TERMS & CONDITIONS
1. Privacy Policy
2. Disclaimer
3. Terms and Conditions
4. The Clandestine Group’s Terms and Conditions
5. Promotion of Access to Information
6. POPI Act
7. Anti-Bribery and Anti-Corruption Policy
Privacy Policy
Effective Date: 01 January 2025
Your privacy is important to us. The Clandestine Group is committed to respecting your
personal information and complying with all applicable laws and regulations governing
its collection, use, and protection. This Privacy Policy applies to all personal information
we may collect about you across our website, www.clandestinegroup.com, and any other
platforms we own or operate.
“Personal information” refers to any data that can be used to identify you. This includes,
but is not limited to, your name, address, identity details, payment information, and data
relating to your interactions with our website.
Where our website contains links to third-party sites or services, please note that those
external platforms maintain their own privacy policies. Once you navigate away from our
site, you are subject to the terms and conditions, including the privacy practices, of the
respective third-party site. We strongly recommend reviewing their privacy policies to
understand how your personal information may be collected, used, or shared.
This Privacy Policy does not govern any of your activities outside of our website.
Information We Collect
The information we collect falls into two categories: “voluntarily provided” information
and “automatically collected” information.
Voluntarily provided information refers to any personal information that you knowingly
and actively submit to us.
Automatically collected information refers to data automatically transmitted by your
device when you access or interact with our website, products, or services.
LOG DATA
When you visit our website, our servers may automatically log standard information
provided by your web browser. This may include your device’s Internet Protocol (IP)
address, browser type and version, the pages you visit, the dates and times of your visits,
the time spent on each page, and other details about your visit.
If you encounter certain errors while using the site, we may automatically collect data
about the error and the surrounding circumstances. This may include technical details
about your device and browser, the action being performed at the time of the error, and
other technical information related to the problem. You may or may not receive a
notification that such an error has occurred.
Please note that while this information may not identify you on its own, it may be possible
to combine it with other data to personally identify you.
PERSONAL INFORMATION
We may request personal information from you, for example, when you register an
account or when you contact us. This may include (without limitation):
Full name
Email address
Phone or mobile number
Other contact details or information as may be reasonably required at the time
LEGITIMATE REASONS FOR PROCESSING YOUR PERSONAL INFORMATION
We only collect and use your personal information where we have a legitimate and lawful
reason to do so. In such instances, we will only collect personal information that is
reasonably necessary to provide our services to you, operate our business, or comply
with applicable legal or regulatory obligations.
COLLECTION AND USE OF INFORMATION
We may collect personal information from you when you do any of the following on our
website:
1. Register for an account
2. Use a mobile device or web browser to access our content
3. Contact us via email, social media, or similar platforms
4. Interact with content where TCG is mentioned or tagged on social media or similar
platforms
We may collect, hold, use, and disclose personal information for the following purposes,
and will not further process personal information in a way that is incompatible with these
purposes:
1. To provide you with our core products, features, and services
2. To contact and communicate with you
3. To enable you to access and use our website, associated applications, and
associated platforms
4. For internal recordkeeping and administrative purposes
5. For security and fraud prevention, and to ensure that our sites and applications
are safe, secure, and used in accordance with our terms of use
We may also combine voluntarily provided and automatically collected personal
information with general information or research data we receive from other trusted
sources. For example, our marketing and market research activities may generate data
and insights, which we may combine with information about how visitors use our site to
improve our o erings and your overall user experience.
SECURITY OF YOUR PERSONAL INFORMATION
During the collection, processing, and retention of your personal information, we will take
commercially reasonable and appropriate measures to protect it against loss, theft,
unauthorised access, disclosure, copying, use, modification, or any other reasonably
foreseeable risk.
While we take these steps to protect the information you provide to us, please note that
no method of electronic transmission or storage is completely secure, and we cannot
guarantee absolute data security.
HOW LONG WE KEEP YOUR PERSONAL INFORMATION
We retain your personal information only for as long as it is reasonably necessary for the
purposes set out in this Privacy Policy, unless a longer retention period is required or
permitted by law.
For example, if you have provided personal information as part of creating an account as
a service provider with us, we may retain this information for as long as your services are
required or your account remains active.
When your personal information is no longer required for the purposes for which it was
collected, we will either delete it or de-identify it by removing all details that can
reasonably identify you. However, we may retain certain information where necessary:
1. To comply with legal, accounting, or reporting obligations; or
2. For archiving purposes in the public interest, scientific or historical research, or
statistical purposes, where such retention is permitted by law.
CHILDREN’S PRIVACY
Our products and services are not directed at minors, and we do not knowingly collect
personal information about minors. If we become aware that we have collected personal
information from a minor without appropriate consent, we will take reasonable steps to
delete such information.
DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES
We may disclose personal information to:
• A parent, subsidiary, or a iliate within the group
• Third-party service providers for the purpose of enabling them to provide their
services, including (without limitation) IT services, data storage, hosting and
server providers, analytics, error loggers, debt collectors, maintenance,
marketing providers, professional advisors, and payment system operators
• Our employees, contractors, and/or related entities
• Our existing or potential agents, business partners, or investors
• Credit reporting agencies, courts, tribunals, and regulatory authorities in the event
that you fail to pay for services provided
• Courts, tribunals, regulatory authorities, and law enforcement o icials, as
required by law, in connection with any actual or prospective legal proceedings,
or to establish, exercise, or defend our legal rights
• Third parties, including agents or subcontractors, who assist us in providing
information, products, services, or direct marketing
• Third parties engaged to collect and process data on our behalf
• Any entity that acquires, or to which we transfer, all or substantially all of our
assets or business
Where personal information is disclosed to third parties, we will take reasonable steps to
ensure that such parties are bound by appropriate confidentiality and data protection
obligations consistent with this Privacy Policy and applicable law.
YOUR RIGHTS AND CONTROLLING YOUR PERSONAL INFORMATION
Your choice
By providing personal information to us, you acknowledge and understand that we will
collect, hold, use, and disclose your personal information in accordance with this Privacy
Policy. You are not obliged to provide personal information to us; however, if you choose
not to, this may a ect your ability to use our website or access certain products and/or
services.
Information from third parties
If we receive personal information about you from a third party, we will handle it as set
out in this Privacy Policy. If you are a third party providing personal information about
another person, you represent and warrant that you have that person’s consent to provide
their personal information to us.
Marketing permission
If you have previously consented to us using your personal information for direct
marketing purposes, you may withdraw that consent at any time by contacting us using
the details provided below. We will then update our records accordingly.
Access
You may formally request details of the personal information that we hold about you in
the form and manner prescribed by applicable law. We may require proof of identity
before providing access.
Correction
If you believe that any personal information we hold about you is inaccurate, out of date,
incomplete, irrelevant, or misleading, please contact us using the details in this Privacy
Policy. We will take reasonable steps to correct any information found to be inaccurate,
incomplete, misleading, or out of date.
Non-discrimination
We will not unlawfully discriminate against you for exercising any of your rights over your
personal information. Unless your personal information is essential to provide a
particular service (for example, user support), we will not deny you goods or services,
charge you di erent prices or rates, or provide you with a di erent level or quality of goods
or services solely because you exercised your privacy rights.
Notification of data breaches
We will comply with applicable data protection laws in respect of any data breach,
including notifying a ected individuals and the relevant regulatory authorities where
required.
Complaints
If you believe that we have breached any data protection law and wish to lodge a
complaint, please contact us using the details below and provide full particulars of the
alleged breach. We will investigate your complaint and respond in writing, outlining the
outcome of our investigation and any steps we will take to address your concerns.
You also have the right to contact a regulatory body or data protection authority in relation
to your complaint.
Unsubscribe
To unsubscribe from our email database or opt out of marketing communications, you
may use the opt-out facility provided in the communication or contact us using the
details listed in this Privacy Policy. We may need to request specific information from you
to help us confirm your identity.
USE OF COOKIES
We use “cookies” to collect information about you and your activity across our site. A
cookie is a small data file that our website stores on your device and accesses each time
you visit, helping us understand how you use our site. This allows us, for example, to
remember your preferences and serve you content aligned with your interests.
At any time, you may decline cookies from our site if your browser permits. Most browsers
allow you to adjust settings to refuse all or some cookies. Your ability to limit cookies
depends on your browser settings and capabilities. Please note that disabling cookies
may a ect certain features or functionality of our website.
BUSINESS TRANSFERS
If we or our assets are acquired, or in the unlikely event that we undergo business rescue
or provisional liquidation, data (including personal information) may form part of the
assets transferred to the acquiring or successor entity. You acknowledge that such
transfers may occur and that any entity which acquires us may, to the extent permitted
by applicable law, continue to use your personal information in accordance with this
Privacy Policy, which it will be required to assume as the basis for any ownership or use
rights we have in respect of such information.
LIMITS OF OUR POLICY
Our website may contain links to external websites that are not operated by us. Please be
aware that we have no control over the content or policies of those sites and cannot
accept responsibility or liability for their respective privacy practices. We encourage you
to review the privacy policies of any third-party sites you visit before submitting any
personal information.
CHANGES TO THIS POLICY
We may, in our sole discretion, update or modify this Privacy Policy from time to time to
reflect changes in our business processes, industry best practices, or legal and
regulatory requirements. Any changes will be posted at the same link through which you
accessed this Privacy Policy.
If the changes are material, or if required by applicable law, we will notify you (based on
your selected communication preferences) and our registered users, and provide links to
the updated policy. Where required by law, we will obtain your consent or provide you
with an opportunity to opt in or opt out of any new uses of your personal information.
LEGAL BASES FOR PROCESSING YOUR PERSONAL INFORMATION
We will only collect and use your personal information where we have a lawful basis to
do so. We will always process personal information lawfully, fairly, and in a transparent
manner. The main legal grounds on which we rely are:
1. Consent
Where you have given us your explicit consent to collect and use your personal
information for one or more specific purposes. You may withdraw your consent at any
time, subject to legal or contractual restrictions, by using the contact details provided in
this Privacy Policy. Withdrawal of consent will not a ect the lawfulness of processing
based on consent before its withdrawal.
For example, when you contact us, you may consent to us using your name and email
address so that we can respond to your enquiry.
2. Performance of a Contract or Transaction
Where processing is necessary for the performance of a contract or transaction to which
you are a party, or in order to take preparatory steps at your request prior to entering into
such a contract or transaction. For example, we may require your name and contact
details to respond to a service enquiry or to create and manage your account.
3. Our Legitimate Interests
Where processing is necessary for our legitimate interests or those of a third party,
provided that such interests are not overridden by your rights and freedoms. Our
legitimate interests may include:
• Providing, operating, and improving our services
• Understanding our audience and how our services are used
• Marketing and promoting our services (in line with applicable law)
• Conducting research and development
• Ensuring the security and integrity of our systems and operations
• Protecting our legal rights and interests
4. Statutory and Regulatory Compliance
In some instances, we may have a legal obligation to collect, use, or retain your personal
information. Examples include:
• Complying with court orders, subpoenas, or other legal processes
• Responding to statutory or regulatory requests
• Fulfilling recordkeeping obligations imposed by law
If you have further queries about how we rely on legal bases to process and retain
personal information, you may contact us using the details in the “Contact Details”
section of this Privacy Policy.
CONTROLLING YOUR PERSONAL INFORMATION
Restricting processing
You have the right to request that we restrict the processing of your personal information
if:
1. You are concerned about the accuracy of your personal information;
2. You believe your personal information has been unlawfully processed;
3. You need us to maintain the information solely for the purpose of a legal claim; or
4. We are in the process of considering your objection to processing based on our
legitimate interests.
Objecting to processing
You have the right to object to the processing of your personal information where it is
based on our legitimate interests or on a public-interest ground. If you object, we will only
continue processing if we can demonstrate compelling legitimate grounds that override
your interests, rights, and freedoms, or where processing is required for the
establishment, exercise, or defence of legal claims.
Data portability
You may have the right to request a copy of the personal information we hold about you
in a structured, commonly used, and machine-readable format. Where technically
feasible and lawful, you may also request that we transfer this information to a third party
in writing.
Deletion (right to be forgotten)
You may have the right to request that we delete the personal information we hold about
you. We will take reasonable steps to delete your personal information from our current
records, subject to legal or legitimate business grounds for retention. Where an exception
applies, we will inform you of the reasons why we cannot fully comply with your request.
Please be aware that search engines and similar third parties may retain cached or
archived copies of your personal information that has been publicly available (for
example, profile information or public comments), even after the information has been
removed from our services.
DO NOT TRACK
Some web browsers o er a “Do Not Track” (DNT) feature that signals to websites that you
do not want your online activity tracked. At this time, we do not respond to DNT signals.
We will continue to apply the standards set out in this Privacy Policy and will only collect
and process personal information lawfully, fairly, transparently, and for legitimate, legal
purposes.
COOKIES AND PIXELS
You may decline cookies from our site where your browser permits this. Most browsers
allow you to configure settings to refuse all or some cookies and similar technologies.
Your ability to limit cookies is determined by your browser settings.
We may also use tracking technologies such as pixels (also known as web beacons) in
conjunction with cookies to measure the e ectiveness of our communications and
understand usage patterns across our services.
OUR INFORMATION OFFICER
Information O icer: Danvir Haridass
Email: popia@clandestine-group.com
THE SOUTH AFRICAN INFORMATION REGULATOR
You have the right to lodge a complaint with the Information Regulator of South Africa.
