Privacy Policy

This policy covers use and operation of the Digital Complaints Committee process (“DCC process”) through the Real411 website (“the Website”) which is operated, controlled and owned by Media Monitoring Africa (“MMA”) and any complaint laid by you (“you/the User”), referral of your complaint to the DCC process and resolution thereof by the DCC in terms of the DCC process under the Code of Conduct found on this website. (together, the “Services”).

By signing on to receive the Services, you acknowledge that the Website is the Intellectual Property of MMA and is run and owned by MMA.

By signing on to receive the Services, you consent to Media Monitoring Africa collecting and storing and processing your personally identifying information (“PI”) during the period of your complaint for the DCC who will use the PI on inter alia the following basis:-

• to be stored for purposes of verifying a Complaint made by you;
• to contact you regarding your Complaint including keeping you updated on the progress, process and finalisation of your Complaint including any appeal or review processes associated with your Complaint;
• to provide you with access to the Website and the associated Website services;
• to keep records of complaints made in terms of the DCC process; and
• in accordance with the provisions of this Privacy Policy as set out below.

MMA is a Non-Profit Trust registered in South Africa. It is our policy to respect your privacy regarding any information we may collect while operating the Services.

MMA takes privacy seriously. In summary:

• we don’t collect personal information unless we truly need it;
• we don’t share personal information with anyone except to ensure that we can properly process your complaint, comply with the law and/or protect our rights;
• we don’t store personal information on our hosted servers unless required for the on-going operation of one of our Services. If you have questions about your personal data or this privacy policy, please contact us.

Like most website operators, MMA collects non-personally-identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. MMA’s purpose in collecting non-personally identifying information is to better understand how visitors use the Website. From time to time, MMA may release non-personally-identifying information in the aggregate, e.g., by publishing a report on trends in the usage of our Website.

MMA also collects potentially personally-identifying information like Internet Protocol (IP) addresses for logged in Users.

The User may visit the Website without providing any personal information. The Website servers will in such instances collect the IP address of the User computer, but not the email address or any other distinguishing information. This information is aggregated to measure the number of visits, average time spent at the Website, pages viewed, etc. MMA uses this information to determine use of the Website, and to improve content thereon. MMA assumes no obligation to protect this information, and may copy, distribute or otherwise use such information without limitation.

For the purpose of this clause, “personal information” shall be defined as detailed in the Protection of Personal Information Act, No 4 of 2013.

In this Policy, "European Data Protection Legislation" means all applicable legislation relating to data protection in the European Economic Area ("EEA"), including the EU General Data Protection Regulation 2016/679 ("GDPR") and all laws adapted under or replacing the GDPR. Where this Policy uses terms specially defined in the GDPR, the GDPR definitions apply. If the GDPR applies to you, your specific rights are listed at the end of this Policy.

Certain visitors to the website choose to interact in ways that require MMA to gather personally-identifying information. The amount and type of information that we gather depends on the nature of the interaction. For example, should you wish to lay a Complaint on the website, you are required to provide your name, email address and telephone number.

We collect, store and process such information on behalf of the DCC only insofar as is necessary or appropriate:-

• to communicate with you and to make sure that you actually exist (you are not a fraudster);
• to fulfil the purpose of your interaction with MMA or the DCC including but not limited to receiving and processing your Complaints;
• comply with any legislation or regulation which requires us to collect the information;
• to analyse the reports produced as a result of your Complaint and the processing of your Complaint.

MMA will be collecting and storing the content of each Complaint on behalf of the DCC (Text, checkboxes selected, optional URL and optional image upload) excluding any personally identifying information for the purpose of:

• assessing each Complaint;
• analyzing and reporting on the Complaints lodged and finalized

MMA does not, however, warrant ownership of the content - that rests with the copyright holder nor does MMA warrant veracity of content of each Complaint submitted.

MMA does not disclose personally-identifying information other than as described below. And visitors can always refuse to supply personally-identifying information, with the caveat that it may prevent them from fully engaging in the complaint making process or other Website-related activities.

