Privacy Policy

Konnected Kasi – Free Connectivity Terms And Conditions For Nominated Institutes

1. Definitions

In this Policy (as defined below), unless the context requires otherwise, the following words and expressions bear the meanings assigned to them and cognate expressions bear corresponding meanings:

“Child” means any natural person under the age of 18 (eighteen) years.
“Customer” means a natural or juristic person who or which receives services and/or products from SADV, including business customers, Prospective Customers or consumers.
“Data Breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Information under the control of or in the possession of SADV.
“Data Subject” has the meaning ascribed thereto under POPIA which may include a Third Party, Customers, Employees, suppliers, service providers, partners, contractors and other natural or juristic persons, whose Personal Information we may be required to Process from time to time.
“Employees” means any employee of SADV.
“Personal Information” has the meaning ascribed thereto under POPIA and specifically includes any form of information that can be used to identify a Data Subject.
“Policy” means this Privacy Policy.
“POPIA” means the Protection of Personal Information Act No. 4 of 2013.
“Processing” has the meaning ascribed thereto under POPIA and “Process” has a corresponding meaning.
“Prospective Customer” means natural or juristic persons who have enquired about and/or are interested in the services, but have not contracted with SADV for the use of the services and includes natural or juristic persons to whom SADV may offer or promote their services.
“Regulator” means the Information Regulator established in terms of POPIA.
“Responsible Party” means a public or private body or any other person which alone or in conjunction with others, determines the purpose of and means for Processing Personal Information.
“SADV” means SADV Proprietary Limited, a private company incorporated in terms of the Companies Act 71 of 2008, as amended, with registration number 2019/588585/07 and registered address at 31 Georgian Crescent East, Bryanston, Gauteng, South Africa, and/or any of its brand or trade names (whether registered as trademarks or not) and all its subsidiaries from time to time. “Us”, “we” and “our” has the corresponding meaning.
“Special Personal Information” means Personal Information relating to: (i) religious or philosophical beliefs, race or ethnic origin, trade union membership, political persuasion, health or sex life or biometric information; or (ii) criminal behaviour to the extent that such information relates to: (a) the alleged commission of any offence; or (b) any proceedings in respect of any offence allegedly committed or the disposal of such proceedings.
“Third Party” means any independent contractor, agent, consultant, sub-contractor or other representative of SADV (including fibre network operators).
“Website” means any internet site, web-based platform, mobile site, or application (including any mobile or smart device application) maintained and operated by SADV.

2. Purpose of this Policy

The purpose of this Policy is to inform Data Subjects about how SADV Processes their Personal Information. SADV, in its capacity as Responsible Party, shall strive to observe, and comply with its obligations under POPIA as well as accepted information protection principles, practices and guidelines when it Processes Personal Information from or in respect of a Data Subject.

This Policy applies to Personal Information collected by SADV in connection with the fibre optic communication solutions and related goods and services which SADV provides and offers. This includes Personal Information collected when:

you provide your Personal Information to SADV;
you use any services and provide SADV with any of your Personal Information in connection therewith;
you access the Website; and/or
you engage with SADV.

Personal Information may also be collected under one of SADV’s affiliated brands or trade names. Regardless of the brand under which it is collected, all Personal Information is subject to the same safeguards and protections outlined in this Policy.

In addition to collecting Personal Information from Data Subjects directly, SADV may also collect Personal Information about Data Subjects from Third Parties and public sources where such information is available. We may also appoint certain Third Parties to Process Personal information on our behalf, in which case we conclude appropriate agreements with such Third Parties to manage such processing activities in line with applicable law.

This Privacy Policy does not apply to the information practices of (i) Third Parties whom we may engage with in relation to our purpose (including, without limitation, their websites, platforms and/or applications) which we do not own or control; or (ii) individuals that SADV does not manage or employ; and (iii) Third Parties who are required to Process Personal Information in their own right and not necessarily only for and in relation to SADV, where they will each be responsible for complying with their legal obligations relating to such Processing activities as Responsible Parties. Each of these Third Parties and Third-Party sites may have their own privacy policies and terms and conditions and we encourage you to read them before using them.