Information Regulator (South Africa)
PO Box 31533, Braamfontein, 2017
27 Stiemens Street, Braamfontein
(You may refer to the Information Regulator’s o icial website for the most up-to-date
contact details.)
“The Clandestine Group (Pty) Ltd (hereinafter referred to as ‘TCG’)”
1: PRIVACY POLICY
The Clandestine Group (Pty) Ltd (hereinafter referred to as “TCG”)
E ective Date: 01 January 2025
1. INTRODUCTION
Your privacy is important to us. TCG is committed to respecting your personal information
and complying with all applicable laws and regulations governing its collection, use, and
protection. This Privacy Policy applies to all personal information collected across our
website, www.clandestinegroup.com, and any related websites, platforms, or services
operated by TCG.
“Personal information” refers to any data that can be used to identify you, including (but
not limited to) your name, contact information, identity details, payment details, and
information relating to your use of our website.
Where our website contains links to third-party sites, please note that those sites operate
independently and maintain their own privacy policies. Once you navigate away from our
site, this Privacy Policy no longer applies.
2. INFORMATION WE COLLECT
2.1 Voluntarily Provided Information
Information you knowingly and actively provide, including when you:
• Register an account
• Contact us
• Submit forms, requests or enquiries
2.2 Automatically Collected Information
Information automatically sent by your device, including:
• IP address
• Browser type and version
• Pages visited
• Dates and times of access
• Time spent on each page
• Error reports and related technical diagnostics
While this information may not identify you on its own, it may be possible to combine it
with other data to personally identify you.
3. PERSONAL INFORMATION WE MAY REQUEST
We may ask for personal information, including (but not limited to):
• Full name
• Email address
• Phone or mobile number
• Other contact or identification details as required
4. LEGITIMATE REASONS FOR PROCESSING
We collect and process personal information only where we have a legitimate and lawful
reason, including:
• Providing our products or services
• Operating our website
• Internal administration, recordkeeping and compliance
• Security and fraud prevention
We only collect information that is reasonably necessary for these purposes.
5. COLLECTION AND USE OF INFORMATION
We may collect information when you:
• Register for an account
• Access our website via any device
• Communicate with us
• Interact with TCG on social media
We may use this information to:
• Provide our services and core features
• Communicate with you
• Maintain secure systems
• Improve website functionality and user experience
• Conduct internal analytics and administrative operations
We may combine voluntarily provided information with data from trusted sources,
including marketing or research datasets, to enhance your experience on our site.
6. SECURITY OF PERSONAL INFORMATION
We take commercially acceptable measures to protect your personal information against
loss, theft, unauthorised access, disclosure, copying, or modification. However, no
electronic storage or transmission method is fully secure.
7. DATA RETENTION
We retain your personal information only for as long as necessary to fulfil the purposes
set out in this Privacy Policy or to comply with legal obligations.
When no longer required, information will be deleted or de-identified unless retention is
justified for:
• Legal or regulatory compliance
• Accounting or reporting
• Research or historical archiving (where permissible by law)
8. CHILDREN’S PRIVACY
Our services are not directed at minors, and we do not knowingly collect personal
information from anyone under the age of 18.
9. DISCLOSURE OF PERSONAL INFORMATION
We may disclose personal information to:
• TCG parent, subsidiary or a iliated entities
• Service providers (hosting, IT, analytics, marketing, legal, payment processors)
• Employees, contractors, and agents
• Business partners and professional advisors
• Credit bureaus and debt collectors
• Courts, tribunals or regulatory authorities
• Law enforcement, where required
• Successors in title in the event of a merger, acquisition, sale, business rescue, or
liquidation
We take reasonable steps to ensure third parties are bound by confidentiality and data
protection obligations.
10. YOUR RIGHTS
You have the following rights over your personal information:
10.1 Access
Request details of the personal information we hold about you.
10.2 Correction
Request correction of inaccurate, incomplete or outdated details.
10.3 Restriction
Request limited processing in specific circumstances.
10.4 Objection
Object to processing based on legitimate interests.
10.5 Data Portability
Request a machine-readable copy of your personal information or its transfer to a third
party, where lawful and technically feasible.
10.6 Deletion
Request deletion of your personal information, subject to lawful retention requirements.
10.7 Marketing
Withdraw your consent to receive marketing communications at any time.
10.8 Complaints
Lodge a complaint with TCG or the South African Information Regulator.
