Acknowledgment: By registering for or using the App, you acknowledge that you have read, understood, and agree to these Terms, as well as our Privacy Notice (set forth in Part B), which explains how we collect and handle your personal information.

Voluntary Use: Use of the App is voluntary and intended solely for employment-related engagement and communication purposes. Access to certain features and content may be restricted to specific employee groups or roles, as determined by the Company. You understand that the App is designed to facilitate workplace communication and enhance your employment experience.

Modification of Terms: We reserve the right to update or modify these Terms at any time. Continued use of the App following any updates signifies your acceptance of the revised Terms. It is your responsibility to review these Terms periodically for changes. Any changes will be effective immediately upon posting within the App or through other official communication channels.

Eligibility: The App is provided exclusively to individuals within the Company’s workforce, including employees, contractors, and affiliates authorised by the Company. You represent that you meet the eligibility criteria at the time of registration.

Registration: To access the App, you may be required to register by providing personal data, including your employee number and date of birth, and other employment-related details (i.e email address). You agree to provide accurate and complete information during the registration process, which is essential for effective communication and support.

Accuracy of Information: You agree that all registration information is accurate and up to date. Providing outdated or incorrect information may affect your ability to receive timely and relevant communications. The Company reserves the right to suspend or terminate your access if we suspect that you have provided false or misleading information. You are responsible for keeping your account information current.

Account Security: You are responsible for maintaining the confidentiality of your login credentials. You agree to notify us immediately of any unauthorised access or suspected misuse of your account. The Company is not liable for any loss or damage arising from your failure to comply with this obligation. You should take reasonable steps to ensure your account remains secure, including using strong passwords and logging out after each session.

Permissible Use: You may use the App solely for workforce engagement and communication purposes related to your role within the Company. Unlawful or unauthorised uses are strictly prohibited, including but not limited to:

Monitoring: The Company may monitor your use of the App to ensure compliance with these Terms and to improve service quality and functionality. Monitoring is conducted in accordance with our Privacy Notice and applicable data protection laws. You acknowledge that your use of the App may be subject to monitoring and that any non-compliance may result in corrective actions, including termination of access.

Personal Data: We collect, store, and process your personal data as outlined in our Privacy Notice. Your use of the App indicates consent to the collection, processing, and transfer of your personal data for workforce engagement and communication purposes. This may include your interactions within the App and any information you provide during your use.

Data Security: While we strive to protect your personal data using industry-standard security measures, please note that no system is entirely secure. You agree to report any security issues to the Company’s data protection team promptly. We will take all reasonable measures to address any reported vulnerabilities. It is important for you to also take precautions, such as using secure passwords and logging out after use.

Data Sharing with Third-Party Vendor: Your personal data may also be accessible to the third-party vendor of the App, Wyzetalk (Proprietary) Limited (dpo@wyzetalk.com). Their role includes hosting the personal data you provide to us and conducting necessary activities related to the App’s administration and management, such as:

The Vendor processes data in compliance with our instructions and applicable data protection laws. The Company ensures that any third parties involved in data processing maintain the same level of protection as required under applicable laws.

Ownership: All content, software, and technology used to create and operate the App are owned by or licensed to the Company or the Vendor, and are protected by copyright, trademark, and other intellectual property laws. Unauthorised use of any intellectual property is strictly prohibited. You agree not to remove any copyright notices or other proprietary rights notices from the App.

License: The Company (through its Vendor) grants you a limited, non-exclusive, non-transferable license to use the App solely for workforce engagement purposes during your employment or affiliation with the Company. This license is subject to compliance with these Terms.

Restrictions: You may not modify, copy, distribute, or create derivative works from any part of the App without the Vendor’s prior written consent. You may not reverse engineer, decompile, or disassemble the App. Any unauthorised use may result in termination of your access and legal action.

Disclaimer: The App is provided on an "as-is" and "as-available" basis. We do not guarantee that the App will meet all your requirements or be uninterrupted or error-free. You acknowledge that the use of the App may be subject to limitations and that we may modify or discontinue features at any time without prior notice.