MMA may collect statistics about the interaction of visitors with the Website. MMA may display this information publicly or provide it to others. However, MMA does not disclose personally-identifying information other than as described below.

MMA will not rent or sell potentially personally-identifying and personally-identifying information to anyone.

MMA and the DCC will only disclose potentially personally-identifying and personally-identifying information to those of our employees, contractors and affiliated organizations that:

1. need to know the information in order to process it or your Complaint on our behalf, to provide the Services available at our Website or store the personal information and complaints; and
2. that have agreed not to disclose it to others.
3. Other than to our employees, contractors and affiliated organizations, as described above, we disclose potentially personally-identifying and personally-identifying information only in response to a subpoena, court order or other governmental request, or when we believe in good faith that disclosure is reasonably necessary to protect our property or rights, or the property or rights of third parties or the public at large;
4. we will send you email updates to keep you informed of the process and progress of your Complaint and to keep you up to date with what’s going on with the Services. We take all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of potentially personally-identifying and personally-identifying information.

You have:

The right to access: You have the right to obtain information about the processing of your personal data and a copy of your personal data that MMA stores

The right to rectify your data: You have the right to request that MMA update your personal data if it is inaccurate or incomplete.

The right to request data erasure: You have the right to have your personal information erased from the MMA files if the data is no longer necessary for the purpose for which it was collected, you withdraw your consent and no other legal basis for our processing your data exists, or your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing our processing.

The right to restrict or object to processing: You have the right to restrict or object to our processing if we are processing your data based on legitimate interests or performance of a task in the public interest as an exercise of official authority (including profiling) or processing your data for purposes of scientific or historical research and statistics.

The right to lodge a complaint: If you think we have processed your personal information unfairly or unlawfully, or we have not complied with your rights under law, you have the right to complain to a national data protection authority, the Information Regulator. Contact details for data protection authorities are available here.

A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. The Website uses cookies to help us identify and track visitors, their usage of the Website, and their Website access preferences. Visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using the Website, with the drawback that certain features of the Website may not function properly without the aid of cookies.

If you are a resident of the EEA or Switzerland, the following applies for purposes of processing and legal basis for processing personal information:

As explained above, we process personal information in various ways depending upon your use of the Services.

We process personal information on the following legal bases:

1. with your consent;
2. as necessary to perform the Services; and
3. as necessary for our legitimate interests in providing services where those interests do not override your fundamental rights and freedom related to data privacy.

Individual Rights: If you are a resident of the EEA or Switzerland, you have certain rights under the GDPR. To verify your identity, we might need you to provide us with PI prior to accessing any records containing information about you.

The right to access: You have the right to obtain information about our processing of your personal data and a copy of your personal data that we store.

The right to rectify your data: You have the right to request that we update your personal data if it is inaccurate or incomplete.

The right to request data erasure: You have the right to have your personal information erased from our files if the data is no longer necessary for the purpose for which it was collected, you withdraw your consent and no other legal basis for our processing your data exists, or your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing our processing.

The right to restrict or object to processing: You have the right to restrict or object to our processing if we are processing your data based on legitimate interests or performance of a task in the public interest as an exercise of official authority (including profiling) or processing your data for purposes of scientific or historical research and statistics.

The right to lodge a complaint: If you think we have processed your personal information unfairly or unlawfully, or we have not complied with your rights under GDPR, you have the right to complain to a national data protection authority. Contact details for data protection authorities are available here.

To submit any request to us under the GDPR, please contact us at the address in the next paragraph for more information.

Although most changes are likely to be minor, we may change our privacy policy from time to time at our sole discretion. We encourage visitors to check this page frequently for any changes to the privacy policy. Your continued use of our Website after any change in this privacy policy will constitute your acceptance of such change.

Should you wish to lodge a complaint or enforce your rights in terms of this Privacy Policy, please contact the Data Protection Officer: