WiredLight (Pty) Ltd (“WiredLight”, “we”, “us” or “our”) is committed to processing personal information lawfully, reasonably and securely. This Privacy Policy explains what we process, why we process it, how it may be shared and the rights available to data subjects.

This policy is primarily written to meet the requirements of the Protection of Personal Information Act 4 of 2013 (“POPIA”). Where another data-protection law applies to a particular activity, WiredLight will also comply with the additional requirements of that law.

1. Who we are

WiredLight (Pty) Ltd is a private company registered in the Republic of South Africa. For the processing described in this policy, WiredLight is generally the “responsible party” under POPIA. Where we process personal information solely on a client’s documented instructions, we may instead act as an “operator” for that client.

2. Personal information we may process

The information we process depends on how you interact with WiredLight and on the services or business relationship involved.

Website visitors and enquiries

• Name, organisation, job title and business contact details that you choose to provide.
• The content of an enquiry, correspondence and records of subsequent communications.
• Limited technical information generated when the website is accessed, such as IP address, browser or device information, request timestamps, security logs and error information processed by our hosting, infrastructure or security providers.

The Contact page is designed to create a draft in your own email application. Information typed into that interface is not submitted to WiredLight through the website itself. WiredLight receives the information only if you choose to send the resulting email.

Clients, prospective clients, suppliers, partners and professional contacts

• Names, roles, organisations and business contact details.
• Proposal, contract, project, service, support and commercial correspondence.
• Billing, payment and other business-administration information where required.
• Records reasonably required to manage, deliver, support or protect a business relationship.

Employees, contractors and applicants

Where applicable, WiredLight may process recruitment, employment, contractor, payroll, tax, performance, access-control and related records. Special personal information is processed only where there is a lawful basis or authorisation to do so.

Client-controlled information

When WiredLight processes personal information on behalf of a client as part of a contracted service, the client is normally the responsible party and its privacy notice governs the relationship with the relevant data subjects. WiredLight processes such information in accordance with the client’s instructions, the applicable agreement and POPIA.

3. Where we obtain personal information

• Directly from you.
• From your employer, organisation or an authorised representative.
• From clients, suppliers, delivery partners, advisers or professional referrals.
• From legitimate public sources, such as company websites, professional directories and public records, where collection from another source is permitted by law.
• Automatically from website, hosting and security infrastructure when you access the site.

4. Why we process personal information

• To respond to enquiries and communicate with you.
• To discuss, prepare and manage proposals, contracts and service relationships.
• To deliver, administer, secure and support our services and systems.
• To manage suppliers, partners, contractors and other professional relationships.
• To operate, maintain, diagnose and protect the website, infrastructure and business systems.
• To maintain accounting, tax, contractual, corporate and other business records.
• To comply with legal and regulatory obligations and lawful requests.
• To establish, exercise or defend legal rights and manage disputes or security incidents.

Under POPIA, processing may be justified by consent, contractual necessity, compliance with a legal obligation, protection of a legitimate interest of the data subject or the legitimate interests of WiredLight or a third party, depending on the circumstances.

5. Whether providing information is voluntary

For an ordinary website enquiry, providing personal information is voluntary. If you do not provide contact details or enough information for us to understand the enquiry, we may be unable to respond. In a client, supplier, employment or other formal relationship, certain information may be required to enter into or perform a contract, meet tax or company-record obligations, administer payments, comply with employment requirements or satisfy another applicable legal requirement. Where information is mandatory, we will indicate this where reasonably practicable.

6. Direct marketing and business communications

WiredLight will send unsolicited electronic direct marketing only where permitted by POPIA. This generally requires the data subject’s consent unless the existing-customer conditions in section 69 of POPIA apply. Marketing communications will identify WiredLight and provide a simple, free means to ask that the communications stop. An opt-out is not treated as consent.

7. Sharing personal information

Where necessary and lawful, personal information may be supplied to the following categories of recipients:

• WiredLight directors, employees and authorised contractors who need the information for their work.
• Hosting, cloud, email, collaboration, support, IT, cybersecurity and other technology providers.
• Professional advisers, including legal, accounting, audit and insurance advisers.
• Delivery partners, consultants, subcontractors and suppliers where necessary for an engagement.
• Banks, payment providers and tax or accounting service providers where relevant.
• Regulators, courts, law-enforcement bodies, public authorities or other persons where disclosure is required or permitted by law.

WiredLight does not sell personal information. Operators processing personal information for WiredLight are required to provide appropriate security and process information only as authorised, in accordance with applicable law and contractual arrangements.

8. International transfers

WiredLight operates from South Africa and may use cloud, email, collaboration, hosting, security and professional service providers that process information in other countries. Where personal information is transferred outside South Africa, WiredLight will ensure that the transfer is permitted by section 72 of POPIA, for example because the recipient is subject to an adequate law or binding agreement, the data subject has consented where appropriate, or another statutory transfer ground applies. The countries involved depend on the service and configured provider region and may include the United Kingdom, countries in the European Economic Area, the United States and other jurisdictions in which approved providers operate.

9. Retention

WiredLight retains personal information only for as long as it is reasonably required for the purpose for which it was collected, for a lawful business purpose, for the performance of a contract, or for a period required or authorised by law. Retention periods vary by record type and may be affected by company, tax, employment, contractual, dispute-resolution and regulatory requirements. When personal information is no longer authorised to be retained, it is deleted, destroyed or de-identified as soon as reasonably practicable, in a manner designed to prevent reconstruction where required by POPIA.

10. Security

WiredLight maintains appropriate technical and organisational safeguards having regard to the nature of the information and the risks involved. Measures may include access controls, least-privilege permissions, multi-factor authentication where supported, encryption in transit and at rest where appropriate, endpoint and infrastructure security, backups, logging, patching, supplier controls, confidentiality obligations and incident-response procedures.

If WiredLight has reasonable grounds to believe that personal information has been accessed or acquired by an unauthorised person, WiredLight will follow the security-compromise notification requirements in section 22 of POPIA, including notifications to the Information Regulator and affected data subjects where required.

11. Cookies and similar technology

The website does not intentionally use advertising or behavioural-tracking cookies. Essential technology may be used where necessary to operate, deliver and secure the website. If WiredLight introduces non-essential analytics, advertising or similar tracking technology, the website and this policy will be updated and any consent mechanism required by applicable law will be implemented before that technology is activated.

12. Automated decision-making

WiredLight does not use personal information collected through this website to make decisions based solely on automated processing that produce legal consequences or otherwise affect a data subject to a substantial degree.

13. Your rights

Subject to POPIA and other applicable law, you may have the right to:

• Ask whether WiredLight holds personal information about you and request access to it.
• Request correction of inaccurate, irrelevant, excessive, out-of-date, incomplete, misleading or unlawfully obtained personal information.
• Request destruction or deletion of records where WiredLight is no longer authorised to retain them.
• Object, on reasonable grounds, to certain processing carried out under the grounds identified in section 11(1)(d) to (f) of POPIA.
• Object to direct marketing and withdraw consent where processing is based on consent.
• Lodge a complaint with the Information Regulator where you believe your rights under POPIA have been infringed.

Privacy requests and objections can be sent free of charge to info@wiredlight.net. For objections and requests for correction, destruction or deletion, WiredLight accepts forms substantially similar to the current POPIA Form 1 and Form 2. The website should provide direct access to those current forms from the Privacy page. WiredLight will respond within the periods required by applicable law.

14. Updates to this policy

We may update this policy when our website, services, providers, processing activities or legal obligations change. The version and date at the beginning identify the current version.