Privacy Policy

This agreement

1. Ubiquity Applications Proprietary Limited (“Ubiquity”, “we”, “our”, “us”) owns and operates the Sociable website located at https://thesociableapp.com and app (“Sociable” formerly "Howya") and this privacy notice (the “Privacy Notice”) applies to every person who uses and who interacts with us whether through the website or the app (”you”/”your”).
2. The Privacy Notice explains what personal information we collect and use, how and why we collect or otherwise use your personal information, who we share this information with, and what your rights and choices are regarding your personal information.

Information We Collect

1. We collect your personal information in various instances, including when you:

• use Sociable in any manner;
• create any Sociable account;
• when you host an event using Sociable;
• are invited to an event posted on Sociable and you choose to accept such an event invitation on Sociable;
• access Sociable or a Sociable account;
• choose, in your discretion, to upload information to Sociable (such as your contacts, a profile picture, an event banner, event details, and any other images or communications);
• submit an enquiry to us;
• communicate with us in any manner (including, for example, through telephone, via email or text messaging) for any reason whatsoever;
• engage with us via Sociable (whether on the website or the app);
• sign up for our mailing list; and
• take part in events, promotions or competitions.

1. Please note that, if you access Sociable without giving us any personal information, we may still gather certain non-personal information from you, including information regarding your activities on the Sociable website and app. For example, we make use of Google Firebase for storage related purposes. Google Firebase automatically collects certain analytical data, however, this information cannot be used to identify you personally and includes, without limitation, information pertaining to your general country of use, average screen time spent on the Sociable app (this information is collated from our users collectively and is not targeted to any one specific user), and notifications received collectively by Sociable users (as opposed to any specific user). In addition, we also make use of certain cookies. Details thereof are set out in clause 8 (Cookies) below.
2. In some instances, it is compulsory for you to provide us with your personal information, such as when you wish to create a Sociable account and when you need to pay for your account subscription. This enables us to make Sociable available to you and allows us to provide our Sociable services to you. In other instances, providing the information is optional, such as when you wish to subscribe to or opt out from our mailing list. If you do not provide the information when it is compulsory, we will not be able to make Sociable available to you and it may limit our ability to interact with you when you, for example, submit a query to us. If you do not provide the information when it is optional, you will not receive the benefit of providing that information (for example, receiving promotional materials).

Purpose of Personal Information Used

1. We collect or otherwise process your personal information for, among others, the following purposes, namely to:

• provide the Sociable services to you;
• ensure that you are over the age of 18 years and have the legal capacity to create a Sociable account or attend an event created on Sociable;
• increase the specificity on Sociable accounts;
• enable you to use Sociable to create and attend events;
• improve and enhance Sociable, and your experience when using the Sociable website or app;
• marketing, promoting and advertising products to you;
• communicating with you in order to provide our services to you, for our internal purposes such as, amongst others, managing your Sociable account or responding to you when you contact us; and
• complying with any legal obligations imposed on us.

1. Without limiting the generality of the aforesaid, the Sociable website and app uses analytics to monitor and analyse web traffic and your behaviour on the website and app.
2. We may process personal information:

• to provide goods or services to you in terms of an agreement with you or where we wish to conclude an agreement with you;
• in order to protect your legitimate interests;
• in our legitimate interests;
• in the legitimate interests of another person to whom we supply your personal information;
• to comply with legal or regulatory obligations;
• if you have provided consent; or
• if the processing is allowed by law.

Retention of Information

1. Your personal information will be processed and stored for as long as required for the purpose it has been collected for pursuant to the provisions of this Privacy Notice and for as long as its retention is required by applicable law.
2. Personal information collected for purposes related to the performance of a contract between Ubiquity and you will be retained while the contract is being performed. Personal information collected for the purpose of our legitimate interests will be retained for as long as is needed to fulfil that purpose.
3. We may retain personal information for a longer period in instances where you have given consent to such processing, and where such consent has not been withdrawn. We may also be required to retain personal information for a longer period when required to do so in the performance of a legal obligation, in accordance with tax or accounting requirements or upon the order of a court order.
4. Where you created a Sociable account and choose to delete it, any personal information uploaded onto your account will be deleted including, without limitation, your user profile, images uploaded onto your user profile, events which you created and details pertaining to such events, as well as the status of attendees.

Disclosure of Personal Information

1. We may release your personal information or disclose it to third parties in certain circumstances, including, but not limited to the following:

• if required or authorized to do so by law or a court order;
• in order for it to enforce its rights; and
• in order for it to provide goods or services.

