Vumba Privacy Policy

This Privacy Policy is effective as of 4th September, 2024.

Vumba (alternately “we”, “us”, or “our”) respects your privacy and is committed to complying with this privacy policy (“Privacy Policy”), which describes what information we collect about you, including how we collect it, how we use it, and with whom we may share it. This Privacy Policy applies to information collected on our website located at https://vumba.io/ (the “Website”), and the “Vumba” mobile application (the “Mobile Application”), the Mobile Application website located at https://app.vumba.io/admin/login (the “Mobile Application Site” and, collectively with the Mobile Application and the Website, the “System”).

What Information Do We Collect?

Vumba collects certain information from or about you that can be used to identify you (“Personal Information”). We collect Personal Information from a variety of sources, including information that you provide directly and information that we automatically collect when you access and use the System.

Information You Provide Us. You may provide information about yourself to us through the System, including your name, email, and phone number. If you make a donation to us, we and our third party service providers will also request your payment card or bank account information and related information required to process your donation. You may also provide your resume or curriculum vitae data, which may contain Personal Information, when you apply for a job or submit an employment application to us. 

Information Collected Automatically. We and our third party service providers may collect information automatically from you when you visit and use the System. Such information includes the following:

Usage Information. We may collect information about how you interact with the System. This may include information such as the dates and time you visit the System, the page you view, referring / exit URLS, your browser type, and the domain name of your internet service provider. In some cases, we may collect this information through cookies and similar technologies. To learn more about these technologies, please see the “Cookies and Usage Reports” section below. 

Device Information. We may collect information about the devices you use to access the System, including your device make and model, IP address, inferred geolocation information, operating system, and unique device identifiers.

Cookies and Usage Reports

By placing a small file known as a cookie on your computer or other device, Vumba and its third party service providers’ servers may passively gather information about our visitors’ use of the System for reasons that include: statistics collection and analysis, System optimization, analytics, maintenance of user login information, security (such as authentication), and to personalize your experience while visiting the System. The information that we and our third party service providers track with cookies may include the type of browser (such as Google Chrome or Internet Explorer) and Internet-connected devices being used to access the System, your IP address, your home domain or Internet service provider, your referrer URL (the URL for the website that you were viewing prior to visiting the System), how you were directed to the System, which specific pages you access on the System, how long you view each page, the time and date you access our System and the total number of visitors to the System and any portions thereof. 

Most popular Internet browser applications will allow you to configure the browser so as not to accept cookies. However, setting your browser to reject cookies may, in certain instances, prevent you from taking full advantage of the System (or some portion thereof) and its capabilities, or cause some features of the System to function improperly or more slowly. 

Google Analytics

We use Google Analytics, a web analysis service provided by Google, in order to better understand your use of the System and how we can improve it. Google Analytics collects information such as how often users visit a website, what pages you visit when you do so, and what other websites you used prior to coming to such a website. Google Analytics collects only the IP address assigned to you on the date you visit a website, rather than your name or other directly identifying information. We do not combine the information collected through the use of Google Analytics with your Personal Information. Although Google Analytics plants a persistent cookie on your web browser to identify you as a unique user the next time you visit a website, the cookie cannot be used by anyone but Google. Google Analytics uses its cookie(s) and the information Google Analytics collects to track your online activities over time and across different websites when you use our System, and other websites. Google’s ability to use and share information collected by Google Analytics about your visits to the System is governed by the Google Analytics Terms of Service and the Google Privacy Policy. Google utilizes the data collected to track and examine the use of the System, to prepare reports on its activities, and share them with other Google services. To more fully understand how Google may use the data it collects on the Website, please review “How Google Uses Information From Sites or Apps That Use Our Services” (located here). 

Session-Replay Tools

We use third party services provided by Hotjar that employ software code to record users’ interactions with the System in a manner that allows us to watch DVR-like replays of those user sessions. The replays include users’ clicks, mouse movements, scrolls, and keystrokes/key touches during those sessions. These replays help us diagnose usability problems with the System and identify areas improvement of the System. You can learn more about Hotjar at https://www.hotjar.com/legal/policies/privacy/. You can opt-out of session recording by Hotjar at https://www.hotjar.com/privacy/. 

