1Introduction
1.1This is the Privacy Policy of AlphaCode, a division of Rand Merchant Investments Limited (“we”, “our” or “us”). This Privacy Policy applies to the personal information of users of the AlphaCode website, available at: www.alphacode.club (the "Website"), and their associated entities, our members and our suppliers (collectively “you”) and aims to help you understand how we handle personal information when you interact with us through any medium. This is because we respect your privacy rights and comply with all laws in respect of the handling of your personal information; including collection, use, storage, sharing and disposal.
1.2This document does not apply to any third party websites which may be accessible through links on the Website. We make no representations or warranties about the privacy practices of any third party and we do not accept any responsibility for the privacy practices of, or content displayed on, third party websites. Third party website providers are responsible for informing users about their own privacy practices.
2What personal information do we handle?
2.1When used in this Privacy Policy, the term personal information, has the meaning given to it in the Protection of Personal Information Act, 2013 (POPI).
2.2Generally speaking, it refers to any information about an identifiable, living, natural person, such as your name and surname, date of birth, contact details (e.g. your home address, postal address, e-mail address or phone number), and other information that can be used to identify you or is held in association with information that can be used to identify you.
2.3Personal information also includes any information about an identifiable juristic person or other legal entity (such as a company or trust) and includes registration numbers, registered addresses, financial information, and other information that can be used to identify the juristic person or legal entity or is held in association with information that can be used to identify the juristic person or legal entity.
2.4Personal information that we may collect from you when you apply to become a member, interact with us or use the Website may include:
(1) your name, surname, identity/passport number, citizenship, home address, occupation, contact details email address, date of birth, gender, unique identifier, profile picture, Skype name, LinkedIn address, Twitter handle , Facebook address, and Website URL;
(2) a list of your partners, suppliers, customers, financiers and personnel, a description of your financial situation, your business plans, and Broad-based Black Economic Empowerment certificates where applicable; and
(3) if applicable, your associated entity’s name, registration number, address, contact details, Skype name, LinkedIn address, Twitter handle, Facebook address, Website URL, business plans, information regarding the founding of the associated entity, its digital and physical presence, the products or services which it offers and the industry that the associated entity is part of, the founding team's names and roles, details of the board members, whether the associated entity has a revenue, the revenue band that the associated entity generally falls into, the associated entity’s BEE status, whether the associated entity has funding and, if so, the details of that funding and a secondary person's name and surname and their designation.
(4) Log information that we may require includes your “site activity information”, such as details of how, when and for how long you accessed and used the Website and other site traffic and usage information, URLs, which pages you accessed, the number of pages viewed and the order of those pages, the amount of time spent on those pages, the number of clicks, which videos you watched, when and for how long you watched them, how you interacted with other Website users, and exit pages (i.e. sites which you navigated to when leaving the Website).
2.5We may also obtain, from you, the personal information of third parties that you wish to allow to use your member benefits. You must ensure that you are permitted to disclose your associated entity’s information and the information of these third parties to us.
2.6We and our employees, directors or agents will not be liable for, and you indemnify and hold us harmless against, any loss or harm, direct, indirect or consequential, arising from, or connected to the disclosure to us, by you, of your associated entity’s information and the information of these third parties.
3How do we collect your personal information?
3.1We collect your personal information directly from you in several ways. These include:
(1)when you access or use the Website;
(2)when you apply to become a member of the AlphaCode Club and during the course of your membership;
(3)when you visit us or use the facilities or other benefits offered or made available by us;
(4)when you communicate with us in any way; and
(5)when you submit personal information to us for any other reason, or authorise third parties to do so.
3.2We also collect your personal information from third parties, including credit bureaus and any public information sources.
3.3Some of the information we receive from you is personal information, and some is non- personal information that becomes personal if it is connected to you or to another person or legal entity. In some circumstances we will de-identify, anonymise or segregate information so that we may make use of it in aggregate form without treating it as personal information.

How do we use your personal information?

3.4We use the information we collect to:
(1)provide, maintain, and improve the AlphaCode Club, the Website and the facilities, services, products and content we provide or make available, to develop new services, and to protect our services and our users.
(2)to provide you with information and to fulfil your requests;
(3)to consider your applications for membership of the AlphaCode Club;
(4)to establish, verify or authenticate your identity; to administer and operate the AlphaCode Club and the member benefits;
(5)to maintain and update our own or our affiliates’ customer, or potential customer, databases;
(6)to diagnose and deal with technical issues, and other queries;
(7)to detect, prevent or deal with actual or alleged fraud, security or the abuse, misuse or unauthorised use of the AlphaCode Club, the Website, member benefits and/or contravention of this Privacy Policy;
(8)to conduct market research surveys, research and development;
(9)to provide you with the latest information about the AlphaCode Club, or the facilities, products, services, events and other member benefits on offer, subject to your communications preferences;
(10)to communicate with you and maintain records of our communications with you, which also includes to inform you about any changes to the AlphaCode Website, our products and services and the member benefits, or changes to the terms and conditions of any agreement we have with you;
(11)to fulfil or enforce any contractual obligations we may have to you or any third party;
(12)to improve the AlphaCode Club and improve your user experience and the overall quality of the member benefits and the AlphaCode Club;
(13)to compile, use, disclose and trade with non-personal statistical information about users and members or the Website, and about habits, patterns, preferences, and demographics which we may use to develop, provide, administer and improve the AlphaCode Club, the Website and member benefits;
(14)for security and administrative;
(15)to meet legal or other regulatory obligations imposed on it;
(16)to update our records; and
(17)for other activities not specifically mentioned that are lawful, reasonable, and relevant to our activities, provided that we will comply with applicable laws in doing so.
4What happens if we are not permitted to collect your personal information?
4.1What happens if we are not permitted to collect your personal information?