3. Process of Collecting Personal Information

SADV will always collect Personal Information in a fair, lawful and reasonable manner to ensure that it protects the Data Subject’s privacy and will Process the Personal Information based on legitimate grounds in a manner that does not adversely affect the Data Subject in question.

SADV generally collects Personal Information directly from Data Subjects or it may obtain Personal Information from Third Parties. Examples of such Third Parties include: (i) our Customers when SADV handles Personal Information on their behalf; (ii) recruitment agencies; (iii) other companies providing services to SADV; and (iv) publicly available sources of information.

4. Lawful Processing of Personal Information

Where SADV is the Responsible Party, it will only Process a Data Subject’s Personal Information (other than for Special Personal Information) where:

consent of the Data Subject (or a competent person, where the Data Subject is a Child) is obtained;
Processing is necessary to carry out the actions for the conclusion of a contract to which a Data Subject is a party;
Processing complies with an obligation imposed by law on SADV;
Processing protects a legitimate interest of the Data Subject; and/or
Processing is necessary for pursuing the legitimate interests of SADV or of a Third Party to whom the information is supplied.

SADV will only Process Personal Information where one of the legal bases above are present. Where required, SADV will obtain the Data Subject’s consent prior to collecting, and in any case, prior to using or disclosing the Personal Information for any purpose. A Data Subject may withdraw their consent at any time; this will not affect the lawfulness of Processing carried out prior to withdrawal or any Processing justified by another legal ground under POPIA.

5. Special Personal Information and Personal Information of Children

SADV acknowledges that it will only Process Special Personal Information (such as biometric information for access control and/or security reasons or employee health data), based on a general or specific lawful basis under POPIA, including that:

Processing is carried out in accordance with the Data Subject’s consent;
Processing is necessary for the establishment, exercise or defence of a right or obligation in law;
Processing is for historical, statistical or research purposes, subject to stipulated safeguards;
the Personal Information has deliberately been made public by the Data Subject; or
specific authorisation applies in terms of POPIA.

SADV acknowledges that it may not Process any Personal Information concerning a Child and will only do so where it has obtained the consent of a legally competent person (i.e. the parent or guardian of that Child) or where it is permitted to do so in accordance with applicable laws.

6. Purpose for Processing Personal Information

SADV understands its obligation to make Data Subjects aware of the fact that it is Processing their Personal Information and inform them of the purpose for which SADV Processes such Personal Information.

SADV will only Process a Data Subject’s Personal Information for a specific, lawful and clear purpose (or purposes). It will ensure that there is a legal basis for the Processing and that Processing relates only to the purpose for which the Data Subject has been made aware (and, where relevant, consented to).

Non-exhaustive purposes include:

to establish and manage business and Customer relationships and provide Customer service and support, including responding to enquiries, processing orders and transactions and delivering products and services;
to manage relationships with Third Parties, including fibre network providers/operators, suppliers and distributors;
for providing the services and products as per Customer requests including to manage or fulfil contracts and orders, and to provide product/service-related information;
for Customer onboarding and credit vetting;
to improve our knowledge and better meet the expectations and needs of our Customers;
for onboarding suppliers as approved suppliers of SADV;
in connection with the execution of payment processing functions, including payment of suppliers’/service providers’ invoices;
for monitoring the use of SADV’s electronic systems and online platforms by consumers;
for preventing, discovering and investigating non-compliance with internal policies or procedures;
for the purposes of investigating fraud or other related matters;
for employment-related purposes such as recruitment, administering payroll and carrying out background checks;
in connection with internal and external audit purposes;
to respond to correspondence sent to SADV;
to facilitate and process an application by a Data Subject to become a Customer;
to address Customer or end-consumer complaints in respect of SADV’s products and services;
to contact the Data Subject from time to time (including mailing lists where consented);
to analyse and better understand Customers’ business needs and to improve the delivery and provision of products and services;
for project management related activities, civil contractor management and fibre network infrastructure installation;
to communicate with dedicated installation liaison officers on site;
for personal development of staff through training in line with job specification;
to comply with applicable legal obligations imposed on SADV; and
for such other purposes as authorised and in compliance with applicable law.

