05 March 2019 min read

Privacy Policy of Rafiki by PANEOTECH

Owner and Data Controller
PANEOTECH (PTY) LTD - 2nd Floor, West Tower - Nelson Mandela Square - Maude St, Johannesburg, 2146, South Africa

Owner contact email: This email address is being protected from spambots. You need JavaScript enabled to view it.

Types of Data collected
Among the types of Personal Data that Rafiki by PANEOTECH collects, by itself or through third parties, there are: Tracker; Usage Data; email address; first name; last name; phone number; payment info; Data communicated while using the service; various types of Data.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Rafiki by PANEOTECH.
Unless specified otherwise, all Data requested by Rafiki by PANEOTECH is mandatory and failure to provide this Data may make it impossible for Rafiki by PANEOTECH to provide its services. In cases where Rafiki by PANEOTECH specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by Rafiki by PANEOTECH or by the owners of third-party services used by Rafiki by PANEOTECH serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through Rafiki by PANEOTECH and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Rafiki by PANEOTECH (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing
Rafiki by PANEOTECH may process Personal Data relating to Users if one of the following applies:

Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which the Owner is subject;
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Access to third-party accounts, Analytics, Contacting the User, Hosting and backend infrastructure, Handling payments, Remarketing and behavioral targeting, Advertising, Registration and authentication, Tag Management and Interaction with live chat platforms.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Google API Services User Data Policy
Our app complies with the Google API Services User Data Policy, including the Limited Use requirements. We understand the importance of protecting user data and have implemented measures to ensure compliance with the policy. We only use user data for the purposes outlined in our privacy policy and do not share or sell user data to third parties. By using our app, you acknowledge and agree to our compliance with the Google API Services User Data Policy.

Google Drive: We only read the list of Spreadsheets to allow you to select the Spreadsheet you want to work with.

Google Sheets: We allow you to get data and update your Spreadsheet.

Google Calendar: We read the list of events on your calendar to avoid overbooking. Also, we add events to your Calendar when a customer book an appointment.

Dialogflow: we use Dialogflow to allow you to automate customer services using Dialogflow. We only use Dialogflow to detect user intents.

Facebook permissions asked by Rafiki by PANEOTECH

Rafiki's use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy , including the Limited Use requirements.

Facebook permissions asked by Rafiki by PANEOTECH Rafiki by PANEOTECH may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows Rafiki by PANEOTECH to connect with the User's account on the Facebook social network, provided by Facebook Inc.

For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.

The permissions asked are the following:

Basic information By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.

About Me Provides access to the 'About Me' section of the profile.

Business Management API Read and write with Business Management API.

Contact email Access the User's contact email address.

Instagram basic Allows reading an Instagram account profile information and media.

Instagram manage comments Allows the creation, deletion and hiding of comments on behalf of the Instagram account linked to a Page. Also allows reading and responding to public media and comments that a business has been photo tagged in or @mentioned in.

Manage Pages Enables the application to retrieve access_tokens for Pages and Applications that the User administrates.

Managing Page Advertisements Allows managing advertisements associated with the Page.

Page Messaging Send and receive messages through a Facebook Page.

Pages manage engagement Allows creating, editing and deleting comments posted on the page.

Pages manage metadata Allows subscribing and receiving webhooks about activity on the Page, and updating settings on the Page.

Pages manage posts Allows the creation, editing and deletion of the User’s Page posts.

Pages read engagement Provides access to content (posts, photos, videos, events) posted by the Page, access to followers data (including name, PSID), and profile picture, and access to metadata and other insights about the Page.

Pages User locale Provides access to the User’s locale through the connected Page.

Pages User timezone Grants access to a User’s time zone through the connected Page.

Show List of Managed Pages Provides the access to show the list of the Pages that the User manages.

Detailed information on the processing of Personal Data Personal Data is collected for the following purposes and using the following services:

Access to third-party accounts This type of service allows Rafiki by PANEOTECH to access Data from your account on a third-party service and perform actions with it. These services are not activated automatically but require explicit authorization by the User.

Facebook account access (Facebook, Inc.) This service allows Rafiki by PANEOTECH to connect with the User's account on the Facebook social network, provided by Facebook, Inc. Permissions asked: About Me; Business Management API; Contact email; Instagram basic; Instagram manage comments; Manage Pages; Managing Page Advertisements; Page Messaging; Pages manage engagement; Pages manage metadata; Pages manage posts; Pages read engagement; Pages User locale; Pages User timezone; Show List of Managed Pages.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: identifiers; internet information; inferred information. Advertising This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on Rafiki by PANEOTECH, possibly based on User interests. This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below. Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside Rafiki by PANEOTECH. For more information, please check the privacy policies of the relevant services. In addition to any opt-out feature offered by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page. Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

Google Ad Manager (Google Ireland Limited) Google Ad Manager is an advertising service provided by Google Ireland Limited that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with. In order to opt out from being tracked by various advertising networks, Users may make use of Youronlinechoices. In order to understand Google's use of data, consult Google's partner policy. This service uses the “DoubleClick” Cookie, which tracks use of Rafiki by PANEOTECH and User behavior concerning ads, products, and services offered. Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.

