Privacy Policy

Privacy Policy

1. Introduction

1.1 Twisted Light is an electronic signature system owned and operated by ZonkeTech (Pty) Ltd ("ZonkeTech", "us", "we" or "our"), which can be accessed online at

1.2 We are committed to protecting and respecting your privacy.  We strive to ensure that our use of your Personal Information is lawful, reasonable, and relevant to our business activities, with the ultimate goal of improving our services and your experience.  To better protect your privacy, we provide this Privacy Policy explaining our online information practices and the choices you can make about the way your Personal Information is collected and used.  To make this Privacy Policy easy to find, we make it available on our homepage and at every point where Personal Information may be requested.

1.3 This Privacy Policy describes how we will treat your Personal Information, whether provided by you to us, or collected by us through other means when you engage with us, in your ordinary use of our products and services including in accessing our website (the “Website").

1.4 We have appointed an Information Officer who is responsible for overseeing questions in relation to the Privacy Policy.  You may contact our Information Officer at [Insert] to discuss this Privacy Policy or your rights under data protection laws that are applicable to you.

1.5 This Privacy Policy applies to

1.5.1 us, and our successors-in-title; and

1.5.2 you, namely a user who accesses the Website, regardless of the device which you use to access it ("AccessDevice").

1.6 This Privacy Policy does not apply to other parties' websites, products or services, such as websites linked to, from or advertised on the Website.

1.7 To the extent that this Privacy Policy refers to definitions or provisions in the Twisted Light Terms and Conditions of Use that apply to the use of the Website (the "Terms"), they are hereby incorporated in this Privacy Policy by reference.

2. Your consent to the Processing of your Personal Information

2.1 We may collect, get, receive, record, organize, collate, store, update, change, retrieve, read, process, use and share your Personal Information in the ways set out in this Privacy Policy.  When we do one or more of these actions with your Personal Information, we are "Processing" your Personal Information (and "process" has a corresponding meaning).

2.2 If you are concerned about any aspect of this Privacy Policy as it relates to your Personal Information, please do not continue to engage with us or use our Website.

2.3 We may, where permitted or required to do so by applicable law, process your Personal Information without your knowledge or permission if sufficient grounds of justification are present, and we will do so in accordance with the further provisions of this Privacy Policy.

3. What is Personal Information?

3.1 "Personal Information" refers to private information about an identifiable living natural person or, where applicable, an identifiable existing juristic person.  Personal Information does not include information that does not identify you (including in instances where that information has been deidentified so that it does not identify a person).  The Personal Information that we collect about you may differ on the basis of your engagement with us or the products and services that you receive from us.

1.1 We may process various types of Personal Information about you, as follows: 

1.1.1 Identity Information, which includes information concerning your name, username or similar identifier, signature, marital status, title, occupation, interests, date of birth, gender, race and legal status, as well as copies of your identity documents, photographs, identity number and registration number;

1.1.2 Contact Information, which includes your billing addresses, delivery addresses, e-mail addresses and telephone numbers;

1.1.3 Device and Device event information, which includes your IP address, unique device identifier, the nature of the Access Device which you used to access the Website (e.g. a tablet or smart phone, and which type thereof), the geographic location from which you accessed the Website (i.e. the geographic location of your Access Device), hardware model and settings, operating system type and version, browser language, system activity, crashes;

1.1.4 Financial Information, which includes bank account details;

1.1.5 Transaction Information, which includes details about payments made to or received from you and company information, which may consist of financial activity;

1.1.6 Technical Information, which includes your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Website, use our products and/or services or engage with us in any other way;

1.1.7 Usage Information, which includes information as to your access to and use of the Website, such as what links you went to, what content you accessed, the amount of content viewed and the order of that content, as well as the amount of time spent on the specific content;

1.1.8 Location Information, which includes geographical information from your Access Device (which is usually based on the GPS or IP location); and

1.1.9 Marketing and Communications Information, which includes your preferences in respect of receiving marketing information from us and our third parties, and your communication preferences.