Correspondence

We appreciate your questions and comments about the System and welcome your messages at [email protected]. If you correspond with Vumba, we may collect information including the content of, and metadata regarding, any correspondence you may provide us. We may share your messages with those within our organization who are most capable of addressing the issues contained in your message. We may archive your message for a certain period of time or discard it.

How Can I Opt-Out of Promotional Correspondence? 

We or our third party service providers may send you emails with promotional offers. If you would no longer like to receive this information from us, please click the unsubscribe link at the bottom of any such email you receive from us and follow the instructions. Otherwise, please contact us via e-mail at [email protected] with the word “UNSUBSCRIBE” or “REMOVE” in the subject line. Your email address will be removed from our marketing list. Please allow us a reasonable period of time in order to satisfy your request, as some communications may already be in process. 

Online Account Management

If you elect to subscribe to certain services available on the System, including the ability to access any password-protected areas of the System through your account, you may be required to submit Personal Information for the purpose of verifying your identity and your authority to manage the account. 

How Do We Use The Information That We Collect?

Vumba and our third party service providers collect and use Personal Information for purposes that include but are not limited to:

1. providing our products and services to you;
2. processing donations;
3. operating and providing the System;
4. improving our products and services, the System, user experience, and our business; 
5. security purposes, including addressing System integrity and security issues and fraud and crime prevention/detention;
6. sending information that you request from us, including responding to inquiries or requests for information about or from Vumba;
7. sending promotional or marketing materials regarding Vumba; 
8. evaluate your qualifications for career positions with Vumba; 
9. other business purposes, including verifying your identity, age, or payment details, investigating complaints about the System, risk assessment, monitoring, research and analysis, marketing and advertising, and dispute resolution;
10. in connection with a merger or similar consolidation of Vumba into or with another entity; 
11. complying with law enforcement, government agencies, or a governmental mandate;
12. complying with or as permitted by any Vumba policies and any applicable legal requirements; and
13. engaging in other activities discussed under this Privacy Policy or by Vumba in its discretion. 

With Whom Do We Share Information That We Collect?

In addition to the uses mentioned or described elsewhere in this Privacy Policy, we may add Personal Information to our database. 

We may share Personal Information with third parties, such as trusted business partners and service providers, to help provide the System, deliver our services, provide marketing or advertising, process donations, perform statistical analysis, send you correspondence, provide customer, volunteer, or donor support, protect against potential fraud, collect, maintain, or analyze candidates for career positions, or perform any other functions consistent with the operation of the System and our services. We may also share Personal Information with professional advisors, such as lawyers, auditors, bankers, and insurers in the course of the professional services they render to us. These third parties have agreed to adhere to appropriate data protection and confidentiality provisions. 

We may also disclose Personal Information if we become subject to a subpoena or court order, or if we are otherwise legally required to disclose information. We may also use and disclose Personal Information to establish or exercise our legal rights, to assert and defend against legal claims, or if we believe such disclosure is necessary to investigate, prevent, or take other action regarding actual or suspected illegal or fraudulent activities or potential threats to the physical safety or well-being of any person.

In the event we merge with, are acquired by or otherwise combine with another legal entity, the Personal Information we collect may be transferred to such entity. If any bankruptcy, liquidation or reorganization proceeding is brought by or against us, your information may be considered an asset that may be transferred to third parties.

How Long Do We Keep Your Information?

Vumba will only keep your Personal Information for so long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is permitted or required by law (such as tax, accounting, or other legal requirements). 

Sweepstakes, Promotions, Contests & Surveys?

On the System, you may wish to participate in certain online polls, surveys, contests, sweepstakes and other promotions that may be offered from time to time by us, a partner, or other entity through which you are using the System. Participation in these activities is completely voluntary; you have a choice about whether to disclose information required to enter. Information requested may include Personal Information such as your name, address, date of birth, phone number, e-mail address, username, password, and/or similar information. We use the information you provide to administer the polls, surveys, contests, sweepstakes, and other promotions. Subject to applicable contractual or legal restrictions, we also may use the information to communicate with you, or the other people you select, about our services or products. In connection with such promotions, may choose to participate in activities such as sharing information with others and sending email invitations. We are not responsible for, and this Privacy Policy does not apply to, the privacy practices of our partners or another entity through which you are using the System in the course of any poll, survey, contest, sweepstakes, or promotion offered by any third party.

