1. INTRODUCTION

This Privacy Policy describes how Commec CC, trading as cAfrica ("cAfrica", "we", "our", or "us") collects, uses, stores, protects, transfers and otherwise processes personal information when individuals access or use any cAfrica products or services.

This Privacy Policy applies to all users of the cAfrica ecosystem, including users of:

  • the cAfrica website
  • cAfrica mobile applications
  • Smart TV applications
  • Android TV applications
  • Samsung TV applications
  • LG webOS applications
  • Hisense VIDAA applications
  • Apple TV applications
  • Amazon Fire TV applications
  • Roku TV applications
  • the cAfrica TV Stick
  • Live Television services
  • Video-on-Demand ("VOD") services
  • subscription-based services
  • advertising-supported streaming services

any future applications, websites or digital platforms operated by Commec CC trading as cAfrica.

By accessing or using the Service, the user acknowledges that they have read, understood and accepted this Privacy Policy.

Where applicable, additional consent may be requested before particular categories of personal information are collected or processed.

Nothing contained in this Privacy Policy limits any rights that users may have under applicable privacy or consumer protection legislation.

2. OUR COMMITMENT TO PRIVACY

cAfrica recognises that privacy is a fundamental right.

Accordingly, Commec CC trading as cAfrica is committed to processing personal information:

  • lawfully
  • fairly
  • transparently
  • securely
  • proportionately

only for legitimate business purposes.

Our privacy programme has been developed with reference to internationally recognised privacy principles and applicable legislation, including, where applicable:

  • the Protection of Personal Information Act, 2013 ("POPIA")
  • the Promotion of Access to Information Act
  • the General Data Protection Regulation ("GDPR")

the California Consumer Privacy Act ("CCPA") and California Privacy Rights Act ("CPRA");

other applicable privacy legislation in jurisdictions where cAfrica operates.

Where local legislation grants users additional rights, those rights shall apply to the extent required by applicable law.

3. SCOPE OF THIS POLICY

This Privacy Policy governs all personal information collected through or in connection with the Service.

It applies regardless of whether access occurs through:

  • desktop computers
  • laptops
  • smartphones
  • tablets
  • Smart TVs
  • streaming devices
  • set-top boxes
  • gaming consoles
  • connected television devices

future supported devices.

It also applies to interactions involving:

  • customer support
  • competitions
  • promotions
  • surveys
  • newsletters
  • subscription services
  • advertising services
  • partner integrations
  • account registration
  • payment processing
  • authenticated services

content recommendations.

Certain third-party services accessible through the Service may publish separate privacy policies.

cAfrica is not responsible for privacy practices of third parties that operate independently of Commec CC.

Users are encouraged to review the privacy policies of external websites and services before providing personal information.

4. INFORMATION WE COLLECT

The categories of information collected depend upon how the Service is used.

4.1 Information Provided by Users

Users may voluntarily provide information including:

  • full name
  • email address
  • telephone number
  • date of birth (where required)
  • billing information
  • account credentials
  • communication preferences
  • customer support enquiries
  • competition entries

marketing preferences.

Providing certain information may be necessary to access subscription services or account-based functionality.

4.2 Device Information

To ensure proper functionality, security and optimisation of the Service, cAfrica may collect technical information including:

  • IP address
  • device identifiers
  • device manufacturer
  • operating system
  • operating system version
  • browser type
  • browser version
  • application version
  • language settings
  • screen resolution
  • network provider
  • approximate geographic location
  • streaming capability
  • internet connection quality
  • crash diagnostics

error reports.

4.3 Viewing and Usage Information

To improve user experience and platform performance, cAfrica may collect information relating to:

  • content viewed
  • viewing duration
  • watch history
  • search history
  • navigation behaviour
  • clicks
  • content ratings
  • favourites
  • watchlists
  • viewing preferences
  • viewing frequency
  • session duration
  • playback interruptions
  • streaming quality metrics

buffering statistics.

This information assists cAfrica in improving service quality and personalising user experiences.

