Privacy Policy

Data privacy policy

This data privacy policy sets out how COFCO International South Africa uses and protects any information that you give COFCO International South Africa when you use this website.

Overview

At COFCO International South Africa (CIL SA, we, our or us), we are committed to protecting the confidentiality, accuracy and integrity of any Personal Information you provide to us. We always strive to safeguard such data from misappropriation, loss, misuse, unauthorized access, disclosure and/or alteration. We only collect personal information (as defined in South Africa’s data protection law, the Protection of Personal Information Act 4 of 2013 (POPIA)) that is relevant for our described purposes, as described herein. This Privacy Policy describes what types of information we gather and track when you use our websites and/or visit some of our offices, or otherwise provide personal information to us, how this information is used and with whom it is shared. If you have any questions about this Privacy Policy, please contact us.

Please note that, where applicable, defined terms in this Privacy Policy have the same meaning as those defined in POPIA.

COFCO International South Africa (Pty) Ltd (registration number 2003/030380/07) and Standerton Oil Mills (Pty) Ltd (registration number 2011/008659/07) will be the Responsible Parties and our nominated representatives in relation to this Privacy Policy.

COFCO International has appointed a Global Data Protection Officer, who can be reached at [email protected]. You can also review our global Privacy Policies available at /data-privacy-center/.

By providing Personal Information to CIL SA, you agree to the terms and conditions of this Privacy Policy.

Scope

This Privacy Policy describes which Personal Information CIL SA collects, the purpose of the processing of such data as well as the rights that Data Subjects have regarding use of Personal Information. This notice also describes how you can contact us about our data protection practices.

Which Personal Information CIL SA collects

CIL SA processes Personal Information  in accordance with applicable data protection laws and only for limited, explicit and legitimate purposes and to the extent needed to perform its business. CIL SA will not use Personal Information  for any purpose that is incompatible with the purpose for which it was initially collected unless you provide your prior explicit consent for further use.

Examples of types of Personal Information that we may collect from CIL SA’s customers, business partners, suppliers, contractors and other stakeholders include the following:

1. Contact Data, which includes information such as job title, first and last names, e-mail address, mailing address, zip code, phone numbers, company, address, country, personal ID, passports or others;
2. Economical and Transactional data, which includes information such as data related to company shareholders and legal representatives, banking information such as account and routing numbers, payment and other invoice information such as tax identification number;
3. Commercial Relationship data, which includes information about products or services that are of interest to you;
4. Job Applicant data, which includes information such as your Contact Data and all information available in your resumé as well as the information filled in CIL SA’s website, i.e., country, residence, work permit, languages, years of experience, current company, current/previous positions, current/previous functions, current/previous professional areas, CV or cover letter, all in accordance with our Candidate Privacy Policy.
5. IT and Communication Information, which may include information such as usernames and email addresses, network and system access logs, , as well you IP address, browser or device as described in our Cookie Policy.
6. Details of the interactions with us, such as correspondence received, meetings we have held, feedback you have provided as well inquiries about our products and services.
7. Images from customers, employees, contractors, visitors and other stakeholders entering the monitored space within and around some of our buildings and facilities through the use of Closed-Circuit TV (“CCTV”) devices. In such cases, a CCTV signage will be placed to alert you that a CCTV installation is in use.

CIL SA will not collect Personal Information if such collection is prohibited under the applicable data protection laws. We will always indicate whether the information requested is mandatory or optional. If you fail to provide mandatory information, in some circumstances this may mean CIL SA will be unable to process your request or enter into an agreement with you.

How do we collect your Personal Information

We collect Personal Information in three ways:

• Personal Information that we receive directly from you, in one of the situations listed above, in one of the situations listed above, when you voluntarily submit it to us or  that we ask you for when you interact with us;
• Personal Information that we receive from other sources also involved in commercial transactions, such as our business partners and affiliates or third parties (if and to the extent permitted by applicable law);
• Personal Information that we collect automatically using browser Cookies. Some of this information is partially anonymized, like geographical location, the purpose of this collection is to have statistical reports on the web site usage.

