PRIVACY POLICY

1. This Privacy Policy sets out the manner in which Lightstone Consumer Proprietary Limited (Registration Number: 2001/013329/07), with registered address at 3rd Floor, Sasfin House, 56 Mangold Street, Newton Park, Port Elizabeth ("MyEcho") collects, uses, shares and protects information in connection with the Services (as described more fully in clause 2 below), provided on http://www.my-echo.co.za ("the Website").
2. This Privacy Policy is in addition to the Terms of Use published on the Website.
3. This Privacy Policy applies when any person accesses, uses or visits any portion of the Website. Should any person that accesses the Website or makes use of the Services ("you" or "User") disagree with any of the terms of this Privacy Policy, you must refrain from accessing the Website and/or using or participating in the Services.
4. If you are under the age of 18, you must obtain your parents' or legal guardians' authorisation, permission and consent to be bound by this Privacy Policy before using or participating in the Services.
5. If you are acting on behalf of any juristic person, voluntary association, trust or any other collection of persons, corporate or incorporate, you warrant your authority to act on behalf of such person or persons and you agree to this Privacy Policy on behalf of such person or persons.

MyEcho provides services aimed at compiling usable, meaningful information ("Content") for Survey Creators from raw data gathered from persons identified by the Survey Creators to participate in a survey ("Survey Participants"). MyEcho and the Website act as a conduit through which the Survey Creators create surveys and send them to Survey Participants. The Survey Creators assume responsibility for obtaining consent from Survey Participants to be contacted, and for providing information (such as e-mail addresses or telephone numbers) of Survey Participants which allow them to participate in the surveys.

1. http://www.my-echo.co.za/contact

1. Users accept the terms of this Privacy Policy by clicking or tapping on a button which indicates the User’s acceptance hereof, by executing a document which references the Privacy Policy, or by using or participating in the Services.
2. MyEcho reserves the right, in its sole discretion, to amend and/or replace any of, or the whole of, the Privacy Policy. Such amendments shall supersede and replace any previous Privacy Policy and shall be made available on the Website. Each time a User accesses the Website and/or uses the Services, the User shall be deemed to have consented, by such access and/or use, to the Privacy Policy, as amended and/or replaced by MyEcho from time to time. If you are not satisfied with the amended Privacy Policy, you should refrain from accessing the Website or by using the Services.
3. If there is anything in this Privacy Policy that you do not understand then please contact us as soon as possible. Please see clause 3 above for contact details. Please note that calls to us are charged at national rates and may be monitored for training, security and quality assurance purposes.

1. "Personal information" is information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person, including, but not limited to
   1. information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, wellbeing, disability, religion, conscience, belief, culture, language and birth of the person;
   2. information relating to the education or the medical, financial, criminal or employment history of the person;
   3. any identifying number, symbol, email address, physical address, telephone number, location information, online identifier or other particular assignment to the person;
   4. the biometric information of the person;
   5. the personal opinions, views or preferences of the person;
   6. correspondence sent by the person that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence;
   7. the views or opinions of another individual about the person; and
   8. the name of the person if it appears with other personal information relating to the person or if the disclosure of the name itself would reveal information about the person.
2. Any personal information gathered about any person for the purposes of the Services shall be used only in as far as it is necessary to conduct the Services.
3. Notwithstanding anything else in this Privacy Policy, personal information may be disclosed to a third party if:
   1. the disclosure of the record would reveal evidence of:
      1. a substantial contravention of, or failure to comply with, the law; or
      2. imminent and serious public safety or environmental risk;
   2. the public interest in the disclosure of the record clearly outweighs the harm contemplated in the provision in question;
   3. the personal information has been de-identified to the extent that it cannot be re-identified again;
   4. the disclosure is justified in light of national security, including activities that are aimed at assisting in the identification of the financing of terrorist and related activities, defence or public safety; or
   5. the disclosure is made to a public body, the purpose of which is the prevention, detection, including assistance in the identification of the proceeds of unlawful activities and the combating of money laundering activities, investigation or proof of offences, the prosecution of offenders or the execution of sentences or security measures, to the extent that adequate safeguards have been established in legislation for the protection of such personal information.

1. We may collect the following information from any person who accesses the Website or uses or participates in the Services:
   1. USAGE DATA: Whenever you interact with the Services, we collect usage data from you. This may include which webpages you visit, what you click on, when you performed such actions etc.
   2. DEVICE INFORMATION: Information from the device (computer, smartphone, tablet etc.) and application (browser) which you use to access the Services or compile or complete surveys which may include the IP address and operating system. Your geographical information may also be inferred based on your IP address.
   3. REFERRAL DATA: information about the source that referred you to a survey. This may be a link on a website, e-mail or text message.

1. A cookie is a small string of information that the website you visit transfers to your computer for identification purposes. The information we receive from cookies is not personal, or connected to surveys. It helps the website to remember information about your visit, like your preferred language and other settings Cookies can be used to follow your activity while accessing the Website or using the Services and that information helps us to understand your preferences and improve your experience.
2. For a simple explanation on how companies use cookies, watch this video.

