LAST UPDATED: February 8, 2017
ReturnX Digital (Pty) Ltd


1. Your Privacy 

This privacy policy (this “Privacy Policy”), as amended from time to time, applies to (“Website”) or any other online product or service to which you have access or use as well as any Account (defined below) you use to access the Website or other online products or services (together, the "Service") offered by ReturnX Digital (pty) ltd or any of its subsidiaries and affiliates (collectively, “we”, “us”, “our ” or "ReturnX"). ReturnX respects the privacy rights of its visitors and users (collectively, “Users”, “you” or ”your”) and is committed to protecting Users’ information collected through the Service. ReturnX has adopted this Privacy Policy to explain how ReturnX collects, stores, and uses information collected in connection with the Service. 


2. Information We Collect & How We Use It 

ReturnX may collect and use both personal and non-personal data from Users using the Service. This section of the Privacy Policy will describe the type of information that may be collected and how the information may be used. 

2.1. Personal Data 

  2.1.1. “Personal Data” Definition For the purposes of this Privacy Policy, “personal data” means personally identifiable information that specifically identifies you as an individual and includes those items specifically listed below. 

  2.1.2. Registering for an Account
Users may make personal data such as their name, date of birth, address, gender, username, password and email address available to ReturnX when they register for an account on the Service (an “Account”). 

  2.1.3. Use of the Service 
ReturnX may collect, store and use personal data such as name, email address, name, IP address to optimize use of the Service and the content presented to Users, to provide technical support and respond to Users’ inquiries, when Users subscribe to newsletters or other updates from ReturnX and in connection with use of the Service where personal data is required, including to leave reviews (where the first name and country of residence will be displayed) and to post on the Service’s Forum (where the username will be displayed).

  2.1.4. Other Purposes 
Additionally, ReturnX may collect, store, and use personal data such as name, username and email address to solicit Users’ feedback to help improve the Service and other ReturnX products, inform Users about new products or promotional material offered by ReturnX or its trusted third party business partners and affiliates, notify Users about changes to the Service or other products, provide Users with advertising and marketing material from ReturnX and its trusted business partners and communicate with Users for other commonly accepted purposes such as notifying them that they are a potential winner of a contest. Finally, ReturnX may collect and use personal data as required or permitted by applicable law. 

  2.1.5. Mobile Devices 
If Users access the Service on mobile and tablet devices, ReturnX may collect mobile device identifiers, including MAC Address and IP Address, and ReturnX may assign to your device an identifier that is similar to an account number. ReturnX may collect the name you have associated with your device, device type, telephone number, country, and any other information you choose to provide, such as user name, character name, geo-location or e-mail address. We may also access your contacts to enable you to invite friends to join you in the Service. 

  2.1.6. Data Storage
ReturnX may store and/or transfer your personal data outside of South Africa in accordance with applicable legislation and this Privacy Policy. 

  2.1.7. Third Party Privacy Policies 
ReturnX may make available links through advertisements or otherwise enable you to access third party products or services. While using such products or services, you are using products or services that are not affiliated with or controlled by ReturnX. ReturnX is not responsible for those people or companies, the content of their products or services, the use of information you provide to them, or any products or services they may offer. Providing links or otherwise enabling access to third party products or services does not constitute sponsorship of, or affiliation with those people or companies. You recognize and agree that ReturnX is not liable for a third party’s use of your personal data and you should review the privacy policies of these third parties. 

  2.1.8. User Generated Content
Users may contribute user generated content (“User Generated Content”) to the Service, including but not limited to, reviews, ratings, forum posts, chat posts, profiles, messages, and information that displays or displayed in any Account. Any information which Users choose to disclose when contributing User Generated Content to the Service is public information and there is no expectation of privacy or confidentiality. ReturnX is not responsible for any personal data you choose to make public on the Service. 

  2.1.9. Minors 
Users must be eighteen (18) years or older to register for an Account to use the Service. ReturnX does not knowingly collect any personal data from persons under the age of eighteen (18) years of age. In the event that ReturnX learns that it has inadvertently collected or stored personal data from persons under the aforementioned age without the consent of their legal guardian, ReturnX will take reasonable measures to promptly erase such personal data from its records. 

2.2. Non Personal Data 

  2.2.1. Definition
For the purpose of this Privacy Policy, “non-personal data” means information that does not directly identify you.

  2.2.2. Trusted Partners and Contractors 
ReturnX may use and disclose to its affiliated companies, contractors or other trusted businesses or persons the collected non-personal data for the purpose of auditing, researching and analyzing usage of the Services, ensuring the technical functionality of ReturnX’s Services and to further develop the Services and other ReturnX products. 

