PRIVACY POLICY (UPDATED)

On March 20th 2019, The Walt Disney Company has acquired certain 21st Century Fox businesses, including those providing the services described below. This policy has been updated to reflect that transaction.

Effective:   01 July 2021

INTRODUCTION

The Walt Disney Company Africa Proprietary Limited, having its seat at 16 Fricker road, Illovo, South Africa, 2196  (“Company” or “we”), which can be contacted at the email address TFCF.privacy.africa@disney.com wants to inform you about how we collect, use and disclose personal information from and about you, through this websitehttps://www.natgeotv.com/za and its associated mobile sites, applications and widgets (collectively, the “Company  Services”).

You can find a Table of Content and a brief summary of this Privacy Policy in the chart below. For further details with regard to the data processing carried out by the Company click on the links in each section of the summary. 

CONTENTS

  1. WHAT AND WHO DOES THIS PRIVACY POLICY COVER?
  2. WHAT TYPE OF PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?
  3. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
  4. ON WHAT LEGAL BASIS DO WE PROCESS YOUR PERSONAL INFORMATION?
  5. HOW DO WE USE YOUR PERSONAL INFORMATION?
  6. WHO HAS ACCESS TO YOUR PERSONAL INFORMATION?
  7. IS YOUR PERSONAL INFORMATION TRANSFERRED ABROAD?
  8. WHAT ARE YOUR RIGHTS WITH REGARD TO YOUR PERSONAL INFORMATION?
  9. FOR HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
  10. UPDATE TO THIS PRIVACY POLICY
  11. CONTACT US

 

 

Issue

Information

1.   

What and who does this Privacy Policy cover?

The Company is the responsible party of the personal information we collect from and about you through the Company Services.

This Privacy Policy applies to all users, including both those who use the Company Services without being registered or having subscribed and those who have registered with or subscribed to a Company Service.

For further information click here

2.   

What kind of personal information do we collect about you?

The Company might collect data from and about you.

In particular, the Company collects (1) registration data, (2) public data and information you post, (3) data that you have permitted social media to share with the Company  and (4) activity data.

However, we do not collect either financial information from a payment service provider or special personal information relating to you.

For further information click here

3.   

How do we use your personal information?

The main reason why we collect data about you is to provide you with Company Services and to allow you to interact with such services.

In addition, with your prior consent, we can send you offers promotions and marketing communications, including where they are based on your personal preferences and habits.

For further information click here

4.   

On what legal basis do we use your personal information?

Your personal information is mainly collected in order to provide you with Company Services.

Your personal information may also be collected to comply with applicable legal obligations and/or to protect the legitimate interest of the Company.

Failure to provide such data will mean that it is impossible to offer and/or provide to you the Company Services.

When your personal information is collected for marketing purposes, you have the option not to provide the Company with your personal information.

For further information click here

5.   

How do we process your personal information?

The security of your data is a priority for us. Accordingly, the Company has implemented adequate administrative, technical and physical measures designed to safeguard your personal information against loss, theft and unauthorized use, disclosure of modification.

For further information click here

6.   

Who can access to your personal information?

 

The Company might share your personal information with (i) service providers, (ii) our affiliated companies and (iii) national authorities, when allowed by the applicable laws.

For further information click here

7.   

Is your personal information transferred abroad?

Your personal information may be transferred to countries outside of South Africa where the Company or its service providers have operations, including to the European Economic Area and United States. In any case, we always make sure that appropriate and suitable safeguards designed to protect your personal information (such safeguards being compliant with applicable laws) are in place to protect your personal information.

For further information click here

8.   

What are your rights with regard to your personal information?

According to the Protection of Personal Information Act, 2013 ("POPIA"), you have among others the right to request access to, to complete, to update, to amend and to delete your personal information.

For further information click here

9.   

For how long do we keep your personal information?

Your personal information will be generally stored in our systems for the period necessary to provide you with the Company Services.

For further information click here

10. 

Updates to this Privacy Policy

The Company may modify or update this Privacy Policy also in order to comply with applicable law.

