FICME (Pty) Ltd ("FICME", "we" or "us") is committed to protecting your personal information. We act as the responsible party for website processing whose purposes and means we determine. For privacy enquiries, contact privacy@ficme.app.
This policy addresses browsing our public website, submitting enquiries and website communications and tracking. Read it with our General Privacy Statement for our general safeguards and rights procedures, and our Cookie Policy for the technologies used. Account registration, subscriptions, document sharing and add-on verification services are addressed in the Core Privacy Policy and applicable service notices, including when accessed through the website.
Information we collect:
You can browse our public website without creating an account or submitting a contact form, although technical information may be collected as described below. When you contact us, we collect the name, email address or mobile number you provide, your enquiry and relevant correspondence. Required and optional fields are identified on the form; without the contact details or information needed for your enquiry, we may be unable to respond. Please supply only relevant information and use the designated secure platform for compliance documents.
Automatically collected information:
Website requests may automatically disclose technical information, such as IP addresses, device and browser details and access logs. This may be personal information where it identifies or can reasonably be linked to a person; it is not treated as anonymous merely because it is collected automatically.
Cookies:
Our Cookie Policy identifies the cookies and similar technologies actually deployed, their providers, purposes and durations, and the available controls. Essential technologies are distinguished from optional analytics or advertising. Where consent is relied upon, optional technologies are activated only after consent and can be disabled through the available controls without preventing use of essential website functions.
Third-party tracking tools:
Where third-party analytics or tracking tools are used, we identify the provider, information collected, purpose and applicable lawful basis in the Cookie Policy or relevant collection notice. We assess the provider’s role and safeguards and remain responsible for our own processing and choice of tools. We do not treat third-party control as removing FICME’s obligations.
Log information:
Website logs may include IP address, browser and device type, operating system, pages requested, timestamps, errors and referring pages where supplied by the browser. We use relevant logs to deliver the website, detect misuse and diagnose faults. Optional analytics is governed by the separate controls described in this policy and the Cookie Policy.
We use the information we receive from you as follows:
To respond to your enquiries and requests: where necessary for steps towards a contract with you, or on an applicable legitimate-interest basis;
To operate, secure and improve the website and remember selected preferences: on an applicable lawful basis, including legitimate interests where appropriate and consent where required for optional tracking;
To understand website use through proportionate analytics, using effectively de-identified or aggregated information where practicable. Information remains personal information if it can reasonably be re-identified. We do not sell personal information or use compliance documents for unrelated advertising or profiling.
Transfer of your personal information:
Where website hosting, support or other providers process personal information outside South Africa, we establish a lawful basis under section 72 of POPIA and the required safeguards before transfer. The General Privacy Statement explains our approach. The relevant provider locations, purposes and level of protection are identified in that Statement, the Cookie Policy or the applicable collection notice.
Disclosure of your personal information:
If a proposed merger, acquisition or asset sale requires disclosure of website personal information, we establish an applicable lawful basis and limit disclosure to information reasonably necessary for the transaction, with appropriate confidentiality and security safeguards. Any recipient’s subsequent use must comply with POPIA, including purpose compatibility and applicable notification requirements. We provide affected persons with the notice required by law and obtain fresh consent where required. The transaction does not itself authorise new or incompatible processing.
We may disclose relevant information to regulators, courts, law enforcement or other recipients where required by law or otherwise supported by an applicable lawful basis and appropriate safeguards. We assess the authority, purpose and scope of a request before disclosure; an informal request does not automatically compel disclosure. We notify affected persons where lawful and appropriate, subject to any prohibition or permitted delay. Necessary provider disclosures are addressed under “Service providers” below.
Retention of your personal information:
We retain enquiry records, website logs and cookie information only for their identified purposes or as otherwise permitted or required by law. Retention depends on the nature of the enquiry, applicable obligations and any properly assessed need to resolve a dispute or protect legal rights. Cookie durations are described in the Cookie Policy. We securely delete or effectively de-identify information when retention is no longer justified; the General Privacy Statement explains our general retention approach.