1. The third parties to whom we disclose personal information include, but are not limited to, our corporate affiliates and partners; third parties who provide goods and/ or services to us; and government authorities and registries, organs of state, regulators, courts, tribunals and law enforcement agencies.

Marketing and Promotional Material

1. We may from time to time send marketing and promotional material to you.
2. You may unsubscribe from receiving further marketing and promotional material. If you wish to do so, you can follow the “unsubscribe” link in the material or send an email to us using our email address as provided in its contact details below.

Transfer of Personal Information

1. Personal information which we collect may be transferred to third party partners and businesses, including online payment and/or storage providers (such as Google Firebase and Amazon). In such cases, we will take reasonable steps to ensure that such persons have appropriate privacy measures in place.
2. We may also transfer personal information which we collect to persons in other countries. Those countries’ laws might not protect personal information in the same way or on the same level as the law in South Africa. However, we will take reasonable steps to ensure that recipients in other countries have appropriate privacy measures in place, for example, by executing a legal agreement with the recipient where necessary.

Cookies

1. Sociable makes use of cookies to collect data. A cookie is a small piece of data that is stored on a website user’s electronic device (computer, mobile phone, tablet etc) by a website’s server. It allows a website to keep track of the user’s browsing activities, remember information such as their product preferences. Cookies typically collect information such as web browser used, IP address and time zone.
2. We use cookies which are absolutely essential for the Sociable to function properly. These cookies ensure basic functionalities and security features on Sociable. We do not use cookies for marketing or advertisement related purposes. Further, we use analytical cookies to understand how visitors interact with Sociable and to enhance or

improve Sociable. These cookies help provide information on metrics, the number of visitors, the bounce rate, traffic source etc.

1. Sociable does not capture or store additional data through the use of cookies. However, we may in future extend and add features to Sociable for purposes of communication and event management on the Sociable. To the extent that we make use of any additional cookies for these purposes, we will advise you thereof.
2. You may disable or decline cookies. However, if this is done, you may not be able to use Sociable properly and certain aspects of the website may not function.

Security and Encryption of Information

1. We take all reasonable steps to protect and avoid unauthorised access to personal information.
2. Personal Information that we collect and store (including your name, surname, the password you use for your Sociable account, your date of birth, gender, email address and, to the extent applicable, your bank account details) is encrypted with UTF8 encryption and a stored decryption key.
3. When you make use of the messaging function on Sociable, your messages will be encrypted with UTF8 encryption and a stored decryption key and we will not have access to display such messages.
4. Any images uploaded to Sociable will be stored in an Amazon “storage bucket” and will be accessible through privacy keys, but will not be accessible by the public at large.
5. In addition, when you create a Sociable account, you will be assigned a unique number which will be used for any data storage and/or data retrieval purpose. We will not use the unique number assigned to you as a Sociable user to link your information to the personal information processed by any third party.

Your Rights

1. You may exercise certain rights regarding your personal information which we process. In particular, subject to the provisions of applicable law, you have the following rights:

• the right to access personal information;
• the right to rectify personal information;
• the right to object to the processing of personal information;
• the right to delete personal information; and
• the right to restrict the processing of personal information.

1. We may, in certain instances, legally refuse or decline your request to exercise these rights.
2. In some instances, you may withdraw consent for processing. This withdrawal will have no effect on any lawful processing of personal information preceding such withdrawal.
3. If you wish to exercise any of the rights set out above, please contact us using our contact details below. We may charge a fee for accessing, amending or deleting your personal information. You will be advised of this fee in advance, if applicable.
4. We encourage you to contact us directly if you have a complaint about our processing of your personal information. However, you have the right to contact the Information Regulator (South Africa) using the details below (or any new details as may be published by the Information Regulator on its website from time to time):

Address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg PO Box 31533, Braamfontein, Johannesburg, 2001
Email: POPIAComplaints.IR@justice.gov.za
Website: https://justice.gov.za/inforeg/

Changes to this Notice

1. We reserve the right to amend, modify or update this Privacy Notice from time to time in our sole discretion. If any changes are made to this Privacy Notice, we will publish an updated version thereof on our website.

Contact Details

1. You can contact us for purposes relating to this Privacy Notice by using the following contact details:Ubiquity Proprietary Limited (Registration Number: 2020/686084/07) 21 Bellevue Road,
   E-mail address: info@thesociableapp.com