FIRST RESPONDER PRIVACY NOTICE

INTRODUCTION

Bateleur Connect treats its clients’ personal information with the utmost discretion. This is in accordance with the South African Constitution, which protects the right to privacy. The Protection of Personal Information Act 4 of 2013 (POPIA), which operationalises the constitutional right to privacy, further strengthens our resolve to protect our clients’ and stakeholder’s personal information. POPIA promotes the fair and transparent use of this information and requires us to safeguard it appropriately. Personal information as defined by POPIA is any information that can be used to identify you as an individual, and, where applicable, a legal entity. Examples of personal information is your identity number, account number, telephone number, email address, physical address, or other unique identifier.  

As part of our commitment to safeguard our clients’ personal information and continue to comply with the law, our processing activities involving personal information are aligned to the provisions of POPIA. 

This Privacy Notice sets out how your personal information will be used by Bateleur Connect and applies to any information, including personal and special personal information, you give to Bateleur Connect or which Bateleur Connect may receive from third parties. 

It is important that you read this Privacy Notice carefully before submitting any personal information to Bateleur Connect via our First Responder platform. 

By submitting any personal information to Bateleur Connect, you provide consent to the processing of your personal information as set out in this Privacy Notice and the detailed terms and conditions for the relevant products that you will sign.  

The provisions of this Privacy Notice are subject to mandatory, unalterable provisions of applicable laws. 

Please do not submit any personal information to Bateleur Connect if you do not agree to any of the provisions of this Privacy Notice. If you do not consent to the provisions of this Privacy Notice, or parts of the Privacy Notice, Bateleur Connect may not be able to provide its products and services to you. 

What is personal information? 

Personal information is data that can be used to identify you. This includes personal information you  share with us, personal information that we gather during onboarding and our relationship with you as our client, as well as information about your marketing preferences.

 This information includes, but not limited to:  

• your gender as may be required for statistical purposes or by law;
• your marital status, nationality or social origin;
• your age, physical or mental health and well-being, disability, religion, conscience, belief, culture, and language; 
• your education 
• any medical conditions; 
• any identifying number, symbol (like account, identity or passport numbers);
• your email address, physical address or telephone number (as this may be needed for us to communicate with you);
• your location and online identifiers [this can be Internet Protocol (IP) addresses or geolocations]
• biometric information (eg fingerprints, and facial or voice recognition); and
• your personal opinions or views.

There may be circumstances in which we will collect your special personal information. Such information may include: 

• your race or ethnicity (as required by law and for statistical purposes); 
• facial recognition biometrics 
• any medical conditions
• your updated health status, allergies or pescription medication

The processing of your special personal information will only happen with your consent, if this is necessary to establish, exercise or defend a right or obligation in law, to comply with a law, for historical, statistical or research purposes or if it is otherwise lawful to do so.  

Aim and objective of this privacy notice 

It is to give you and our stakeholders guidance  on how we collect, use, and protect personal information. The privacy notice will tell you: 

1. why we collect your personal information and how we may process it; 
2. how we share your personal information with third parties; 
3. how we protect your personal information; 
4. how long we hold onto your personal information; and  
5. what your rights are. 

Why do we process your personal information?   

For us to offer you a real time medical emergency product and service, we need to process (collect, use, share and store) personal information about you so that we can: 

• develop suitable products and services to meet your needs; 
• market relevant products and services to you; 
• conduct market research and client satisfaction surveys; 
• verify your identity and to assess your stored medical information in case of an emergency
• record and monitor any communications between you and us and use these recordings to verify your instructions to us to analyse, assess and improve our services to clients, and for training and quality purposes; and 
• communicate with you by post, phone, SMS, email, and other electronic media, mobile applications, or online services, about products that may be of interest to you, with your permission which you may op out of at any time. 

 It is your right to refuse to provide personal information, but this refusal may limit our ability to provide the required products and services to you. We will only collect personal information from you that is necessary and relevant to the service or product we have to provide. 