Limitation of Liability: To the maximum extent permitted by law, the Company is not liable for any indirect, incidental, special, or consequential damages resulting from your use of or inability to use the App, including but not limited to loss of data, goodwill, or other intangible losses. This limitation applies whether the claims arise from breach of contract, damages, or any other legal theory.

Aggregate Liability: The Company’s total liability to you for all claims arising out of your use of the App will not exceed the amount paid, if any, to access or use the App. This limitation of liability is intended to allocate risk between you and the Company.

Data Retention: Personal data processed through the App is retained for the duration of your employment or affiliation with the Company, or as otherwise required by law. Data related to health and wellbeing initiatives may be retained for limited periods, as described in our Privacy Notice. The retention period will be determined based on the purpose of processing and legal requirements.

Data Processing: Your personal data may be processed to enable workforce engagement activities and other related Company initiatives. Please refer to our Privacy Notice for additional details on data processing, including the purposes for which your data is collected and how it is used.

Termination by Company: The Company reserves the right to suspend or terminate your access to the App for any violation of these Terms or for misuse that compromises the security, privacy, or efficiency of the App. Termination may occur without prior notice in cases of serious misconduct.

Effect of Termination: Upon termination of access, your personal data may be retained or deleted as specified in our Privacy Notice and applicable data retention policies. You will not have access to the App or any content contained therein after termination. Any ongoing obligations regarding confidentiality and intellectual property will survive termination.

Use of Automated Processes: Certain features within the App may utilise automated decision-making to enhance workforce engagement. You will be notified if such processing affects your data rights, and you may opt-out of certain automated decision processes where applicable. We strive to ensure that any automated processes are fair and transparent.

Data Transfers: As part of the App’s operation, your personal data may be transferred to or processed in countries outside of South Africa. All cross-border data transfers are conducted in compliance with applicable data protection laws to ensure that your information is adequately protected.

Safeguards: The Company ensures appropriate safeguards, such as standard contractual clauses, are in place for any international transfers of your personal data. We assess the legal frameworks of countries receiving data to ensure compliance with POPIA and other applicable regulations.

Access and Rectification: You have the right to access and correct your personal data processed by the Company. Requests for access or correction can be submitted to our data protection team and/or HR team by email, who will respond within a reasonable timeframe.

Data Restriction and Deletion: You may request restriction or deletion of certain data, as outlined in our Privacy Notice, where legally permitted. We will comply with your request unless we are required to retain the data for legal or contractual reasons.

Objection to Processing: You have the right to object to certain types of data processing. We may continue processing if we demonstrate a legitimate business need that overrides your objection or if necessary for legal claims. You will be informed of your rights regarding objection at the time of data collection.

Lodging a Complaint: You may submit complaints related to data processing to the appropriate regulatory authority if you believe your rights have been infringed. We encourage you to first contact our data protection team and/or HR team to address any concerns directly.

Modifications: The Company may revise these Terms periodically. Significant updates will be communicated via the App or other official Company channels. Continued use of the App indicates acceptance of any modified Terms. You are encouraged to check for updates regularly.

Review and Compliance: We encourage you to review these Terms regularly to remain informed about your responsibilities and rights as a User. It is your responsibility to remain aware of any changes that may affect your use of the App.

Scope and Purpose: This Privacy Statement applies to all users of ItalConnect (the “App” or “Service”), a workforce engagement solution provided by the Company. It serves to inform you about how we collect, use, protect, and disclose your personal information. This document is intended to be clear and straightforward, enabling you to understand our practices and your rights regarding your personal data.

Acceptance of Terms: By accessing or using the App, you confirm that you have read, understood, and agreed to the terms outlined in this Privacy Statement. If you have any questions, require clarification, or need this Privacy Statement in an alternative format, please do not hesitate to contact our Information Officer and/or HR Officer.

Voluntary Use and Right to Withdraw: The use of the App is entirely voluntary. If you do not agree with the terms outlined in this Privacy Statement, we encourage you to discontinue use immediately. You may also contact us for assistance with any data-related requests, including the deletion of your information or withdrawal of consent where applicable.