Please look at the Effective Date at the top of this Privacy Policy to see when this Privacy Policy was last revised.

11. 

How can I contact you with regard to the processing of my personal information?

You can contact us at the following email address TFCF.privacy.africa@disney.com

 

  1.  WHAT AND WHO THIS PRIVACY POLICY COVERS?

    The Company is the responsible party of the personal information (e.g. information that identifies a specific natural or juristic person, such as full name or email address) we collect from and about you through the Company Services that is processed in compliance with the terms of this Privacy Policy.

    This Privacy Policy and our Cookies Policy apply to all users, including both those who use the Company Services without being registered with or subscribing to a Company Service and those who have registered with or subscribed to a Company Service.

    As set forth in our Terms of Use, the Company Services are for a general audience, are not targeted at children, and do not knowingly collect personal information from children under 18 years of age.

  2.  WHAT TYPE OF PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?

    The Company collects (1) registration data, when you sign up or for a Company Service, (2) public data and posts that you share through the Company Services, (3) data that you have permitted social media to share with this Company, (4) activity data when you access and interact with a Company Service. More in particular, the Company may collect the following types of data from and about you:
  1. Registration data is the information you submit to register for a Company Service. Registration Information may include, for example, name, surname, email address, gender, country, postcode and birthday date.
  2. Public data and Posts which consist of comments or content that you post on the Company Services and the personal information about you that accompanies those posts or content, which may include a name, user name, comments, likes, status, profile information and picture. Public information and Posts are always public, which means they are available to everyone and may be displayed in search results on external search engines.
  3. Data from Social Media. If you access or log-in to a Company Service through a social media service or connect a Company Service to a social media service, the data we collect may also include your user ID and/or user name associated with that social media service, any information or content you have permitted the social media service to share with us, such as your profile picture, email address or friends lists, and any information you have made public in connection with that social media service. When you access the Company Services through social media services or when you connect a Company Service to social media services, you are authorizing the Company to collect, store, and use such data and content in accordance with this Privacy Policy.
  4. Activity Data.When you access and interact with the Company Services, we may collect certain information about those visits. For example, in order to permit your connection to the Company Services, our servers receive and record information about your computer, device, and browser, including potentially your IP address, browser type, and other software or hardware information. If you access the Company Services from a mobile or other device, we may collect a unique device identifier assigned to that device, geolocation data, or other transactional information for that device. Cookies and other tracking technologies (such as browser cookies, pixels, beacons) and Adobe Flash technology commonly called “Flash cookies”) may also be collected. These technologies may also be used to collect and store information about your usages of the Company Services, such as pages you have visited, content you have viewed, search queries you have run and advertisements you have seen. For more information please visit our Cookie Policy.
  5. Information from Other Sources.We may supplement the information we collect with information from other sources, such as publicly available information from social media services and commercially available sources.

We do not collect:

      • Financial information from a payment service provider: in some cases, we may use an unaffiliated payment service to allow you to purchase a product or make payments (“Payment Service”). If you wish to purchase a product or make a payment using a Payment Service, you will be directed to a Payment Service webpage. Any information that you provide to a Payment Service will be subject to the applicable Payment Service's privacy policy, rather than this Privacy Policy. We have no access to any payment data regarding the Payment Service.
      • Sensitive information: we ask that you do not send us, and you do not disclose, any special personal information (such as ID numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the Company Services or otherwise.

Linked Services. The Company Services may also be linked to sites, including social media sites, operated by unaffiliated companies, and may carry advertisements or offer content, functionality, games, newsletters, contests or sweepstakes, or applications developed and maintained by unaffiliated companies. The Company is not responsible for the privacy practices of unaffiliated companies, and once you leave the Company Services or click an advertisement you should check the applicable privacy policy of the other service.