How Do We Protect Information Collected About You?

Vumba takes commercially reasonable measures to secure and protect information on the System. We restrict access to Personal Information to Vumba employees, contractors, and agents who need to know that information in order to process it for us, and who are subject to appropriate confidentiality obligations. Nevertheless, no security system is impenetrable. We cannot guarantee that information that users of the System transmit or otherwise supply will be secure. 

Linked Websites

For your convenience, some hyperlinks may be posted on the System that link to other websites not under our control. We are not responsible for, and this Privacy Policy does not apply to, the privacy practices of those websites or pages not under our control or of any companies that we do not own or control. We do not endorse any of those websites or pages, the services or products described or offered on such sites or pages, or any of the content contained on those sites or pages. 

User-Provided Content

Any information, communications, or material that you submit to the System is done at your own risk and without any expectation of privacy, except as expressly set forth in this Privacy Policy. 

Social Media Platforms 

Any information, communications, or material that you submit to any pages associated with Vumba on social media platforms is done at your own risk and without any expectation of privacy. All such submissions are subject to the terms of use and privacy policy of such social media platform. 

Visiting The System From Outside The United States

If you are visiting the System, or any part thereof, from outside of the United States, your information may be transferred to, stored and processed in the United States. The data protection and other laws of the United States may not be as comprehensive as those in your country. By using any portion of the System, you consent to the transfer of your Personal Information to our servers and databases in the United States and those third parties with whom we share such information as described in this Privacy Policy.

Do Not Track Requests

Certain state laws require that we indicate whether we honor “Do Not Track” settings in your browser concerning targeted advertising. We adhere to the standards set out in this Privacy Policy and do not monitor or follow any Do Not Track browser requests.

Other Data Protection Rights

Subject to applicable law, you may have certain rights regarding your Personal Information, including the right to access, update, correct inaccuracies in, delete, or revoke consent to our use of your Personal Information. Please send such requests to [email protected]. We may request certain information to verify the identity of the individual making such a request. 

Changes to our Privacy Policy

We may change this Privacy Policy at any time. The most recent version of the Privacy Policy is reflected by the effective date at the top of this Privacy Policy. All amendments to this Privacy Policy will be effective immediately upon notice thereof, which we may give by any means, including by posting a revised version of the Privacy Policy or other notice on the System. 

Whom Can You Contact For More Information?

If you have any questions, please contact us at [email protected]. 

Residents of the Republic of South Africa

This portion of our Privacy Policy applies to our customers in the Republic of South Africa only and applies to the extent of any inconsistency with the information above. All terms not otherwise defined in this section shall have the meanings as defined under the Protection of Personal Information Act (“POPIA”). 

Failure to Provide Information

Where we require personal information in order to provide you with our products or services or process donations, failure to provide us or our third party service providers with the necessary information will result in our inability to provide such products and services or process donations. 

International Data Transfers

The information that Vumba collects in association with the System is hosed in the United States of America. If personal information is transferred outside of the Republic of South Africa, Vumba may transfer the personal information where Vumba is permitted to do so in accordance with the provisions applicable to cross-border flows of personal information under POPIA. 

Exercising Your Rights

Right to Access. After providing adequate proof of identity, you have the right to request: 1) Vumba to  confirm, free of charge, whether or not we hold personal information about you; and 2) to obtain from Vumba the record or description of personal information concerning you and any information regarding the recipients or categories of recipients who have had access to the personal information.

Right to Rectify. You may also request Vumba:  1) correct or delete personal information about you in its lawful possession or under its control that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully; or 2) destroy or delete a record of personal information about you that Vumba is no longer authorized to retain records in terms of POPIA’s retention and restriction of records provisions. 

Right to Object to Processing. In certain circumstances, you have the right to object to our processing of your personal information, such as if we are using your personal information for direct marketing. 