7. Types of Personal Information and Special Personal Information Processed

SADV collects and Processes Personal Information required to effectively carry out its business. The Personal Information that is Processed includes (non-exhaustive):

Data Subjects	Personal Information
Employees	Name and surname; ID/passport numbers; contact details; physical and postal address; date of birth; age; disability information; employment history; criminal/background checks; education history; banking details; income tax reference number; remuneration and benefits information (including medical aid, pension/provident fund information); disciplinary procedures; employee disability information; performance records; physical access records; CCTV records; health and safety records; time and attendance records.
Suppliers/Service Providers/Third Parties	Entity name; registration number; VAT number; contact details for representative persons/directors; KYC documentation; BBBEE certificates; invoices and proof of payments; bank account and payment details; financial history; contractual documentation.
Directors	Name, surname, ID numbers, and financial information required for statutory reporting.
New Job Applicants	Name; surname; address; contact details; email address; telephone number; details of qualifications, skills, experience and employment history; background checks including credit/criminal history (if required for the role); current level of remuneration and benefit entitlements; disability for reasonable adjustments (where applicable); entitlement to work in South Africa.
Website Visitors	Name; email address; IP address; contact details; geographic location.
Visitors	Physical/electronic access records, scans and CCTV records.
Customers	Name and surname (if individuals); email; physical and postal address; address photographs; date of birth or age range; ID/passport numbers (if individuals); contact details; FICA documentation; company name and registration number; directors/authorised representative details; VAT reference number.

8. Keeping Personal Information Accurate

SADV will take reasonable steps to ensure that all Personal Information is kept as accurate, complete and up to date as reasonably possible depending on the purpose for which Personal Information is collected or further processed. SADV may not always expressly request the Data Subject to verify and update their Personal Information unless specifically necessary; SADV expects the Data Subject to notify SADV in writing of any updates required.

9. Storage and Processing of Personal Information by SADV and Third Parties

SADV may store Personal Information in hardcopy and/or electronic format using SADV’s own secure on-site servers or other internally hosted technology. Personal Information may also be stored by Third Parties, via cloud services or other technology, with whom SADV has contracted to support SADV’s operations. These Third Parties may have access to Personal Information in connection with the original purposes, and must process it in accordance with this Policy, internal policies and POPIA. Such parties do not use or have access to Personal Information other than for specified purposes and must employ at least the same level of security as SADV.

10. How We Use Cookies

Our Website uses cookies to ensure that the Website functions properly, store user preferences when needed and collect anonymous statistics on usage.

Types of cookies used may include:

Strictly Necessary Cookies — required for core functionality. Blocking them will prevent the Website from working. These typically do not store Personal Information.
Functional Cookies — enable enhanced functionality and personalisation. If rejected, some services may not function properly.
Performance Cookies — allow counting visits and traffic sources to measure and improve performance. Information is aggregated and not personal to a Data Subject. In some cases, these may be sent to Third Parties for analytics.
Targeting/Advertising Cookies — set by SADV or advertising partners to deliver relevant adverts and measure campaign effectiveness.

Data Subjects may refuse cookies via their browser settings. If cookies are refused, certain Website features may be unavailable.

11. Use of Personal Information on our Website and for Marketing Purposes

Website users may share Personal Information with SADV via our Website. This Policy applies to Personal Information shared on the Website. SADV will comply with POPIA and applicable laws for personalised marketing. We will provide reasonable opportunities to object to marketing and include “unsubscribe” or “opt-out” options in each communication. SADV will not send marketing where it has been requested not to do so, and will ensure telemarketing complies with applicable laws.

12. Retention of Personal Information

SADV may keep records of Personal Information, correspondence, or comments in electronic or hardcopy format. In terms of POPIA, SADV may not retain Personal Information longer than necessary for the purpose collected, and must delete, destroy (irreversibly) or de-identify it as soon as reasonably practicable once the purpose has been achieved. This prohibition will not apply where retention is required or authorised by law, needed to fulfil SADV’s lawful functions or activities, required by contract, consented to by the Data Subject (or competent person for a Child), or for historical/research/statistical purposes with safeguards.

13. Failure to Provide Personal Information

If SADV needs to Process Personal Information to fulfil a legal obligation or perform a contractual obligation and such information is not provided when requested, SADV may be unable to comply with its obligations or provide services. SADV may then decline to provide the relevant services and will notify the affected Data Subject where this is the case.

14. Safe-keeping of Personal Information

SADV shall preserve the security of Personal Information and take steps to prevent its alteration, loss and damage, or access by unauthorised third parties. SADV will ensure security and integrity with appropriate, reasonable technical and organisational measures, maintain and verify effectiveness, and update in response to new risks.

15. Data Breaches

A Data Breach can happen for many reasons, including loss or theft of data or equipment, inappropriate access controls, equipment failure, human error, unforeseen circumstances, deliberate attacks (hacking, malware, phishing), unauthorised alteration of Personal Information, or loss of availability. SADV will address Data Breaches in accordance with POPIA and notify the Regulator and affected Data Subjects (unless delayed by law) as soon as reasonably possible after becoming aware.

16. Provision of Personal Information to Third Parties

SADV may disclose Personal Information to Third Parties. Where they act as operators under POPIA, SADV will enter into appropriate written agreements to ensure Processing in accordance with this Policy and POPIA. Third Parties may assist with, for example:

data storage and notifications;
processing information required to provide fibre services (e.g., name, contact details, address, package selection, installation preferences);
processing property details (including geo-coordinates, address photos, stand/ERF numbers), access information, and contact details for coordination with installers, municipal authorities, or contractors;
civil works, trenching, and last-mile fibre deployment where necessary;
equipment delivery, provisioning, support activation, or scheduling of site visits;
identity verification and credit checks (where applicable) through third-party providers;
fibre network performance and service usage to improve coverage, reliability, and support;
compliance with RICA and other applicable laws, including ID verification and record retention;
integrations with third-party platforms (billing systems, self-service apps, partner portals, SMS/email providers);
improving service quality and training via call recordings or support ticket history;
facilitating transfer of services to or from another ISP.

Personal Information may be sent to foreign jurisdictions for Processing and storage. SADV will obtain necessary consent for cross-border transfers or transfer where permitted under POPIA. As part of the Maziv group, SADV may share Personal Information within the group for necessary purposes (e.g., provision of services, internal administration, accounting, reporting) in accordance with applicable laws.

17. Access to Personal Information

POPIA, read with the Promotion of Access to Information Act, No. 2 of 2000 (PAIA), confers certain access rights on Data Subjects, including:

Right of access: to request confirmation whether SADV holds Personal Information and a description of such information, including Third Parties who have or had access.
Right to request correction or deletion: to request correction/deletion of Personal Information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully; or destruction/deletion where not authorised to retain.
Right to withdraw consent and to object to Processing: where consent was provided, it may be withdrawn by notice; a Data Subject may object on reasonable grounds to Processing.

Requests should be made in writing and in accordance with SADV’s PAIA Manual. SADV may request sufficient identification. SADV will respond in accordance with POPIA and PAIA, generally within 30 days (extendable once for up to 30 days). Prescribed fees are referenced in the PAIA Manual.

18. Changes to this Policy

SADV reserves the right to amend this Policy from time to time and will use reasonable efforts to notify Data Subjects of such amendments. The then-current version governs each time the Website is accessed and used.

19. Contacting Us

All comments, questions, concerns or complaints regarding your Personal Information or this Policy should be forwarded to our Information Officer:

Information Officer

Heydon Hall

Address: 31 Georgian Crescent East, Bryanston, 2191, Johannesburg, Gauteng

Postal: 31 Georgian Crescent East, Bryanston, 2191, Johannesburg, Gauteng

Email: information-officer@sadv.co.za

If required, the Information Regulator (South Africa) can be contacted:

Information Regulator

Website: https://inforegulator.org.za

Physical: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001

Postal: P.O. Box 31533, Braamfontein, Johannesburg, 2017

General enquiries: enquiries@inforegulator.org.za

Tel: 010 023 5200 | Fax: 086 500 3351

Complaints (PAIA): PAIAComplaints@inforegulator.org.za

Complaints (POPIA): POPIAComplaints@inforegulator.org.za