4.4 Advertising Information

As cAfrica operates a hybrid advertising-supported and subscription-supported streaming service, certain information relating to advertising interactions may be processed, including:

  • advertisement requests
  • advertisement impressions
  • advertisement completion rates
  • advertisement interaction events
  • campaign performance metrics
  • anonymous audience segmentation
  • device category
  • approximate location

advertising identifiers where permitted by applicable law.

Advertising technologies may use cookies, software development kits (SDKs), pixels or similar technologies in accordance with user consent where legally required.

No advertising is currently delivered within cAfrica's Radio or Audio services.

4.5 Payment Information

Where users subscribe to premium services, payment processing is performed by authorised payment providers.

cAfrica generally does not store complete payment card information.

Payment providers may process:

  • cardholder name
  • billing address
  • payment token
  • transaction reference
  • payment status

fraud prevention information.

Payment processing is governed by the relevant payment provider's privacy policies and security standards.

5. HOW WE USE PERSONAL INFORMATION

Personal information is processed only where there is an appropriate legal basis.

Depending upon the Service used, cAfrica may process information for purposes including:

5.1 Service Delivery

To:

  • provide streaming services
  • authenticate users
  • deliver subscriptions
  • maintain accounts
  • provide customer support
  • deliver purchased services

remember user preferences.

5.2 Platform Performance

To:

  • improve streaming quality
  • optimise bandwidth
  • improve application performance
  • diagnose technical faults
  • monitor system availability
  • improve accessibility
  • conduct software testing

improve user experience.

5.3 Personalisation

To provide:

  • personalised recommendations
  • content suggestions
  • viewing history
  • recently watched content
  • continue watching functionality
  • language preferences

interface customisation.

Personalisation may be disabled where technically feasible.

5.4 Advertising Services

Where applicable and permitted by law, personal information may be processed to:

  • deliver relevant advertising
  • manage advertising frequency
  • prevent repetitive advertising
  • measure campaign performance
  • detect invalid traffic
  • prevent advertising fraud
  • measure audience engagement

support reporting and revenue reconciliation.

Advertising is delivered only through authorised commercial partners acting on behalf of cAfrica or under lawful contractual arrangements.

5.5 Legal Compliance

Personal information may also be processed to:

  • comply with legal obligations
  • respond to lawful requests from competent authorities
  • detect fraud
  • investigate misuse of the Service
  • protect intellectual property rights
  • enforce contractual rights
  • resolve disputes

protect the security and integrity of the Service.

6. LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION

Commec CC trading as cAfrica shall process personal information only where permitted by applicable law and where at least one lawful basis for processing exists.

Depending on the jurisdiction in which a user resides, one or more of the following legal bases may apply.

6.1 Consent

Where required by law, cAfrica shall obtain the user's consent before processing personal information for specific purposes, including:

  • the use of non-essential cookies
  • personalised advertising
  • marketing communications
  • optional account features

participation in promotional campaigns.

Users may withdraw their consent at any time. Withdrawal of consent shall not affect the lawfulness of processing undertaken before such withdrawal.

6.2 Performance of a Contract

Personal information may be processed where necessary to:

  • provide streaming services
  • manage user accounts
  • authenticate users
  • deliver subscription services
  • process payments
  • provide customer support
  • enable access to licensed content

fulfil contractual obligations owed to users.

Failure to provide certain information may prevent cAfrica from providing specific services.

6.3 Legitimate Interests

Subject to applicable law, cAfrica may process personal information where it has a legitimate business interest, provided such interest does not override the rights and freedoms of users.

Legitimate interests include:

  • improving platform performance
  • fraud prevention
  • cybersecurity
  • audience measurement
  • network optimisation
  • service analytics
  • enforcing contractual rights
  • protecting intellectual property
  • ensuring platform stability
  • business reporting

internal auditing.

6.4 Legal Obligations

Personal information may be processed where necessary to comply with legal or regulatory obligations, including:

  • taxation laws
  • accounting obligations
  • court orders
  • law enforcement requests
  • anti-fraud legislation
  • consumer protection legislation

financial reporting requirements.

6.5 Protection of Vital Interests

Where necessary, personal information may be processed to protect the life, health or safety of any individual where permitted by law.

7. COOKIES AND SIMILAR TECHNOLOGIES

To improve user experience and platform functionality, cAfrica uses cookies and similar technologies across its digital services.