Right to Withdraw Consent. If we have collected and processed your personal information with your consent, you are free to withdraw your consent at any time. Withdrawing your consent will affect the lawfulness of processing we conducted prior to such withdrawal, nor will it affect processing of your personal information conducted in reliance on a legal basis other than consent. 

Right to File a Complaint. If you have a complaint about how Vumba uses your personal information, we hope that you will contact us according to the contact information below and we will promptly address your concern. However, you can always file a complaint with the Information Regulator. The Information Regulator’s contact details are as follows:

The Information Regulator (South Africa)
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
P.O. Box 31533, Braamfontein, Johannesburg, 2017
Website: https://www.inforegulator.org.za/ 
Email: [email protected] 

Contact Information. Please direct any rights requests (as described above) or additional questions that you may have regarding this Privacy Policy to [email protected]. Vumba’s registered South African address is Shop 17 Bosveld Village, R40, Hoedspruit, Limpopo. . 

Residents of the European Economic Area (“EEA”) and the United Kingdom

This portion of our Privacy Policy applies to our customers in the EEA and the United Kingdom only and applies to the extent of any inconsistency with the information above. All terms not otherwise defined in this section shall have the meanings as defined under the General Data Protection Regulation or the UK General Data Protection Regulation, as applicable. 

Legal Basis for Processing Personal Data

Vumba’s legal basis for processing personal data will depend on the personal data collected and the specific context in which we collect it. We normally process personal data from you when: 

• We have your consent to do so;
• We have a contract with you and it is necessary to process your personal data to perform our contract with you, including to operate our business, provide our products and services, and provide you with the benefits of the System; 
• The processing is in our legitimate business interests, such as operating our business, providing our products and services, improving and developing the System, communicating with you, marketing and advertising our products and services, to identify and protect fraud, protect you, us, or others from security threats by enhancing the security of our network and information systems, and complying with applicable laws and industry regulations; and 
• To comply with legal requirements, including applicable laws and regulations. 

International Data Transfers

The information that Vumba collects in association with the System is hosted in the United States of America. If personal data is transferred between countries, we take commercially reasonable efforts to protect such personal data, such as by entering into certain Standard Contractual Clauses as approved by the European Commission or International Data Transfer Agreement as approved by the United Kingdom’s Information Commissioner’s Office. 

Retention Period

We retain the personal data that we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with the services you requested or to comply with an applicable legal requirement). 

Automated Decision Making

We do not engage in any automated decision-making as a part of our services.

Exercising Your Rights

Right to Access, Correction, or Deletion. You may request to access, to correct, or to delete your personal data. Please note that even if you request for your personal data to be deleted, certain aspects may be retained by us to meet our legal or regulatory compliance, exercise, establish or defend claims, and to protect against fraudulent or abusive activity on our System. 

Right to Object to Processing. In certain circumstances, you have the right to object to our use of your personal data, such as if we are using your personal data for direct marketing; for our or a third party’s legitimate interests or the public’s interest; or for scientific or historical research and statistics. 

Right to Restrict Processing. Under some circumstances, you may request that we limit how we use your data or “Restrict Processing.” Simply a difference of opinion or view does not necessarily justify a restriction.

Right to Data Portability. At your request, you may request portability of your personal data. We are happy to provide your personal data in a machine-readable or “portable” format.

Right to Withdraw Consent. If we have collected and processed your personal data with your consent, you are free to withdraw your consent at any time. Withdrawing your consent will affect the lawfulness of processing we conducted prior to such withdrawal, nor will it affect processing of your personal data conducted in reliance on a legal basis other than consent. 

Right to File a Complaint. If you have a complaint about how Vumba uses your personal data, we hope that you will contact us according to the contact information below and we will promptly address your concern. However, you can always file a complaint with the supervisory authority in your jurisdiction. For more information, please contact your local data protection authority (contact details for data protection authorities in the EEA are available at https://edpb.europa.eu/about-edpb/board/members_en. Contact details for the data protection authority in the UK are available at https://ico.org.uk/.

Contact Information. Please direct any rights requests (as described above) or additional questions that you may have regarding this Privacy Policy to [email protected].