Privacy Policy

Willow Creek Olive Estate t/a Mont Rouge Olives

The Information Officer recommends the adoption of the policy:

Note: 

This policy is supported or expanded on by way of other policies recorded in the Willow Creek Olive Estate‘s POPI Compliance Manual.

1. PRIVACY POLICY STATEMENT

1. Willow Creek Olive Estate t/ Mont Rouge Olives is committed, in line with the Protection of Personal Information Act, No 4 of 2013 (“POPI Act”), to protecting the privacy of all its data subjects (such as you), and which in particular include all members, customers, employees, service providers or members of the public with whom Mont Rouge Olives interacts. 

2. Personal information is information that personally identifies you (e.g. telephone number, name, address, transaction history etc.) (“Personal Information”), but, depending on the purpose for which it is required, may include more sensitive information, such as biometrical information and financial information. This policy describes how and why we collect, store, use, share or otherwise process your Personal Information. It also explains your rights in relation to your Personal Information and how to contact us if you have a question or complaint. 

3. Any information that is freely available or accessible in the public domain or furnished under the PAIA or any other law shall not be regarded as sensitive Personal Information. 

4. This Policy is applicable to Personal Information collected by Willow Creek Olive Estate directly from data subjects or through the Willow Creek Olive Estate’s website, online portals, electronic communications and information collected by Mont Rouge Olive’s server from the data subject’s browser.

5. This Privacy Statement only applies to Willow Creek Olive Estate t/a Mont Rouge Olives. It does not apply to other online or offline websites, products or services. Please read the complete Privacy Policy.

6. You may be required as a pre-condition for access to the Willow Creek Olive Estate / Mont Rouge Olives website or for any other type of interaction with ABR, to accept the terms of this Privacy Policy or any other policy or procedure enforced to safeguard Personal Information.

7. This Privacy Policy is subject to the POPI Act and the eight conditions described therein for the protection of Personal Information. 

2. COLLECTION OF YOUR PERSONAL INFORMATION

1. Personal Information collected by Willow Creek Olive Estate may include a wide range of information, depending on the requirements of a function, service, or product provided directly, or in relation you. 

2. Depending on the circumstances, Willow Creek Olive Estate may typically collect and process, but not necessarily limited to, the following Personal Information about you:

1. Your name and contact information, including your email address, telephone number, physical address, postal address and other location information; 

2. Your date of birth, age, gender, race, nationality, title and language preferences;

3. Your identity number, passport number and photograph;

4. Your vehicle registration number, vehicle licence and driving licence; 

5. Your biometric information, including but not limited to, if applicable, that information obtained from your fingerprints, hands, facial recognition and/or retinal scanning; 

6. Your banking and other financial details; 

7. Your employment details; 

8. Correspondence from you of a private or confidential nature; 

9. such other personal information as is reasonably required by us to engage with you and/or provide services to you.

3. Willow Creek Olive Estate may collect or obtain Personal Information about you in various ways, including, but not necessarily limited to: 
   1. from you directly;
   2. during the course of our interactions with you; 
   3. when you visit the Olive Estate; 
   4. when you visit and/or interact with our website or any other social media platforms or IT services; 
   5. from publicly available sources; and 
   6. from a third party who is authorised to share that information; 
   7. via a mobile or other software app developed for the Olive Estate; 
   8. optional information that you voluntarily provide to us. 

3. USE OF YOUR PERSONAL INFORMATION

1. Willow Creek Olive Estate’s use of the Personal Information depends on the relationship we have with you. The POPI Act requires that Personal Information “is collected for a specific, explicitly defined and lawful purpose related to a function or activity of the responsible party.” 

2. Willow Creek Olive Estate uses your personal information for the following, not necessarily exhaustive list of purposes:

1. To effectively and efficiently provide, and deliver, Willow Creek Olive Estate products and services to you;
2. To maintain internal records as per regulatory guidelines;
3. To comply with all laws, regulations, policies and procedures applicable to Willow Creek Olive Estate;
4. For recognition of the customer when he/she conducts online banking;
5. To understand the needs and provide relevant product and service offers;
6. To ensure our website is relevant to your needs;
7. To assist us to create and publish content most relevant to you;
8. To alert or inform you of products, services, updated or new information with regard to Willow Creek Olive Estate;
9. To allow you access to limited-entry areas of our website as appropriate.

3. Should Willow Creek Olive Estate / Mont Rouge Olives wish to use your Personal Information for any other reason, we will provide you with an opportunity to decline this service or such use.