Cookies are small text files or similar technologies stored on a user's device to remember preferences, improve performance and support platform functionality.

Where required by applicable law, cookies will only be placed after obtaining the user's consent, except where such cookies are strictly necessary for operation of the Service.

7.1 Strictly Necessary Cookies

These cookies are essential for operation of the Service and cannot ordinarily be disabled.

They may be used for:

  • account authentication
  • security
  • fraud prevention
  • load balancing
  • video playback
  • user session management
  • payment processing

remembering privacy preferences.

Blocking these cookies may affect functionality of the Service.

7.2 Performance and Analytics Cookies

Subject to applicable law, performance cookies may be used to:

  • understand user engagement
  • improve platform stability
  • measure application performance
  • identify technical issues
  • optimise streaming quality
  • analyse viewing behaviour

improve navigation.

Information collected through analytics technologies is generally aggregated or pseudonymised wherever reasonably possible.

7.3 Advertising Cookies

Where advertising-supported services are provided, advertising technologies may be used to:

  • limit advertisement repetition
  • measure advertisement performance
  • improve advertising relevance
  • detect invalid traffic
  • support campaign reporting

prevent advertising fraud.

Advertising cookies are only used where permitted by applicable law and subject to user consent where required.

No advertising cookies are used in connection with cAfrica's Radio or Audio services.

7.4 Personalisation Technologies

Personalisation technologies may be used to:

  • recommend content
  • remember viewing preferences
  • resume playback
  • improve navigation

customise user experience.

Users may disable certain personalisation features through available platform settings where technically feasible.

7.5 Cookie Preferences

Users may:

  • accept all cookies
  • reject non-essential cookies
  • manage cookie preferences
  • withdraw previously granted consent

delete cookies using browser settings.

Certain functionality may become unavailable if non-essential technologies are disabled.

8. DISCLOSURE OF PERSONAL INFORMATION

Commec CC trading as cAfrica does not sell personal information in the ordinary commercial meaning of the term.

Personal information may, however, be disclosed where necessary to provide the Service or where required by law.

8.1 Service Providers

Personal information may be disclosed to carefully selected service providers assisting cAfrica with:

  • cloud hosting
  • content delivery
  • payment processing
  • customer support
  • cybersecurity
  • infrastructure monitoring
  • software maintenance
  • analytics

lawful advertising services.

Such providers process information only in accordance with contractual obligations and applicable privacy laws.

8.2 Advertising and Measurement Partners

Where users access advertising-supported services, certain information may be processed by authorised advertising and measurement partners for purposes including:

  • advertisement delivery
  • frequency management
  • campaign measurement
  • audience reporting
  • fraud detection
  • revenue reporting

performance optimisation.

Such processing is carried out only to the extent necessary for providing advertising-supported services.

8.3 Business Partners

Information may be shared with business partners where necessary for:

  • competitions
  • promotional campaigns
  • subscription fulfilment
  • bundled service offerings

customer support.

Any such sharing shall be governed by contractual confidentiality obligations.

8.4 Legal Disclosure

Personal information may be disclosed where reasonably necessary to:

  • comply with legal obligations
  • enforce contractual rights
  • respond to lawful governmental requests
  • protect users
  • investigate fraud
  • protect the security of the Service

defend legal claims.

8.5 Corporate Transactions

Should Commec CC undergo:

  • restructuring
  • merger
  • acquisition
  • sale of assets
  • business transfer

corporate reorganisation,

personal information may be transferred as part of the transaction, subject to applicable legal safeguards.

9. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

The cAfrica platform may operate across multiple jurisdictions.

Accordingly, personal information may be processed or stored outside the user's country of residence.

Where international transfers occur, Commec CC trading as cAfrica shall take reasonable steps to ensure that appropriate safeguards are implemented, including where applicable:

  • contractual safeguards
  • recognised transfer mechanisms
  • organisational security measures
  • technical safeguards
  • encryption

access controls.

Where required by law, cross-border transfers shall only occur where an adequate level of protection exists or appropriate legal safeguards have been implemented.

Nothing in this Privacy Policy authorises transfers prohibited by applicable law.