To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we may also collect your Personal Information  automatically or through you providing it to us.

How We Use Your Personal Information

We process the personal information that we collect about you for the following purposes:

1. To communicate and manage our contractual and/or commercial relationship with you, for example, to contact you to successfully resolve your request; to respond to your inquiries about our products, services or to provide you with information that you have requested; to fulfill an order, manage payment and invoice for goods and services; to ship and deliver our products or services to you and bill you for them; when applicable, to record the phone calls with you to monitor the quality of our services;
2. To comply with legal obligations and/or regulatory requirements, for example, to comply with applicable laws and regulations; to respond to judicial, regulatory and supervisory bodies; to respond to requests from public and government authorities, which might include those outside of your country of residence;
3. To protect our rights and property, for example, to protect us against injury, theft, legal liability, fraud abuse, cyber-attacks or other misconducts; to conduct Know Your Client (KYC) procedures; to protect our facilities by using video surveillance systems among other physical security measures;
4. To manage litigation, complaints and others, for example, to assist in the context of any litigation or arbitration, including but not limited to employment court proceedings, to manage and respond to complaints, to manage and follow-up any reported concerns in our integrity hotline;
5. To improve your online user experience, for example, to provide you with a good user experience when you use any of our websites; to improve the content, functionality and usability of any of our websites;
6. To improve our products and services, for example, based on our legitimate interests in developing and improving our products and services, to collect Personal Information for research and analytics purposes as well for possible market and other research studies.

CIL SA will only process your Personal Information where it has a legal basis for doing so. Most of the time, we will be processing your Personal Information in order to fulfil your requests or to fulfil our contractual obligations with you or because it is necessary to comply with a legal obligation. In some cases, we will also be processing your Personal Information because you have given us your consent to do so. In such case, your consent can be withdrawn at any given time. 

How and Why We Share Your Personal Information

CIL SA does not sell, share, or otherwise distribute your Personal Information to third parties for promotional purposes. CIL SA will only share your Personal Information with third parties in strict compliance with this policy, your preferences and applicable laws and regulations. We may disclose personal information collected to the following categories of recipients:

1. Within CIL: CIL operates globally, which means your information may be stored and processed outside of South Africa to carry out the activities specified in this Policy. We restrict information to people within our company based on a “need to know” principle. Because of this we may share your Personal Information with our companies that provide shared services within CIL, for example, in connection with HR, procurement, financial or IT services. If your data has to be shared outside of South Africa, we will make sure that there is a legal basis for such transfer and that your personal information is adequately protected as required by applicable law, for example, by using standard agreements approved by relevant authorities and by requiring the use of other appropriate technical and organizational measures to protect your personal information or by implementing “Binding Corporate Rules” within our company.
2. Outside CIL; We may also share your Personal Information with our third-party services providers that may need your data for the purposes described in this policy. For example, these third parties provide services such as website hosting, data analysis, payment processing, order fulfilment, product distribution, infrastructure provision, IT services, customer service, email delivery services, auditing services, distributors, agents and similar. These third-party service providers act on our behalf and are bound by law or contract to protect your Personal Information and only use your Personal Information in accordance with our instructions.

We may also only disclose your Personal Information outside CIL:

• When legally needed to comply with legal obligations, investigate legal issues, enforce our rights, protect our property or as needed for any other legal or regulatory investigation or proceeding;
• When you give us your explicit consent to disclose your Personal Information. 

Finally, and where permitted by applicable law, Personal Information may be disclosed in connection with corporate restructuring, sale, or assignment of assets, merger or other changes of control or financial status of CIL SA.

Regardless of where your information is processed, we apply the same protections described in this Policy.

How Long We Keep Your Information

Unless a longer retention period is required by law, CIL SA will keep your information for as long as it is necessary for the purposes for which it is collected and processed in accordance with our Data Retention Policy and respective procedures.

When we are no longer able to retain your Personal Information in accordance with this Policy, we will anonymize your information and may retain those records for statistical and analytics purposes.

