BlackBooks Privacy Policy
This Privacy Policy applies to all users of our website, related Mobi-sites and software applications,
collectively referred to as “the Application/Solution”, which are used to access and purchase our
products and services.
The purpose of this Privacy Policy is to set out how, why and when Bokamoso Advisory Services (Pty)
Ltd (“Bokamoso”) uses your Personal Information on the BlackBooks’ platform to comply with the
Protection of Personal Information Act 4 of 2013 (“POPI”).
You must read this Privacy Policy together with our terms and conditions, privacy notices or policies we
may provide from time to time when we collect or use your Personal Information.
Please pay special attention to the clauses in this Privacy Policy that appear in similar text and style
which:
✓ may limit the risk or liability of Scryba or a third party.
✓ may create risk or liability for the user.
✓ may compel the user to indemnify Scryba or a third party.
✓ serves as an acknowledgement, by the user, of a fact.
We respect your privacy and take the protection of Personal Information very seriously. We strive to
deliver excellent service every time you use our platform and to do this, we need to use some of your
Personal Information. This Privacy Policy describes how we handle the Personal Information we collect
about you and/or receive from you. By using our Application/Solution, you agree to the processing of
your Personal Information as set out in this Privacy Policy.
In this Privacy Policy, the terms -
• “Personal Information”, and “process/processing” bear the same meanings as set out in
POPI.
• “we”, “us” or “our” refers to Scryba.
• “you” and “your” refers to every person that accesses or uses our Application/Solution also
referred to as a user.
• “registered user(s)” refers to anyone registered on our Application/Solution and has provided
us with a unique email address and password as well as other Personal Information to make
use of our Application/Solution.
What Personal Information We Collect and Process
Scryba processes Personal Information in a manner that is reasonable, adequate, relevant, non-
excessive and purpose-specific. For users to access and use our Application/Solution we collect and
process some Personal Information. When you become a registered user, we have to collect and
process your Personal Information to render our services to you.
When you register to use our Application/Solution, we may collect the following Personal Information:
• name and surname.
• email address.
• physical address.
• Company details (name, registration number).
• mobile phone number.
Should your information change or you wish to amend and/or correct this Personal Information you can
do this by updating your registered user information in your account profile.
You warrant that the information you have provided is accurate, current, true and correct and that does
not impersonate or misrepresent any person or entity or falsely state or otherwise misrepresent your
affiliation with anyone or anything.
Information from using our Application/Solution.
When you access our Application/Solution, whether you are a registered user, BlackBooks processes
some of your Personal Information. Depending on how you access and use our Application/Solution,
we may receive:
• log information, through online identifiers, including information on how, when and for how long
you use our Application/Solution and other services, the content you view and search queries
you submit.
• information about the equipment you use to access or use our Application/Solution, including
the type of device you are using, how you access our Application/Solution, your browser or
operating system and your Internet Protocol address.
• the geographic location from which you accessed our Application/Solution, including your
device’s global positioning system signal and information about nearby WIFI networks and cell
towers. We get this information when you use location-enabled services.
• other information about you from third parties, such as social media.
Why Do We Process Your Personal Information?
We process the Personal Information we collect and receive to:
• identify you;
• verify your identity;
• create a user account for you; and/or
• enter into a contract with you.
As a registered user, we also process your Personal Information to:
• Allow you access to our platform so you can perform the necessary task you have
subscribed to our platform for.
• Provide you with information, products or services you request from us.
• Communicate with you regarding our Application/Solution and provide you with
information, products or services, including billing, customer support, resolving complaints
and quality control.
• Notify you about changes to our Application/Solution, services and products, terms and
conditions, privacy policy or notices, and any other changes that impact our
Application/Solution, services and products.
• Send you information about competitions, products or services that may interest you
(unless you have opted out of receiving such information).
• Get feedback from you on which we need to develop our products and services and grow
our business.
• Comply with any legal or regulatory obligations such as tax or financial laws.
• Undertake research for statistical purposes. The research and statistics we get from this
process do not include your Personal Information and cannot be linked to you, nor can
you be identified from these statistics.
Retention and Restriction of Records
We keep your Personal Information for as long as:
• We need it to provide our products/services to you.
• As required or allowed by law and is in line with our internal retention policies.
• As necessary to uphold the contract between you and us.
• You have agreed to us keeping your personal information subject to your request for us to stop
processing your Personal Information.
We will retain your Personal Information for as long as is necessary to achieve the purpose for which
this information was collected or subsequently processed. If your Personal Information is used for more
than one purpose, we will retain it until the purpose with the latest period expires but we will stop using
it for the purpose with a shorter period once that period expires.
By accessing and using the Platform, you consent to us retaining records of your Personal
Information for no longer than may be necessary to achieve the purpose for which the
information was initially collected or subsequently processed.
USER TRACKING AND COOKIES
When you access and use our Application/Solution we may use various technological tools to improve
your experience on our websites using cookies and/or user tracking.
Cookies are small text files placed on the device that you use to access our Application/Solution. These
files do not contain your Personal Information but allow us to associate you with a particular device.
Many websites use cookies and we use cookies to:
• Make our Application/Solution more user-friendly.
• Personalise your interactions with our Application/Solution, tailor our services and
Application/Solution to your interests and needs, and ensure they work on your device.