1. The information that MyEcho collects in accordance with clauses 6 and 7 is used to review, investigate and analyse how to improve the way in which the Services are provided. Your information may also be used to monitor, maintain and improve our Services and the Website.
2. We perform statistical and other analysis on information collected to analyse and measure User behaviour and trends, to enable us to understand how people use the Services and to monitor and improve the Services and to identify and solve problems on the Website.
3. We may use your information to keep the Services secure and operational, through conducting tests in order to prevent abusive activity such as fraud, spam and phishing activities.

1. MyEcho and the Survey Creator are ‘responsible parties’ for the purpose of the Protection of Personal Information Act 4 of 2013 ("the POPI Act"). Accordingly, both MyEcho and the Survey Creator are responsible to ensure that any use or processing of your information is done in accordance with the POPI Act.
2. Your personal information will be used only in so far as it is necessary to conduct the survey as created by the Survey Creator.

1. We collect certain information directly from you:
   1. REGISTRATION INFORMATION: This is information related to your MyEcho account which you create before creating surveys, and may include your e-mail address, username and password etc.
   2. BILLING INFORMATION: Where payment is required for your use of the Services, certain billing information is required, such as a name, address, e-mail address and financial information and any additional or ancillary information needed in order for you to affect payment to MyEcho.
   3. ACCOUNT SETTINGS: The personal preferences which you can change in order for you to use the Services, such as your language and location settings.
   4. SURVEY DATA: Contact details of prospective Survey Participants, and responses received from Survey Participants.
   5. OTHER DATA: Any other data which you volunteer to MyEcho.
2. We collect certain information about you from other sources:
   1. SURVEY RESPONSES: Survey Participants may, by virtue of participating in the surveys provide us with information about you.
   2. Any such information as set out in clause 6 above.

1. All information related to surveys, including contact details of Survey Participants and the survey responses will be treated as private to you, provided that you may elect to make the survey responses public.
2. We will not share any information related to surveys with any third party, except:
   1. for providing the Services you requested and for which MyEcho collaborates with third parties;
   2. when we receive express instructions from you;
   3. where it is required as provided for in clause 5.3 above.
3. Your data will be retained only for the purposes of completing the survey.
4. If a Survey Participant informs Lightstone that such person has been contacted without consenting thereto as per clause 14 below, MyEcho may at their sole and absolute discretion delete any and all information related to such Survey Participant.

1. MyEcho and the Survey Creator are ‘responsible parties’ for the purpose of the Protection of Personal Information Act 4 of 2013. Accordingly, both MyEcho and the Survey Creator are responsible to ensure that any use or processing of your information is done in accordance with the POPI Act.
2. Your personal information will be used only in so far as it is necessary to conduct the survey as created by the Survey Creator.

1. Your privacy is very important to us. We will only contact you if you have consented to be contacted for marketing purposes. Consent must be obtained from you by the Survey Creator.
2. In addition to consenting to be contacted for marketing purposes, you must also consent to your personal information being entered into the Website. This allows the survey to be transmitted to you in order for you to participate in a survey. You may be contacted in a variety of ways, as surveys are conducted on a variety of platforms.
3. Even if you have consented to being contacted for marketing purposes, there is no obligation on you to complete a survey or answer any specific questions, and participation in the survey is completely voluntary.
4. If you have not consented to be contacted, or if you have any objection to the manner in which you have been contacted, please contact MyEcho in accordance with clause 3 above.

1. We collect certain information directly from you:
   1. SURVEY DATA: Your responses to the Survey Creator’s survey. These are created by the Survey Creator who is responsible for the information created. If you have any further questions relating to the survey, please contact the Survey Creator, who is the person who requested that you complete the survey.
2. We collect certain information about you from other sources:
   1. FROM THE SURVEY CREATOR: The information needed to contact you for the purpose of conducting a survey has been entered into the Website by the Survey Creator. This must have been done with your consent as set out in clause 14 above. This information will typically include an e-mail address or phone number.
   2. Any such information as set out in clause 6 above.

1. Your data will be retained only for the purposes of completing the survey. Once the survey is completed, we will retain your information for a period of 5 years, unless you authorise us to retain same to contact you for further feedback.
2. Once your information is destroyed, it will be in a form which cannot be identified in any way.
3. If MyEcho has been advised that the consent to be contacted as required by clause 14 above is lacking, all personal information will be destroyed as soon as reasonably possible.
4. If you have provided adequate proof of your identity, you will have the right to:
5. 1. request MyEcho or a Survey Creator to inform you whether or not either party hold any personal information about you; and
   2. request MyEcho or the Survey Creator to provide you with a record or a description of the personal information about you which is currently held by either Lightstone or the Survey Creator; provided that the request will not be complied with if:
      1. the personal information related to you has been de-identified;
      2. disclosure of the personal information would involve the unreasonable disclosure of personal information about a third party, including a deceased individual;
      3. disclosure of the personal information would disclose commercial information of a third party, the disclosure of which would cause such a third party harm;
      4. disclosure would constitute an action for breach of a duty of confidence owed to a third party in terms of an agreement.
      5. disclosure could reasonably be expected to endanger the life, physical safety or physical integrity of an individual, a building or similar structure, a method of transport.

1. Any personal information will be de-identified before any further processing is done with reference to such information, subject to clause 17.2 below.
2. Your personal information will not be used in any form of further processing unless you have consented thereto. This consent will have to be obtained by the Survey Creator in accordance with clause 14 above.