

10. Service Providers, Staff and Customers Duties and Rights Regarding the Personal Information that Gimtrac has about them

10.1 Duties – Service Providers, Staff and Customers Neet to:

• Inform GIMTRAC of any changes to their personal information as soon as possible after the changes.
• Provide information regarding their spouses, dependants and any other person whom they have permission from to do so, if it impacts on services, work related matters, conditions of service or any other related matter.

10.2 Rights – Staff and customers have the following rights:

• Right to correction, deletion or destruction of personal information if it is inaccurate, irrelevant, outdated, incomplete, obtained unlawfully or outdated.
• GIMTRAC may request documentary proof to substantiate the requests for removal of personal information.
• Right to objection. Staff and customers may object on reasonable grounds to the processing and management of their personal information where the objection is in their personal interest. Such objection must be submitted in the prescribed way in writing.
• The right to withdraw consent. Where a staff member, service provider or customer has provided their consent for the processing of their personal information, they may withdraw their consent. GIMTRAC shall then not use their personal information for those areas where consent has been withdrawn.
• Right to complain of an alleged contravention of the protection of their personal information. GIMTRAC will deal with such complaints as far as possible. Thereafter service providers, customers and staff will have the right to submit such complaints to the relevant regulatory body.

11. Security Protocols

GIMTRAC has the following security protocols I place to prevent access to personal information     of service providers, staff and customers:

• Complex passwords
• No open shares
• All access to any information is password controlled with restricted access as well as auditing

12. Website Security Protocols

The Gimtrac website (https://www.gimtrac.co.za) is owned and operated by “Gimtrac”. By using the Gimtrac website site, you agree to the Internet Privacy Policy of the website (“our website – https://www.gimtrac.co.za”). The Internet Privacy Policy relates to the collection and use of personal information you may supply to us through your conduct through our website.

We recognise the importance of protecting the privacy of information collected about visitors through our website, in particular information that is capable of identifying an individual (“personal information”). The Internet Privacy Policy governs the manner in which your personal information, obtained through the website, will be dealt with. The Internet Privacy Policy should be reviewed periodically so that you are updated on any changes.

Collection of Personal Information

Personal information about visitors on our site is collected only when knowingly and voluntarily submitted. For example, we may need to collect such information to provide you with further services or to answer or forward any requests or enquiries. It is our intention that this policy will protect your personal information from being dealt with in any way that is inconsistent with applicable privacy laws in South Africa.

Use of Personal Information

Personal information that visitors submit through our site (https://www.gimtrac.co.za) is used only for the purpose for which it is submitted or for such other secondary purposes that are related to the primary purpose. Copies of correspondence sent from the website, that may contain personal information, are stored as archives for record-keeping and back-up purposes only.

Disclosure

Apart from where you have consented or disclosure is necessary to achieve the purpose for which it was submitted, personal information may be disclosed in special situations where we have reason to believe that doing so is necessary to identify, contact or bring legal action against anyone damaging, injuring, or interfering (intentionally or unintentionally) with our rights or property, users, or anyone else who could be harmed by such activities. Also, we may disclose personal information when we believe in good faith that the law requires disclosure.

We may engage third parties to provide you with goods or services on our behalf. In that circumstance, we may disclose your personal information to those third parties in order to meet your request for goods or services.

Security

We strive to ensure the security, integrity and privacy of personal information submitted to our sites, and we review and update our security measures in light of current technologies. Unfortunately, no data transmission over the Internet can be guaranteed to be totally secure.

However, we will endeavour to take all reasonable steps to protect the personal information you may transmit to us or from our online products and services. Once we do receive your transmission, we will also make our best efforts to ensure its security on our systems.

In addition, our employees and the contractors who provide services related to our information systems are obliged to respect the confidentiality of any personal information held by us. However, we will not be held responsible for events arising from unauthorised access to your personal information.

Collecting Information for Users

• IP Addresses – Our web servers gather your IP address to assist with the diagnosis of problems or support issues with our services. Again, information is gathered in aggregate only and cannot be traced to an individual user.
• Cookies and Applets – We use cookies to provide you with a better experience. These cookies and Applets allow us to increase your security by storing your session ID and are a way of monitoring single user access.
• This aggregate, non-personal information is collated and provided to us to assist in analysing the usage of the site.

Access to Information

We will endeavour to take all reasonable steps to keep secure any information which we hold about you, and to keep this information accurate and up to date. If, at any time, you discover that information held about you is incorrect, you may contact us to have the information corrected.

In addition, our employees and the contractors who provide services related to our information systems are obliged to respect the confidentiality of any personal information held by us.

Problems or questions

If we become aware of any ongoing concerns or problems with our websites, we will take these issues seriously and work to address these concerns. If you have any further queries relating to our Privacy Policy, or you have a problem or complaint, please contact us.

Advertising – Google Adwords

In accordance with some of Google’s recent compulsory policies, we herewith inform you that we might be tracking your cookies as our web site / company is currently undertaking Google AdWords remarketing of any other Google AdWords feature that tracks such cookies.

By visiting this site, you agree that certain of our Google AdWords remarketing and or other advertisements can follow you as you visit other web sites that forms part of Google’s Display Network (GDN).

Note that we shall under no circumstances be utilizing any personally identifiable information as obtained through our Google AdWords remarketing campaign in any other related marketing endeavours – online or otherwise. (Such restricted utilization of information includes the sharing of such with third parties.)

The Company shall under no circumstances be using any sensitive information of any nature on any of our remarketing tags.

The Company shall duly endeavour to adhere to all of the current in-effect policies of Google related to remarketing or any other form of Google advertising in all of its Google AdWords marketing campaigns. (In instances of possible non-conformity to such, the Company shall endeavour to rectify such in a prompt manner.)

You may opt out of seeing advertisements for web site, by simply clicking here: – http://www.google.com/policies/technologies/ads/.

13. Keeping Information

GIMTRAC will keep personal information for as long as:

• At least three years after the year in which a staff member has left the employ of GIMTRAC or as determined by any other Act or legal requirement of the industry.
• A contract between GIMTRAC and a service provider or customer requires GIMTRAC to keep it.
• It is required for statistical and reporting purposes.

This policy was approved during a management meeting held on Monday 28 June 2021.