[Revision: 26 June 2019]
ENGAGE VIDEO GROUP
(including “Foodies of South Africa”, “Foodies of Nigeria”, “Foodies of Kenya”, “The Foodies”, “Awesome DIY”, “Great Stuff to Know”, “Coffee Tribe”, and other brands)
1.3. We collect publicly available information, content and communications that you, a data subject and an “author” provide or share in the public domain via a social media platform, blog, forum and/or news site. Some of this information can be personal data. As an example, your name in connection with the user name of your Facebook or Twitter profile along with the profile picture is set to public on your user profile privacy settings. As an author, you are the source of the data and have control under the user profile privacy settings of each platform you interact with and can at any time restrict any of this information appearing in the public domain in accordance with the terms of the relevant platform.
1.6. We do not circumvent any of the personal privacy settings on any of the platforms and/or suppliers from which we collect data. Our system is intended for and focused on publicly available information.
1.7. This privacy notice will inform you about what data we collect from our data suppliers, including various social platforms, with whom we have direct relationships for purposes of our business, how we use such data, circumstances where we may disclose this data to others, and how we keep it secure.
1.8. In this policy, “Data Protection Legislation” means all applicable legislation which relates to the protection of individuals with regards processing personal data, including the General Data Protection Regulation (EU) 2016, the UK Data Protection Act 2018 and the South African Protection of Personal Information Act, No. 4 of 2013.
1.9. In this policy “Services” means all services offered and/or rendered by us from time to time to our customers and consumers, which includes providing [creation, curation and publication of educational and entertainment content in various formats – including audio, video and mixed media – on digital channels and social platform; the collection, synthesis, analysis, aggregation and reporting of consumer and audience information relating to Engage Video Group content and channels for our customers; marketing of customer products and brands through publication of content on various platforms and through various channels; and ancillary services relating to these.]
1.10. Any questions relating to this policy and our privacy practices should be sent to us using the contact details set out below.
2 THE INFORMATION WE COLLECT
2.1. We may collect, use, store and transfer different kinds of information which you post or make publicly available online, including but not limited to:
• Blogs & Blog comments;
• Mainstream news sources; and
together referred to as “Social Platforms” within this policy.
2.2. Such information/data may include:
• Your name, username, handle, or other identifier;
• The content of the information you have published via that name, username, handle, or other identifier, including comments, expressions, opinions, posts, preferences, beliefs etc;
• From the content of these above, we can sometimes infer information such as your race, gender etc;
• Your profile picture, or other images or videos that you post or interact with;
• Your approximate location;
• The content of your posts on Social Platforms, including your opinions, preferences and beliefs;
• Your non-private communications with other users of Social Platforms on such Social Platforms; and
• Any other information you publicly provide or post on Social Platforms.
2.3. The data that we collect (as set out above) will be referred to as “Public Social Data” throughout this policy.
2.5. We do not knowingly collect or share:
• except in the form of Aggregated Data (please see comments at paragraph 2.4 above), any special categories of
personal data, within the meaning of the Data Protection Legislation, about you (this includes details about your
race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union
membership, information about your health, and genetic and biometric data);
• any information about criminal convictions and offences.; or
• any information relating to children under the age of 13.
2.6. We are committed to respecting the privacy of children online. If we learn that our systems have inadvertently collected information relating to children under the age of 13, we will promptly delete the information and notify the relevant representatives of the customer (with whom we may have inadvertently shared such data) to facilitate a consultation on how this data was collected and put measures in place for it not to happen again.
3 HOW WE COLLECT AND PROCESS YOUR DATA
3.1. We collect your Public Social Data from publicly available online sources directly from certain Social Platforms and/or from third party suppliers such as blogs, forums and news sites who collect public online data, in connection with the delivery of our Services to our customers.
3.2 We may also collect inferences about you from your Public Social Data; for example we may be able to determine certain information about you from the content of your Public Social Data such as your gender, sentiment and preferences (referred to as “Inferences”). We draw such Inferences from your Public Social Data in two ways:
• by using algorithms that analyse the data that you have posted on the Social Platforms; and
• through manual analysis and modelling based on your observed engagement and interactions on the Social
4 WHY WE USE THIS INFORMATION ABOUT YOU
4.1. We use your Public Social Data we collect about you:
• to provide our Services, including the collection, synthesis, analysis, aggregation and reporting of consumer and audience information relating to Engage Video Group content and channels for our customers, and marketing of our customer products and brands through publication of content on various platforms; and
• in related or ancillary ways, to the Services that we offer. For example, we may use the data to comply with our legal obligations or enforce our rights, including the legal obligations or enforcement of rights of third parties.
We may also use the data to improve our services.
4.2. We will only process your Public Social Data when we have legal grounds to do so. Generally, we rely on the legal ground in Data Protection Legislation which allows us to use your Public Social Data 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.
4.3 Our legitimate interests for processing data are in order to provide our Services to our customers, which include providing technology and related services that empowers our customers to ensure their marketing efforts reach their target audiences with much greater accuracy and impact, and with objectives that may include improving that customer’s own services or products to its end users. Our Services allow our customers to reach bigger, more relevant and more engaged consumer audiences, and to learn more about their products and brands, their customers, their competitors, and other information available on the internet that may be relevant to our customers. You are able to restrict access to such information through using the privacy settings available on the relevant Social Platforms at any time.