Personal Data processed: Tracker; Usage Data.

Place of processing: Ireland – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

Facebook Lookalike Audience Facebook Lookalike Audience is an advertising and behavioral targeting service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on the location Rafiki by PANEOTECH is accessed from, that uses Data collected through Facebook Custom Audience in order to display ads to Users with similar behavior to Users who are already in a Custom Audience list on the base of their past use of Rafiki by PANEOTECH or engagement with relevant content across the Facebook apps and services. On the base of this Data, personalized ads will be shown to Users suggested by Facebook Lookalike Audience. Users can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page.

Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Category of personal information collected according to CCPA: internet information.

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers. Handling payments Unless otherwise specified, Rafiki by PANEOTECH processes any payments by credit card, bank transfer, or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. Rafiki by PANEOTECH isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.

Stripe (Stripe Technology Europe Ltd) Stripe is a payment service provided by Stripe Technology Europe Ltd.

Personal Data processed: email address; first name; last name; payment info.

Place of processing: Ireland – Privacy Policy.

Category of personal information collected according to CCPA: identifiers; commercial information.Contacting the User Mailing list or newsletter (Rafiki by PANEOTECH) By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Rafiki by PANEOTECH. Your email address might also be added to this list as a result of signing up to Rafiki by PANEOTECH or after making a purchase.

Personal Data processed: email address; first name; last name; phone number; Usage Data.

Category of personal information collected according to CCPA: identifiers; internet information.Interaction with live chat platforms This type of service allows Users to interact with third-party live chat platforms directly from the pages of Rafiki by PANEOTECH, in order to contact and be contacted by Rafiki by PANEOTECH's support service. If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.

Facebook Messenger Customer Chat The Facebook Messenger Customer Chat is a service for interacting with the Facebook Messenger live chat platform provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on the location Rafiki by PANEOTECH is accessed from,

Personal Data processed: Data communicated while using the service; Tracker; Usage Data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Google Cloud Storage (Google LLC): Google Cloud Storage is a hosting service provided by Google LLC. Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

Google App Engine: Google App Engine is a hosting service provided by Google LLC or by Google Ireland Limited, depending on the location Rafiki by PANEOTECH is accessed from. Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

Registration and authentication: By registering or authenticating, Users allow Rafiki by PANEOTECH to identify them and give them access to dedicated services. Depending on what is described below, third parties may provide registration and authentication services. In this case, Rafiki by PANEOTECH will be able to access some Data, stored by these third-party services, for registration or identification purposes. Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.

Google OAuth (Google Ireland Limited): Google OAuth is a registration and authentication service provided by Google Ireland Limited and is connected to the Google network. Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: Ireland – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

Facebook Authentication (Facebook Ireland Ltd): Facebook Authentication is a registration and authentication service provided by Facebook Ireland Ltd and is connected to the Facebook social network. Personal Data processed: Tracker; various types of Data as specified in the privacy policy of the service.

Place of processing: Ireland – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

Facebook OAuth: Facebook OAuth is a registration and authentication service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on the location Rafiki by PANEOTECH is accessed from, and is connected to the Facebook social network. Personal Data processed: Tracker; various types of Data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

Remarketing and behavioral targeting: This type of service allows Rafiki by PANEOTECH and its partners to inform, optimize and serve advertising based on past use of Rafiki by PANEOTECH by the User. This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity. Some services offer a remarketing option based on email address lists. In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.

Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

Facebook Custom Audience (Facebook Ireland Ltd): Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook Ireland Ltd that connects the activity of Rafiki by PANEOTECH with the Facebook advertising network. Users can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page. Personal Data processed: email address; Tracker.

Place of processing: Ireland – Privacy Policy – Opt Out.

Category of personal information collected according to CCPA: identifiers; internet information.

Facebook Remarketing (Facebook Ireland Ltd): Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook Ireland Ltd that connects the activity of Rafiki by PANEOTECH with the Facebook advertising network. Personal Data processed: Tracker; Usage Data.

Place of processing: Ireland – Privacy Policy – Opt Out.

Category of personal information collected according to CCPA: internet information.

Google Ads Remarketing (Google Ireland Limited): Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google Ireland Limited that connects the activity of Rafiki by PANEOTECH with the Google Ads advertising network and the DoubleClick Cookie. Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings. Personal Data processed: Tracker; Usage Data.

Place of processing: Ireland – Privacy Policy – Opt Out.

Category of personal information collected according to CCPA: internet information.

LinkedIn Website Retargeting (LinkedIn Corporation): LinkedIn Website Retargeting is a remarketing and behavioral targeting service provided by LinkedIn Corporation that connects the activity of Rafiki by PANEOTECH with the LinkedIn advertising network. Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out.

Category of personal information collected according to CCPA: internet information.

Twitter Remarketing (Twitter, Inc.): Twitter Remarketing is a remarketing and behavioral targeting service provided by Twitter, Inc. that connects the activity of Rafiki by PANEOTECH with the Twitter advertising network. Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out.

Category of personal information collected according to CCPA: internet information.

Tag Management: This type of service helps the Owner to manage the tags or scripts needed on Rafiki by PANEOTECH in a centralized fashion. This results in the Users' Data flowing through these services.

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