At Flux Full Circle, your privacy is of utmost importance to us. We are committed to complying with data protection laws and best practices and ensuring the protection of your personal data.
This policy outlines which data we collect about you, why we collect it and how we process and utilise it. Throughout this policy, when we refer to “Flux Full Circle”, “we”, “us,” or “our,” it refers to Flux Full Circle Pty Ltd, registered in South Africa, with headquarters located at 27 Somerset Road, De Waterkant, Cape Town, South Africa, 8001.
By using any of our websites and online platforms, you agree to be bound by this policy. If you do not agree with any term of this policy, you must refrain from using Flux Full Circle’s websites. You can contact us at firstname.lastname@example.org if you would like more information about how we collect, utilise and secure the data we collect.
The personal data we collect from you will include information such as your name, country of residence, email address, telephone number, the company you work for, your job title, and date of birth. This information is used to contact you and provide you with initial information and quotations.
We process your personal data so that we can meet legal, compliance and regulatory obligations. We also process your personal data for crime prevention and detection purposes, including the prevention of fraud for online payments, identity verification, credit checking and scoring purposes, and accounting or audit purposes.
We collect personal data from third parties who have been authorised to provide your personal data. We also collect personal data from individuals who may refer you as someone who may be interested in our products or services. We ask these individuals to confirm that you would like to hear from us.
We collect different personal data depending on your payment method. For example, for credit card payments we may collect the credit cardholder name, address, card number, expiry date and CVC code.
We may post client testimonials and comments on our websites, which may contain personal information.
We use external service providers to assist us to process personal data for the specified purposes, and they may hold this personal data on their own servers for these purposes. For example, we may use analytics, advertising and remarketing service providers such as Google Analytics, Google AdWords, Google Tag Manager, Facebook Business Manager, LinkedIn Ads, Hotjar and Hubspot. We are not responsible for the privacy practices of these external third parties.
We may use personal data to communicate with you about our products and services. This may be based on your preferences, derived from Cookies or inferred from your interactions with us.
We also use social media and other digital websites to provide you with advertisements within those websites. We may provide them with your name and contact details (such as your email address or phone number). If these websites match the profile information we provide, with profile information that they hold, then they will serve you our advertisements. The social media websites will not identify you or share other personal data in your social media account with us.
We will only send you direct marketing in accordance with your marketing preferences. We may contact you via email, SMS/text, social media, or through other communication channels that we think you may find helpful. If at any time you would like us to stop sending you marketing material, contact us or choose the available “unsubscribe” options.
We use personal data such as your date of birth, gender, country of residence, transactions, information derived from Cookies and your preferences and behaviours for profiling. Some of the legitimate purposes we profile personal data include:
We will take steps to ensure that prior to profiling your personal data for a legitimate interest that your own interests or fundamental rights and freedoms do not override our legitimate interests.
We aggregate personal data and remove any identifying elements to analyse patterns and improve our marketing and promotional efforts, and to analyse website use, to improve our content, products and services, to customise website content, products and services, and to support our business operations.
We collect certain usage information like the number and frequency of visitors to our website. This information includes which website you were redirected from, which web pages you visit during your session, what browser you are using, your device ID and your IP address. This collective data helps us to determine how our customers use parts of our website and do research on our users’ demographics, interests, and behaviour to better understand them.
In our efforts to improve the quality of service we offer you, we may use your personal data to:
We will only collect, process, use, share and store your personal data where we are satisfied that we have an appropriate legal basis to do this. This may be because:
We do not share your personal data with companies, organisations or individuals outside of Flux Full Circle except in the following cases:
We may share your personal data when you have provided consent as described at the time of consent.
We may share your personal data with third parties, who help us manage our business and deliver our products and services. These third parties have agreed to confidentiality obligations. Any personal data we share with them or which they collect on our behalf is used solely for the purposes of providing the contracted service to us.
These third parties:
We may need to share certain reservation details with the payment service provider and the relevant financial institution to verify payments (such as banks and payment card companies). We may share information with relevant financial institutions if we consider it strictly necessary to detect fraudulent transactions and security incidents.
We may share personal data with governments, government organisations and agencies, border control agencies, regulators, law enforcement and others as permitted or required by law, in relation to API or such other legal requirements as they apply from time to time when travelling to or from a particular country, and to generally comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies.
