Privacy Policy

  1. Introduction
    1. Exponential Brilliance Pty Ltd (“Exponential Brilliance, we us our”) is sensitive to the personal nature of the information you provide to us.
    2. This privacy policy (“this Policy”) explains how we protect and use your Personal Information.
    3. By providing us with your Personal Information, you –
      1. Agree to this Policy and authorise us to process such information as set out herein; and
      2. Authorise Exponential Brilliance, its Associates, our Service Providers and other third parties to process your Personal Information for the purposes stated in this policy.
    4. We will not use your Personal Information for any other purpose than that set out in this policy and will endeavour to protect your Personal Information that is in our possession from unauthorised alteration, loss, disclosure, or access.
    5. Please take note that we may review and update this policy from time to time. The latest version of this policy is available on request.
    6. This policy applies to all external parties with whom we interact, including but not limited to individual clients, representatives of client organisations, visitors to our offices, and other users of our services (“you”).
  2. Collection of Personal Information
    1. We may collect or obtain Personal Information about you –
      1. Directly from you;
      2. In the course of our relationship with you;
      3. In the course of providing any service to you or your organisation;
      4. When you make your Personal Information public;
      5. When you visit and/or interact with our website or our various social media platforms;
      6. When you register to use any of our services, including but not limited to newsletters, newsflashes and updates;
      7. When you interact with any third-party content or advertising on our website; or
      8. When you visit our offices.
    2. We may also receive Personal Information about you from third parties (eg, law enforcement authorities).
    3. In addition to the above, we may create Personal Information about you such as records of your communications and interactions with us, including, but not limited to, your attendance at events or at interviews in the course of applying for employment with us, subscription to our newsletters and other mailings and interactions with you during the course of our digital marketing campaigns.
  3. Categories of Personal Information we may process
    We may process the following categories of Personal Information about you –
    1. Personal Details: name; and photograph;
    2. Demographic Information: gender; date of birth / age; nationality; salutation; title; and language preferences;
    3. Identifier Information: national identity number or passport number; utility provider details; bank statements; tenancy agreements;
    4. Contact Details: correspondence address; telephone number; e-mail address; and details of your public social media profile(s);
    5. Instruction Details: details of individuals instructing Exponential Brilliance; Personal Information included in correspondence, documents, or other materials we process in the course of providing our services;
    6. Attendance Records: details of meetings and/or other events organised by or on behalf of Exponential Brilliance that you have attended;
    7. Consent Records: records of any consents you may have given, together with the date and time, means of consent and any related information;
    8. Payment details: billing address; payment method; bank account number or credit card number; invoice records; payment records; payment amount; and payment date;
    9. Data relating to your visits to our Website: your device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to our Website; and other technical communications information;
    10. Employer Details: where you interact with us in you capacity as an employee of an organisation; the name; address; telephone number and e-mail address of your employer to the extent relevant; and
    11. Content and advertising data: records of your interactions with our online advertising and content; records of advertising and content displayed on pages displayed to you; and any other interaction you may have had with such content or advertising (including, but not limited to) cursor hover; clicks and any forms you complete).
  4. Sensitive Information
    Where we need to process your Sensitive Personal Information, we will do so in the ordinary course of our business, for a legitimate purpose, and in accordance with the applicable law.
  5. Purposes of Processing and Legal Bases of Processing
    1. We will process your Personal Information in the ordinary course of the business of providing our services. We will primarily use your Personal Information only for the purpose for which it was originally or primarily collected. We will use your Personal Information for a secondary purpose only if such purpose constitutes a legitimate interest and is closely related to the original or primary purpose for which the Personal Information was collected. We may subject your Personal Information to processing during the course of various activities, including, without limitation, the following –
      1. Operating our business;
      2. Analysis evaluation, review and collation of information in order to determine any issues relating to our service, memoranda, agreements, correspondence, reports, publications, and other documents and records (whether in electronic or any other medium whatsoever)
      3. Compliance with applicable law and fraud prevention;
      4. Transfer of information to our Service Providers and other third parties, or;
      5. Recruitment.
    2. We may process your Personal Information for relationship management and marketing purposes in relation to our services (including but not limited to processing that is necessary for the development and improvement of our services); for accounts management; and for marketing activities in order to establish, maintain and/or improve our relationship with you and with our Service Providers. We may also analyse your Personal Information for statistical purposes.
