Legal Frameworks


Customer Data Research and Development Privacy Policy

1. Introduction

This Digital Process Innovations Customer Data Research and Development Privacy Policy (also referred to as the ‘Privacy Policy’ or ‘policy’) informs data subjects (‘you’) on the collection and use (collectively referred to as ‘processing’ or ‘process’) of your personal information in connection with Digital Process Innovations’s artificial intelligence and machine learning (“AI/ML”) activities in order to analyze, develop, and improve Digital Process Innovations products and services, and for security and compliance purposes. This Privacy Policy also explains your privacy rights in relation to these processing activities.
This Privacy Policy was created on December 16, 2022. However, the Privacy Policy can change over time, for example to comply with legal requirements or to meet changing business needs. The most up-to-date version can be found on this site. In case there is an important change that we want to highlight to you, we will also inform you in another appropriate way (for example, via a pop-up notice or statement of changes on our website).

As used in this Privacy Policy, ‘personal information’ means information that relates to an identified individual or to an identifiable individual. For example, this could include among other things your name, address, email address, or information about your use of Digital Process Innovations products and services, or your interactions with Digital Process Innovations. Personal information about you that Digital Process Innovations may process is also referred to as ‘information about you.’ For more detail about the types of information about you that Digital Process Innovations may process, please refer to section 4 below.

Scope Of The Privacy Policy

The Privacy Policy applies to Digital Process Innovations’s processing of information about you that has been provided to Digital Process Innovations by Digital Process Innovations customers for AI/ML activities.

Who Is Responsible For Processing Your Personal Information?

Digital Process Innovations South Africa, Inc. is responsible for the processing of information about you as described in our Privacy Policy.

Personal Information Do We Process?

Digital Process Innovations may process personal information that may indirectly identify you, such as your IP address, as well as information that may directly identify you such as your name or email address.

Where Do We Source Your Personal Information?

Digital Process Innovations obtains information from Digital Process Innovations customers when agreed to by contract with those customers.

Why And How Do We Use Your Personal Information?

Digital Process Innovations uses personal information to analyse, develop, improve, and optimise the use, function and performance of Digital Process Innovations products and services to provide our customers with a more intelligent experience; to manage the security of our sites, networks and systems and the products and services Digital Process Innovations provides to our customers; and to comply with applicable laws and regulations and to operate our business.

How Will We Share Or Sell Your Personal Information?

Your personal information may be shared throughout Digital Process Innovations’ organization as necessary for the purposes of processing. Your personal information is not sold to or shared with third parties for any commercial purpose.

What Are Your Privacy Rights?

You have privacy rights for the information we process about you. You can object to our use of your personal information, delete or restrict your personal information, or access or correct your personal information.

How To Contact Digital Process Innovations IF You Have Any Questions, Comments OR Complaints?

If you believe your personal information has been used in a way that is not consistent with the Privacy Policy, please contact the Global Data Protection Officer.

Who Is Responsible For Processing Your Personal Information?

This Privacy Policy applies to Digital Process Innovations’s processing of personal information that Digital Process Innovations has obtained from a Digital Process Innovations customer when agreed to by contract with that customer to use such information for AI/ML processing for the purposes specified in this Privacy Policy.

3. Who Is Responsible For Processing Your Personal Information?

Digital Process Innovations is responsible for processing your personal information in scope of our Privacy Policy.

4. Which CATEGORIES And Specfic Pieces OF PERSONAL INFORMATION DO WE PROCESS?

Personal information that can directly or indirectly identify you may include, for example:
• Contact details: Name, email, phone number, mailing address, zip code;
•Company and employment data: your employment with and role within a company, including information related to such company such as company name, size, location, as well as publicly available company information and activity;
•Device information: Information related to a device interacting with Digital Process Innovations products, services, and websites including IP address, browser, device type, operating system, the presence or use of “apps”, screen resolution, preferred language;
•Interactions with Digital Process Innovations services or products: Information related to the use of Digital Process Innovations services and products, such as products and services purchased, subscriptions, features used or platform preferences, or performance of Digital Process Innovations services or products;
Digital Process Innovations may also collect customer and systems operations data, which may incidentally contain personal information:
•Customer data: Data provided by Digital Process Innovations customers (when agreed to by contract with the customer) such as transaction data, invoices or receipts, product inventory, and other customer-provided datasets;
•Systems operations: Information related to the use, operation, and performance of Digital Process Innovations systems such as log files, event files, and other trace and diagnostic files.