1.2 We may also process, collect, store and/or use aggregated data, which may include historical or statistical data ("Aggregated Data") for any purpose, including for research purposes.  Aggregated Data may be derived from your Personal Information but is not always considered Personal Information, as this data does not directly or indirectly reveal your identity.  However, if we combine or connect Aggregated Data with your Personal Information in a manner that has the result that it can directly or indirectly identify you, we will treat the combined data as Personal Information, which will be managed in accordance with this Privacy Policy.

2. How we collect your Personal Information

2.1 We collect your Personal Information in two ways, namely:

2.1.1 actively from you; and

2.1.2 passively from your Access Device when you use the Website and any of our products and/or services.

2.2. Active collection from you

2.2.1 We may require you to submit certain information in order for you to register for the Website or use our products and/or services.  We may collect Personal Information from you by asking you specific questions and by permitting you to communicate directly with us, for example via e-mail, feedback forms, site comments and forums.

2.2.2 If you contact us, we may keep a record of that correspondence.

2.2.3 The information we may actively collect from you may include your: identifying information (e.g. your name, surname, signature, photograph and employment information); contact details (e.g. e-mail address); and any other information which we may request from you from time to time.

2.3 Passive collection from your Access Device

2.3.1 We passively collect some of your Personal Information from the Access Device which you use to access and navigate through the Website, using various technological means, for instance, using server logs to collect and maintain log information.

2.3.2 The information which we may passively collect from your Access Device may include your identifying information, contact details, Access Device and Access Device event information, activity information, log information, telephony log information, location information and any other information which you permit us, from time to time, to passively collect from your Access Device.

3. How we use your Personal Information

3.1 We use the Personal Information we collect to provide, maintain, and improve the Website and our products and/or services, to develop new services, and to protect us, our services and our users.

3.2 We may use your Personal Information:

3.2.1 to retain and make information available on the Website;

3.2.2 to create your user account and ensure that it doesn’t duplicate an existing user account on the Website;

3.2.3 to maintain and update our customer, or potential customer, databases;

3.2.4 as a registered user, to send you notifications and authenticate your identity when you view and access the Website;

3.2.5 to diagnose and deal with technical issues and customer support queries and other user queries, such as problems with our server, determine the optimal and fastest route for your Access Device to use in connecting with the Website, and administer, maintain and secure the Website;

3.2.6 to detect, prevent or deal with actual or alleged fraud, security or the abuse, misuse or unauthorised use of the Website and/or contravention of this Privacy Policy;

3.2.7 to provide you with the latest information about the goods and services, provided you have agreed to receive such information;

3.2.8 to conduct market research surveys, product research and development;

3.2.9 to communicate with you;

3.2.10 to compile non-personal statistical information about browsing habits, click patterns and access to the Website;

3.2.11 to improve the Website, analyse trends and administer the Website, including requesting feedback on any information made available on or by means of the Website (the "Content") and our services, products, address any issues and liaise with users in that regard;

3.2.12 to keep a record of our communications with you and your communications with us;

3.2.13 to fulfil any contractual obligations we may have to you or to any third party;

3.2.14 to inform you about any changes to the Website, the Terms, this Privacy Policy or other changes which are relevant to you;

3.2.15 to compile and use statistical information about you and other users and their access to and use of the Website, browsing habits, click-patterns, preferences, and demographics which we may use to develop, provide and improve the Website, including, recommendations to users and tailoring information and Content for users;

3.2.16 to compile, use, disclose and trade with non-personal statistical information about our users and their access to and use of the Website, browsing habits, click-patterns, preferences, demographics which we may use to develop, provide and improve the Website and other products and/or services.  Please note that the information referred to in this clause 5.2.17 is aggregate information about our users which has de-identified users' Personal Information such that it cannot be linked back to identify you.  We will not disclose your identifiable Personal Information to anyone without your permission;

3.2.17 for security, administrative and legal purposes;

3.2.18 for customer relations; and

3.2.19 other activities not specifically mentioned which are lawful, reasonable, relevant to our business activities and the minimum necessary and adequate in order for us to provide the Website.

3.3 We will get your permission, or otherwise establish a clear lawful basis, before collecting or using your Personal Information for any other purpose.

4. Compulsory information and consequences of not sharing with us

Only your e-mail address, name and surname, contact details and such other information as we specify from time to time, constitutes compulsory information.  Device and Device event information, log information and unique application numbers, as detailed above, are automatically collected.  All other information is optional.  If you do not agree to share your compulsory information with us, then you will not be able to enjoy all the features and functionality on the Website.

5. Sharing of your Personal Information

5.1 We will not intentionally disclose, for commercial gain or otherwise, your Personal Information other than as set out in this Privacy Policy or with your permission.

5.2 You agree and consent that your Personal Information may be shared under the following circumstances:

5.2.1 to our agents, advisers, service providers and suppliers which have agreed to be bound by this Privacy Policy;

5.2.2 to our employees, suppliers, service providers and agents if and to the extent that they need to know that information in order to process it for us and/or to provide services for or to us, such as hosting, development and administration, technical support and other support services.  We will authorise any information processing done by a third party on our behalf, amongst other things by entering into written agreements with those third parties governing our relationship with them and containing confidentiality and non-disclosure provisions. Such persons may be disciplined, their contracts terminated or other appropriate action taken if they fail to meet their obligations;

5.2.3 in order to troubleshoot and correct reported technical problems.  All error and transaction logs are purged every 45 days;

5.2.4 in order to enforce or apply the Terms or any other contract between you and us;

5.2.5 in order to protect our rights, property or safety or that of our customers, employees, contractors, suppliers, service providers, agents and any other third party;

5.2.6 in order to mitigate any actual or reasonably perceived risk to us, our customers, employees, contractors, agents or any other third party;

5.2.7 to governmental agencies, exchanges and other regulatory or self-regulatory bodies if we are required to do so by law or if we reasonably believe that such action is necessary to: comply with the law or with any legal process; protect and defend the rights, property or safety of us, our affiliates or our customers, employees, contractors, suppliers, service providers, agents or any third party;

5.2.8 detect, prevent or deal with actual or alleged fraud, security or technical issues or the abuse, misuse or unauthorised use of the Website and/or contravention of this Privacy Policy;

5.2.9protect the rights, property or safety of members of the public (if you provide false or deceptive information about yourself or misrepresent yourself as being someone else, we may proactively disclose such information to the appropriate regulatory bodies and/or commercial entities).

5.3 We may use your Personal Information to compile profiles for statistical purposes.

5.3.1 We will get your permission before disclosing your Personal Information to any third party for any other purpose.

6. Storage and transfer of your Personal Information

6.1We store your Personal Information:

6.1.1 at on our cloud databases

6.1.2 on our servers;

6.1.3 on the premises and/or servers of our third party service providers, such as IT systems or document storage service providers.  In this event, we will ensure that we have entered into a written contract that require such third party service providers to secure the integrity and confidentiality of Personal Information in its possession by taking appropriate, reasonable technical and organisational measures.

6.2 We reserve the right to transfer to and/or store your Personal Information on servers in a jurisdiction other than where it was collected, and such jurisdiction may not have comparable data protection legislation.

6.3 If the location that Personal Information is transferred to does not have substantially similar laws which provide for the protection of Personal Information, we will take reasonably practicable steps to ensure that your Personal Information is adequately protected in that jurisdiction.

7. Security

7.1 We take reasonable technical and organisational measures to secure the integrity of retained information, using accepted technological standards to prevent unauthorised access to or disclosure of your Personal Information, and protect your Personal Information from misuse, loss, alteration or destruction.

7.2 From time to time, we review our information collection, storage and processing practices, including physical security measures, to keep up to date with good practice.

7.3 See clause 7.2.2 regarding measures to protect the information which is provided to employees, agents and contractors on a need-to-know basis.

7.4 We also create a back-up for operational and safety purposes.

7.5 We will promptly notify you if we become aware of any unauthorised use, disclosure or processing of your Personal Information.

7.6 Even by taking the above measures when Processing Personal Information, we do not guarantee that your Personal Information is 100% secure.  Subject to the provisions of this clause 9.6, as far as the law allows, we will not be liable for any loss, claim and/or damage arising from any unauthorised access, disclosure, misuse, loss, alteration or destruction of Personal Information.

8. Retention of your Personal Information

8.1 We retain all Personal Information which we collect from you unless there is a valid technical, legal or business reason for us to delete, destroy or de-identify it (“Retained Information”).

8.2 We may keep all Retained Information for as long as you continue to access the Website, Content or products and/or services for as long as reasonably necessary or until you contact us and ask us to destroy the retained information.

8.3 Notwithstanding clause 10.2 above and any other provision of this Privacy Policy, we may keep some or all of your Personal Information if and for as long as:

8.3.1 we are required or permitted by law, a code of conduct, or a contract with you to keep it;

8.3.2 we reasonably need it for lawful purposes related to our functions and activities;

8.3.3 we reasonably need it for evidentiary purposes; or

8.3.4 you agree to us keeping it for a specified further period.

9. Keeping your Personal Information updated and correct

9.1 Where required by law, we take reasonable steps to ensure that your Personal Information is accurate, complete, not misleading, and up to date.

9.2 We also acknowledge that you may have rights of access to, and the right to rectify, your Personal Information, and rights to object to the Processing of your Personal Information in certain circumstances.

9.3 You must let us know if any information we have about you is incorrect, incomplete, misleading or out of date, by notifying us at the contact details set out below.  If you have already registered on the Website, you can at a later stage modify some of the Personal Information you have included in your profile by logging in and recreating your profile with your updated Personal Information.

9.4 Where required by law, we will take reasonable steps to correct or update the relevant Personal Information accordingly having regard to the purpose for which the Personal Information was collected or used.

10. You give up your rights

Sometimes the law says that we have a duty to make you aware of some information or other matters, unless you agree that we do not need to do these things (this is called a waiver of rights).  In these cases, you agree that where the law requires us to make you aware of something (to inform or notify you) or to do something else, we do not have to do this.  Because you agree to this, we will not have this duty anymore and will not need to make you aware of the information or other matters.

11. Changes to this Privacy Policy

We may change this Privacy Policy from time to time.  If we do so, we will post the revised policy on the Website and take reasonably practicable steps to ensure that you are aware of the updated Privacy Policy (including, if we have your e mail address, e-mailing you notifications of the updated Privacy Policy).

12. Children

The Website is not targeted at children under the age of 18.  We will not knowingly collect information from persons in this age group without permission to do so.

13. Direct marketing

13.1 When you register on the Website, you may receive marketing communications from us.

13.2 You may refuse to accept, require us to discontinue, or pre-emptively block any approach or communications from us if that approach or communication is primarily for the purpose of direct marketing (“Direct Marketing Communications”).

13.3 You may opt out of receiving Direct Marketing Communications from us at any time by requesting us (in any manner, whether telephonically, electronically, in writing or in person) to desist from initiating any Direct Marketing Communications to you.

13.4 If you have opted out, we may send you written (which may include electronic writing) confirmation of receipt of your opt out request, and not send you any further Direct Marketing Communications.

14. Third party sites

14.1 To the extent allowed by law, we are not responsible for the privacy practices of a third party site to which there may be a link on the Website, or for any claims, loss or damage arising from these.

14.2 We advise you to read the privacy policy of each site which you visit and to determine your privacy settings in accordance with your personal preferences.

14.3 We are not liable if you suffer losses or damages when visiting third party websites by following a link to that website from the Website.  You accept that there may be risks when you use such third party websites, and you do so at your own risk.

15. Your rights

15.1 Data protection laws may confer certain rights on you in respect of your Personal Information.  We aim to be clear about what Personal Information we collect so that you can make meaningful choices about what Personal Information you make available to us.

15.2 Should you wish to exercise you rights or have any queries about your Personal information, please contact applicable.  You may, for example:

15.2.1 Block all cookies, by setting your browser to do so, including cookies associated with our products and services or to indicate when a cookie is being sent by us.

15.2.2 Request access to your Personal Information (commonly known as a “data subject access request”), which indicates what Personal Information we have about you.

15.2.3 Request the correction of your Personal Information, in order to ensure that any incomplete or inaccurate Personal Information is corrected.

15.2.4 Request erasure of your Personal Information, where there is no lawful basis for the retention or continued processing of it.

15.2.5 Object to the processing of your Personal Information for a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.

15.2.6 Request restriction of processing of your Personal Information.  This enables you to ask us to suspend the processing of your Personal Information in limited circumstances, which may differ by jurisdiction.

15.2.7 Withdraw consent which you previously gave to the processing of your Personal Information at any time.  You may withdraw your consent for us to process your Personal Information at any time.  The withdrawal of your consent can only be made by you on condition that such withdrawal of your consent: does not affect the processing of your Personal Information before the withdrawal of your consent; or does not affect the processing of your Personal Information if the processing is in compliance with an obligation imposed by law on us; or does not affect the processing of your Personal Information where such processing is necessary for the proper performance of a public law duty by a public body; or does not affect the processing of your Personal Information as required to finalize the performance of a contract in which you are a party; or does not affect the processing of your Personal Information as required to protect your legitimate interests or our own legitimate interests or the legitimate interests of a third party to whom the information is supplied.

15.2.8 Withdrawal of consent may limit our ability to provide certain products and services to you but will not affect the continued processing of your Personal Information in instances in which your consent is not required.

15.2.9 Institute civil proceedings regarding an alleged interference with the protection of your Personal Information processed in accordance with this Privacy Policy.

15.3 As far as the law allows, we may charge a fee for attending to any of the above requests and may also refuse to carry out any of your requests in whole or in part.

16. Consumer Protection Act, Protection of Personal Information Act and other laws

16.1 If this Privacy Policy or any provision in this Privacy Policy is regulated by or subject to the Consumer Protection Act, the Protection of Personal Information Act ("POPI") or other laws, it is not intended that any provision of this Privacy Policy contravenes any provision of the Consumer Protection Act, POPI or such other laws.  Therefore, all provisions of this Privacy Policy must be treated as being qualified, to the extent necessary, to ensure that the provisions of the Consumer Protection Act, POPI and such other laws are complied with.

16.2 No provision of this Privacy Policy:

16.2.1 does or purports to limit or exempt us from any liability (including, without limitation, for any loss directly or indirectly attributable to our gross negligence or wilful default or that of any other person acting for or controlled by us) to the extent that the law does not allow such a limitation or exemption;

16.2.2 requires you to assume risk or liability for the kind of liability or loss, to the extent that the law does not allow such an assumption of risk or liability; or

16.2.3 limits or excludes any warranties or obligations which are implied into this Privacy Policy by the Consumer Protection Act (to the extent applicable), POPI (to the extent applicable), or other applicable laws or which we give under the Consumer Protection Act (to the extent applicable), POPI (to the extent applicable), or other applicable laws, to the extent that the law does not allow them to be limited or excluded.

17. Governing law

17.1 South African law applies to this Privacy Policy.

17.2 If any provision of this Privacy Policy is judged to be illegal, void or unenforceable due to applicable law or by order of a court of a competent jurisdiction it shall be deemed deleted and the continuation in full force and effect of the remainder of the provisions will not be prejudiced.

18. Queries

If you have questions about our Privacy Policy, please contact us

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