5 GENERAL USE OF YOUR DATA
5.2. In respect of your Public Social Data, we will not (without your express prior written consent):
• sell, licence or purchase any data obtained from Social Platforms;
• directly or indirectly transfer any of your Public Social Data (including anonymous, aggregate, or derived data)
to any ad network, data broker or other advertising or monetization-related service;
• use your Public Social Data to make decisions about eligibility, including whether to approve or reject an
application or how much interest to charge on a loan;
• put your Public Social Data in a search engine or directory, or include web search functionality on our apps on Social Platforms
• prefill any content in captions, comments, messages or the user message parameter of posts;
• proxy, request or collect your usernames or passwords for Social Platforms;
• transfer your Public Social Data to a data broker or sell your Public Social Data;
• share your user IDs for Social Platforms with service providers who build or run any of our apps. Your user IDs for Social Platforms will be kept secure and confidential; and/or
• use friends or connections data from Social Platforms to establish social connections in our apps, unless you
have granted you access to that information.
5.3. In respect of the Public Social Data, we will:
• promptly delete all your Public Social Data that we have received from a particular Social Platform if we stop
collecting data from such Social Platform; and
• comply with all applicable laws and regulations in the jurisdiction where our apps are available.
5.4. We are not accountable for any faulty or non-compliant practices deployed by third party websites or Social Platforms.
6 DATA SECURITY
6.1. We have put in place appropriate security measures to prevent your Public Social Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Public Social Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Public Social Data on our instructions, and they are subject to a duty of confidentiality.
6.2. Although it is the responsibility of our customers to use our Services properly and we cannot ultimately bear responsibility for our customers’ use of our platform or system, we have implemented adequate safeguards to protect your data. Through contracts with our customers, we require our customers to comply with applicable law, including Data Protection Legislation, when using our Services and our customers agree to abide by the policies of third party websites.
7 DISCLOSURE OF PERSONAL DATA
7.1. We will treat your information as confidential. However, we may disclose your Public Social Data to other third parties for the purposes set out below or for any additional purposes approved by you:
Our People: our employees, officers, shareholders and advisors, but only to the extent that the information is necessary for them to enable us to provide our services;
Our Customers: our customers which include banks, supermarkets, manufacturers and other organizations;
Internal Third Parties: other companies in the Engage Video Group of companies who will perform analysis and/or improvement of the Services and our internal tools and processes;
Content Creation Contractors: for purposes of creating more relevant, more impactful content services, we may share your data with our Content Creation Contractors, which is a group of companies and individuals who have been carefully curated and vetted by us and who are contractually bound by Engage Video Group’s policies and procedures which align with all current legislation around data privacy;
Service Providers: service providers who provide IT, hosting and systems administration services;
Authorities: tax authorities, regulators and other authorities if required;
Joint Venture Parties: if our organisation enters into a joint venture with or is sold to or merged with another organisation, your information may be disclosed to our new business partners or owners; and
Analytics and Search Engine Providers: such parties assist us in the improvement of our website and systems.
7.2. We require all third parties to respect the security of your Public Social Data and to treat it in accordance with Data Protection Legislation. If any third-party processes any of your data, we ensure there are sufficient contractual and operational safeguards protecting your data.
8 TRANSFERS OUTSIDE THE EEA
8.1. Other companies comprised within Engage Video Group may access and process data (which may include personal data) inside the Engage Video Group channels and platforms in order to deliver our Services. At all times, our data remains in our data centre which is based is stored within the Google Suite of applications and the Google Cloud.
8.2. Customers based outside the European Economic Area (EEA) may access your Public Social Data in the context of the Services we provide, but your data remains on our system, and is only accessible through our secure platform or app.
8.3. In the event of us transferring your Public Social Data out of the EEA, we ensure a similar degree of protection is afforded to such data by implementing appropriate safeguards as required under Data Protection Legislation.
9 HOW LONG WE WILL KEEP YOUR INFORMATION
9.1. We review our data retention periods regularly and will only hold your Public Social Data for as long as is necessary for the relevant activity, or as required by law (we may be legally required to hold some types of information). However, if you request that we delete your data, we will delete your data from our systems, provided it is not in contravention of any laws or current legislation.
9.2. Details of retention periods for different aspects of your personal information are available in our retention policy, which is available by contacting us using the details provided below. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your Public Social Data, the purposes for which we process your Public Social Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
10 YOUR RIGHTS
10.1. Under Data Protection Legislation, you have the following rights in connection with your Public Social Data, which can be exercised in certain circumstances:
• Request access to your personal information (commonly known as a “data subject access request”). This
enables you to receive a copy of the personal information we hold about you and to check we are lawfully
• Request correction of the personal information that we hold about you. This enables you to have any incomplete
or inaccurate information we hold about you corrected;
• Request erasure of your personal information. This enables you to ask us to delete or remove personal
information where there is no good reason for us continuing to process it. You also have the right to ask us to
delete or remove your personal information where you have exercised your right to object to processing (see
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a
third party). You also have the right to object where we are processing your personal information for direct
• Request the restriction of processing of your personal information. This enables you to ask us to suspend
the processing of personal information about you, for example if you want us to establish its accuracy or the
reason for processing it;
• Request the transfer of your personal information to another party. We will provide to you, or a third party you
have chosen, your Public Social Data in a structured, commonly used, machine-readable format; and
• Withdraw your consent where we are relying on consent to process your Public Social Data. However, this will
not affect the lawfulness of any processing carried out before you withdraw your consent.
10.2. If you would like to exercise any of your rights above, please contact us at and provide us with your full details (including name, telephone number, address and email and the precise nature of your request and/or grievance).
10.3. You also have the right to make a complaint at any time to the supervisory authority for data protection issues in the Member State where you live, where you work or where the issue took place, relating to our use of your information.
12 CONTACT US
12.1. We have appointed Hayley Murison as our data protection representative, who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below:
Data Protection Representative: Hayley Murison – Operations Manager
Engage Video Group
21 Dreyer Street