Account Information: We collect personal information necessary to create and maintain your user account within the App. This information includes, but is not limited to:

Employment Information: When utilising the App in a work-related context, we may collect additional information relevant to your employment role. This includes:

Optional Information: Through specific features of the App, you may voluntarily provide additional personal information, which can include:

Health Information: In certain limited circumstances, we may collect health-related information, especially for safety and compliance purposes. This may include:

Direct Collection: The majority of personal information is collected directly from you at the time of registration or through your interactions with the App. This includes information you provide in registration forms, updates to your profile, and during the use of the App’s features.

Automatic Collection: The App may automatically collect certain technical information about your device and usage. This may include:

Cookies and Tracking Technologies: We may use cookies and similar tracking technologies to collect additional information about your interactions with the App. Cookies are small data files placed on your device that help us improve your user experience. You can manage cookie preferences through your browser settings.

Providing the App: We process your personal information primarily to authenticate accounts, facilitate communication, and support workforce engagement activities. Specific uses include:

Compliance with Legal Obligations: Certain processing activities are necessary for us to comply with applicable laws, regulations, or industry standards. This includes:

Legitimate Interests: We process your personal information based on our legitimate interests, which include:

Consent: In instances where specific types of data require your explicit consent (such as health data), we will seek your permission before processing your information. You have the right to withdraw your consent at any time, and we will respect your decision and shall where required destroy any such personal information.

Customisation and Personalisation: We may utilise automated decision-making processes to personalise your experience within the App. This could include:

User Notification: Any significant automated processing that could materially affect you will be communicated clearly. This includes information about how automated decisions are made and the logic behind them. Where applicable, opt-out options will be provided, allowing you to choose whether to participate in automated processes.

Retention Policy: We retain personal information only for as long as necessary to fulfil the purposes for which it was collected or as required by law. This means:

Employment-Related Data: Information collected in connection with your employment will be retained for the duration of your employment and thereafter for as long as legally required. This includes:

Internal Access Controls: Access to your personal information is restricted to designated Company personnel, such as HR and IT staff, who require this information to perform their job duties. We implement strict access controls, including:

Third-Party Vendor Access: Your personal data may also be accessible to our third-party vendor, Wyzetalk (dpo@wyzetalk.com), who provides hosting and administrative support for the App. Their activities include:

The Vendor processes data: The Vendor processes data only as instructed by us and is contractually obligated to comply with POPIA and any applicable data protection regulations. We regularly review their compliance with our data protection standards.

Legal Requirements: We may disclose personal information if required by law, regulatory authorities. This may include:

Data Transfers: Personal information may be transferred outside South Africa when necessary for the provision of services or compliance with legal obligations. Such transfers will be conducted in accordance with applicable data protection laws to ensure your information remains protected.

Safeguards: We implement appropriate safeguards for cross-border transfers, such as:

Access and Correction: You have the right to request access to and correction of your personal information. If you believe any information we hold about you is incorrect or incomplete, please let us know:

Objection to Processing: You may object to the processing of your personal information where it is not necessary for fulfilling our legitimate interests or contractual obligations. We will evaluate your request and respond accordingly.

Deletion: You may request the deletion of your personal information if it is no longer necessary for the purposes for which it was collected or if you withdraw your consent. We will comply with your request unless we have legal grounds to retain the information.

Data Portability: You may request a copy of your personal information in a commonly used and machine-readable format. This allows you to easily transfer your data to another service provider, should you choose to do so.

Filing Complaints: If you believe your rights under POPIA have been infringed, you may contact our Information Officer and/or HR Officer or lodge a complaint with the Information Regulator of South Africa. We take all complaints seriously and will cooperate fully with any investigation.

Security Measures: We implement reasonable and appropriate security measures to protect your personal information from unauthorised access, use, or disclosure. This includes:

Incident Response Plan: In the unlikely event of a data breach, we have an incident response plan in place to address and mitigate the situation effectively. This includes:

Updates and Revisions: We may periodically update this Privacy Statement to reflect changes in our data practices, technology, or legal requirements. We will make reasonable efforts to notify you of any significant changes.

Review of Statement: We encourage you to review this Privacy Statement regularly to stay informed about how we handle your personal information and to understand your rights and responsibilities regarding your data.

Last Update: This Privacy Statement was last updated on 7 November 2024. Any future updates will be communicated effectively to maintain transparency and trust.