Information regarding your data protection rights:
Our processing is subject to the Protection of Personal Information Act, 4 of 2013 ("POPIA"), where applicable. POPIA protection is not limited to South African citizens or residents.
The lawful basis for processing depends on the particular information, purpose and context, irrespective of your nationality or residence. We identify an applicable ground under section 11 of POPIA for each activity.
Depending on the activity, the applicable grounds may include:
processing necessary to take steps for the conclusion or performance of a contract to which you are a party;
your voluntary, specific and informed consent, where relied upon;
processing necessary to pursue an appropriately assessed legitimate interest of FICME or a third party, or to protect your legitimate interest, subject to POPIA’s requirements and applicable rights of objection;
processing that complies with an obligation imposed by law on FICME.
Subscription, credit and payment processing is addressed in the Core Privacy Policy and applicable payment notices.
You have certain data protection rights.
Subject to the applicable legal requirements and limitations, you may:
request, free of charge, confirmation whether we hold personal information about you, and request access subject to lawful procedures and limitations;
request correction or deletion of information where the statutory requirements are met;
object to processing on the grounds and in the circumstances provided by POPIA;
request restriction of processing where POPIA provides for it; and
withdraw consent for future consent-based processing without affecting the lawfulness of processing before withdrawal.
Contact privacy@ficme.app to exercise your rights. We may request proportionate proof of identity and authority. The General Privacy Statement explains the procedures, applicable limitations and any lawfully permitted access fees. You need not have an account to exercise rights concerning your information.
You may complain directly to the Information Regulator without first completing our internal complaint process. Its complaint procedures and contact details are available at https://inforegulator.org.za/complaints/.
Service providers:
We use providers for website hosting, security, communications and, where implemented, analytics. Providers acting as operators process information on our instructions under written confidentiality and security obligations. Providers determining their own purposes and means have their own responsible-party obligations; their role and relevant processing must be identified in the applicable notice. We apply appropriate, reasonable security safeguards as described in the General Privacy Statement, including the applicable security-compromise notification procedures.
Analytics:
Any analytics service used on this website will be identified in our Cookie Policy, together with its actual configuration, information collected, sharing, retention and relevant international transfers. Optional advertising features are subject to their own lawful basis and applicable consent controls.
You may manage optional tracking through the website controls described in the Cookie Policy. A provider’s browser add-on, where available, is an additional option and does not replace any consent required before tracking begins.
Links to third-party websites:
Links may take you to independently operated websites with their own privacy notices. Review those notices before providing information. This policy does not govern their independent processing. FICME remains responsible for its own disclosures and for any third-party tools embedded in our website to the extent required by law.
Our email policy:
We distinguish replies and essential service communications from direct marketing. Electronic direct marketing is sent only where permitted by POPIA and applicable consumer law, including with consent where required or under the qualifying existing-customer exception. Marketing messages identify us and provide a means to opt out without charge other than any transmission cost. Opting out of marketing does not stop necessary replies or service notices. We do not sell, rent or trade your email address for third-party marketing.
Special Note About Children:
Our website services and independent accounts are intended for adults. Please do not submit children’s personal information through general enquiry forms unless necessary for a lawful enquiry. Processing children’s information requires an applicable authorisation under section 35 of POPIA. Where consent is relied upon, it must be given beforehand by a competent person. The Core Privacy Policy addresses children’s information submitted through the compliance platform. Contact privacy@ficme.app if you believe children’s information has been submitted improperly.
Updates to our privacy policy:
We may update this policy to reflect lawful changes to our website practices. We publish the revised policy and effective date and give appropriate notice of material changes through the website and, where appropriate, directly to affected persons.
Where a change requires fresh consent or a further processing notice, we obtain that consent or provide the notice before the affected processing begins. Publication of an amended policy does not retrospectively authorise processing or remove accrued rights.
For questions or requests, contact privacy@ficme.app. Full Information Officer details and the relevant rights procedures appear in the General Privacy Statement.