Privacy Policy

INTOBRANDS (PTY) LTD Privacy Policy

INTOBRANDS (PTY) LTD is the sole authorised distributor for footwear brands including FitFlop, Ugg, Holster, Loci, and Hunter Boots in South Africa. The websites trenton.co.za, fitflop.co.za, hunterbootsza.co.za, and holsterfashion.co.za are operated by INTOBRANDS (PTY) LTD.

Introduction

Welcome to our Privacy Policy. This notice explains how we obtain, use, and disclose your personal information in accordance with the requirements of the Protection of Personal Information Act No. 4 of 2013 (POPIA). At INTOBRANDS (PTY) LTD, we are committed to protecting your privacy and ensuring that your personal information is collected and used properly, lawfully, and transparently.

The purpose of this policy is to describe how we collect, store, use, and protect information that can be associated with you or another natural or juristic person and that can be used to identify you or that person (personal information).

Please read this policy to familiarise yourself with details of the information that we collect from you when you access or use the following websites:

Safeguarding Your Information

We are legally obliged to provide adequate protection for the personal information we hold and to prevent any unauthorised access and/or use. INTOBRANDS (PTY) LTD continuously reviews its security controls and processes to ensure that personal information remains secure.

Our privacy policies and procedures cover:

Physical security
Computer and network security
Access to personal information
Secure communication
Security in contracting out activities or functions
Retention and disposal of information
Acceptable usage of personal information
Governance and regulatory compliance
Monitoring access and usage of personal information
Investigating and responding to security incidents

When we contract with third parties, we impose appropriate security, privacy, and confidentiality obligations on them to ensure that the personal information for which we remain responsible is kept secure.

Audience

This policy applies to:

A customer who has ordered products that we provide, either online or in-store.
A customer who signs up for our loyalty programme.
A customer who subscribes to receive our newsletter.
A customer who has entered one of our promotional competitions.
A customer who has ordered our products through an affiliate link.
A visitor to our websites.

This policy applies under certain circumstances.

Personal Information

Definition of Personal Information

Personal information includes:

Certain information that we collect automatically when you visit our website.
Certain information collected during registration (see below).
Certain information collected upon submission.
Optional information that you provide to us voluntarily (see below).

However, personal information excludes:

Information that has been anonymised and does not identify a specific person.
Permanently de-identified information that cannot be traced back to a specific person or source.
Non-personal statistical information collected and compiled by us and/or our partners and operators.
Information voluntarily provided by you in an open, public environment or forum, including blogs, chat rooms, communities, classifieds, or discussion boards. Such information is disclosed in a public forum, is no longer confidential, and does not constitute personal information subject to protection under this policy.

Common Examples of Personal Information We May Collect and Process

Identifying information – such as name, date of birth, or identification number of any kind.
Contact information – such as a telephone number or email address.
Address information – such as a physical or postal address.
Demographic information – such as your age, gender, or marital status.
Product-related information – such as your shoe size.

Sensitive Personal Information

Depending on the products or services that you require, we may also collect sensitive personal information, including your:

Financial information – such as bank account details.

Acceptance

Acceptance Required

All the terms of this policy must be accepted when ordering our products. If a person does not agree with anything in this policy, then our products may not be ordered.

Legal Capacity

You may not access our website or order our products if you do not have the legal capacity to enter into legally binding contracts.

Deemed Acceptance

By accepting this policy, you are deemed to have read, understood, and agreed to be bound by all its terms.

Your Obligations

You may only send us your own personal information or the personal information of another data subject where you have their permission to do so.

Changes to This Policy

We may change the terms of this policy at any time by updating our web pages and serving notices through regular communication channels such as email. We will notify you of any changes by:

Placing a notice in a prominent location on the website.
Sending an email detailing the changes made and the date of the update.

If you do not agree with the changes, you must stop using the website and our products or services. If you continue to use the website or our products and services following notification of a change, the updated terms will apply, and you will be deemed to have accepted them.

Collection of Personal Information

On Registration

Once you register on our website, sign up for our newsletter, or become a loyalty rewards member, you will no longer be anonymous to us.