We may share aggregated data (combined data of our website users or clients that no longer identifies or references an individual website user or client) and non-personally identifiable information for analysis, demographic profiling, marketing and advertising, and other business purposes.
To facilitate our operations, we might transfer information to companies or entities that are located in other countries that help us deliver or fulfil our service offerings. The purpose of this transfer will only be for the purposes described in this policy.
We have implemented and maintain appropriate technical and organisational security measures, policies and procedures designed to protect the personal data that you share with us and safeguard the privacy of such information. For example, the measures we take include:
In some circumstances, we may store your personal data for longer periods of time, for example, where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements. In specific circumstances, we may store your personal data for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or if we reasonably believe there is a prospect of litigation relating to your personal data or dealings.
We undertake to process your personal data in a reasonable manner and take appropriate, reasonable security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of your personal data. All data processing shall be carried out by employees, consultants or third-party service providers using computers and/or IT enabled tools, following standard organizational procedures and modes.
In some cases, personal and non-personal data may be accessible to certain types of persons involved with the operation of the websites (administration, sales, marketing, finance, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies to name a few) appointed, if necessary, by us as data processors.
How long we keep information we collect about you depends on the type of information. After such time, we will either delete or anonymize your information or, if this is not possible, we will securely store your information and isolate it from any further use until deletion is possible.
We retain Personal Information that you provide to us where we have an ongoing legitimate business need to do so (for example, as needed to comply with our legal obligations, resolve disputes and enforce our agreements).
When we have no ongoing legitimate business need to process your Personal Information, we securely delete the information or anonymise it or, if this is not possible, securely store your Personal Information and isolate it from any further processing until deletion is possible. We will delete this information at an earlier date if you so request.
If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services. We retain information derived from Cookies and other tracking technologies for a reasonable period of time from the date such information was created.
For children younger than 16 years old, the use of our services is only permitted with the lawful consent of a parent or a guardian.
Our website is not intended for or targeted at children under 16, and we do not knowingly or intentionally collect personal information about children under 16. If you believe we have collected information about a child under 16, please contact us, so that we may delete the information.
We reserve the right to erase all personal data of any child under 16 years old if we become aware that the data was provided to us without the lawful consent of a parent or a guardian.
A “Cookie” is a small computer file that is downloaded to your device. It collects information as to how you navigate our websites. Cookies cannot harm your computer in any way and are an industry standard. They are small text files that contain only information provided by you, the visitor, to the website. Furthermore, our users may configure their browsers to not accept our cookies.
Cookies may collect personal data about you. Cookies help us remember information about your visit to our website and other settings and searches. Cookies enable us to understand who has seen which web pages and how frequently, and to determine which are the most popular areas of our website. They can also help us to operate our website more efficiently and customise your view of the website to reflect your preferences and activities. They also help us tailor our marketing and advertisements to you on our website, other websites you visit, social media websites and other devices.
You have certain rights in relation to your personal data. In order to exercise your rights, we may ask you for additional information to confirm your identity and for security purposes, in particular before disclosing personal data to you.
You can exercise your rights by emailing us at email@example.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request within the amount of time prescribed by the applicable data protection laws and regulations or inform you if we require further information in order to fulfil your request.
We may not always be able to fully address your request, for example, if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
You have the right to be given reasonable access to your personal data. You may also have the right to request copies of personal data that you have provided to us in a structured, commonly used, and machine-readable format.
You have a right to request that we rectify inaccurate personal data. We may seek to verify the accuracy of the personal data before rectifying it.
If you no longer want us to use your information, you can also request that we erase your personal data in limited circumstances where:
We are not required to comply with your request to erase personal data if the processing of your personal data is necessary:
Please note that if you request the erasure of your personal data:
You can object to any processing of your personal data, which has our legitimate interests as its legal basis if you believe your fundamental rights and freedoms outweigh our legitimate interests.
If you think that we have not complied with data protection laws, you have the right to lodge a complaint with your local supervisory authority.
Data Protection & Information Officer: Stuart Lewis
Deputy Information Officer: Taahir Isaacs
South African citizens can access our Promotion of Access to Information (PAIA) manual here, which outlines in detail how you can get access to the information we have in relation to you.
Last Updated: 22 June 2021