  2.2.3. Cookies, Beacons and Tracking 
ReturnX may use “cookies” and other technologies such as pixel tags, locally shared objects, clear GIFs and web beacons. ReturnX treats information collected by cookies and similar technologies as non-personal data. A “cookie” is a small bit of record-keeping information that is sent to the Users’ computer. ReturnX’s cookies do not include personal data and may be used to: (1) facilitate Users’ login authentication, (2) help Users navigate around the ReturnX’s websites, (3) monitor how many people are using the Service, and (4) store Users preferences and track trends. Most browsers are initially set up to accept cookies, but you can disable cookies or set your browser to indicate when a cookie is being sent. However, disabling cookies may affect your ability to use the Service.
ReturnX may also use Flash cookies (locally shared objects) and HTML5 storage (locally stored objects). Locally shared objects are small files similar to browser cookies and are used to remember your settings to personalize the look and feel of the Service. Locally shared objects only collect data in the aggregate. You may prevent locally shared objects from being placed by disabling locally stored objects in your browser or by visiting Locally stored objects, such as HTML5 Web Storage, are used for similar purposes as cookies but typically may contain a greater amount and different types of data than browser cookies. ReturnX may also use web beacons and pixel tags to count Users who have visited certain pages or viewed certain advertisements. Web beacons, like cookies, do not include personal data. E-mails and other electronic communications ReturnX sends to you may contain pixel tags that enable ReturnX to track your usage of the communication, including whether the communication was opened and/or what links were followed. 

  2.2.4. Server Logs 
ReturnX’s servers may log information about your use of the Service, such as: (1) your search activity, pages viewed, the date and time of activity; and (2) any information provided by your computer or mobile device in connection with your use of the Service, such as your browser type, browser language, IP address, mobile carrier, unique device identifier, location, and requested and referring URLs. 

3. Who We Disclose Personal Data To 

3.1. Disclosure of Personal Data 
ReturnX does not sell, rent, share or trade personal data with third parties for their direct marketing purposes. However, in providing the Service, ReturnX may disclose personal data to other companies or individuals in the following limited circumstances: 

 3.1.1. If ReturnX Media receives your consent; 
 3.1.2. If ReturnX Media has a good faith belief that access, use, preservation or disclosure of such personal data is reasonably necessary to: 

   a) satisfy any applicable law, regulation, legal process or enforceable governmental request;

   b) enforce applicable Terms of Use including investigation of potential violations thereof; 

   c) detect, prevent, or otherwise address fraud, security or technical issues; 

   d) protect against imminent harm to our rights and/or property; or 

 3.1.3. As required or authorized by applicable law. ReturnX reserves the right to contact you by email under the following limited circumstances: 

   a) If a company that receives a review provides a public reply on the website; 

   b) From time to time, and as may be required, to provide any necessary updates in relation to the service. You authorise and acknowledge that companies may use the website to reply to user reviews, and companies may also opt to receive a notification by email when a review is left for their survey panel or website. 

3.2. Data Processing
ReturnX may also disclose personal data to its affiliated companies, contractors or other trusted businesses or persons for the purpose of processing personal data on its behalf. ReturnX requires that these parties agree to process such personal data based on ReturnX’s instructions and in compliance with the Privacy Policy and any other appropriate confidentiality and security measures. 

3.3. Sale of Business
As ReturnX continues to develop and grow, we may buy or sell parts of a business, which could include personal data as one of the transferred business assets. If ReturnX becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, it will provide notice before personal data is transferred and becomes subject to a different privacy policy. 

4. Choices for Personal Data

If ReturnX proposes to collect, use or disclose personal data for any purpose other than those described in this Privacy Policy, ReturnX will obtain the Users’ prior consent or offer the Users an effective way to opt out of the use of personal data for those other purposes. You may choose to withdraw your consent to the use, collection or disclosure of your personal data as outlined in this Policy at any time. If a User withdraws his or her consent, then ReturnX may no longer be able to provide the same level of Service. Users are also given the opportunity to “opt-out” of having their personal data used for specific purposes such as receiving newsletters or other information from ReturnX. Withdrawals of consent will not have an effect on personal or other data that ReturnX has used or disclosed in accordance with this Privacy Policy prior to such withdrawals. 

5. Information Security

ReturnX takes appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. 

6. Accuracy and Access/Control over Personal Data

ReturnX processes personal data only for the purposes for which it was collected and in accordance with this Policy. ReturnX may take reasonable steps to ensure that the personal data processed is accurate, complete and current, but ReturnX is not responsible for verifying the correctness of personal data. ReturnX will allow you to access your personal data in the custody or control of ReturnX, and you may request that ReturnX: 

   1) update or correct such personal data; 
   2) change your preferences with respect to communications and other information received from ReturnX; or 
   3) delete your personal data on ReturnX’s primary system, by submitting a request to Customer Support. ReturnX will use commercially reasonable efforts to honor your request. ReturnX may retain an archived copy of your records as required by law of for legitimate business purposes. Such updates, corrections, deletions and changes are only effective as of the date they are made and will not effect other information that ReturnX maintains (including archived data and other back-ups), or information that ReturnX has provided to third parties in accordance with this Privacy Policy, prior to such update, correction, deletion or change. 

7. Retention of Personal Data 

ReturnX stores personal data collected pursuant to this Privacy Policy only as long as is reasonably required to fulfil the purposes for which it was collected or as required or authorized by law. ReturnX may still retain some of the data to the extent such retention is necessary to resolve disputes, enforce ReturnX’s user agreements, and comply with technical and legal requirements and constraints related to the security, integrity and operation of the Service. 

8. Changes to this Policy 

ReturnX reserves the right to modify this Privacy Policy from time to time, so please review it frequently. If ReturnX makes material or significant changes to this Privacy Policy, ReturnX will post the amended Privacy Policy on, or within, the Service or on our Website along with the date it was last modified. Your continued use of the Service will signify your acceptance of the changes to this Privacy Policy. 

9. Contact Information 

Should you have any questions relating to this Privacy Policy, please contact us.