The personal information you provide may include:

Name and surname
Email address
Telephone number
Company name, company registration number, and VAT number
Postal address or street address
Username and password

We will use this personal information to fulfill your account requirements, understand your needs, provide additional services, and for any other purposes outlined in this policy.

On Order or Request

When you order our products or request our services, you may be asked to provide additional information on a voluntary basis (products or services information).

From Browser

We collect certain information from your web browser, including your internet usage information when you visit our website.

We automatically receive and record internet usage information on our managed server logs from your browser, including:

Internet Protocol (IP) address
Browsing habits and click patterns
Version of installed software
System type and screen resolution
Color capabilities and plug-ins
Language settings and cookie preferences
Search engine keywords
JavaScript enablement
Content and pages accessed on the website
Dates and times of visits, paths taken, and time spent on sites and pages within the website

Please note that other websites visited before entering our website may place personal information within your URL. We have no control over such websites. Accordingly, a subsequent website that collects URL information may log some of your personal information.

Cookies

For information on how we deal with cookies, please refer to our Cookie Policy.

Web Beacons

We collect certain information from web beacons on our website to compile anonymous data about our website’s usage.

Our website may contain electronic image requests (such as a single-pixel GIF or web beacon request) that allow us to count page views and access cookies. Any electronic image viewed as part of a web page (including an ad banner) can act as a web beacon.

Our web beacons do not collect, gather, monitor, or share any of your personal information. We use them solely to compile anonymous website usage data.

Optional Information

We collect certain optional information that you provide when you upload or download content from our website, enter competitions, take advantage of promotions, respond to surveys, or register and subscribe to additional products or services.

You may also voluntarily provide additional information, including:

Content or products you upload or download from our website.
Participation in competitions, promotions, or surveys.
Ordering certain additional products or services.
Using optional website features and functionality.

Purpose of Collection

We may use or process any product information or optional information that you provide to us for the purposes indicated when you agreed to provide it.

Processing includes gathering, disclosing, and combining your personal information with other data. We generally collect and process your personal information for:

Product or service purposes – such as processing orders or service requests.
Marketing purposes – for lawful and related marketing activities.
Business purposes – including internal audits, accounting, business planning, joint ventures, business disposals, or other transactions.
Legal purposes – such as handling claims, complying with regulations, or ensuring good governance.
Accuracy – verifying and updating personal details.
Statistical analysis – using aggregate data processing to identify trends.
Reference purposes – such as credit reference verification and services.

We may also use your usage information to:

Remember your details so you do not have to re-enter them during future visits.
Monitor website usage metrics, such as the total number of visitors and pages accessed.
Track your entries, submissions, and status in promotions or other website-related activities.

Consent to Collection

We will obtain your consent to collect personal information:

In accordance with applicable law.
When you provide us with any registration information or optional information.

Use

Our Obligations

We may use your personal information to fulfill our obligations to you.
To confirm, verify, and keep your details up to date.

Messages and Updates

We may send administrative messages and email updates to you about the website. In some cases, we may also send you primarily promotional messages. We may wish to provide you with information about new products or services in which we think you may be interested. We will not send you promotional messages unless you have chosen to opt into them. You can choose to opt out of promotional messages. We may also send you one message asking you to opt into promotional messages without you having previously opted in.

We may use your information to send you administrative messages and email updates regarding the website and for marketing purposes within the bounds of relevant legislation.

Targeted Content

We may use your information for targeted content in certain specified instances.

While you are logged into the website, we may display targeted advertisements, recommendations, or other relevant information based on your personal information. This process is fully automated, with computers processing your personal information to match it to advertisements or related content. We never share personal information with advertisers unless you specifically provide us with your consent. Advertisers receive a record of the total number of impressions and clicks for each advertisement but do not receive any personal information. If you click on an advertisement, we may send a referring URL to the advertiser’s website, identifying that a customer is visiting from our website. However, we do not send personal information to advertisers with the referring URL. Once you are on the advertiser’s website, the advertiser may collect your personal information.