    3. We may process your Personal Information for internal management and management reporting purposes, including, but not limited to: conducting internal audits; implementing internal business controls, providing central processing facilities, and for management reporting analysis.
    4. We may process your Personal Information for safety and security purposes.
  6. Disclosure of Personal Information to Third Parties
    1. We may disclose your Personal Information to our Associates and Service Providers, for legitimate business purposes, in accordance with applicable law and subject to applicable professional and regulatory requirements regarding confidentiality. In addition, we may disclose your Personal Information –
      1. If required by law;
      2. Legal and regulatory authorities, upon request, or for the purpose of reporting any actual or suspected breach of applicable law or regulation;
      3. Third party Operators (including, but not limited to, data processors such as providers of data hosting services and document review technology and services) located anywhere in the world, subject to paragraph 6.2;
      4. To any relevant party for the purpose of the prevention; investigation; detection or prosecution of criminal offences or the execution of criminal penalties; including, but not limited to, safeguard against, and the prevention of threats to public security;
      5. To any relevant third party provider, where our Website uses third party advertising, plugins or content.
    2. If we engage a third party operator to process any of your Personal Information, we recognise that any operator who is in a foreign country must be subject to a law, binding corporate rules for binding agreements which provide an adequate level of protection similar to PoPIA. We will review our relationships with operators we engage we engage and, to the extent required by any applicable law force, we will require such operators to be bound by contractual obligations to –
      1. Only process such Personal Information in accordance with our prior written instructions; and
      2. Use appropriate measures to protect the confidentiality and security of such Personal Information.
  7. International Transfer of Personal Information
    1. We may transfer your Personal Information to recipients outside of the Republic of South Africa.
    2. Subject to paragraph 6.2, Personal Information may be transferred outside of the Republic of South Africa provided that the country to which the data is transferred has adopted a law that provides for an adequate level of protection substantially similar to PoPIA, the operator / third party undertakes to protect the Personal Information in line with applicable data protection legislation and the transfer is necessary in order to provide our service that are required by our clients.
  8. Data Security
    1. We implement appropriate technical and organisational security measures to protect your Personal Information that is in our possession against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, in accordance with applicable law.
    2. Where there are reasonable grounds to believe that your Personal Information that is in our possession has been accessed or acquired by any unauthorised person, we will notify the relevant regulator and you, unless a public body responsible for detection, prevention or investigation of offences or the relevant regulator informs us that notifying you will impede a criminal investigation.
    3. Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Information that is in our possession, we cannot guarantee the security of any information transmitted using the internet and we cannot be held liable for any loss or privacy occurring during the course of such transmission.
  9. Data Accuracy
    The Personal Information provided to Exponential Brilliance should be accurate, complete and up to date. Should Personal Information change, the onus is on the provider of such data to notify us of the change, and provide us with the accurate data, by way of the Exponential Brilliance Swift App.
  10. Data Minimisation
    Exponential Brilliance will restrict its processing of Personal Information to data which is sufficient for the fulfilment of the primary purpose and applicable legitimate purpose for which it was collected.
  11. Data Retention
    Exponential Brilliance shall only retain and store Personal Information for the period for which the data is required to serve its primary purpose or a legitimate interest or for the period required to comply with an applicable legal requirement, whichever is longer.
  12. Your legal rights
    You may have rights under the South African and other laws to have access to your Personal Information and to ask us to rectify, erase and restrict use of your Personal Information. You may also have rights to object to your Personal Information being used, to ask for the transfer of Personal Information you have made available to us and to withdraw consent to the use of your Personal Information.
  13. Cookies and Similar Technologies
    1. We may process your Personal Information by our use of Cookies and similar technologies.
    2. When you visit our Website we may place Cookies on your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser, and some cases, your preferences and browsing habits. We may process your Personal Information through Cookies and similar technologies.
  14. Direct Marketing
    1. We may process your Personal Information for the purposes of providing you with the information regarding services that may be of interest to you. You may unsubscribe for free at any time.
    2. If you currently receive marketing information from us which you would prefer not to receive in the future, please contact us here.
  15. Contact Details
    You may contact us here.

You may download our privacy policy here.

Last updated: 2 July 2021