Privacy Policy
Last Updated: [Insert Publication Date]
Digital Brush (Pty) Ltd (“Digital Brush”, “we”, “us” or “our”) respects your privacy. This Privacy Policy explains how we collect, use, store and share personal information when you visit our website, contact us or use our services.
We are based in Johannesburg, South Africa, and process personal information in accordance with the Protection of Personal Information Act 4 of 2013 (“POPIA”).
1. Who This Policy Applies To
This policy applies to our website visitors, prospective clients, clients, suppliers and people who communicate with us.
Digital Brush is the responsible party for personal information collected for our own business purposes.
When we process information on behalf of a client—for example, while managing their website, enquiries or email campaigns—we act according to our agreement with that client and their lawful instructions. The client’s privacy policy governs their collection and use of that information.
2. Personal Information We Collect
Depending on how you interact with us, we may collect:
- Contact details: Your name, email address, telephone number, company name and job title.
- Enquiry and project information: Information you provide when requesting a quote, completing a form, discussing a project or engaging our services.
- Business and billing information: Company details, billing addresses, VAT details and transaction records needed to administer our services.
- Communication records: Emails, messages, feedback and other correspondence with us.
- Technical information: Your IP address, browser type, device information, pages visited and website activity, where collected through server logs or enabled website tools.
- Marketing preferences: Your subscription choices and requests to receive or stop receiving marketing communications.
Please avoid submitting sensitive personal information through our website forms unless we specifically request it through an appropriate channel.
3. How We Collect Information
We collect information directly from you when you complete a form, contact us, subscribe to communications or become a client.
Certain technical information may be collected automatically when you use our website.
We may also receive relevant business contact information from your authorised colleagues, referrals or service providers involved in your project. Where required, we will explain the source and purpose of information obtained indirectly.
Providing information is generally voluntary. However, if you do not provide information needed to respond to an enquiry, prepare a quote or deliver a service, we may be unable to assist. We will identify mandatory information where applicable.
4. How We Use Your Information
We use personal information to:
- Respond to enquiries and prepare proposals or quotations.
- Deliver website development, design, SEO, digital marketing and related services.
- Manage projects, client relationships, billing and payments.
- Communicate about service delivery, support and administration.
- Maintain and improve our website and understand its performance.
- Protect our systems, investigate misuse and prevent fraud.
- Send marketing communications where permitted.
- Meet legal obligations and establish, exercise or defend legal rights.
Depending on the purpose, we rely on your consent, steps needed to enter into or perform a contract, legal obligations, or legitimate interests recognised under POPIA.
Visiting our website or submitting an enquiry does not automatically subscribe you to marketing communications.
5. Cookies and Website Tracking
Our website may use cookies and similar technologies to support website functionality, remember preferences and measure visitor activity.
Where analytics, advertising or embedded third-party tools are enabled, these may collect information about your device and interactions with our website.
[Before publishing, insert the tools actually used, their purposes, cookie durations and how visitors can manage their choices, or link to a separate Cookie Policy containing these details.]
Where consent is required, we will request it before activating the relevant tracking technologies.
You can also manage or delete cookies through your browser settings. Blocking certain cookies may affect website functionality. Browser cookie settings do not necessarily prevent every form of technical logging.
6. Marketing Communications
We send electronic direct marketing where you have consented or where the existing-customer exception under POPIA applies.
Where we rely on that exception, marketing will concern our own similar services, and you will have an opportunity to object when your details are collected and in each marketing communication.
You can unsubscribe using the link in our marketing emails or contact us using the details below. Opting out of marketing does not stop necessary project, billing or service communications.
7. Sharing Your Information
We do not sell your personal information.
Where necessary for the purposes described in this policy, we may share relevant information with:
- Hosting, IT support, security and cloud storage providers.
- Email, communication and project management providers.
- Analytics or marketing providers, where those tools are enabled.
- Contractors and specialist partners involved in delivering your services.
- Accountants, legal advisers and other professional advisers.
- Authorities or other parties where disclosure is legally required or necessary to protect lawful rights.
We limit access to what is needed for the relevant task. Where a provider processes information on our behalf, we require appropriate confidentiality and security obligations.
8. Information Processed Outside South Africa
Some service providers may store or process information outside South Africa.
Before transferring personal information internationally, we will ensure that an appropriate basis under POPIA applies, such as adequate protection through applicable law or a binding agreement, your consent, or another legally permitted ground.
You may contact us for information about international processing relevant to your personal information.
9. Keeping Your Information Secure
We take reasonable technical and organisational measures to protect personal information against loss, misuse, unauthorised access, alteration and disclosure.
Access is limited to authorised people who need the information for their work. We review safeguards in light of the information we hold and the risks involved.
No online system is completely secure. If a security compromise affects your personal information, we will respond and notify the Information Regulator and affected people where required by law.
10. How Long We Keep Information
We retain personal information for as long as reasonably necessary for the purpose for which it was collected, unless longer retention is required or permitted by law.
Retention periods depend on the nature of the information, our relationship with you, contractual requirements, accounting obligations and any relevant disputes.
When information is no longer needed, we securely delete, destroy or de-identify it, subject to applicable retention requirements.
We may retain limited records of marketing opt-outs to ensure that your preferences continue to be respected.
11. Your Privacy Rights
Subject to applicable legal requirements and exceptions, you may:
- Ask whether we hold personal information about you and request access.
- Request correction of inaccurate or incomplete information.
- Request deletion of information that we are no longer entitled to retain.
- Object to certain processing of your information.
- Withdraw consent where processing relies on consent.
- Object to direct marketing.
- Submit a complaint to the Information Regulator.
Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal.
To exercise your rights, contact us using the details below. We may need to verify your identity before acting on a request. Where a prescribed procedure or lawful fee applies, we will explain this to you.
12. Third-Party Websites
Our website may link to external websites or platforms. Those services have their own privacy policies and practices.
Please review the relevant policy before providing personal information to a third party.
13. Children’s Information
Our website and services are intended for businesses and adult users. We do not intentionally collect children’s personal information through our website.
If you believe a child has provided personal information to us, please contact us so that we can investigate and take appropriate action.
14. Changes to This Policy
We may update this Privacy Policy to reflect changes to our services, website or legal obligations.
The latest version will be published on this page with an updated date. Where necessary, we will provide additional notice or request consent for changes to how information is processed.
15. Contact Us
For privacy enquiries or requests relating to your personal information, contact:
Digital Brush (Pty) Ltd
Attention: Information Officer
Email: [Insert Privacy Contact Email]
Telephone: [Insert Business Telephone Number]
Physical Address: [Insert Full Business Address]
Website: [Insert Website URL]
You may also lodge a complaint directly with South Africa’s Information Regulator. You do not need to obtain our permission or contact us first.
Information Regulator South Africa
Website: inforegulator.org.za
Complaints: Complaint Procedures and Submission Options
