Thrive Together

Privacy Policy

1.    Introduction

1.1.    This policy will apply whenever you submit personal information to Thrive Together, which will include (but will not be limited to) when you browse our website or engage with any of our product and/or service offerings, including instances where your personal information is submitted to us through or by a third party (collectively “Services”).

1.2.    Your continued use of our Services indicates that you have read and consented to the terms of this policy.

1.3.    This policy sets out how Thrive Together will use your personal information and applies to any information, including personal information and special personal information, you give to Thrive Together or that Thrive Together may collect from Third Parties.

1.4.    It is important for you to read this policy carefully before submitting any personal information to Thrive Together.  By submitting any personal information to Thrive Together, you consent to the processing of your personal information as set out in this policy.

1.5.    This policy is subject to mandatory and unalterable provisions of applicable laws.

1.6.    Please do not submit any personal information to Thrive Together if you do not agree to any of the provisions of this policy. Please note that if you do not consent to the provisions of this policy, or parts of the policy, Thrive Together may not be able to provide its products and services to you.

2.    How to Contact Us 

If you have any comments or questions about this policy, please contact our Information Officer:

Postal Address:    6 Kallisti, 101 Ocean Drive, Shaka’s Rock, Ballito

Physical Address:    6 Kallisti, 101 Ocean Drive, Shaka’s Rock, Ballito

Phone:         076 740 8319

Email:        hello@thrivetogether.global

3.    Amendments

3.1.    We may amend this policy from time to time for any of the following reasons:

3.1.1.    to provide for the introduction of new systems, methods of operation, services, products, or offerings;

3.1.2.    to comply with changes in the law; 

3.1.3.    to ensure that our policy is clear and favourable to you;

3.1.4.    to rectify any mistake that may be discovered from time to time; and/or

3.1.5.    any other reason that Thrive Together, in its sole discretion, may deem reasonably necessary.

3.2.    Any such amendment will come into effect and become part of any agreement you have with Thrive Together when notice of the change is given to you by publication on our website.  It is your responsibility to check the website often.

4.    Privacy and Indemnity

4.1.    Thrive Together takes your privacy and the protection of your personal information very seriously.  We will only use your personal information in accordance with this policy and applicable data protection laws.  It is important that you take all necessary and appropriate steps to protect your personal information yourself (for example, by securing all passwords and access codes).

4.2.    We have implemented reasonable technical and operational measures to keep your personal information secure.

4.3.    You hereby indemnify and hold Thrive Together harmless from any loss, damages, or injury that you may incur as a result of any unintentional disclosures of your personal information to unauthorised persons or the provision of incorrect or incomplete personal information to Thrive Together.

5.    Information We May Collect About You

5.1.    We may collect the following information about you:

5.1.1.    your name, address, contact details, date of birth, place of birth, identity/registration number, passport number, bank details, financial information and electronic information (including your internet address, domain, activity logs, unique identifiers and geo-locations);

5.1.2.    records of correspondence or enquiries from you or anyone acting on your behalf;

5.1.3.    details of your transactions with us;

5.1.4.    details of your contracts with us;

5.1.5.    sensitive or special categories of personal information, including biometric information, such as images and voiceprints.

5.2.    Where you provide us with the personal information of a third party, you should inform the third party that you need to disclose their details to us. We will process their personal information in accordance with this policy.

6.    How We Collect Information

We may be provided with and/or collect your personal information:

6.1.    directly or indirectly (i.e., through an agent acting on your behalf), through the completion of an application form for our products and services or a request for further information about our products and services, whether in writing, through our website, over the telephone or any other means.

6.2.    from any regulator, or other third party that may hold such information.

7.    How We Use the Information Collected

7.1.    We may use, transfer, and disclose your personal information for the purposes of:

7.1.1.    providing you with the Services and notifying you about important changes to the Services, and to improve or evaluate the effectiveness of our business, products, services or offerings;

7.1.2.    managing your account with or our relationship with you and complying with your instructions or requests;

7.1.3.    detecting and preventing fraud and money laundering and/or in the interest of security and crime prevention;

7.1.4.    assessing and dealing with complaints and requests;

7.1.5.    operational, marketing, auditing, legal and record keeping requirements;

7.1.6.    verifying your identity or the identify of your beneficial owner;

7.1.7.    transferring or processing your personal information outside of the country in accordance with applicable laws, including for cloud storage purposes and the use of our website;

7.1.8.    complying with applicable laws, including lawful requests for information received from local or foreign law enforcement, government and tax collection agencies;

7.1.9.    recording and/or monitoring your telephone calls and electronic communications to/with Thrive Together in order to accurately carry out your instructions and requests, to use as evidence and in the interests of crime prevention;

7.1.10.    where you have unsubscribed from certain direct marketing communications, ensuring that we do not send such direct marketing to you again;

7.1.11.    disclosing your personal information to third parties for reasons set out in this policy or where it is not unlawful to do so, this may include but is not limited sharing information with credit bureaus and prospective buyers or sellers of our  business or assets);

7.1.12.    monitoring, keeping record of and having access to all forms of correspondence or communications received by or sent from Thrive Together or any of its employees, agents or contractors, including monitoring, recording and using all telephone communications between you and Thrive Together as evidence;

7.2.    From time to time, we may contact you for market research and about, services, products and offerings, available from Thrive Together or our or affiliates, which we believe may be of interest to you, by email, phone, text or other electronic means, unless you have unsubscribed from receiving such communications. You can unsubscribe from receiving such communications by emailing the Information Officer at: [email protected]

8.    Disclosure of your information

8.1.    Your personal information may be shared with Thrive Together’s affiliates, employees, our agents and sub-contractors, and selected third parties who process the information on our behalf.

