1.1) The Box Fashion Proprietary Limited with registration number 2014/271386/07 (‘we’, ‘us’, ‘our’, ‘The Box Fashion’) is the first local accessories membership service company that provides our members with the latest fashion pieces and styling advice, all delivered to your doorstep in a box. The Box Fashion is part of a group of companies including Platinum Life, Isabella Garcia International, IPS Health and Wellness and Besige Breintjies (“the Group Affiliates“) which enables us to provide holistic care and support to our clients, including –
1.1.1) personal care enhancements (including, amongst others, fashion accessories and facial care);
1.1.2) insurance products;
1.1.3.) general health and wellness products;
1.1.4) child learning support, nurturing creativity and imagination and overall development.
1.2) Our business model is largely based on an online marketing system as well as a referral system. Therefore, our success depends on reviews from our clients and our relationship with members, clients and business partners. This relationship is built on trust and quality service. When we collect your personal information from sources other than directly from you, you will have had to confirm that you are agreeable for others to have shared your information. To provide holistic care and support to our members we rely on all Group Affiliates and their services. The Box Fashion and the Group Affiliates are committed to offering you an all-encompassing solution, that is in your interest and that will benefit your health and wellbeing.
1.3) We value our membership holders, clients and business partners. We understand the sensitive nature of the personal information which we hold. It is for this reason that the protection of your personal information is one of our top priorities. We endeavour to maintain the confidentiality of your personal information and process your personal information in adherence to the Protection of Personal Information Act 4 of 2013 (“POPIA“).
1.4.1) how we collect, use, transfer and protect your personal information; and
1.4.2) the rights you have in relation to your personal information in terms of POPIA.
2) WHAT IS PERSONAL INFORMATION
2.1) In terms of POPIA, personal information is information that may be used to identify an individual or a company.
2.2) Examples of personal information include, but are not limited to –
2.2.2) identification number;
2.2.3) contact information;
2.2.4) financial information;
2.2.5) information relating to race, gender or sexual orientation, age;
2.2.6) fashion and style-related preferences;
2.2.7) physical attributes and health; and
3) PERSONAL INFORMATION THAT WE COLLECT
3.1) We collect and use personal information mainly to perform direct marketing, and to perform contractual obligations. We undertake direct marketing in instances where we have a pre-existing relationship with you, and you have agreed for us to contact you for purposes of direct marketing or where we have asked your permission to do so. In other words, where there is a legitimate and mutual interest.
3.2) We may collect personal information which includes, but is not limited, to–
|Type of information||Description of information|
Identification and contact information and information that will assist us to provide products and services to you
Financial information and account details
|Physical Attributes and Health||
Other sensitive information
3.3) We may also collect feedback, comments and questions received from you in service-related communication and activities.
3.4) When personal information is collected, we will indicate the purpose for the collection of the personal information and whether the personal information required is compulsory or voluntary. We will, to the extent possible, inform you of the consequences for failing to provide the requested information.
4) HOW WE COLLECT PERSONAL INFORMATION
We collect your personal information in one of the following ways –
4.1) directly from you through a telephone call centre;
4.2) directly from you by filling in online forms on our website and/ or on social media;
4.3) from our clients that refer you to us;
4.4) when you use our website your information may be automatically collected (e.g. data gathered by cookies);
4.5) when you use our website for online queries or chat box functionality;
4.6) when your personal information is publicly available; and
4.7) if you gave consent to the collection of your information from another source (including our Group Affiliates) and we have provided you with the detail of the source
5) USE OF PERSONAL INFORMATION
Personal information collected by us may be used, stored, disclosed or shared for the following purposes –
5.1) to communicate with you regarding membership information, your membership application and membership servicing;
5.2) to send you important information regarding changes to our membership, and other terms and conditions;
5.4) to process your membership fee and other payments;
5.5) To ensure that the content of our website is presented in the most effective manner for you and your computer;
5.6) To allow you to participate in interactive features of our service, should you choose to do so;
5.7) In allowing ourselves to carry out our obligations concerning any contracts entered into between you and The Box Fashion, where you place orders or purchase products from us;
5.8) to conduct market research;
5.9) to provide marketing information to you (including information about other products and services in the interest of your overall well-being linked to your membership, offered by Group Affiliates and in so doing enhance our holistic service to you by ensuring you have the necessary care)
5.10) to comply with our internal policies and procedures such as –
5.10.1) audit reports;
5.10.2) finance and accounting;
5.10.3) billing and collections;
5.10.4) IT systems;
5.10.5) data and website management; and
5.10.6) records management.
5.11) to respond to queries or resolve complaints regarding products and/ or services;
5.12) to handle requests for the correction, updating, access or deletion of your personal information;
5.13) to comply with applicable laws and regulatory obligations; and
5.14) to access suitability for a product.
6) SHARING OF PERSONAL INFORMATION
6.1) Access to your personal information within The Box Fashion and the Group Affiliates is restricted to those individuals who require access to your personal information for business purposes.
6.2) To provide products and services to you that enhances holistic care and support, we share your information with the following Group Affiliates, which are our sister companies –
6.2.1) Platinum Life, an authorised financial services provider, offering top-class insurance services which include male and female cancer cover, permanent disability cover by accidental causes and accidental death cover;
6.2.2) Isabella Garcia International, a lifestyle company that strives to provide clients with the highest quality products and services to complement their individual skincare needs;
6.2.3) IPS: Health and Wellness, a lifestyle company focused on providing clients with nutritional supplements based on their unique requirements; and
6.2.4) Besige Breintjies, an educational program designed to develop and improve children’s intellectual, social, physical and emotional well-being through one-on-one interaction between parent and child.