 

3. HOW DO WE USE YOUR PERSONAL INFORMATION?

We use the personal information we collect from and about you to:

  1. Provide the Company Services and features to you;
  2. Allow you to comment on content, and participate in online games, contests, or rewards programs;
  3. Provide you with customer support and to respond to inquiries;
  4. Comply with the law or legal obligation or respond to requests from public and government authorities;
  5. Measure and improve the Company Services and features;
  6. Protect the rights of the Company and others: more in particular there may be instances when the Company may use your personal information, including situation where the Company has a good faith belief that such processing is necessary in order to: (i) protect, enforce, or defend the legal rights, privacy, safety, or property of the Company, our Company Affiliates or their employees, agents, contractors, licensors and suppliers (including enforcement of our agreements and our terms of use); (ii) protect the safety, privacy, and security of users of the Company Services or members of the public; (iii) protect the Company, as well as other third parties involved, such as Company suppliers, against fraud or for risk management purposes;
  7. Complete a corporate transaction, such as a proposed or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Company business, assets or stock (including in connection with any bankruptcy or similar proceedings).For example if the Company  is  involved in a merger or transfer of all or a material part of its business, the Company may transfer your information to the party or parties involved in the transaction as part of that transaction;
  8. Allow social sharing functionality; if you log in with or connect a social media service account with the Company Services, we may share your user name, picture, and likes, as well as your activities and comments with other users of that Company Service and with your friends associated with your social media service. We may also share the same information with the social media service provider;
  9. Improve your experience with both online and off-line Company Services by delivering content you will find relevant and interesting;
  10. Upon your prior consent, send to you - via email, SMS, telephone, chat and social media - offers, promotions and other marketing communications regarding the Company Services and/or third parties services / products operating in the following sectors media, broadcasting, film, publishing and/or travel, including group companies and co-branded services or features, such as contests or other promotions arranged together with a third party or Company Affiliate that may be hosted on the Company Services or on the Company Affiliate or third party's services;
  11. Upon your prior consent – send to you marketing communications customized to your interests and needs by means of the channels of communication set out under letter j) above.

We may use anonymized personal information or information that does no longer identify you personally, even indirectly (e.g. statistics) for additional purposes or share it with third parties.

 

4. ON WHAT LEGAL BASIS DO WE PROCESS YOUR PERSONAL INFORMATION?

  • The processing of your personal information for the purposes of:
  • Section 3, letters from a) to c) of this Privacy Policy is necessary for the provision of the Company Services and therefore it is mandatory since otherwise the services could not be provided;
  • Section 3, letter d) of this Privacy Policy is mandatory as it is requested under applicable laws; and
  • Section 3, from letters e) to g) of this Privacy Policy is performed on the basis of the legitimate interests of the Company and/or of its counterparties which are adequately balanced with your interest since the data processing is performed within the limits strictly necessary to perform such  These data processing activities are not mandatory and you can object at any time through the modalities as per Section 10 of this Privacy Policy, unless the Company has compelling legitimate grounds to continue the processing.


On the contrary, the processing of:

  • Section 3, letter h) is discretionary, but without your consent, it is impossible to connect to social media services account with the Company Service so that you will have to log to the Company Service using a different mechanism;
  • Section 3, from letter i) to k) is discretionary, but without your consent, it is impossible for the Company to provide you with personalized content, to provide you with generic marketing communications of the Company and third parties services/products or communications based on your interests and needs and to provide co-branded services.

You can revoke your consent to the processing of your personal information for the purposes as per Section 3, letters h) to k) at any time by sending a communication to the e-mail address of Section 11 below. Please note that the activities under letter i) may be performed through cookies tracking technologies. For more information on how to disable cookies, please visit our Cookie Policy. Finally, you can withdraw your consent or object to direct marketing communications in the case of j) and k), by either simply changing your preferences on your user profile settings, if you are registered, or through the consent management tool available on our website, if you are not registered, or by following the unsubscribe instructions in our communications. Below you can find an explanatory chart on the matter above:

Purpose of processing

Legal Basis

Voluntary or necessary provision of personal information

Section 3 lett. a): Provision of Company Services (e.g. when user registration is necessary).

