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:
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:
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 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:
future supported devices.
It also applies to interactions involving:
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.
Users may voluntarily provide information including:
marketing preferences.
Providing certain information may be necessary to access subscription services or account-based functionality.
To ensure proper functionality, security and optimisation of the Service, cAfrica may collect technical information including:
error reports.
To improve user experience and platform performance, cAfrica may collect information relating to:
buffering statistics.
This information assists cAfrica in improving service quality and personalising user experiences.
As cAfrica operates a hybrid advertising-supported and subscription-supported streaming service, certain information relating to advertising interactions may be processed, including:
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.
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:
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:
To:
remember user preferences.
To:
improve user experience.
To provide:
interface customisation.
Personalisation may be disabled where technically feasible.
Where applicable and permitted by law, personal information may be processed to:
support reporting and revenue reconciliation.
Advertising is delivered only through authorised commercial partners acting on behalf of cAfrica or under lawful contractual arrangements.
Personal information may also be processed to:
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.
Where required by law, cAfrica shall obtain the user's consent before processing personal information for specific purposes, including:
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.
Personal information may be processed where necessary to:
fulfil contractual obligations owed to users.
Failure to provide certain information may prevent cAfrica from providing specific services.
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:
internal auditing.
Personal information may be processed where necessary to comply with legal or regulatory obligations, including:
financial reporting requirements.
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.
These cookies are essential for operation of the Service and cannot ordinarily be disabled.
They may be used for:
remembering privacy preferences.
Blocking these cookies may affect functionality of the Service.
Subject to applicable law, performance cookies may be used to:
improve navigation.
Information collected through analytics technologies is generally aggregated or pseudonymised wherever reasonably possible.
Where advertising-supported services are provided, advertising technologies may be used to:
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.
Personalisation technologies may be used to:
customise user experience.
Users may disable certain personalisation features through available platform settings where technically feasible.
Users may:
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.
Personal information may be disclosed to carefully selected service providers assisting cAfrica with:
lawful advertising services.
Such providers process information only in accordance with contractual obligations and applicable privacy laws.
Where users access advertising-supported services, certain information may be processed by authorised advertising and measurement partners for purposes including:
performance optimisation.
Such processing is carried out only to the extent necessary for providing advertising-supported services.
Information may be shared with business partners where necessary for:
customer support.
Any such sharing shall be governed by contractual confidentiality obligations.
Personal information may be disclosed where reasonably necessary to:
defend legal claims.
Should Commec CC undergo:
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:
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:
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.
Commec CC trading as cAfrica implements reasonable technical and organisational measures designed to protect personal information against:
data loss.
Security measures may include:
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.
Users may request confirmation as to whether cAfrica processes their personal information.
Where applicable, users may request access to:
available privacy rights.
Users may request correction of inaccurate, incomplete or outdated personal information.
Reasonable efforts will be made to update information promptly after verification.
Subject to applicable law, users may request deletion of personal information where:
applicable legislation requires deletion.
This right may be limited where cAfrica is legally required to retain certain information for:
regulatory compliance.
Where permitted by law, users may request that processing be temporarily restricted while disputes relating to accuracy or lawfulness are investigated.
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.
Where technically feasible and legally required, users may request a copy of certain personal information in a structured, commonly used and machine-readable format.
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.
Where the Protection of Personal Information Act applies, users may exercise rights including:
submission of complaints to the Information Regulator.
Where the GDPR applies, users may exercise rights including:
withdrawal of consent.
Where applicable, users may request:
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:
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:
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:
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:
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:
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 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:
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
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:
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.