Bhava Collective – Privacy Policy

August 2021 | Version 1.0

1. Introduction

We respect your privacy and take it very seriously. We are Bhava Collective (Pty) Ltd (Registration number 2021/436691/07), also known as Bhava Collective, managing the MyCreation, HotPlates and other websites, and this is our plan of action for the protection of your personal information. It describes how we collect, use, disclose, and store your personal information.

2. Application

This policy applies to you when you visit our website, enter a competition on our website, or vote for any of the entrants in these competitions.

3. Personal information

3.1 Scope. Your personal information includes information we collect:

automatically when you visit our website; accept on registration, submission or entry to any competition on our website; when you vote for a contestant in any competition on this website; when we host competitions as an operator on a responsible part’s behalf; or which you provide voluntarily. It excludes anonymous, de-identified, statistical, and public information.

3.2 Common examples. Common examples of the types of personal data which we may collect and process include your:

identifying information – such as your name, date of birth, or identification number of any kind; contact information – such as your phone number or email address; address information – such as your physical or postal address; or demographic information – such as your gender or marital status.

3.3 Examples of sensitive personal information we may collect. Depending on the competition that you enter, we may also collect sensitive personal information, including your:

financial information – such as your bank account details; sensitive demographic information – such as your race or ethnicity;

3.4 Your obligations. You may only send us:

your own personal information if you are 18 years or over; someone else’s personal information if they are older than 18 and you have their permission to do so; or your child’s personal information provided you have the legal capacity to do so; if you are a legal resident in South Africa.

4.1 Acceptance. You may not enter any competition or vote for any contestant in any competition if you do not accept this policy or any changes to it.

4. Acceptance and changes

4.2 Changes. We may change this policy at any time and will notify you of the changes on our website or by email. The changed policy applies to you if you:

continue using our website; continue entering the competitions; continue voting for entrants in the competitions; or fail to withdraw your entry in a competition after we have notified you of the policy change during the duration of that competition.

4.3. Acceptance required. You must accept all the terms of this policy when you enter any of the competitions, vote for any contestant in any competition, or use our websites. If you do not agree with anything in this policy, then you may not enter any of our competitions, vote for any contestant, or use our websites. 4.4. Legal capacity. You may not access our websites, enter our competitions, or vote for any contestant if you are younger than 18 years old or do not have legal capacity to conclude legally binding contracts. 4.5. Deemed acceptance. By accepting this policy, you are deemed to have read, understood, accepted, and agreed to be bound by all of its terms. 5. Collection 5.1. Automatically through website. When you visit our website, we automatically collect your Internet usage information (including your IP address, browser details and usage information) through your browser, which we may use to display our website correctly, track your activities on it, or for other necessary purposes. 5.2. On registration or submission. We may ask you to provide us with certain identifying information (including your first name, surname and email address) when you register on or otherwise submit information through our website, enter the competitions, or vote for any of the contestants for the first time. 5.3. Voluntarily. We may ask you to provide us certain optional information on a voluntary basis. 5.4. Consent to collection. We will process your personal information only where we have a lawful justification to do so, and where required by law, we will get your consent to collect your personal information when you provide us with it. 5.5. Purpose for collection. We may process your information that you provide to us for the purposes that you indicated when you agreed to provide it to us. Processing includes gathering your personal information, disclosing it, and combining it with other personal information. 6. Use 6.1. Processing. We may process your personal information to fulfil our obligations to you. 6.2. Cookies. We may place small text files on your device when you visit our website that allow us to provide you with a personalised experience by associating your personal information with your device. They let us remember your preferences, allow third parties to provide services to you, and otherwise serve useful purposes for you. Your internet browser generally accepts them automatically, but you can often change this setting or delete them manually. However, we won’t be able to provide you with access to certain aspects of our website where cookies are necessary if you do so. We have no access to or control over any cookies that our business partners use on our website and they have their own privacy policies that govern them. 6.3. Messages. We may use your identifying information to send you administrative or update messages about our website, or the competitions on our website. 6.4. Promotional messages. We will not send you promotional messages unless you have chosen to opt-into them. But, we may send you one message asking you to opt-into promotional messages without you having opted-into promotional messages. 6.5. Targeted content. We may use your personal information to provide you with targeted content through our website in a completely automated process. 6.6. Recording calls. We may monitor and record any telephone calls that you make to us, unless you specifically request us not to. 7. Disclosure 7.1. Sharing. We may share your personal information with third parties for the purposes of fulfilling our obligations to you, including with: other companies or divisions within our group; our contractors who help us meet our obligations to you, including those that help us understand your personal information; or third parties as required by applicable law. 7.2. Honour this policy. We will require anyone that we share your personal information with to honour this policy whenever possible in terms of applicable law. We will not sell your personal information. No personal information will be disclosed to anyone except as provided in this privacy policy. 7.3. Mandatory disclosure. We may disclose personal information to third parties if required for legal reasons, such as if required by the relevant authorities, regulators or a court order. 7.4. Marketing purposes. We may disclose aggregate statistical information that we derive from your and other people’s personal information to our advertisers or business partners. 7.5. Personnel. We may need to disclose personal information to our personnel to do their jobs, but will not do so unnecessarily. 7.6. Change of ownership. We may assign our rights to the personal information we process to our new owners if our ownership changes for any reason. 8. Security 8.1. We take the security of personal information very seriously and always do our best to comply with applicable data protection laws. Our hosting company will host our website in a secure server environment that uses a firewall and other advanced security measures to prevent interference or access from outside intruders. We implement disaster recover procedures where appropriate. 9. Storage 9.1. Access. You may ask us to provide you with a description of the personal information that we hold on you, correct or update it or delete it (provided that we do not need it to fulfil our obligations to you or applicable law does not require us to keep it). We will take all reasonable steps to verify your identity before doing so. We may charge a fee to recoup our costs associated with this request if there is a cost to us associated with it and provided that applicable law allows us to do so. Please contact us with your name and any other information needed to identify you correctly if you want access to information or want us to correct, update or delete it. 9.2. Accuracy. We will do our best to keep your personal information that we collect accurate, complete, and up to date. 9.3. Participation. We may ask you to update your personal information from time to time, but will take steps to verify your identity to prevent unauthorised access when doing so. 9.4. Retention. We will only keep your personal information for as long as is necessary to fulfil our obligations to you, unless you have given us permission to keep it longer or we are otherwise legally allowed to do so. 9.5. Transfer. We may transfer your personal information outside of the country in which it was collected to a foreign country. You consent to us processing your personal information in a foreign country with less stringent data protection laws than the country in which it was collected. 10. General 10.1. Updating or removing. You may update or remove your personal information: through our website; or by contacting us. 10.2. Limitation. We are not responsible for anyone else’s privacy policies or practices. This includes the privacy policies and practices that may relate to external competitions we might host on our website. 10.3. Enquiries. Please contact us by email at inventor@mycreation.co.za if you have any questions about this privacy policy or how we handle your personal information. Please feel free to contact us to discuss any concerns or questions you may have. You can also complain to the Information Regulator if you are unhappy with how we have used your Information. Their contact details are as follows: The Information Regulator (South Africa) JD House 27 Stiemens Street Braamfontein Johannesburg 2001 Complaints email for POPIA: POPIAComplaints.IR@justice.gov.za Complaints email for PAIA: PAIAComplaints.IR@justice.gov.za