How And Where We Store Your Personal Information

We store your Personal Information carefully. We follow industry standard measures to protect them against unauthorized access to, and unlawful interception or processing of Personal Information. Once we have received your Personal Information, we will use strict procedures and security features to prevent unauthorized access.

Your Personal Information collected will be stored in South Africa, in the European Economic Area (“EEA”) and Switzerland.

When your Personal Information has to be transferred outside of South Africa, you must be aware that such destination countries may have different levels of privacy protection than in your country of residence. In such cases we will take all steps legally necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy and the applicable legislation, namely by entering into international transfer agreements or other appropriate safeguards, such as imposing contractual obligations on the recipients of your Personal Information. We may alternatively implement “Binding Corporate Rules”.

Your rights

Right of Notification
This Privacy Policy serves as us upholding your right to be notified that your Personal Information is being collected and/or processed.

Right of Access
You have the right to inquire whether we hold your Personal Information, as well as access and receive a copy of your Personal Information held by us.

Right to Rectification
You have the right to demand that we correct incorrect information about you.

Right to Erasure and Destruction
You have the right to request the erasure and /or destruction of your Personal Information at any time, if you consider that we do not have the right to hold it. We may retain certain information about you as required by law and for legitimate business purposes permitted by law.

Right to Restrict Processing
You can ask us to suspend the processing of your Personal Information in several scenarios, including if you want us to verify the accuracy of the data, and if you believe our use of your data is unlawful but you do not want us to erase it.

Right to Data Portability
You can request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. This right only applies to information which you initially provided consent for us to use, where we used the information to perform a contract with you or where the processing of your Personal Information is carried out by automated means.

Right to Object
You have the right to object to your Personal Information being processed for a particular purpose (including direct marketing) or to request that we stop using your Personal Information.

Right to Withdraw Consent
Where our processing of your Personal Information is based on your consent, you have the right to withdraw your consent at any time. If you do so we will stop processing your Personal Information unless there is another lawful basis we can rely on, if which case we will inform you of this.

Right to Reject Automated Individual Decision-Making
You can request not to be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your Personal Information.

Right to be Informed about an Actual or Suspected Data Breach
You have the right to be informed that there has been a data breach or suspected data breach which has compromised or has potentially compromised your Personal Information.

Right to submit a complaint and/or institute civil proceedings
You have a right to submit a complaint to the established data protection authority (i.e. the Information Regulator) in respect of any interferences, or alleged interferences, with your Personal Information; and/or institute civil proceedings against us or any person who has interfered with, or allegedly interfered with, your Personal Information.

Changes to this Policy
You have a right to submit a complaint to the established data protection authority (i.e. the Information Regulator) in respect of any interferences, or alleged interferences, with your Personal Information; and/or institute civil proceedings against us or any person who has interfered with, or allegedly interfered with, your Personal Information.

How You Can Contact Us
Please contact us if you have any complaints, questions or comments about our privacy practices, your privacy choices, or this Policy. You can always reach us by e-mail at [email protected] or at  [email protected].

You can also contact us at the following details:

• Information Officer: Yvette Gradwell
  email: [email protected]
  tel: 021 808 1900
• Deputy Information Officer for COFCO International South Africa: Elsie Smit email: [email protected]
  Tel: 021 808 1900
• Deputy Information Officer for Standerton Oil Mills: Nomusa Mncube 
  email: [email protected]
  tel: 017 720 0324

Relevant definitions

In the context of this document:

Personal Information
“Personal Information” has the same meaning ascribed by POPIA, and means any information relating to you that would allow a party to identify you as an individual or to contact you, including, but not limited to, your full name, address, telephone number, document number, birthdate or email address.

Company, CIL, COFCO
COFCO International Limited and its affiliated companies.

Data Subjects
A data subject is any person whose personal information is being collected, held or processed.

CIL Group
CIL Group means our subsidiaries, our ultimate holding parent company and its subsidiaries and/or affiliates.