4. AWillow Creek Olive Estate may merge site-visitation data with anonymous demographic information for research purposes, and we may use this information in aggregate to provide more relevant content. 
5. In some limited-entry sections of Willow Creek Olive Estate’s website, we may with your prior approval, combine site-visitation data with your Personal Information in order to provide you with personalised content. If you decline permission, Willow Creek Olive Estate will not provide you the personalised service and won’t merge your Personal Information with site-visitation data.

6. Willow Creek Olive Estate may from time-to-time contract other entities to provide services or products on its behalf, and will only provide those entities the Personal Information they need to deliver the service or product. They will be prohibited from using such Personal Information for any other purpose.

7. Depending on the circumstances, Willow Creek Olive Estate may disclose your Personal Information to the following categories of persons: 

1. Auditors, legal and other professional advisers and consultants of Willow Creek Olive Estate or other third parties and service providers who assist us to deliver products or services, including the Willow Creek Olive Estate’s marketing agents, employees, the board of directors and all of its committees; 
2. Information technology and other service providers who assist Willow Creek Olive Estate to operate the Olive Estate or otherwise manage or store the personal information; 
3. Government and law enforcement authorities; 
4. Financial institutions; 
5. Affiliated entities;
6. Other third parties where disclosure is required by law or otherwise required for us to perform our obligations and provide our products and services; and 
7. To any other person with your consent to the disclosure.

8. Willow Creek Olive Estate and Mont Rouge Olives may disclose your Personal Information if required to do so by law or in the good-faith belief that such action is necessary to:

1. conform to the edicts of the law or comply with legal processes served on Willow Creek Olive Estate;
2. protect and defend the rights or property of Willow Creek Olive Estate and its website; or
3. act in urgent circumstances to protect the personal safety of Willow Creek Olive Estate’s employees, members, users of our products or services or members of the public.

4. CONTROL OF YOUR PERSONAL INFORMATION 

1. Willow Creek Olive Estate will take reasonable steps to protect the confidentiality and security of your Personal Information when it is disclosed to a third party and will seek to ensure that such third-party deals with your information in accordance with our instructions, applicable privacy laws, and only for the purpose for which it is disclosed.

2. When you register on our website, or otherwise give us Personal Information, Willow Creek Olive Estate will not share that Personal Information with third parties without your permission, other than for the limited exceptions already listed, and will only be used for the purposes stated above.

3. Willow Creek Olive Estate may send out periodic e-mails informing you of technical service or security issues related to a product or service you requested, or confirming that you requested a product or service. You will not be able to choose to unsubscribe to these mailings, as they are considered an essential part of the service you have chosen.

5. ACCESS TO YOUR PERSONAL INFORMATION

1. Willow Creek Olive Estate will provide you with the means to ensure that your Personal Information is correct and current.

2. Some services offered on Willow Creek Olive Estate’s website may collect information. However, in such cases, you can access your Personal Information by contacting Willow Creek Olive Estate as described at the bottom of this statement.

6. SECURITY OF YOUR PERSONAL INFORMATION

1. Willow Creek Olive Estate t/a Mont Rouge Olives is committed to protecting the security of your Personal Information. We use a variety of security technologies and procedures to protect your Personal Information from unauthorised access, use, disclosure, destruction or alteration. 

2. Willow Creek Olive Estate for instance stores the Personal Information you provide in computer servers with limited access that are located in controlled facilities. The transmission of sensitive information (such as a credit card number) over the internet, is protected through the use of encryption.

3. Data transmission across the internet is inherently insecure and therefore, although Willow Creek Olive Estate strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee that your Personal Information will always remain private.

7. PROTECTION OF CHILDREN’S PERSONAL INFORMATION

Willow Creek Olive Estate has a general audience website and may as a consequence collect Personal Information from children, along with other forms of interaction in the rendering of services and products. To the extent that Personal Information is collected and processed from children, such will be done in terms of the POPI Act and Willow Creek Olive Estate’s Child Protection Policy for Personal Information.

8. ACCURACY

Willow Creek Olive Estate will endeavour to keep Personal Information accurate, complete, and up to date as may be required for its use and Willow Creek Olive Estate may accordingly from time to time request you to update your Personal Information. If at any time there is a reason to believe that Personal Information residing with Willow Creek Olive Estate is incorrect, the data subject should inform Willow Creek Olive Estate in this regard. Willow Creek Olive Estate shall correct the erroneous information as quickly as possible.

9. RETENTION 

Willow Creek Olive Estate will only retain your Personal Information for as long as it is necessary to fulfil the purposes for which it was obtained, or to comply with applicable legal, tax or accounting requirements. Willow Creek Olive Estate maintains a Document Retention Policy for this purpose.

10. PERSONAL INFORMATION OUTSIDE SOUTH AFRICA. 

1. Information that you provide may be hosted and stored in countries internationally, or Willow Creek Olive Estate may in certain instances transmit or transfer Personal Information outside South Africa, and where such a foreign country’s data protection laws may not be the same as those that are in force in South Africa. 

2. When Willow Creek Olive Estate transmits Personal Information to a foreign country, we will take appropriate safeguards to protect your Personal Information to ensure that the recipient will handle the information in a manner consistent with this policy and the level of protection provided for in the POPI Act.

3. Willow Creek Olive Estate may offer goods or services to European Union residents, and hence the European Union’s General Data Protection Regulation (“GDPR”) may in such instances apply in the processing of Personal Information.  A comforting fact for European customers, is the deliberate synergy that already exists between the POPI Act and the GDPR, and which makes this Privacy Policy already compliant.  

In the application of this Privacy Policy, we will nevertheless continue to consider the implications of the GDPR in the processing of Personal Information of EU customers.

11. USE OF COOKIES

1. When someone visits the Willow Creek Olive Estate / Mont Rouge Olives website, a cookie may be placed on the visitor’s machine (if the visitor accepts cookies) or is read if the visitor has visited the site previously. The use of cookies is to assist in the collection of the site visitation statistics described above.

2. Willow Creek Olive Estate may also use cookies to collect information on which newsletter links are selected by visitors. This information is used to ensure that we are sending information which users want to read. It is collected in aggregate form and never linked with your Personal Information, unless with your prior consent.

3. Web beacons, also known as clear gif technology, or action tags, may be used to assist in delivering the cookies on our site. This technology tells us how many visitors selected key elements (such as links or graphics) on Willow Creek Olive Estate’s website. We do not use this technology to access your personally identifiable information on our website. It is merely a tool we use to compile aggregated statistics about Willow Creek Olive Estate’s website usage. We may share aggregated site statistics with partner companies, but do not allow other companies to place clear gifs on our website.

4. If you choose to not have your browser accept cookies from Willow Creek Olive Estate’s website, you will be able to view the text on the screens, however you will not experience a personalised visit nor will you be able to subscribe to the service offerings on the site.

12. YOUR RIGHTS 

1. You have the right to request, from us, a description and/or record of your Personal Information that we hold. Depending on the format required, provision of this information may be subject to the payment of a reasonable administrative fee to be determined by Willow Creek Olive Estate and the supply of appropriate evidence of your identity. 

2. If you wish to update your Personal Information or if you want us to delete your Personal Information entirely, please send us a written request to addressee as set out below, or in the Contact Us section of our website along with your full contact details. Please note that we will not delete Personal Information that we are required to retain for our business operations or for legal compliance. 

3. You may be given the option to “opt out” of receiving any direct marketing from us by clicking on the “unsubscribe” link, failing which we can direct such request to the Information Officer at the contact details provided below. 

4. If a data subject does not wish to provide consent for usage of its Personal Information or later withdraws the consent, Willow Creek Olive Estate shall have the right not to provide services or to withdraw the services for which the information was sought from the data subject.

5. Should you believe that we have not complied with the POPI Act in the processing of your Personal Information, you have the right to contact the Information Regulator in this regard. The Information Regulator can be contacted by email: inforeg@justice.gov.za or by telephone: 012 406 4818. 

6. You may at any time object to the processing of your Personal Information by submitting such objection to the Information Officer at the contact details provided below. The same applies to the exercising of any of your other rights and the submitting of any queries regarding the Personal Information that we hold about you.

13. THIRD PARTY WEBSITES 

Willow Creek Olive Estate may permit third parties to link to this website or to post a link to their website on ours. Unless expressly stated otherwise, we have no control over and accept no responsibility for the privacy practices of any third-party websites to which links may have been provided and we recommend that you review the privacy policy of any website you visit before using that website. This privacy policy applies only to our website. 

14. CHANGES TO THIS PRIVACY POLICY 

From time to time and without notice, Willow Creek Olive Estate may amend to this Privacy Policy to reflect any changes to our privacy practices. When we do, we will also reflect the revision date at the top of the Privacy Policy. For material changes to this Policy, Willow Creek Olive Estate will place notifications thereon prominently on its website.

15. CONTACT INFORMATION

Willow Creek Olive Estate and Mont Rouge Olives welcomes your comments regarding this Privacy Statement, please contact us by e-mail or postal mail.  

This Privacy Policy is available on Mont Rouge Olive’s website at:  www.montrougeolives.com

Information Officer E-mail:         

onlineshop@montrougeolives.com

Deputy Information Officer Name:  

Mr Mikhail van der Sandt

Physical Address:                           

Willow Creek Olive Estate t/a Mont Rouge Olives,
Nuy Road Nuy Valley,
Worcester,
6851

Telephone:

+27 (0) 23 342 5793

Website: www.montrougeolives.com