6.3) We may also share your information with other companies who are not Group Affiliates. This will only be done to the extent that it is in pursuance of our legitimate interests or once you have given us your explicit and prior consent to do so. Furthermore, we may share your personal information with third parties in the event of any of the following occurring –
|Assignment||Transfer of all or any part of The Box Fashion|
|Any insolvency or similar proceedings|
6.4) Where we disclose your personal information to the above parties, they will be bound to use that personal information for the reasons and purposes it was provided to them and not for any other purpose.
6.5) The Box Fashion may be obliged to disclose your personal information to the extent that it is required to do so by law or where we believe it is necessary to protect our rights.
7) SECURING YOUR PERSONAL INFORMATION
7.1) The Box Fashion will –
7.1.1) take reasonable and appropriate technical and organisational measures to ensure that your personal information is kept secure and is protected against unauthorised or unlawful processing, accidental loss, destruction or damage, alteration, disclosure or access. This includes, for example, encryption of your personal information and ensuring that adequate firewalls are in place;
7.1.2) provide you with access to your personal information to view and/or update your personal details;
7.1.3) promptly notify you if we become aware of any unauthorised use, disclosure or processing of your personal information; and
7.1.4) provide you with reasonable evidence of our compliance with our obligations under this policy on reasonable notice and request
7.2) Whilst we will do all things reasonably necessary to protect your rights of privacy, we cannot guarantee or accept any liability whatsoever for unauthorised or unlawful disclosures of your personal information, whilst in our possession, by a third party who is not subject to our control, unless such disclosure is as a result of our gross negligence.
7.4) All information obtained by The Box Fashion is stored on dedicated servers within the borders of South Africa. The servers are secured behind a firewall and access to the servers are password protected and strictly limited. Notwithstanding this, no security measures or systems are impenetrable. We cannot make any guarantees against data breaches.
8) HOW YOU CAN REVIEW AND CORRECT YOUR PERSONAL INFORMATION
8.1) We undertake to provide you with access to your personal information and provide mechanisms so that any personal information found to be inaccurate or incomplete can be corrected or amended as feasible, subject to any requirement or rule for such personal information to be retained by law.
8.2) Prior to the amendment, correction or removal of your personal information, we will require you to identify yourself and to identify the portion of information requested to be amended, corrected or removed. A request for the amendment, correction or removal of personal information may be declined if the process of the request is unreasonably repetitive, require disproportionate technical effort, or jeopardizes the privacy of others.
8.3) The services of access and correction of personal information is done free of charge, except to the extent that it would require disproportionate effort by The Box Fashion. Once personal information is deleted, residual copies of the information may take a period of time before they are deleted from our servers and may remain in our backup systems.
8.4) It is important that any information you provide directly to us is accurate and correct. Please let us know as soon as you can if any information that we hold about you is no longer correct.
8.5) Providing false or inaccurate information in order to obtain a product or service may also result in said product or service being restricted or cancelled.
8.6) For further information on how to exercise your right of access to personal information, please refer to our procedure for data subject access to, objection to, correction or deletion of personal information processed by The Box Fashion as set out in the PAIA/POPIA Manual which is available at https://theboxfashion.co.za/popia/
9) DATA RETENTION
9.1) We will only retain your personal information to the extent and duration that we have a legitimate interest to process your personal information as defined in point 5 above (“Use of Personal Information”).
9.2) We will upon your request, promptly return or destroy any and all of your personal information in our possession or control, save for that which we are legally obliged to retain.
10) CROSS BORDER PERSONAL INFORMATION TRANSFERS
To the extent that we transfer your personal information outside the borders of South Africa, we will ensure appropriate safeguards are in place, including, for example, ensuring that the third party who is the recipient of the information is subject to a law or binding agreement which provides for an adequate level of protection similar to POPIA.
11) YOUR RIGHTS AS A DATA SUBJECT
11.1) As a data subject, you have a number of data privacy rights. These rights include –
11.1.1) a right of access: subject to certain exceptions, a data subject after providing adequate proof of identity has the right to –
184.108.40.206) request The Box Fashion to confirm whether any personal information is held about the data subject; and/or
220.127.116.11) request from The Box Fashion a description of the personal information held including information about third parties who have or have had access to personal information.
11.1.2) a right to request correction or deletion: a data subject may request The Box Fashion to –
18.104.22.168) correct or delete personal information about the data subject in our possession or control that is inaccurate, irrelevant, excessive, outdated, incomplete, misleading or obtained unlawfully; and/or
22.214.171.124) destroy or delete a record of personal information about the data subject that The Box Fashion is no longer authorised to retain in terms of the relevant legislative provision.
11.1.3) a right to withdraw consent and to object to processing: a data subject that has previously consented to the processing of his/her/its personal information has the right to withdraw such consent and may do so by providing The Box Fashion with notice to such effect to our Information Officer (at the contact details set out below). Furthermore, a data subject may object, on reasonable grounds, to the processing of personal information relating to him/her/it;
11.1.4) a right to not be subjected to direct marketing by means of unsolicited electronic communications: a data subject has a right not to be subject to direct marketing by means of unsolicited electronic communications unless you have given us your consent or you are an existing customer of ours;
11.1.5) a right not to be subjected automated decision making: a data subject has a right not to be subject to a decision which results in legal consequences for him/her/it which is based solely on the basis of the automated processing of personal information.
11.2) As a data subject you also have a right to lodge a complaint to the Information Regulator of South Africa if you are unsatisfied with the manner in which The Box Fashion addresses any complaint with regard to The Box Fashion’s processing of your personal information, the contact details of the Information Regulator are as follows –
12) CONTACT US
If you have any questions about this notice or treatment of your personal information or wish to exercise any of your rights, please address an email to firstname.lastname@example.org.
13) VERSION CONTROL
Last updated: January 2021.