11. USE OF COOKIES AND TRACKING TECHNOLOGY
We use cookies and similar technologies to:
• Improve your site experience
• Remember preferences
• Analyse site usage
• Enhance performance
You may decline cookies via your browser settings. Disabling cookies may a ect
functionality.
12. DO NOT TRACK
We do not currently respond to Do Not Track (DNT) signals.
We continue to apply the protections described in this Privacy Policy.
13. BUSINESS TRANSFERS
If TCG undergoes a merger, acquisition, restructuring, business rescue, sale of assets, or
liquidation, your personal information may be transferred to the acquiring entity, which
will continue to process it in accordance with this Privacy Policy.
14. LIMITS OF THIS POLICY
We are not responsible for the privacy practices of third-party websites linked to or from
our site. Please review their policies before submitting personal information.
15. CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time. Material changes will be
communicated where required by law. Continued use of our website constitutes
acceptance of the updated policy.
16. OUR INFORMATION OFFICER
Danvir Haridass
Email: popi@Clandestinegroup.com
17. SOUTH AFRICAN INFORMATION REGULATOR
Information Regulator (South Africa)
27 Stiemens Street, Braamfontein
PO Box 31533, Braamfontein, 2017
END OF PRIVACY POLICY
WEBSITE TERMS & CONDITIONS OF USE
The Clandestine Group (Pty) Ltd (hereinafter referred to as “TCG”)
1. INTRODUCTION
These Terms and Conditions (“Terms”) govern your use of the TCG website located at
www.Clandestinegroup.com and all associated websites (“the Website”). By accessing
or using the Website, you agree to be bound by these Terms. If you do not agree, you must
immediately discontinue use.
Your use of this Website must be lawful and must not involve:
• Committing a criminal o ence
• Gaining unauthorised access to systems
• Uploading or transmitting malicious, unlawful, or abusive content
• Interfering with website functionality
2. ELECTRONIC COMMUNICATIONS
By using the Website or communicating with TCG electronically (including email, online
forms, or any digital platform), you consent to receiving communications electronically
and acknowledge that all agreements, notices, and disclosures satisfy any legal
requirement for written communication.
Emails and attachments may contain confidential or privileged information. If received in
error, you must notify the sender and permanently delete the communication.
3. AMENDMENTS TO TERMS
TCG may amend, modify, or update these Terms at any time. Changes become e ective
when posted on the Website. Continued use constitutes acceptance of the amended
Terms.
4. COPYRIGHT & INTELLECTUAL PROPERTY RIGHTS
All content on the Website, including text, graphics, images, software, videos, audio,
publications, designs, trademarks, and data compilations (“Content”), is owned by TCG,
its a iliates, or third-party licensors.
You may not copy, distribute, modify, publish, or reproduce any Content without prior
written consent from TCG or the lawful owner.
Third-party links are provided for convenience. TCG does not endorse or control external
sites and is not responsible for their content or data-protection practices.
5. LIMITATION OF LIABILITY
The Website and all Content are provided “as is” without warranty of any kind. TCG does
not guarantee the accuracy, reliability, completeness, or suitability of the Content.
To the maximum extent permitted by law:
• TCG is not liable for any direct, indirect, consequential, or special damages arising
from your use or inability to use the Website or linked websites.
• TCG makes no representation that the Website is error-free, secure, or
uninterrupted.
6. PRIVACY
You may visit the Website without submitting personal information. Personal information
is collected only with your knowledge or consent, in accordance with TCG’s Privacy
Policy.
Usage information collected may include:
• Date and time of visits
• Pages viewed
• IP addresses
• Referring websites
• Device and browser data
Such information may be used to improve site performance and user experience.
Cookies may be used. You may reject cookies via your browser settings.
7. SOCIAL MEDIA PLUG-INS
When you visit a page containing a social media plug-in (e.g., Facebook, Instagram,
LinkedIn), your browser may automatically connect to the respective network, even if you
do not interact with the plug-in.
If you are logged into that social network:
• Information may be linked to your profile.
• Social networks may store information about your visit.
We encourage you to review the relevant social networks’ privacy policies.
8. GOVERNING LAW
These Terms are governed by the laws of the Republic of South Africa.
Any disputes shall be resolved in the High Court of South Africa.
If any provision of these Terms is found unenforceable, the remaining terms will continue
to apply.
These Terms constitute the entire agreement between you and TCG regarding website
use.
9. CONTACT DETAILS
The Clandestine Group (Pty) Ltd
Attention: Mr. Danvir Haridass
Telephone: tbc
Email: danvir@clandestine-group.com / popi@clandestinegroup.com