Lynx is an online events management platform, through which events are organized and promoted. Lynx is operated by wCyber Solutions (Pty) Ltd, a private company registered in South Africa with registration number 2015/127072/07.
This privacy policy sets out with greater clarity how we handle data that we collect from users of, and visitors to, our website, including:
(i) Lynx account holders who are event organizers and planners ("Organizers");
(ii) Lynx account holders who want to buy tickets, or register for events, or donate to events ("Buyers");
(iii) other users or visitors to our website.
We may update this policy from time to time by publishing a new version on the Lynx website. You should check this page occasionally to ensure you are happy with any changes to this policy. We may notify you of changes to this policy by email or public notice on our website. This Privacy Policy also serves to tell you about your privacy rights and how the law protects you and your Personal Information when wCyber processes it.
It is important that you read this Policy with our Website Terms and any additional terms and conditions and policies incorporated in this Policy by reference. Each Data Subject needs to accept all the provisions in this Policy when he/she/it signs up for any of our Services or when providing your Personal Information to us in any other manner. If you do not agree with anything in this Policy, then you may not register and/or use any of the Services.
This Policy was last updated on 13 November 2019.
All terms are not necessarily defined in order.
By accepting this Policy, accessing our Website or using our Services, you are regarded as having read, understood and agreed to be bound by this Policy.
i. This Privacy Policy complies with, and facilitates the obligations required from, the European Commission’s General Data Protection Regulation, 2016/679 (“GDPR”) as well as the South African Protection of Personal Information Act No. 4 of 2013 ( “POPI”), as amended.
ii. Due to the nature of some of our services as a provider of various payment and facilitation tools, we process not only your General Personal Information, but also Special Categories of Personal Information, being your Financial Data.
iii. It is important that you read this Privacy Policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing Personal Information about you, so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.
iv. You may not submit any other person’s personal information to wCyber, and warrant that such information you submit is your own, and lawfully yours to provide.
i. wCyber is the data controller and is responsible for your Personal Information in instances where we decide the processing operations concerning your Personal Information. Sometimes we also operate as a processor of Personal Information on behalf of a third-party data controller, where that data controller’s privacy terms will apply, but we will draw your attention to them when applicable.
ii. We have appointed a data representative at wCyber who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the representative using the details set out below.
iii. You have the right to make a complaint at any time to your territories’ specific South African, European Union or UK information regulator’s office (such as the Information Regulator’s Office of South Africa . We would, however, appreciate the chance to deal with your concerns before you approach any such regulator, so please contact us in the first instance.
i. We may amend this Policy at any time by posting a revised version on our Website. The revised version will apply to all Data Subjects with effect from the time we post it.
ii. This Privacy Policy version was last updated on 13 November 2019 and historic versions are archived and can be obtained by contacting us.
iii. It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us.
i. The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements or terms. When you leave our Website, or engage with such third parties, we encourage you to read the distinct privacy policy of every third-party you engage with.
a. Personal data, or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
b. We may collect, use, store and transfer (“process”) different kinds of Personal Information about you which we have grouped together follows:
i. Identity Data including first name, last name, ID number, date of birth, passport number, city and country that you reside in, Google Authentication Token, Facebook Authentication Token, legal entity name, company registration number, country of incorporation, and the personal details of all your directors and/or office bearers;
ii. Contact Data includes billing address, delivery address, email address, social media contact details and telephone numbers;
iii. Financial Data including, third-party payment provider information and payment card details, credit card tokens, credit card brand, card bin numbers, card trailing digits, card holder name, card expiry details, location of in-store payment, an internally-calculated flag for risk and banking details for outgoing and incoming payments;
iv. Transaction Data includes details about payments to and from you, contracts, contractual terms, contract fees, signups, subscriptions, invoices and other details of products and services you have obtained from us;
v. Social Media Data including all information accessible on your publicly available profile such as images, photos, photo tags, likes, followers, comments, posts and stories;
vi. Technical Data including internet usage information, including your Internet Protocol address (“IP Address”), browsing habits, click patterns, unique user ID, version of software installed, system type, screen resolutions, colour capabilities, plug-ins, language settings, cookie preferences, search engine keywords, JavaScript enablement, the content and pages that you access on the Website, App or Platform, and the dates and times that you visit the Website, App or Platform, paths taken, and time spent on sites and pages within the Website, App or Platform;
vii. Profile Data including your Website username and password, your interests, preferences, feedback and form and survey responses;
viii. Biometric Data including your age, gender and derived data from your profile;
ix. Usage Data including information about how you use our assessment tools, Website, surveys, events and services; and
x. Marketing and Communications Data including your preferences in receiving notices and marketing from us and our third parties and your communication preferences.