10. DATA RETENTION AND INFORMATION SECURITY

Commec CC trading as cAfrica retains personal information only for as long as reasonably necessary to fulfil the purposes for which it was collected, unless a longer retention period is required or permitted by law.

Retention periods may vary depending upon:

  • contractual requirements
  • legal obligations
  • regulatory obligations
  • dispute resolution
  • fraud prevention
  • accounting requirements
  • taxation legislation
  • security investigations

business continuity.

When personal information is no longer required, cAfrica shall securely delete, anonymise or otherwise dispose of such information in accordance with applicable legal requirements.

10.1 Security Measures

Commec CC trading as cAfrica implements reasonable technical and organisational measures designed to protect personal information against:

  • unauthorised access
  • accidental disclosure
  • unlawful processing
  • destruction
  • alteration
  • misuse
  • cyberattacks

data loss.

Security measures may include:

  • encryption in transit
  • encryption at rest where appropriate
  • role-based access controls
  • authentication controls
  • network monitoring
  • vulnerability assessments
  • security logging
  • incident response procedures
  • regular software updates

secure infrastructure management.

Although cAfrica employs commercially reasonable safeguards, no internet-based service or electronic storage system can be guaranteed to be completely secure. Users acknowledge that transmission of information over the internet carries inherent risks.

Users are responsible for maintaining the confidentiality of their account credentials and for promptly notifying cAfrica of any suspected unauthorised access or compromise of their account.

11. YOUR PRIVACY RIGHTS

Commec CC trading as cAfrica respects the privacy rights afforded to users under applicable privacy and data protection legislation.

Subject to applicable law and reasonable verification of identity, users may exercise one or more of the following rights.

11.1 Right of Access

Users may request confirmation as to whether cAfrica processes their personal information.

Where applicable, users may request access to:

  • personal information held by cAfrica
  • categories of information collected
  • purposes of processing
  • categories of recipients
  • retention periods

available privacy rights.

11.2 Right to Rectification

Users may request correction of inaccurate, incomplete or outdated personal information.

Reasonable efforts will be made to update information promptly after verification.

11.3 Right to Deletion

Subject to applicable law, users may request deletion of personal information where:

  • the information is no longer required
  • consent has been withdrawn
  • processing is unlawful

applicable legislation requires deletion.

This right may be limited where cAfrica is legally required to retain certain information for:

  • taxation
  • accounting
  • fraud prevention
  • contractual enforcement
  • dispute resolution

regulatory compliance.

11.4 Right to Restrict Processing

Where permitted by law, users may request that processing be temporarily restricted while disputes relating to accuracy or lawfulness are investigated.

11.5 Right to Object

Users may object to processing based upon legitimate interests where applicable legislation grants such right.

cAfrica will consider each request in accordance with applicable legal obligations.

11.6 Right to Data Portability

Where technically feasible and legally required, users may request a copy of certain personal information in a structured, commonly used and machine-readable format.

11.7 Right to Withdraw Consent

Where processing relies upon consent, users may withdraw such consent at any time.

Withdrawal of consent shall not affect processing undertaken before the withdrawal became effective.

11.8 Rights Under POPIA

Where the Protection of Personal Information Act applies, users may exercise rights including:

  • access
  • correction
  • deletion
  • objection to processing

submission of complaints to the Information Regulator.

11.9 Rights Under GDPR

Where the GDPR applies, users may exercise rights including:

  • access
  • rectification
  • erasure
  • restriction
  • portability
  • objection

withdrawal of consent.

11.10 Rights Under CCPA / CPRA

Where applicable, users may request:

  • disclosure of personal information collected
  • deletion of qualifying personal information
  • correction of inaccurate personal information

limitation of certain data sharing activities.

12. CHILDREN'S PRIVACY

The cAfrica Service is intended for general audiences unless specific content indicates otherwise.

cAfrica does not knowingly collect personal information from children below the minimum age prescribed by applicable law without appropriate parental or legal guardian consent.

Where cAfrica becomes aware that personal information has been collected contrary to applicable legislation, reasonable steps will be taken to:

  • investigate the matter
  • suspend processing where appropriate

delete the information where legally required.