5. For What Commercial Or Business Purpose Do We Use Your Personal Information?

In cases where the processing of personal information is not central to the purposes of processing for the below AI/ML activities, Digital Process Innovations will limit the use of personal information when technically possible or feasible. ‘Dataset’ refers to a set of data that may contain this limited personal information.

•to analyse, develop, improve, and optimise the use, function and performance of Digital Process Innovations products and services to provide our customers with a more intelligent experience.
•to manage the security of websites, networks and systems and the products and services Digital Process Innovations provides to our customers; and
•to comply with applicable laws and regulations and to operate our business.

These purposes are described below in further detail. to analyse, develop, improve, and optimise the use, function and performance of Digital Process Innovations products and services to provide our customers with a more intelligent experience
Digital Process Innovations will use these datasets for internal research for technological development and demonstration and to improve, upgrade, or enhance Digital Process Innovations products and services to provide more intelligent, automated and predictive functionalities.
Example: Digital Process Innovations provides our eCommerce platform customers with flagging functionality that enables customers to see that inventory is low for a certain good in the customer’s product catalog. Using AI/ML processing under this Privacy Policy, Digital Process Innovations can now help predict when the inventory may be low in the near future so the customer can take action before the inventory becomes low.
•to manage the security of our sites, networks and systems and the products and services Digital Process Innovations provides to our customers
Digital Process Innovations processes datasets to detect, prevent, or predict malicious, deceptive, fraudulent, or illegal activity on Digital Process Innovations sites, networks, and systems, as well as on Digital Process Innovations products and services used by our customers. AI/ML activities, subject to this policy, allow Digital Process Innovations to provide more intelligent and predictive functionalities to investigate, prevent, or predict malicious activity, fraud, or bad actors.
•to comply with applicable laws and regulations and to operate our business

In some cases, we may process personal information to comply with applicable laws and regulations. For example, to respond to a request from a regulator or to defend a legal claim. We may also process personal information in the operation of our business.
Example: Digital Process Innovations may process the datasets to conduct audits and investigations, for finance and accounting, archiving and insurance purposes, or to process individual rights requests.

6. Categories of Sources OF Personal Information

Personal information subject to this Privacy Policy is provided to Digital Process Innovations from Digital Process Innovations customers when agreed to by contract with the customer.

7. For Information About You Collected In The EU/EEA, What is Our Legal Basis?

Digital Process Innovations will process information about you as may be necessary for internal research for technological development and demonstration and to improve, upgrade, or enhance Digital Process Innovations products and services based on our legitimate interests when such processing has a limited privacy impact on the individual.
Digital Process Innovations will process information about you as may be necessary to detect, prevent, or predict malicious, deceptive, fraudulent, or illegal activity on Digital Process Innovations sites, networks, and systems based on our legitimate interests in order for Digital Process Innovations to safeguard such systems.
Digital Process Innovations may also process personal information as necessary for compliance with our legal obligations.

8. For What Period Do We Retain Information About You?

Digital Process Innovations maintains personal information provided by Digital Process Innovations customers for processing to achieve the intended purposes described in this Privacy Policy for only as long as necessary, which is approximately 3 months but no longer than 12 months. Digital Process Innovations will maintain evidence of access, opt-out, or deletion requests as long as necessary to document Digital Process Innovations’s compliance with such requirements.

9. When and How Can We Share Your Personal Information?

Sharing within Digital Process Innovations As a global organization, information about you can be shared with other Digital Process Innovations entities globally throughout Digital Process Innovations’s worldwide organization as needed for the purposes of processing.
Digital Process Innovations employees are authorized to access personal information only to the extent necessary to serve the applicable purpose(s) and to perform their job functions.
Sharing with or selling with third parties We do not share or sell personal information subject to this Privacy Policy with third parties for any commercial purposes.
We may share such personal information with the following third parties for a business purpose:
•third-party service providers (for example, IT service providers, lawyers and auditors) in order for those service providers to perform business functions on behalf of Digital Process Innovations;
•relevant third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings);
•as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to government requests, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes.