c. We also collect, use and share Aggregated Data and Non-Personal Information such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Information but is not considered Personal Information in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Privacy Policy.
d. We do collect Special Categories of Personal Information about you (being, for example, Financial Data and data relating to minors), which you hereby expressly consent to WCyber doing. We process Financial Data in accordance with South African and EU laws requiring us to do so, and also due to the nature of WCyber as a provider of payment services requiring such information to operate, which you understand and expressly consent to. We enforce additional special precautions regarding the safety and integrity of any Special Categories of Information provided to us.
e. Where we need to collect Personal Information by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with Services or allow you access to the Website). In this case, we may have to cancel Website-access or services you have with us, but we will notify you if this is the case at the time.
f. “Cookies” Information: When you access the Website, App or Platform, we may send one or more cookies (small text files containing a string of alphanumeric characters) to your computer to collect certain Usage Details. We may use both session cookies (which disappears after you close your browser) and persistent cookies (which remain after you close your browser which can be removed manually) and may be used by your browser on subsequent visits to the Website, App and Platform. Please note that the use of cookies is standard on the internet and many major websites use them. Please review your web browser “Help” file to learn more about modifying your cookie settings.
a. We use different methods to collect data from and about you including through:
i. Direct interactions: You may give us your Identity, Contact, and Financial Data by filling in various WCyber forms, Website forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Information you provide when you:
ii. Automated technologies or interactions: As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this Personal Information by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies
iii. Third parties or publicly available sources: We may receive Personal Information about you from various third parties and public sources as set out below.
i. Where we need to perform on the contract we are about to enter into or have entered into with you;
ii. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
iii. Where you have provided your express consent thereto, which by accepting this Policy, are hereby doing; and/or
iv. Where we need to comply with a legal or regulatory obligation.
i. We have set out below, in a table format, a description of all the ways we plan to use your Personal Information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
ii. Note that we may process your Personal Information for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at info@wcyber.net if you need details about the specific legal ground we are relying on to process your Personal Information where more than one ground has been set out in the table below.
| PURPOSE/ACTIVITY | TYPE OF DATA | LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST |
|---|---|---|
| To allow you to make use of the Services |
Identity Contact Financial Transaction Marketing and Communications Biometric |
|
| To contract with you as a service provider to wCyber |
Identity Contact Financial Transaction Marketing and Communications Social Media Market Research |
|
| To process market research data provided by you as a result of you opting into a market research or cultural research study |
Identity Contact Financial Transaction Marketing and Communications Social Media Market Research |
|
| To allow you to use the Website, or register you as a new Website user or participant in any wCyber event or competition |
Identity Contact Financial Transaction |
|
| To process and service your payment and/or ticketing activities for any wCyber event, To manage payments, fees and charges incurred by you by using our Website or wCyber Services |
Identity Contact Financial Transaction Marketing and Communications |
|
| To manage our relationship with you which may include notifying you about changes to our terms or Privacy Policy |
Identity Contact Profile Marketing and Communications |
|
| To enable you to partake in a wCyber study or complete a survey |
Identity Contact Profile Usage Marketing and Communications |
|
| To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
Identity Contact Technical Usage |
|
| To market our own Services to other companies or External Third Parties |
Identity Contact Profile |
|
| To deliver relevant Website or service content and advertisements to you and measure or understand the effectiveness of the notices we serve to you |
Identity Contact Profile Usage Marketing and Communications Technical |
|
| To use data analytics to improve our Website, services, marketing, programme relationships and experiences |
Technical Usage |
|
| To make suggestions and recommendations to you about events or services that may be of interest to you |
Identity Contact Technical Usage Profile |
|
i. We strive to provide you with choices regarding certain Personal Information uses, particularly around marketing and advertising. To manifest your rights attached to any marketing sent to you, please use the in-built prompts provided on those communications, or contact us.
i. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.
ii. You will receive marketing communications from us if you have requested information from us, have participated in any wCyber Service, assessment or event, or if you provided us with your details when registering for a promotion, event or ticketing and, in each case, you have not opted-out of receiving that marketing.
i. Whilst we may use your Personal Information within our wCyber company group, we will get your express opt-in consent before we share your Personal Information publicly with any company outside the wCyber group of companies for public purposes.
i. You can ask us or third parties to stop sending you marketing messages at any time by logging into the Website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you, or by contacting us at any time.
ii. Where you opt-out of receiving these marketing messages, this will not apply to Personal Information provided to us as a result of your use of the Website, our Services, or your participation in any wCyber event.