Parents and legal guardians who believe that a child has submitted personal information may contact cAfrica using the contact details provided in this Privacy Policy.

13. MARKETING COMMUNICATIONS

Where permitted by applicable law, users may receive communications relating to:

  • new platform features
  • product announcements
  • competitions
  • promotions
  • subscription services
  • customer satisfaction surveys

platform updates.

Users may unsubscribe from marketing communications at any time using the unsubscribe mechanism provided within the communication or by contacting cAfrica directly.

Service-related communications relating to:

  • security
  • billing
  • legal notices
  • account administration

technical maintenance

may continue where reasonably necessary for operation of the Service.

14. USER RESPONSIBILITIES

Users also play an important role in protecting their own privacy.

Users are responsible for:

  • safeguarding passwords
  • protecting login credentials
  • keeping account information accurate
  • preventing unauthorised access to their devices
  • logging out from shared devices

reporting suspected account compromise without unreasonable delay.

Users should avoid sharing passwords or authentication credentials with third parties.

cAfrica shall not be responsible for losses resulting from failure to maintain reasonable account security.

15. DATA BREACH RESPONSE

Commec CC trading as cAfrica maintains procedures designed to identify, investigate and respond to security incidents involving personal information.

Where required by applicable law, cAfrica shall:

  • investigate suspected incidents
  • assess potential impact
  • implement reasonable containment measures
  • notify affected individuals where legally required

notify competent regulatory authorities where legally required.

Nothing contained herein constitutes an admission of liability in relation to any security incident.

16. THIRD-PARTY WEBSITES AND SERVICES

The Service may contain links to third-party websites, applications or services operated independently of Commec CC.

Such third parties maintain their own privacy policies and terms.

cAfrica:

  • does not control third-party privacy practices
  • is not responsible for third-party content
  • is not responsible for third-party security practices

does not endorse third-party privacy policies unless expressly stated.

Users access third-party services at their own discretion.

17. CHANGES TO THIS PRIVACY POLICY

Commec CC trading as cAfrica reserves the right to amend, modify or replace this Privacy Policy from time to time.

Updated versions may reflect:

  • changes in legislation
  • changes to technology
  • new platform functionality
  • additional services
  • operational improvements

security enhancements.

Where material changes are made, reasonable efforts may be undertaken to notify users through appropriate channels.

Continued use of the Service after publication of an updated Privacy Policy constitutes acceptance of the revised Privacy Policy, to the extent permitted by law.

18. CONTACTING cAfrica

Questions, requests or concerns relating to this Privacy Policy may be directed to:

Commec CC trading as cAfrica

351 Beyers Naudé Drive

Northcliff

Randburg

South Africa

Email: support@cafrica.tv

Where required by applicable legislation, requests should include sufficient information to enable identity verification before personal information is disclosed or amended.

19. COMPLAINTS

Users who believe that their personal information has been processed unlawfully are encouraged to contact Commec CC trading as cAfrica in the first instance so that concerns may be investigated and, where appropriate, resolved.

Nothing contained in this Privacy Policy limits a user's statutory right to lodge complaints with a competent regulatory authority.

Where applicable, complaints may be submitted to:

  • the Information Regulator (South Africa)
  • relevant European supervisory authorities
  • competent consumer protection authorities

any other authority having jurisdiction.

20. GENERAL PROVISIONS

This Privacy Policy forms part of the contractual relationship between users and Commec CC trading as cAfrica in relation to use of the Service.

If any provision of this Privacy Policy is found to be invalid, unlawful or unenforceable by a court or tribunal of competent jurisdiction, such provision shall be severed to the minimum extent necessary, and the remaining provisions shall continue in full force and effect.

Failure by Commec CC trading as cAfrica to enforce any provision of this Privacy Policy shall not constitute a waiver of any right or remedy.

This Privacy Policy shall be interpreted in accordance with the laws applicable to Commec CC trading as cAfrica, subject to any mandatory consumer protection or privacy legislation applicable in the jurisdiction of the user.

This Privacy Policy constitutes the entire privacy statement governing the collection, use, disclosure and protection of personal information by Commec CC trading as cAfrica in connection with the Service and supersedes any prior privacy statements relating to the same subject matter.