Disclosure

Sharing

We may share your personal information with:

Other divisions or website operators within the company to provide joint content and services such as registration, transactions, and customer support. This may also help detect and prevent potentially illegal acts and violations of our policies. They will only use this information to send you marketing communications if you have requested their products or services.
An affiliate, in which case we will seek to require the affiliate to honor this privacy policy.
Our products or service providers under contract who help provide certain products or services or assist with business operations, including fraud prevention, bill collection, marketing, and technology services. Our contracts dictate that these providers only use your information in connection with the products or services they supply or the services they perform for us and not for their own benefit.
Credit bureaus to report account information, as permitted by law.
Banking partners, as required by credit card association rules, for inclusion on their list of terminated merchants (if you utilize the services to receive payments and meet their criteria).
Other third parties who provide relevant services where appropriate, including but not limited to Facebook or Google.

We aim to have agreements in place with relevant suppliers and third-party service providers to ensure they comply with privacy requirements as mandated by the Protection of Personal Information Act No. 4 of 2013 (POPIA).

Regulators

We may disclose your personal information as required by law, governmental audits, industry codes, or when necessary to protect our rights.

Law Enforcement

We may disclose personal information if required:

By a subpoena or court order.
To comply with any law.
To protect the safety of any individual or the general public.
To prevent violations of our customer relationship terms.

No Selling

We will not sell personal information. No personal information will be disclosed except as provided in this privacy policy.

Marketing Purposes

We may disclose aggregate statistics (information about the customer population in general terms) to advertisers or business partners.

Employees

We may need to disclose personal information to our employees who require access to fulfill their duties. This includes management, human resources, accounting, audit, compliance, information technology, or other personnel.

Change of Ownership

If we undergo a change in ownership, merger, acquisition, or asset sale, we may assign our rights to the personal information we process to a successor, purchaser, or separate entity. We will disclose such transfers on the website. If you are concerned about your personal information migrating to a new owner, you may request us to delete your personal information.

Security

We take the security of personal information seriously and comply with applicable data protection laws. Our website is hosted in a secure server environment with a firewall and requisite security measures to prevent unauthorized access. Access to personal information is authorized only for employees who require it for job responsibilities. We implement disaster recovery procedures where appropriate.

Accurate and Up to Date

We strive to keep personal information as accurate, complete, and up to date as necessary. You may update your personal information at any time by accessing your account, emailing us, or calling us. To protect your information, we verify your identity before granting access or making corrections.

You have the following rights regarding your personal information:

Right of access – You may request details of your personal information and a copy of it.
Right to rectification – You may correct or remove inaccurate information.
Right to object – You may object to the processing of your information for unsolicited electronic communication.
Right to lodge a complaint – You may file a complaint with the Information Regulator if dissatisfied with our handling of your personal information.

Contact Information

If you wish to lodge a complaint, you can contact the Information Regulator at:

Braamfontein, Johannesburg
JD House, 27 Stiemens Street
Email: inforeg@justice.gov.za
Complaints: complaints.IR@justice.gov.za

Retention

We will retain your personal information only as long as necessary for the purposes outlined in this policy, unless:

Retention is required or authorized by law.
You have consented to the retention of the record.

During the retention period, we will continue to abide by our non-disclosure obligations and will not share or sell your personal information.

Transfer to Another Country

We may transmit or transfer personal information to the country in which it was collected and process it there. Your personal information may be stored on servers outside the country, where privacy laws may differ. You consent to us processing your personal information in such foreign jurisdictions.

Access and Correction of Personal Information

Clients have the right to access, update, correct, or delete the personal information that INTOBRANDS (PTY) LTD holds. You may update or delete your personal information by accessing your account on our website, emailing us, or calling us. Once you object to processing, we will no longer process your personal information.

We are not responsible for the privacy policies or practices of any linked or third-party websites.

Enquiries

For any questions, concerns, or requests regarding this policy, please contact:

Paul Hancock
Chief Information Officer
Email: paulh@intobrands.co.za

INTOBRANDS (PTY) LTD
Reg. No. 2015/109420/07, VAT Reg No. 4760 2697 30
82 Marine Drive, Marine Service Road, Paarden Eiland
Tel: 021 510 4428
Fax: 021 511 5220