8.2.    We may also disclose your personal information to third parties for those reasons recorded in clause 7.

8.3.    If you do not wish us to disclose this information to third parties, please contact us by using the contact details set out above. We may, however, not be able to provide products or services to you if such disclosure is necessary.

9.    Retention of Your Information

We may retain your personal information indefinitely, unless you object, in which case we will only retain it if we are permitted or required to do so in terms of applicable laws. However, as a general rule, we will retain your information in accordance with retention periods set out in applicable laws, unless we need to retain it for longer for a lawful purpose. For example, for the purpose of complaints handling and legal processes/proceedings.

10.    Access to, correction and deletion of your personal information

10.1.    You may request details of personal information which we hold about you under the Promotion of Access to Information Act, 2000 (“PAIA”). Fees to obtain a copy or a description of personal information held about you are prescribed in terms of PAIA. Confirmation of whether or not we hold personal information about you may be requested free of charge. If you would like to obtain a copy of your personal information held by Thrive Together, please review our PAIA Manual located at: https://www.thrivetogether.global.

10.2.    You may request the correction of personal information Thrive Together holds about you. Please ensure that the information we hold about you is complete, accurate and up to date. If you fail to keep your information updated, or if your information is incorrect, Thrive Together may limit the products and services offered to you.

10.3.    You have a right in certain circumstances to request the destruction or deletion of and, where applicable, to obtain restrictions on the processing of personal information held about you. If you wish to exercise this right, please contact us using the contact details set out above.

10.4.    You have a right to object, on reasonable grounds, to the processing of your personal information where the processing is carried out in order to protect our legitimate interests or your legitimate interests, unless the law provides for such processing.

11.    Complaints

11.1.    Should you believe that Thrive Together has utilised your personal information contrary to applicable laws, you undertake to first attempt to resolve any concerns with Thrive Together.

11.2.    If you are not satisfied with the process, you may have the right to lodge a complaint with the Information Regulator, using the contact details below:

Phone:    010 023 5200

Email:      [email protected]

12.    Log Files

When you visit our website, even if you do not create an account, we may collect information, such as your IP address, the name of your ISP (Internet Service Provider), your browser, the website from which you visit us, the pages on our website that you visit and in what sequence, the date and length of your visit, and other information concerning your computer's operating system, language settings, and broad demographic information. This information is aggregated and anonymous data and does not identify you specifically. However, you acknowledge that this data may be used to identify you if it is aggregated with other Personal Information that you supply to us. This information is not shared with third parties and is used only within Thrive Together on a need-to-know basis. Any individually identifiable information related to this data will never be used in any way that is different from that stated above, without your explicit permission.

13.    Cookies

We use cookies. A cookie is a small piece of information stored on your computer or smart phone by the web browser. The two types of cookies used on the website are described below:

13.1.    "Session cookies": These are used to maintain a so-called 'session state' and only last for the duration of your use of the website. A session cookie expires when you close your browser, or if you have not visited the server for a certain period of time. Session cookies are required for the platform to function optimally but are not used in any way to identify you personally.

13.2.    "Permanent cookies": These cookies permanently store a unique code on your computer or smart device hard drive in order to identify you as an individual user.  No Personal Information is stored in permanent cookies. You can view permanent cookies by looking in the cookies directory of your browser installation. These permanent cookies are not required for the website to work but may enhance your browsing experience.

14.    Third Party Links on the Website

14.1.    The services available through the website, may contain links to other third-party websites, including (but not limited to) social media platforms, payment gateways, appointment scheduling and/or live chat platforms ("Third-Party Websites"). If you select a link to any Third-Party Website, you may be subject to such Third-Party Website's terms and conditions and/or other policies, which are not under our control or responsibility.

14.2.    Hyperlinks to Third Party Websites are provided "as is", and we do not necessarily agree with, edit, or sponsor the content on Third Party Websites.

14.3.    We do not monitor or review the content of any Third-Party Website. Opinions expressed or material appearing on such websites are not necessarily shared or endorsed by us and we should not be regarded as the publisher of such opinions or material. Please be aware that we are not responsible for the privacy practices, or content, of other websites, either.

14.4.    Users should evaluate the security and trustworthiness of any Third-Party Website before disclosing any personal information to them. We do not accept any responsibility for any loss or damage in whatever manner, howsoever caused, resulting from your disclosure to third parties of personal information.

15.    Modifications and Amendments

15.1.    Thrive Together may amend this policy from time to time.

15.2.    To the extent permitted by applicable law, any such amendments will come into effect and become binding when notice is given of the change on the website. It is your responsibility to check the website regularly.

15.3.    All amendments or modifications will require your acceptance prior to your continued use of the website and shall thereby be construed as your consent. Your only remedy, should you disagree with such modifications, will be to refuse to accept the amended or updated policy thereby preventing you from using the website and or Services.