Privacy Policy

This privacy notice for Naleso (Pty) Ltd (doing business as Nghenelela) ("we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

• Visit our website at https://nghenelela.2soh.com, or any website of ours that links to this privacy notice
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services.

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You:

• Names
• Email addresses
• Usernames
• Billing addresses
• Debit/credit card numbers
• Contact or authentication data
• Passwords
• Contact preferences
• Job titles
• Phone numbers

Sensitive Information: We do not process sensitive information.

Payment Data: We may collect data necessary to process your payment if you make purchases. All payment data is stored by Stripe. You may find their privacy notice here: https://stripe.com/privacy.

2. HOW DO WE PROCESS YOUR INFORMATION?

We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

• To facilitate account creation and authentication and otherwise manage user accounts
• To deliver and facilitate delivery of services to the user
• To respond to user inquiries/offer support to users
• To send administrative information to you
• To fulfill and manage your orders
• To request feedback
• To send you marketing and promotional communications
• To protect our Services
• To identify usage trends
• To determine the effectiveness of our marketing and promotional campaigns
• To save or protect an individual's vital interest

3. WHAT LEGAL BASES DO WE RELY ON?

We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

Under South African POPIA: We process personal information in accordance with the conditions for lawful processing set out in POPIA, including:

• Consent: We may process your information if you have given us permission to use your personal information for a specific purpose.
• Performance of a Contract: We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you.
• Legitimate Interests: We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests, provided such interests are not overridden by your privacy interests.
• Legal Obligations: We may process your information where we believe it is necessary for compliance with our legal obligations.
• Vital Interests: We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party.

We ensure that our processing activities comply with POPIA's accountability, processing limitation, purpose specification, further processing limitation, information quality, open transparency, and security safeguards principles.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We may share information in specific situations described in this section and/or with the following categories of third parties:

• Payment Processors
• Data Analytics Services
• User Account Registration & Authentication Services
• Cloud Computing Services
• Government Entities

International Data Transfers: Your personal information may be transferred to and processed in countries other than South Africa. We ensure that any such transfers comply with POPIA requirements and that adequate protection is in place for your personal information.

Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible, then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

8. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly collect data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In some regions (like the European Economic Area (EEA), United Kingdom (UK), Switzerland, Canada, and South Africa), you have certain rights under applicable data protection laws. These may include the right to:

• Request access to and obtain a copy of your personal information
• Request rectification or erasure
• Restrict the processing of your personal information
• Data portability (if applicable)
• Not be subject to automated decision-making
• Object to processing of your personal information
• Request restriction of processing
• Be informed of data breaches

South African Rights under POPIA: As a South African data subject, you have additional rights under the Protection of Personal Information Act (POPIA), including:

• The right to be informed that your personal information is being collected
• The right to know whether your personal information is being held by us
• The right to access and copy your personal information
• The right to correct or delete your personal information
• The right to object to the processing of your personal information
• The right to request the destruction or deletion of your personal information
• The right to lodge a complaint with the Information Regulator

You can make such a request by contacting us. We will consider and act upon any request in accordance with applicable data protection laws, including POPIA.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send.

10. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact us at: