Privacy Policy

1. Introduction

1.1. Doing it Together (“DIT”) acknowledges and supports consumer rights and the right to privacy. Accordingly, our customers’ privacy and trust are extremely important to us. We will ensure that personal information (“information”) is collected and handled in a transparent and lawful manner in alignment with the Protection of Personal Information Act, 2013 (“POPIA”). DIT promises to:

Implement reasonable computer (logical), physical and procedural (process) safeguards to protect the security and confidentiality of the information we collect
Limit the information collected to the minimum required to provide a better services and/or product or meet our other goals• To permit only properly trained, authorised employees to access information
Not disclose your information to external parties unless we are required or permitted by law to do so, and authorised by our Information Officer.

1.2. Purpose

1.2.1. DIT offers a wide range of products and services, including but not limited to food and beverage services, delivery and distribution, a subscription programme, and value-added services. This Statement explains how we use the information we collect from you when you use our products and/or services and by using our products and/or services and/or by providing information to us you agree to the information being processed as set out in this Statement. This Statement also:

sets out the types of information that we collect;
explains how and why we collect and use your information;
explains whom we share your information with; and
explains the rights and choices you have when it comes to your information
explains how to contact us or the relevant authorities

1.2.2. Some parts of our business may need to collect and use personal information to provide you with their products and services. In most cases they will refer to this Statement, but you must also read their specific terms and conditions. The DIT website may contain links to websites operated by other organisations that have their own privacy policies. Please make sure you read their terms and conditions and privacy policies carefully before providing any personal information on other websites as we do not accept any responsibility or liability for other organisations. We provide these links merely for your convenience. We have no control over, do not review, and are not responsible for third party sites, their content, or any goods or services available through these sites.

1.3. Legislation and Regulations

1.3.1. This Statement is subject to the laws of the Republic of South Africa in particular POPIA and the Consumer Protection Act, 2008 (“CPA”) as well as other relevant data protection legislation. Any dispute arising will, to the extent permitted by law, first attempted to be settled internally and if this is not possible be referred to arbitration in Cape Town at a venue to be determined by us applying the Uniform Rules of the High Court of South Africa.

2. Information Collection

2.1.1.To register or make an account with the DIT E-commerce website for online shopping you are required to provide us with your personal information including but not limited to your South African ID number or passport number (for non-South African citizens), name, surname, contact information and other personal details.

2.1.2. You may provide personal information to us either directly or indirectly (through a person acting on your behalf), by completing an application form for our products and services or requesting further information about our products and services, whether in writing, through our website, over the telephone or any other means.

2.1.3. We only collect information that is reasonably necessary for our business functions and activities and related purposes. The type of information we collect and hold, will depend on the purpose for which it is collected and used. Where possible, we will inform you what information you are required to provide to us and what information is optional. The information we process is typically to provide you with the goods and services you want to buy and help you with any orders and refunds you may ask for, to manage and improve our day-to-day operations, to manage and improve our customer service, websites and mobile platforms with the aim of improving your customer experience.

2.1.4 We may also collect your personal information from a person acting on your behalf, any regulator, or other third party that may hold such information.

2.1.5 You agree to give accurate and current information about yourself to DIT and to maintain and update such information when necessary. To improve the accuracy of our data and get to know our customers better, we may enrich it from other third parties, including credit bureaus.

2.2. Persons under 18 years

2.2.1. DIT will not knowingly collect any information of persons (minors) under the age of 18 years. Our website and social media platforms, products and services are all directed to people who are at least 18 years old or older.

2.2.2. If you are under the age of 18 years, you must not provide any information to DIT without the consent of your parent or guardian. If you become aware that a minor has provided their personal information without parental consent, please contact us immediately. If we become aware that a minor has provided us with personal information without parental consent, we will take steps to remove the data and cancel the child's account.

2.3. Your Account

2.3.1. When signing up for DIT services you are required to create a user account. You agree that you will provide accurate information to us and keep it updated, and that you will not create a false identity or an account for anyone other than yourself. It is your responsibility to safeguard your account’s username and password. This includes that you make use of a strong password and that you do not intentionally or unintentionally divulge it to anybody else. In the event of someone else using your username and password to make changes to your account or transact on your behalf, you will be held responsible for the changes and the outcome thereof.

3. Purpose and Use of Information

3.1. DIT uses your information for the purposes for which it was collected or agreed with you to facilitate the provision of our products and services to you, and for purposes which are within reasonable expectations and where permitted by law.

3.2. Examples of information collected from you or other sources and processed by DIT are detailed below (which is not an exhaustive list) and linked to the purpose thereof.

ID number / passport number (which you consent we may collect from credit bureaus and/or other aggregators) - to identify you as a unique person on our database as for us to validate who you are when you want to change your profile details or resolve queries related to your account and transactions. We also use this to inform segmentation analytics to provide benefits including targeted birthday, pensioner or other life stagerelevant offers. We are also required to process this information where required by law or to facilitate the registration of an external service or product you have signed up for.
Unique Identifiers – we may collect other unique identifiers such as your account or other numbers, for the purpose of sharing them with other entities in our group and business partners to do data matching if we are legally permitted to do so. We may also collect unique identifiers such as user IDs and passwords.
Contact information - to facilitate essential support, communications as well as better customise our offering to you, including:
- In support of facilitating required activities for services and programs you have chosen to participate in i.e.: OTPs, invoices, statements, deliveries, etc;
- Send information regarding services and programs via direct marketing i.e. new benefits, clubs or partners as well as inform you of promotions or deals;
- Process the delivery or return of products from or to our stores
- Send information regarding services and programs via direct marketing i.e. new benefits, clubs or partners as well as inform you of promotions or deals;
- Send or serve you targeted advertising across social media, other digital media platforms and physical post;
- Contact you where you may have won a competition / draw that you have entered;
- Request your feedback and opinion in the form of surveys, opinion polls or focus groups, should you wish to participate;
- Contact you in relation to Customer Careline feedback, custom complaints or other feedback you wish to give us where you agree to us contacting you.
Any additional information relating to you that you provide to us directly through the website, mobile apps or indirectly through use of thereof, offline or online, through our representatives or otherwise.
About your computer – collect statistical data such as IP address, operating system and browser type including browser actions and patterns to present content in the most effective manner.
Inform segmentation or analysis based on your transaction history for use by our internal commercial team as well as vendors/suppliers and business partners to serve relevant content or offers. We may do this for use and disclosure of the de-identified or pseudonymised information to determine preferences and shopping patterns.
We may also disclose detailed information with our business partners to assist them in marketing products and services as governed by this Statement and the related service’s specific terms and conditions as well as the business partner’s Privacy Policy, Notice or Statements.
Share information with 3rd (third) parties as an outsourced function, with the purpose of communicating to you and/or facilitate (operate) the subscribed service(s).

3.3. We may also use your information for the following reasons:

Complying with statutory and regulatory requirements in respect of the storage and maintenance of documents and information;
Providing customer service and assessing customer complaints;
Detecting and preventing fraud and money laundering and/or in the interest of security and crime prevention;
Assisting in law enforcement, fraud investigations, anti-money laundering and counterterrorist financing initiatives;
Providing you with the services, products or offerings you have requested, and notifying you about important changes to these services, products or offerings;
Managing your account or relationship and complying with your instructions or requests; • Operational, marketing, auditing, legal and record keeping requirements;
Conducting market research and providing you with information about DIT’s products or services from time to time via email, telephone or other means (for example, events);
Where you have unsubscribed from certain direct marketing communications, ensuring that we do not sent such direct marketing to you again;
Disclosing your personal information to third parties like manufactures, promotion sponsors and Brand owners (in which case we will have agreements in place to secure the confidentiality of Your Personal Information) for reasons set out in this Statement or where it is not unlawful to do so;
Monitoring, keeping record of and having access to all forms of correspondence or communications received by or sent from DIT or any of its employees, agents or contractors, including monitoring, recording and using as evidence all telephone communications between you and DIT;
Improving or evaluating the effectiveness of DIT’s business or products, services or offerings.

4. Direct Marketing and Opting Out

4.1. If you are an existing customer, we may communicate with you based on the preferences as selected by you in relation to products or services you have signed up for. This may include making contact via telephone, email, social media and other channels about products and or services which may be if interest to you. If you are not considered to be a customer, we will obtain your consent to opt-in to direct marketing.

4.2. You may opt-out (free of charge) from receiving future promotional information or direct marketing from DIT by either unsubscribing to the specific communications you receive by replying to the email, where one of our customer service representatives will assist you in the unsubsciption of these communications.

5. Retention and Destruction of Information

5.1. Information that DIT collects is kept in a form which permits your identification for no longer than is necessary to honour your choices, to fulfil the purposes for which it was collected and processed in each specific case, and in any case not longer than as specified by the relevant applicable laws unless we have your consent to process it indefinitely.

5.2. DIT will retain your information after you have closed your account where reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our agreement, or fulfil your request to “unsubscribe” from further messages from us.

5.3. We may retain de-identified, anonymised or pseudonymised information after your account has been closed using techniques that do not permit your re-identification. If none of the afore-mentioned scenarios are required, DIT will permanently delete (electronic) and shred (paper) after the purpose of collection the information has expired.

6. Information Preservation and Protection

6.1. DIT will take reasonable steps to protect the information we collect, hold and process from misuse, loss and from unauthorised access, modification or disclosure. We hold information both at our own premises and with the assistance of our service providers.

6.2. This is based on the information security principles of Confidentiality, Integrity,

Availability and Privacy (CIAP) as governed by our Information Security Policy. This sets out DIT’s objectives and general approach to information security, which aims to protect DIT’s business information and safeguard any personally identifiable information within our custody.

6.3. Because no data transmission over the internet is completely secure, and no IT system of physical or electronic security is impenetrable, we cannot guarantee the security of the information you send to us or the security of our servers or databases. Having noted that, we do take every reasonable step within our control, to protect your information and preserve the accuracy thereof. Quality of information means that the information we use must be appropriate, complete and reliable. The higher data quality we maintain, the better service we can render.

7. Information Disclosure

7.1. Notwithstanding anything to the contrary in this Statement, DIT reserve the right to disclose any information about you if we are required to do so by law, and if we believe that such action is necessary to: (a) fulfil a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our website, or other users; or (d) in an emergency to protect the health and safety of our website’s users or the general public.

7.2. Authorised DIT employees will have access to some or all your information. We may also disclose your information within our group of companies. Such data sharing is governed by our CIAP information security principles and associated practices.

7.3. We do use service providers to provide our services and maintain our systems, including but not limited to maintenance, security, analysis, audit, payments, customer service, marketing and system development. These parties will have access to your information as reasonably necessary to perform these tasks on our behalf (namely role-based access). Where we contract with service providers, and wherever possible, we impose contractual obligations on them to ensure that your information is handled and secured in accordance with law and industry good practise.

7.4. Unless you have explicitly consented to this, we will never sell your personal information.

8. Information Breach Notification

8.1. A security compromise or information breach can be described as a threat to the Confidentiality, Integrity, Availability or Privacy of IT systems and/or information. Such incidents are governed by the DIT Security Incident Response process which allows us to deal with the compromise/breach and/or loss in an efficient and effective manner. One of the key pillars of this process is keeping all impacted stakeholders informed and updated.

8.2. When there are reasonable grounds to believe that your information has been accessed, altered, deleted or acquired by any unauthorised person, we will notify the Information Regulator and yourself in cases where your identity can be established. This notification will be done in accordance with the provisions of POPIA and as soon as reasonably possible after the discovery of the compromise, considering the legitimate needs of law enforcement or any measures reasonably necessary to determine the scope of the compromise and to restore the integrity of our systems.

9. Amendment of this Statement

9.1. We may amend this Statement from time to time for any of the following reasons:

To provide for the introduction of new systems, methods of operation, services, products, property offerings or facilities;
To comply with changes to any legal or regulatory requirement;
To ensure that this Statement is clearer and more favourable to you;
To rectify any mistake that may be discovered from time to time; and/or
For any other reason which DIT, in its sole discretion, may deem reasonable or necessary.

9.2. Any such amendment will come into effect and become part of any agreement you have with DIT when Statement is given to you of the change by publication on our website. It is your responsibility to check the website often.

Cookies Policy

This Cookies Policy outlines the details you need to know about what information Doing it Together (“DIT”) collect using cookies and your consent regarding the accumulation of information.

1. Importance of a Cookies Policy

1.1. Our Cookies Policy is important because:

It harnesses a relationship of trust between DIT and you;
It allows you to be selective about the what information you leave behind;
It ensures that privacy legislation is not encroached upon; and
It assures you that your personal information is not used for malicious gain by us or any of our third-parties of social media partners.

What are cookies and why do we use them?
1. DIT might use cookies and other techniques such as web beacons when you visit our websites. “Cookies” are small text files used by us to recognise repeat users, facilitate your on-going access to and use of our websites and allow us to track your usage behaviour and compile aggregated data that will allow us to improve the functionality of our websites and content. “Web beacons” are small, clear picture files used to follow your movements on our websites. For example, storing your preferred settings for the next time you visit.

The information DIT collect from cookies enables us to:
- Tailor our websites to your personal needs;
- Remember the notifications that you have been shown, so that you are not shown them again;
- Help us link your browsing information to you and your personal information, for example, when you choose to register for a service;
- Make improvements and updates to our websites based on the way you want to use them; and
The type of information collected by cookies is not used to personally identify you.

What kind of cookies do we use?

We use the following categories of cookies:

3.1. Category 1: Necessary Cookies

Necessary cookies enable you to use our websites and all its features, such as maintaining an anonymous session while visiting the website and enabling access to secure areas of our websites. Without these cookies you may not be able to use all the features of our websites.

3.2. Category 2: Performance or Analytic Cookies

Performance cookies collect information about how you use our websites so we can maintain availability and continuously improve performance. For example, they collect information on which pages you visit most often and any error messages you may get i.e. the overall user experience. The information collected by these cookies is anonymous. They do not collect any information that can identify you personally.

3.3. Category 3: Functionality Cookies

Functionality cookies enable us to provide you with a more personalised experience. They help us to remember data, such as your username and language preference, to save you having to enter them again the next time you visit. The information these cookies collect is anonymous. They cannot track your browsing activity on other websites.

3.4. Category 4: Targeting or Advertising Cookies

DIT and our service providers may use advertising cookies to deliver ads that we believe are relevant to you and your interests. For example, we may use targeting or advertising cookies to customise the advertising and content you receive on our websites, to limit the number of times you see the same advertisement on our websites and to help measure the effectiveness of our advertising campaigns.

3.5. Category 5: Third Party Cookies

Our websites use third party cookies from social network sites such as Google, Facebook, Twitter and LinkedIn to enable in-depth campaign reporting and to track social network users when they visit our websites, by using a tagging mechanism provided by those social networks. These cookies can also be used for event tracking and re-marketing purposes. Any data collected with these tags will be used in accordance with our Privacy Statement and with the social network's privacy policies. Our websites will not collect or store any personally identifiable information from the user.

How can you manage your cookie settings?
1. To ensure you get the best possible experience when visiting our websites, DIT recommend that you accept cookies. However, you can opt-out of each cookie category (except strictly necessary cookies) by clicking on the “cookie settings” button or disable cookies in your web browser.

To learn about how to control cookies, visit https://www.aboutcookies.org/how-tocontrol-cookies/.

To learn about how to remove cookies, visit https://www.aboutcookies.org/how-todelete-cookies/.

Cookies may, however, be necessary to provide you with certain features available on our website. If you disable such cookies you may not be able to use some website features, and your access to our website may be limited.

5. Security of Cookies

5.1. Cookies do not act maliciously on computer systems. They cannot be used to spread malware or viruses nor access your hard drive. This does not mean that cookies are not relevant to your privacy and anonymity on the Internet.