IN TERMS OF THE PROTECTION OF PERSONAL INFORMATION ACT 4 OF 2013 (“POPIA”)

1. INTRODUCTION

This Privacy policy (“Policy”) provides an explanation on how the LiSTN Player uses, protects, and processes any information that it collects from a Data Subject (“you”). African Media Entertainment (“LiSTN Player”) abides by the Protection of Personal Information Act, No 4 of 2013 (POPIA), and is therefore committed to protecting your privacy and making certain that the Personal Information you provide to the LiSTN Player is collected and used properly, lawfully and transparently. It also contains information regarding the rights of natural and juristic persons to whom Personal Information relates to Data Subjects.

The LiSTN Player reserves the right to amend this Policy or add provisions to it at any time by publishing an updated version on its website/app.

2. COLLECTION OF INFORMATION

• The LiSTN Player collects various Personal Information, this includes but is not limited to:

• General identification and contact information, such as contact numbers, ID numbers, addresses, names etc.
  • Financial records, for example bank statements, company tax numbers, banking details etc.
  • Telephonic recordings, such as video recordings, messages etc.

• The LiSTN Player collects Personal Information in many instances, including when:
  • Data Subjects contact the LiSTN Player;
  • The LiSTN Player provides services to Data Subjects;
  • when persons use the LiSTN Players’ website or engage with the LiSTN Player through social media or messages.

We may collect the information directly from a Data Subject or a Third Party (such as regulators, government authorities, and registries). Interaction with us on our website will result in the collection of information regarding the person’s activities on the website, similarly when an individual engages with us through our social media platforms (e.g., X, Facebook and Instagram etc.) This information includes, but is not limited to, the person’s name, contact details etc.

3. BASIS AND PURPOSE FOR PROCESSING PERSONAL INFORMATION

• We may process your Personal Information:

• to provide services to clients (audio audiences or advertisers).
  • to comply with legal or regulatory obligations.
  • if a Data Subject has provided their consent; or
  • if the processing is allowed by law.

• The purposes for which we process Personal Information includes, but are not limited to:

• marketing and promotion of the LiSTN Player.
  • providing and improving services to our clients (audio audience and advertisers).
  • improving users’ experience when using our website/app.
  • communicating with persons for the LiSTN Player ’s internal purposes.

3.3.5 enabling the LiSTN Player ’s internal operations.

4. DISCLOSURE OF PERSONAL INFORMATION

• The LiSTN Player may need to release Personal Information or disclose it to third parties in certain circumstances. These include, but are not limited to:

• if we are required or authorised to do so by law or a court order.
  • in order for us to enforce its rights.
  • in order for us to provide services to clients (audio audiences and advertisers).

• The third parties to whom we disclose Personal Information include, but are not limited to:

• third party service providers to the LiSTN Player or its clients.
  • third parties who provide research services to the LiSTN Player or its clients.
  • government authorities and registries, organs of state, regulators, courts, tribunals, and law enforcement agencies.

• In the event that a Data Subject discloses Personal Information of a Third Party to the LiSTN Player, the Data Subject agrees to:

• disclose to the Third Party about the content of this Policy; and
  • obtain any legally required consent for the collection, use, disclosure, and transfer of personal information about the Third Party as in accordance with this Policy, the POPIA Protection of Personal Information Act 4 of 2013, and the Protection of Personal Information Act No. 4 of 2013.

5. TRANSFER OF PERSONAL INFORMATION

The Personal Information we collect may need to be transferred to persons in other countries. Those countries’ laws might not protect Personal Information in a similar manner or on the same level as the law in the Data Subject’s country. Nevertheless, we are committed to protect the Personal Information of the Data Subject as well as to take reasonable steps to make sure that recipients in other countries have appropriate privacy measures in place.

6. RETENTION OF PERSONAL INFORMATION

We retain Personal Information for as long as may be reasonably necessary, a contract or business deal requires us to retain it, Data Subjects have continuously given consent for us to retain it. We require it for research purposes and the applicable law(s) require us to do so. Take note, this does mean that we can retain information even if there is no longer a relationship with the Data Subject if other applicable law(s) require us to do so.

7. COOKIES

Our website makes use of cookies. These are small software programs that are installed onto your computer your mobile device for various lengths of time. Cookies store information regarding a specific user and remember your preferences about our website. Cookies have various purposes, such as improving the visitor’s experience on the website and facilitating their use of the website. Cookies record this data, which is then transmitted to the LiSTN Player or to third parties with whom we work. A website visitor may disable or decline cookies. However, if the visitor does so, their user experience on the site/app may be diminished.

8. DIRECT MARKETING

The LiSTN Player may send marketing and promotional communications and material to persons. Recipients may choose not to receive such communications by contacting the LiSTN Player on the details provided below:

Managing Director	David Mark Tiltmann
Telephone number	010 590 4554
Email	dave@ame.co.za

9. SECURITY

The LiSTN Player takes all reasonable steps to protect and avoid unauthorised access to Personal Information. We have implemented several policies, procedures, and software to safeguard Personal Information and regularly review the aforesaid security measures to ensuring that Personal Information is adequately protected, nonetheless, no exchange through the use of the internet can be guaranteed to be secure, in the event that you suspect that our security has been compromised please do not hesitate to contact us, using the contact details provided below.

10. DATA SUBJECT RIGHTS

The law makes provision for the rights of Data Subjects to access, amend or delete Personal Information that is held by the LiSTN Player. Nevertheless, the LiSTN Player may, in certain instances, legally refuse or decline such requests. If applicable, a Data Subject may also have the right to object to the LiSTN Player processing their Personal Information or to file a complaint with a regulator. If a Data Subject wishes to exercise their rights, they can contact the LiSTN Player through the details provided below. The LiSTN Player may charge Data Subjects a fee for accessing, amending, or deleting their Personal Information when applicable. Data subjects are encouraged to contact us in order to update their Personal Information as and when needed. Take note, we will need proof of identity for a Data Subject to enforce any of the aforementioned rights.

11. INFORMATION OFFICER

The Information Officer is appointed according to the legal requirements contemplated in POPIA and PAIA. The responsibilities of the Information Officer include but are not limited to:

1. Encouraging compliance with the needed law(s).
   1. Attending to requests and complaints made by data subjects in terms of POPIA and PAIA.
   1. Assisting the regulator with any investigation.
   1. If any of the provisions of POPIA is breached the Information Officer will be held liable.

1. Ensuring that all processes pertaining to Data Subjects Personal Information is user friendly and easy to understand;
   1. Working alongside the Information Regulator regarding ongoing investigations, arising issues, reporting etc.

12. CONTACT DETAILS

In order to contact the LiSTN Player for purposes relating to this Policy, please contact our Information Officer using these contact details:

Managing Director	David Mark Tiltmann
Physical Address	5 – 8th Street, AME Office Park, Houghton Estate, 2198
Postal address	5 – 8th Street, AME Office Park, Houghton Estate, 2198
Telephone number	010 590 4554
Email	dave@ame.co.za