We will only collect and use your personal information if we are lawfully permitted to do so. 

We may communicate with you and send you direct marketing, but you can unsubscribe by opting out on the relevant Internet-based platform or by advising Bateleur Connect directly via email. 

If we use third-party data providers, we will ensure that they are lawfully allowed to share the information with us. 

The lawful basis we rely on for processing this information are: 

• we have your consent to do so; 
• we have an obligation to carry out actions for the conclusion or performance of a contract with you; 
• we are required by law to process your personal information; 
• the processing protects your legitimate interest; 
• we have a legitimate interest to pursue; and/or 
• a third party has legitimate interest to pursue. 

Processing personal information of children 

We will only process the personal information of a child with the consent of a parent, legal guardian if we are lawfully allowed to do so and if their parents or legal guardian want them to be registered on the First Responder platform in the event of a medical emergency.

How do we collect your personal information? 

We collect your personal information in the following ways: 

• Directly from you when you complete the registration on the First Responder platform.
• Indirectly from you when you interact with us electronically, i.e. use of cookies (refer to details below)  
• Through other entities in the Bateleur Group or divisions/clusters of entities within the Bateleur Group. 

Third parties from which we may collect your personal information may include: 

• financial institutions and service providers; 
• payment associations; 
• Payments Association of South Africa;  

To whom will we disclose your personal information? 

Protecting our interests may sometimes require the disclosure of specific client information to third parties.

Entities and third parties with whom we may share your information may include:  

• Paramedics and associated staff from an emergency response team;
• Doctors and hospital staff attending to your medical emergency
• Medical insurers; 
• the South African Police Service; and 
• other third parties as may be required either contractually, by law, or legitimate interest.  

When sharing your personal information with recipients in other jurisdictions, we will ensure compliance with applicable laws.  

We will never sell your personal information to third parties and will only market to you in compliance with applicable laws and your marketing preference, using, where practicable, the communication method you chose. 

When we correct, destroy or delete your information, if reasonably practicable, we will inform each third party to whom the personal information has been disclosed to. 

How do we protect your personal information? 

We are committed to ensuring that your information is secure. To prevent unauthorised access or disclosure, we have put reasonable physical, electronic, and managerial procedures in place to safeguard and secure the information we collect. 

All online transacting sessions are encrypted, and personal information is stored according to internationally accepted information security practices. 

How long will we keep your personal information?  

We will keep your information only for as long as we need it for a lawful business purpose or as required by law (including tax legislation). 

If we need to keep your personal information for longer than required, and more specifically for historical, statistical or research purposes, we will do so with the appropriate safeguards in place to prevent the records from being used for any other purpose. 

Your personal information may be kept for varying periods from the end of our relationship, depending on regulatory requirements or legitimate business requirements. We will take all reasonable steps to delete, destroy, correct or de-identify the personal information that we hold when it is no longer required. 

We will restrict processing of your personal information if it is not accurate, no longer needed for the purpose we collected it, the processing is unlawful and you oppose its destruction or deletion and request the restriction of its use instead of the information or you have requested us to transmit the information to another automated processing system. We will inform you before lifting the restriction on processing of your information. 

Your data protection rights 

You have the right to ask us to confirm whether we hold any information about you. You may also request a record from us about the personal information we hold about you, as well as information about all third parties with whom we have shared your personal information, including the right to: 