• Provide advertising that is relevant to you, limit the number of times you see the same
advertisement and measure the effectiveness of the advertisements on our Application/Solution
and other websites, based on your online activities such as the websites and apps you use or
content you view, and information we have about you.
• Send Opt-In marketing communication if you are not a registered user.
We will not use your Personal Information for any other purpose without your permission.
By accessing and using the Platform, you consent to our use of cookies.
Opt-Out from Direct Marketing
You have the right to request us not to contact you for purposes of direct marketing by any form of
electronic communication such as automatic calling machines, email and/or SMS notifications by
“opting out” of any direct marketing communications we may send to you.
Who Else Gets to Process Your Personal Information?
We do not sell your Personal Information to third parties for their marketing or any other purposes.
We may provide or make your Personal Information available to:
• Our employees, the staff of Bokamoso Advisory Services (Pty) Ltd and/or third-party service
providers to enable them to assist us to interact with you via our Application/Solution for service
delivery to you.
• Law enforcement, government officials, fraud detection agencies or other third parties when
the disclosure of Personal Information is necessary or appropriate in connection with an
investigation of fraud, intellectual property infringements, or other activity that is illegal or may
expose us to legal liability or financial loss, to report or support the investigation into suspected
illegal activity.
• Third parties (such as a potential purchaser and its professional advisors) in the event of any
reorganisation, merger, consolation, sale, joint venture, or other disposition of any or all of our
assets.
• Our service providers (under contract with us) who help with parts of our business operations
(fraud prevention, marketing, public relations, technology services etc). However, our contracts
dictate that these service providers may only use your Personal Information in connection with
the services they perform for us and not for their benefit or any other purpose and must treat
such information as confidential information.
• Our suppliers or sellers for them to liaise directly with you regarding any goods you have
purchased, for them to comply with their regulatory obligations, or for any other purpose which
may require their involvement.
• The companies under the control of Bokamoso Advisory Services (Pty) Ltd for them to send
you once-off opt-in direct marketing communications.
Sending Your Personal Information Outside South Africa
We may transfer certain Personal Information outside the geographic borders of South Africa
to service providers for purposes set out above (Why we process your Personal Information?),
including for data storage and backup purposes to ensure the integrity of our systems.
When we transfer your Personal Information outside of the geographic borders of South Africa,
we will ensure that we do so per the requirements for lawful transfer outside of South Africa as
set out in POPI.
By accessing and using our Application/Solution, you consent to us transferring your Personal
Information outside of South Africa as set out in POPI.
Securing Your Personal Information
We secure the integrity and confidentiality of your Personal Information in our possession or under our
control by taking appropriate, reasonable technical and organisational measures to prevent loss of,
damage to or unauthorised destruction of Personal Information; and unlawful access to or processing
of Personal Information.
To implement and maintain such measures, we have in place policies, controls and related processes,
which are reviewed and updated regularly. Our policies, controls and procedures cover for example:
• Physical, technical and network security.
• Access controls and monitoring of access.
• Secure storage, destruction and encryption of records of Personal Information.
• Personal Information breach reporting and remediation.
• By way of written agreements, imposition of security and confidentiality obligations on third
parties (based within or outside the borders of South Africa) who process Personal
Information as part of rendering services to us.
Should you disclose your Personal Information to any third party other than BlackBooks,
BlackBooks shall not be liable for any loss or damage arising or suffered by you as a result of
the disclosure of such Personal Information to any third party. This is because we do not
regulate or control how that third party uses your Personal Information. You should always
ensure that you read the privacy policy of any third party.
Know Your Rights
Having provided adequate proof of your identity, you have the right to:
• View, correct and/or amend your Personal Information we process. Please note that as a
registered user, you can do this through your user account for the Personal Information
reflected therein.
• Request a record or description of your Personal Information. Scryba may charge a fee
to provide you with this record of your Personal Information. Where requests to access and
amend your Personal Information are manifestly unfounded, excessive or repetitive
Scryba may charge an additional administrative fee or refuse the request.
• Request to have your Personal Information corrected, destroyed or deleted. Please note that
you can stop being a registered user by cancelling your subscription. In this instance,
BlackBooks will only retain your Personal Information subject to any legislative
requirement and/or our internal retention policy.
• Scryba complying with your requests upon receipt unless we have a credible reason why
we cannot comply.
• Scryba indicating where, if we cannot agree whether to correct or delete your Personal
Information as requested, a correction or deletion was requested but was not made.
• Inform you if reasonably practicable, should we change your Personal Information, and this has
an impact on decisions about you.
• Notify you of the action taken by us because of your request.
• Notify you of unauthorised access to your Personal Information.
• Provide you with reasonable evidence of our compliance with our obligations under this Privacy
Policy on reasonable notice and request.
• Submit a complaint to the Information Regulator.
As a registered user, you can exercise all your rights set out above in terms of POPIA by going to
the settings - about section of our Help Centre.
As any other user, you can exercise all your rights as set out above by referring to our process set out
in our PAIA Manual.
How To Lodge a Complaint with The Information Regulator?
If you have any complaints about this Privacy Policy or our compliance with this Privacy Policy you can
complain to the Information Regulator.
The contact details of the Information Regulator are available on its website at:
https://justice.gov.za/inforeg/
This version of the Privacy Policy replaces any preceding privacy policy provisions on our website. We
may occasionally update this Privacy Policy. When you use our Application/Solution the version of the
Privacy Policy posted on this page applies to you.