10. How Is Personal Information Protected Globally?

Digital Process Innovations personal information processed globally will be protected as necessary in accordance with this policy. If personal information is transferred to a Digital Process Innovations recipient in a country that does not provide an adequate level of protection for personal information under applicable data protection law in the country where such information was collected, Digital Process Innovations will take adequate measures designed to protect the personal information, such as ensuring that such transfers are subject to EU Model Clauses or other adequate transfer mechanism as required under relevant data protection laws.

11. How Is Information About You Secured?

Digital Process Innovations has implemented appropriate technical, physical and organizational measures designed to protect personal information against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorized disclosure or access, as well as all other forms of unlawful processing.

12. Protection of Personal Information Act (POPIA)

For Business Partners and users located in South Africa, please take note of the following: In terms of section 1 of the Protection of Personal Information Act, 2013 (“POPI”), “personal data” or “personal information” includes “information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing, juristic person.”
The corresponding legal grounds and conditions for lawful processing of personal data in South Africa are contained in Sections 8 to 25 of POPI, and relate to “Accountability”; “Processing limitation”; “Purpose specification”; “Further processing limitation”; “Information quality”; “Openness”; “Security safeguards” and “Data subject participation”.
In terms of section 69 of POPI, the processing of personal information of a data subject for the purposes of direct marketing by means of any form of electronic communication, including automatic calling machines, facsimile machines, sms’s or e-mail is prohibited unless the data subject has provided consent to the processing, or is, subject to further conditions, an existing customer of the responsible party.
For purposes of a Data Subject exercising its rights further enquiries and the exercise of its rights in relation to access, objection to, and complaints in respect of the processing of personal data, the contact particulars of the Information Regulator of South Africa, are as follows:

JD House, 27 Stiemens St. Braamfontein. Johannesburg. 2001
PO Box 31533. Braamfontein. Johannesburg. 2017
Complaints: Complaints.IR@Justice.gov.za
General Enquiries: InfoReg@Justice.gov.za

Person Information From Children or Other Sensitive Personal Information? We do not knowingly process personal information of children under 16 years of age or personal information that is sensitive or “special” under applicable data protection laws.
Digital Process Innovations will not use the personal information processed under this policy to make decisions related to an individual’s eligibility for employment, credit, healthcare, or insurance purposes or to make decisions solely by automatic means where the decision has a legal or significant effect on the individual, or in any way that may or does discriminate against any person or promote bigotry, racism or harm.

14. How To Contact Digital Process Innovations If You Have Questions, Comments Or Compliants?

Digital Process Innovations has appointed a Global Data Protection Officer. If you believe your personal information has been used in a way that is not consistent with the Privacy Policy or your choices, or if you have further questions, comments or suggestions related to this Privacy Policy, or if you wish to exercise your right to access to your offline personal information as described in this Privacy Policy, please contact the Global Data Protection Officer by filling out an inquiry form.
Written inquiries to our Data Protection Officer may be addressed to:

1 Mark Shuttleworth Street. Office# M61. The Innovation Centre Building. The Innovation Hub Management Company (TIHMC). Tshwane. 0087.
Tel: +2712 844 0562, Switchboard: +2712 844 0000, Cell: +2784 390 1387. email: Banzi.Nkosi@DigitalProcessInnovations.co.za, web: https://www.digitalprocessinnovations.co.za

15. Filing a Compliant

If you have any complaints regarding our compliance with this Privacy Policy, please contact us by filling out a Contact Us Form. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with this Privacy Policy and in accordance with applicable law. You also have the right to file a complaint with a competent data protection authority if you are a resident of a European Union member state.


Corporate Headquarters

Digital Process Innovations’s corporate headquarters are located at:
1 Mark Shuttleworth Street. Office# M61. The Innovation Centre Building.
The Innovation Hub Management Company (TIHMC). Tshwane. 0087.
Tel: +2712 844 0562, Switchboard: +2712 844 0000, Cell: +2784 390 1387.
email: Banzi.Nkosi@DigitalProcessInnovations.co.za, web: https://www.digitalprocessinnovations.co.za

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