(1)accept you (or your associated entity) as a client or member and provide our products or services to you or your associated entity;
(2)provide you with our publications, brochures and newsletters;
(3)invite you to events; or
(4)customise the content of the Website according to your preferences for a more enjoyable experience.
5Sharing of personal information
5.1We will not sell and will not intentionally disclose your personal information to third parties other than as set out in this Privacy Policy below or with your permission.
5.2We may disclose personal information:
(1)to our affiliates, which includes our holding companies and subsidiaries, for purposes of reporting to them on the activities of the AlphaCode Club and telling them who our members are. We will ensure that these affiliates are bound to honour the requirements of this Privacy Policy;
(2)to our affiliates, which includes our holding companies and subsidiaries, and trusted third parties acting exclusively at our instruction, and who are bound to honour the requirements of this Privacy Policy;
(3)to our employees, contractors, suppliers and agents if and to the extent that they need to know such information in order to process it for us; to provide products or services for or to us; to make benefits available to you, and/or to deal with matters related to your membership of the AlphaCode Club or your use of the member benefits and facilities.
(4)to any third party who acquires (or proposes to acquire) ownership or control of our assets, shares or management, or that of our affiliates, whether by sale, merger, acquisition or otherwise, and/or to any third party from who we acquire (or propose to acquire) ownership or control of assets, shares or management, whether by purchase, merger, acquisition or otherwise, subject to confidentiality provisions consistent with this Privacy Policy;
(5)to governmental agencies, stock exchanges and other regulatory or self-regulatory bodies if we are required to do so by law or if we reasonably believe that such action is necessary to:
(a)comply with the law or with any legal process;es, stock exchanges and other regulatory or self-regulatory bodies if we are required to do so by law or if we reasonably believe that such action is necessary to:
(b)protect and defend the rights, property or safety of the Website, the AlphaCode Club, our affiliates or our customers, employees, contractors and agents or any third party;
(c)detect, prevent or deal with actual or alleged fraud, security or technical issues or the abuse, misuse or unauthorised use of our site and/or contravention of this privacy policy; and/or
(6)protect the rights, property or safety of members of the public;
(7)to our insurers and our professional advisors, including accountants, business advisors and consultants; and
(8)to any other juristic or natural person for any authorised purpose with your express consent.
6Transfer of your personal information to other countries
6.1We generally store your personal information on our own servers or in those of service providers that we retain to enable our services across jurisdictions.
6.2Where your personal information is transferred outside of South Africa, your rights will continue to be respected. If the location to which personal information is transferred does not have substantially similar data protection law to that of South Africa, we will take all reasonable steps to ensure that your transferred personal information is kept secure and receives a similar level of protection as that which it receives in South Africa.
7Security
7.1We take appropriate and reasonable technical and organisational measures to ensure that the personal information is protected from misuse and loss and from unauthorised access, modification or disclosure.
7.2Even by taking these and other confidential measures when processing personal information, no company can ever guarantee that any system is 100% secure, only that we are using reasonable means to keep it safe while it is in our custody.
7.3Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.
8Storage of your personal information
8.1We may retain all personal information that we collect from you so long as it remains necessary for the purposes for which it was collected.
8.2Personal information is destroyed or de-identified when no longer needed or when we are no longer required by law to retain it (whichever is the later).
9Direct marketing
9.1We may use your personal information to send you details of new products and services, news updates, and invitations to events.
9.2These communications may be sent in various forms (including by post and by email) in accordance with applicable marketing laws. If you indicate a preference for a method of communication, we will endeavour to use that method where it is practical to do so.
9.3All of these communications will include information detailing the process of unsubscribing from (or opting out of) receiving the communications if you no longer wish to receive promotional material from us.
10How can you access and correct your personal information?
10.1You have the right to contact us at any time requesting:
(1)confirmation that we have your personal information;
(2)access to the records containing your personal information or a description of the personal information that we hold about you;
(3)the identity or categories of third parties who have had, or currently have, access to your personal information.
10.2When making a request we require adequate proof of identity which will include providing a certified copy of your identity / registration documents.
10.3We will try to provide users with suitable means of accessing information, where you are entitled to it, by for example, posting or emailing it to you.
10.4There may be instances where we cannot grant you access to your personal information. For example, if your access would interfere with the privacy of others or would result in a breach of confidentiality, we may need to refuse access. If we refuse access, we will give written reasons for our refusal.
10.5If you believe that any personal information that we hold about you is inaccurate, irrelevant, outdated, incomplete or misleading, you may request us to correct it by completing the form prescribed by law. If you believe that any personal information that we hold about you is excessive or has been unlawfully obtained or that we are no longer authorised to retain the information, you may request that we destroy or delete it by completing the form prescribed by law. We will consider if the information requires correction, deletion or destruction and if we do not agree that there are grounds for action, you may request that we add a note to the personal information stating that you disagree with it.
10.6We may charge a reasonable fee to cover its administrative and other reasonable costs in providing the information to you. We will not charge for simply making the request or for making any corrections to the personal information.
11Unlawful access to your personal information
11.1If you believe that your personal information has been unlawfully accessed or acquired, you may contact us using the contact information below and provide details of the incident so that we can investigate it.
11.2We will treat your complaints confidentially (unless otherwise required by law), investigate those complaints and aim to ensure that those complaints are resolved within a reasonable time.
12Changes to this Privacy Policy
12.1We may change this Privacy Policy from time to time. If we do so, we will post the revised Privacy Policy on the Website and, you will be requested to agree to any changes when you log into the Website.
13Queries
13.1If you have questions about this Privacy Policy or any general concerns, or if you would like to lay a complaint regarding the treatment of your personal information or a possible breach of your data privacy, please contact our Information Officer using the details set out below:
Email: info@alphacode.club