Performance of contract

Provision is necessary

Failure to provide data would cause impossibility for us to provide the Company Services

Section 3 lett. b): User interactions (comments, contests participation, etc.)

Performance of contract

Provision is necessary

Failure to provide data would lead to failure to provide the Company Services

Section 3 lett. c): Customer support

Performance of contract

Provision is necessary

Failure to provide data would lead to failure to provide the Company Services

Section 3 lett. d):  Compliance with legal obligation

Legal Obligation

Provision is mandatory

Failure to provide data would cause impossibility for us to provide the Company Services

Section 3 lett. e): Analysis and improvement of Company Services

Legitimate Interest

Provision is not mandatory

You can exercise your right to object to processing, but the Company may continue to process your data in case of compelling legitimate grounds, which override your interests

Section 3 lett. f): Protection of Company and third parties’ interests

Legitimate interest

Provision is not mandatory

You can exercise your right to object to processing, but the Company may continue to process your data in case of compelling legitimate grounds, which override your interests

Section 3 lett. g): Corporate transaction

 Legitimate interest

Provision is not mandatory

You can exercise your right to object to processing, but the Company may continue to process your data in case of compelling legitimate grounds, which override your interests

Section 3 lett. h): Social media sharing

Consent

Provision is voluntary

You can exercise your right to withdraw your consent at any time, without consequences other than need to log with different account

Section 3lett. i):  Personalisation of user experience

Consent

Provision is voluntary

You can exercise your right to withdraw your consent at any time, without consequences, other than stop receiving  content that you may find relevant or interesting

Section 3 lett. j): Generic marketing

Consent

Provision is voluntary

You can exercise your right to withdraw your consent at any time, without consequences, other than stop receiving  marketing communications

Section 3 lett. k): Targeted marketing

Consent

Provision is voluntary

You can exercise your right to withdraw your consent at any time, without consequences, other than stop receiving  personalized marketing communications

 

Should you wish to withdraw your consent or object to marketing communications, please contact us at the email address at section 11 or, in the case of j) and k), select the unsubscribe link contained within any marketing communication.

5. HOW DO WE PROCESS YOUR PERSONAL INFORMATION?

With regard to the abovementioned purposes, the data is processed through both electronic and manual means, and is protected through adequate security measures, taking into account generally accepted information security practices and procedures which may apply to the Company generally or required in terms of specific industry or professional rules and regulations. With this regards, the Company uses appropriate administrative, technical, personnel and physical measures to safeguard personal information in its possession against loss, theft and unauthorized use, disclosure or modification.

6. WHO HAS ACCESS TO YOUR PERSONAL INFORMATION?

For purposes consistent with the purposes as per Section 3 of this Privacy Policy, the Company may share your personal information to the following categories of recipients located within South Africa or outside of South Africa in compliance and within the limits of the provisions of Section 7 below:

  • Third parties service providers entrusted with processing activities and duly appointed as operators when required by applicable laws, e.g. cloud service providers, other entities of the group, providers of services instrumental to or supporting the Company Services - and thus, by way of example and without limitation, companies that provide IT services, experts, consultants and lawyers:
  • Companies resulting from corporate transactions possible mergers, demergers, or other transformations, and
  • Business partners. With your prior consent the Company may share your personal information with business partners operating in the entertainment sector following sectors media, broadcasting, film, publishing and/or travel sectors in order to send you marketing communications; 
  • Competent national authorities in order to comply with applicable laws.

7. IS YOUR PERSONAL INFORMATION TRANSFERRED ABROAD?

Your personal information may be transferred to countries outside of South Africa, in particular to the United States and the European Economic Union where data privacy laws, regulations and standards, may not be equivalent to the laws in South Africa. Your use of our Company Services, followed by your submission of information to us, represents your consent to such transfer. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. You have the right to request a copy of the above measure or further information on your personal information by contacting the Company at the address indicated in Section 11 of this Privacy Policy.