i. We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
ii. If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
iii. Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
i. Internal Third Parties as set out in the Glossary;
ii. External Third Parties as set out in the Glossary;
iii. Specific third parties listed in the table above; and/or
iv. Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses/organisations or merge with them. If a change happens to our organisation, then the new owners may use your Personal Information in the same way as set out in this Privacy Policy.
i. We will only transfer your Personal Information to countries that have been deemed to provide an adequate level of protection for Personal Information by the European Commission.
ii. Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Information the same protection it has in Europe.
iii. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to Personal Information shared between Europe and the US.
a. We store and process the Personal Information of all Data Subjects on our computers, and we protect it by maintaining reasonable industry-standard physical, electronic and procedural safeguards. We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorize access to Personal Information only for those employees who require it to fulfil their job responsibilities, which employees are subject to appropriate confidentiality provisions protecting your Personal Information from disclosure beyond what is allowed in terms of this Policy.
b. You should not divulge your account password to anyone. We will never ask you for your password in an unsolicited telephone call or email. You are responsible for maintaining the secrecy of your unique password and account information at all times.
c. For security purposes, if you are a legal entity and not an individual, we will liaise only with your named contact or alternative contact provided by your named contact. It is your responsibility to let us know of any changes to your named contact, where we will not be liable at all for any consequences stemming from your failure to do so.
d. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality.
e. We have put in place procedures to deal with any suspected Personal Information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
a. You can review and edit any of your Personal Information at any time by signing in to your Account and clicking the My Profile menu in any of our pages, where you agree to provide accurate and current information, and, generally, not to impersonate or misrepresent any person or entity or falsely state or otherwise misrepresent your affiliation with anyone or anything
b. You warrant that the Personal Information disclosed to us is directly from you as the Data Subject or on behalf of an entity for which you have all requisite authority to do so, and all such Personal Information is lawfully yours to provide.
c. Deleting your Personal Information yourself:
i. Mobile App: Should you decide to delete your account/profile and related information from the App, you may do so by deleting the App from your device(s). You understand that by deleting the App, your profile/account details including any saved information, and any promotional offers received by you, will no longer be retrievable/accessible or editable by you. However, we make no representations or warranties that content or actions previously posted or embedded onto the App by you will be removed by a deletion of the App.
ii. Website account: You may request that your account is deactivated by emailing us on info@wcyber.net.
iii. Please note: Even after you have removed the App or requested that we deactivate your account on the Website, copies of that information may remain viewable elsewhere, to the extent it has been shared with others, it was otherwise distributed pursuant to User’s privacy settings, or it was copied or stored by other users and partners.
d. In some circumstances, other applicable national laws require us to retain your Personal Information beyond your request for its deletion/amendment, or beyond your direct engagement with us (such as anti-terrorism or financial services laws). As such, we may retain your Personal Information in adherence with compulsory instructions from other applicable national laws, notwithstanding your application to have it deleted or amended.
a. We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
b. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.
c. Details of retention periods for different aspects of your Personal Information are available from us by contacting us.
d. In some circumstances you can ask us to delete your data; see below for further information.
a. Notwithstanding anything contained in this Policy regarding your information, the following information is not regarded as Personal Information for the purposes of this Policy:
i. Permanently de-identified information that does not relate and/or cannot be traced back to you specifically. We may compile, use, share and otherwise process such information as we deem fit;
ii. Non-personal statistical information collected and compiled by us. We own and retain all rights in such information; and/or
iii. Information which you have provided voluntarily in an open, public environment or forum including (without limitation) any blog, chat room, albums, community, classifieds or discussion board. Because the information has been disclosed in a public forum, it is no longer confidential and does not constitute Personal Information subject to protection under this Policy. Since such public environments are accessible by third parties, it is possible that third parties may collect and collate and use such information for their own purposes and you should accordingly be careful when deciding to share any of your Personal Information in such public environments.
a. Under certain circumstances, you have rights under the data protection laws in relation to your Personal Information. Please contact us to find out more about, or manifest, these rights:
i. Request access to your Personal Information;
ii. Request correction of your Personal Information;
iii. Request erasure of your Personal Information;
iv. Object to processing of your Personal Information;
v. Request restriction of processing your Personal Information;
vi. Request transfer of your Personal Information; and/or
vii. Right to withdraw consent.
b. No fee usually required
i. You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
c. What we may need from you
i. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
d. Time limit to respond
i. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
i. If you have questions or concerns regarding this Policy, you should contact us by using the following contact details
wCyber Solutions (Pty) Ltdii. We will promptly notify you if we become aware of any unauthorized use, disclosure or processing of your Personal Information, and should you become aware of such a breach before we discover it, please immediately contact us and mitigate your potential damage as quickly and as much as possible (for example, by immediately changing all relevant Website, App and/or Platform passwords).