Privacy Policy

This Privacy Policy applies to all of the products, services and websites offered by COSA Media, its subsidiaries or affiliated companies.

INFORMATION WE COLLECT & HOW WE USE IT

We may collect the following types of information:

•   Log information – When you access our website services via a browser, application or other client, our servers automatically record certain information. These server logs may include information such as your web request, your interaction with a particular service, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser or your account.

•   User communications – When you send email or other communication to COSA Media, its subsidiaries or affiliated companies, we may retain the communication in order to process your inquiries, respond to your requests and improve our services. When you send and receive SMS messages to, or from one of our services that provides SMS functionality we may collect and maintain information associated with those messages, such as the phone number, the wireless carrier associated with the phone number, the content of the message, and the date and time of the transaction. We may use your email address to communicate with you about our services.

•   COSA Media, its subsidiaries or affiliated companies. Services on other sites – We offer some of our services on, or through other web sites. Personal information that you provide to those sites may be sent to COSA Media or its affiliates in order to deliver the service. We process such information under this Privacy Policy.

•   Third Party Applications – COSA Media, its subsidiaries or affiliated companies may make available third party applications, such as gadgets or extensions, through its services. If you enable a third party application, the information collected by COSA Media, its subsidiaries or affiliated companies is processed under this Privacy Policy. Information collected by the third party application provider is governed by their privacy policies.

•   Location data – COSA Media, its subsidiaries or affiliated companies may offer location-enabled services utilizing Maps and Latitude. If you use those services, COSA Media, its subsidiaries or affiliated companies may receive information about your actual location (such as GPS signals sent by a mobile device) or information that can be used to approximate a location (such as a cell ID).

•   Unique application number – Certain services on our sites may include a unique application number that is not associated with your account or you. This number and information about your installation (e.g., operating system type, version number) may be sent to COSA Media, its subsidiaries or affiliated companies when you install or uninstall that service or when that service periodically contacts our servers (for example, to request automatic updates to the software).

•   Other sites – This Privacy Policy applies to COSA Media, its subsidiaries or affiliated companies only. We do not exercise control over the sites displayed as search results, sites that include COSA Media, its subsidiaries or affiliated companies’ applications, products or services, or links from within our various services. These other sites may place their own cookies or other files on your computer, collect data or solicit personal information from you.

In addition to the above, we may use the information we collect to:

Provide, maintain, protect, and improve our services (including advertising services) and develop new services;

Protect the rights or property of COSA Media, its subsidiaries, affiliated companies or our users. If we use this information in a manner different than the purpose for which it was collected, then we will ask for your consent prior to such use;

COSA Media, its subsidiaries, or affiliated companies process personal information both on our servers in the Republic of South Africa, and in other countries.

CHOICES

Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some COSA Media, its subsidiaries or affiliated companies features and services may not function properly if cookies are disabled.

COSA Media, its subsidiaries or affiliated companies uses the DoubleClick advertising cookie on AdSense partner sites, as well as certain COSA Media, its subsidiaries or affiliated companies’ services, to help advertisers and publishers serve and manage ads across the web. You can view and manage your ads preferences associated with this cookie by accessing the Ads Preferences Manager. In addition, you may choose to opt out of the DoubleClick cookie at any time by using DoubleClick’s opt-out cookie.

INFORMATION SHARING

COSA Media, its subsidiaries or affiliated companies only share personal information with other companies or individuals outside of COSA Media, its subsidiaries or affiliated companies in the following limited circumstances:

•   We have your consent. We require opt-in consent for the sharing of any sensitive personal information.

•   We provide such information to our subsidiaries, affiliated companies or other trusted businesses, or persons for the purpose of processing personal information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.

•   We believe that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, (d) protect against harm to the rights, property or safety of COSA Media, its subsidiaries or affiliated companies, its users or the public as required or permitted by law.

If COSA Media, its subsidiaries or affiliated companies becomes involved in a merger, acquisition, or any form of sale of some, or all, of its assets, we will ensure the confidentiality of any personal information involved in such transactions and provide notice before personal information is transferred and becomes subject to a different privacy policy.

INFORMATION SECURITY

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices, security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data.

We restrict access to personal information to COSA Media, its subsidiaries or affiliated companies employees, contractors and agents who need to know that information in order to process it on our behalf. These individuals are bound by confidentiality obligations and may be subject to disciplinary action, including termination and criminal prosecution, if they fail to meet these obligations.

ACCESSING & UPDATING PERSONAL INFORMATION

When you use COSA Media, its subsidiaries or affiliated companies services, we make an effort to provide you with access to your personal information. Cosa Media undertakes to correct this data if it is inaccurate, or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests. We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Because of the way we maintain certain services, after you delete your information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems. Please review the service Help Centers for more information.

ENFORCEMENT

COSA Media, its subsidiaries or affiliated companies regularly review its compliance with this Privacy Policy. When we receive formal written complaints, it is COSA Media, its subsidiaries or affiliated companies policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between COSA Media, its subsidiaries or affiliated companies and an individual.

Changes to this Privacy Policy

Please note that this Privacy Policy is subject to change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any Privacy Policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.


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