8. WHAT ARE YOUR RIGHTS WITH REGARD TO YOUR PERSONAL INFORMATION?

According to POPIA,   you have the right, in any given time, to:

  1. obtain confirmation as to whether or not the Company holds personal information of you, free of charge.
  2. request a record or description of your personal information, including information about the identity of all third parties or categories of third parties who has access to the information personal information;
  3. request correction or deletion of personal information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully;
  4. request destruction or deletion of personal information that is longer necessary for the purposes for which the Company has collected it;
  5. object for legitimate reasons to the processing of your personal information that is processed on the basis of protecting your legitimate interests or pursuing our legitimate interests or of a third party to whom the information is supplied;
  6. request that Company restricts the processing of your personal information where:
      • you contest the accuracy of the personal information until we have taken sufficient steps to correct or verify its accuracy;
      • the processing is unlawful but you do not want us to destroy or delete the data;
      • the Company no longer requires the personal information for achieving the purpose for which the information was collected or subsequently processed, but it has to be maintained for purposes of proof;
      • you request that your personal information is transmitted to another automated system;

g. lodge a complaint with the Information Regulator of South Africa.

In this regard you may send your request at the address outlined in Section 11of this Privacy Policy. In your request, please include your email address, name, address, and telephone number and specify clearly what information you would like to access, change, update, suppress or delete.

Remember that even after you cancel your account, or if you ask us to delete your personal information, copies of some information from your account may remain viewable in some circumstances where, for example, you have shared information with social media or other services or, for example, when retention of such copies is necessary to comply with legal obligation or legal defense.  Because of the nature of caching technology, your account may not be instantly inaccessible to others.  We may also retain backup information related to your account on our servers for some time after cancellation or your request for deletion, to comply with applicable law.

We give you also many choices regarding our use and disclosure of your personal information for marketing purposes. You may revoke your consent, in any given time, for:

  • Receiving electronic communications from us. If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these marketing-related emails by following the unsubscribe instructions in our communications. You may also send a request to the address of Section 11of the Privacy Policy. In any case the Company may continue to send you administrative communications related to the provision of the Company Services.
  • Our sharing of your personal information with Company Affiliates or business partners for their marketing purposes. If you would prefer that we do not share your personal information on a going-forward basis with Company Affiliates and/or business partners for their direct marketing purposes, you may opt-out of this sharing by following the unsubscribe instructions in our communications or sending a request to the address of Section 11 of the Privacy Policy.

In all the above cases, we may contact you and ask you for more information that is necessary to properly handle your request.

9. FOR HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

We will retain your data only for the period necessary to fulfil the purposes for which the data was collected as outlined in this Privacy Policy. In any case, the following retention periods will apply to the processing of your personal information for the purposes indicated below:

    • Data collected for the purposes as per Section 3, letters from a) to g) of this Privacy Policy is retained for the time of provision of the Company Services or the activities contemplated therein plus the length of any applicable statutory limitation period following the termination of the Company Services;
    • Data collected for the purpose as per Section 3, letter h) of this Privacy Policy is retained for the time necessary to log-in to the Company Services through a social network;
    • Data collected for the purpose as per Section 3, letter i) is retained for a period of 12 months; and
    • Data collected for the purpose as per Section 3, letters j) is retained a period of 2 years;
    • Data collected for the purpose as per Section 3, letter k) is retained for a period of 2 years;

At the end of the retention period your personal information will be either deleted, anonymized or aggregated.

10. UPDATE TO THIS PRIVACY POLICY

The Company may modify or update this Privacy Policy for any reason (including, but not limited to, changes in applicable law and interpretations, decisions, opinions and orders relating to such applicable law). Please look at the Effective Date at the top of this Privacy Policy to see when it was last revised. Any changes to this Privacy Policy will be notified in advance by posting the revised Privacy Policy on the Company Services. If we make material chances to this Privacy Policy that  change the nature or processing or expand our rights to use the personal information we have already collected from you, we will notify you in advance and provide you with a choice about our future use of the personal information, as may be required by applicable law.

11. CONTACT US

If you have questions about this Privacy Policy, please contact the Company at the following email address: TFCF.privacy.africa@disney.com