• be notified when your personal information is being collected; 
• withdraw your consent to process your personal information at any time provided that, it does not affect the lawful basis of processing the information before your withdrawal or us pursuing our legitimate interest and/or that of a third party; 
• be notified when your personal information has been accessed by an unauthorised third party; 
• correct or delete the personal information in our possession or under our control if it is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or has been obtained unlawfully; 
• destroy or delete a record of your personal information that we are no longer authorised to keep in terms of regulatory requirements; 
• object at any time to the processing of your personal information for protecting your legitimate interest, for pursuing our legitimate interest or that of a third party and we will no longer process your information;  
• for us not to rely solely (for decisions) on the basis of the automated processing of your personal information; 
• stop or start sending you marketing messages by informing us in writing via email
• you will be informed of the outcomes of any objections or withdrawals we receive from you to process your personal information and confirmation of any corrections made. 
• submit  a complaint to the Information Regulator regarding any interference with the protection of your personal information to  POPIAComplains@inforegulator.org.za  or visit their website on www.inforegulator.org.za ; and 
• institute civil proceedings regarding the alleged interference with the protection of your personal information 

If you want to verify the information we have about you or want us to update, change, or delete it, you may contact us at  privacy@bateleurconnect.com  or through our website www.bateleurconnect.com

Cookies 

Cookies are very small text files that may be stored on your computer or mobile device when you visit a website, enable images, or click on a link in an email. We use cookies to identify which pages are being used. This helps us analyse data about web page traffic to improve our website and give you a better user experience.  

We use this information for statistical analysis purposes only and the data is then removed from the system. Bateleur Connect does not record your internet usage after you leave our website. 

Cookies play a crucial role in enhancing the functionality of our website and improving your overall experience across our online channels. 

We want to be transparent about our cookie usage, so here’s how we handle them: 

1.     Strictly necessary cookies 

• These cookies are mandatory for the effective operation of our website on your device. They let you use the website and its features, and cannot be switched off. 

2. Performance cookies 

• These cookies collect anonymous information about how you use our website. They help us improve website performance without gathering personal data.  
• Temporary session cookies exist only while you browse our website. They remember your activities during the session and are deleted when you close our website or move to a different one.

3.   Marketing cookies (advertising cookies)

• These cookies deliver relevant and engaging advertisements to you. We measure the effectiveness of our advertising campaigns based on your interaction with these ads.  
• These cookies stay on your device until they reach their set expiry date or until you delete them. They remember your preferences and choices across visits, and display advertising campaigns relevant to your online activity. 

You can manage your cookie settings on your internet browser. Most web and mobile browsers automatically accept them. You can modify your browser settings to manage cookies. However, this may prevent you from taking full advantage of our website experience. Your cookie settings will also affect other websites you visit. 

This is how you can manage your cookie settings: 

Desktop or laptop 

1. Microsoft Edge

• Click on the ellipsis (⋯) in the upper-right corner of your browser.
• Choose 
• Go to View advanced settings.
• Navigate to Cookies and choose Don’t block cookies.
• You may need to restart Microsoft Edge for the changes to take effect.

2. Google Chrome

• Click on the 3-dot menu in the upper-right corner.
• Choose Settings > Privacy > 
• Choose 1 of these options: Enabled, Enabled excluding 3rd party, or 
• To erase all cookies, tick the Clear private data on exit box and choose Cookies and active logins.

Mobile device on iOS or Android 

1. iOS (Safari) 

• Open the Settings 
• Scroll down and tap on Safari. 
• Under Privacy and security, choose Block all cookies or Allow from websites I visit. 

2. Android (Chrome): 

• Open the Chrome 
• Tap on the 3-dot menu in the upper-right corner. 
• Go to Settings > Site settings > 
• Choose your preferred option: Allow all cookies, Block 3rd-party cookies, or Block all cookies. 

Complaints 

You may submit complaints about the processing of your personal information by sending an email to privacy@bateleurconnect.com  

Or, If you are not satisfied with the way we have dealt with your complaints, you can contact the Information Regulator at POPIAComplaints.IR@justice.gov.za . 

Our contact details 

The contact details of the information officer: 

Information Officer: 

Garth Bell

Physical address:  

6 Brendon Avenue

Morningside Manor

Sandton  2196

Johannesburg  

Email: privacy@bateleurconnect.com  

Website: www.bateleurconnect.com