GDPR Compliance

Last Updated: January 2024

Our Commitment to GDPR

dawn-ware is committed to ensuring that our data processing activities comply with the General Data Protection Regulation (GDPR) and the South African Protection of Personal Information Act (POPIA). We respect your privacy rights and are transparent about how we collect, use, and protect your personal information.

Data Controller Information

For the purposes of data protection legislation, the data controller is:

dawn-ware
42 Greenway Boulevard
Sandton, 2196
South Africa

Email: [email protected]

Legal Basis for Processing

We process personal data on the following legal bases:

• Consent: Where you have given clear consent for us to process your personal data for a specific purpose.
• Contract: Where processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract.
• Legal Obligation: Where processing is necessary for compliance with a legal obligation to which we are subject.
• Legitimate Interests: Where processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect your personal data which overrides those interests.

Your Rights Under GDPR

Under data protection legislation, you have the following rights:

Right to Access

You have the right to request a copy of the personal data we hold about you. This is commonly known as a Subject Access Request (SAR).

Right to Rectification

You have the right to request that we correct any personal data that is inaccurate or complete any data that is incomplete.

Right to Erasure

You have the right to request that we delete your personal data in certain circumstances, such as when the data is no longer necessary for the purpose for which it was collected.

Right to Restrict Processing

You have the right to request that we restrict the processing of your personal data in certain circumstances, such as when you contest the accuracy of the data.

Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller.

Right to Object

You have the right to object to the processing of your personal data in certain circumstances, including processing for direct marketing purposes.

Rights Related to Automated Decision-Making

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

Exercising Your Rights

To exercise any of your rights, please contact us using the details provided above. We will respond to your request within one month of receiving it. If your request is complex or you have made multiple requests, we may extend this period by a further two months, but we will notify you of any extension within the first month.

There is no fee for exercising your rights, unless your request is manifestly unfounded or excessive, in which case we may charge a reasonable fee or refuse to act on the request.

Data Transfers

We primarily store and process your data within South Africa. If we transfer your personal data outside of South Africa or the European Economic Area (EEA), we will ensure that appropriate safeguards are in place to protect your data in accordance with applicable data protection laws.

Data Security

We have implemented appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including:

• Encryption of personal data where appropriate
• Regular testing and evaluation of security measures
• Staff training on data protection responsibilities
• Access controls to limit who can access personal data

Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected. Our retention periods are determined based on:

• The nature and sensitivity of the data
• The purposes for which we process the data
• Applicable legal requirements

Complaints

If you believe that your data protection rights have been violated, you have the right to lodge a complaint with a supervisory authority. In South Africa, this is the Information Regulator. In the EU, you may contact your local data protection authority.

Changes to This Statement

We may update this GDPR compliance statement from time to time. Any changes will be posted on this page with an updated revision date.