Privacy Policy

This Privacy Policy applies to SurgeZirc SA (Pty) Ltd and governs the collection, use, processing, and protection of personal information in connection with the provision of our services. SurgeZirc SA is operated by SurgeZirc Media, and this Privacy Policy applies to all platforms, products, and services through which our services are accessed or delivered, including, without limitation, our websites, mobile websites, mobile applications, email communications, and any other digital or technological interface (collectively, the “Platforms”).

In this Privacy Policy, references to “we”, “us”, or “our” mean SurgeZirc SA and/or SurgeZirc Media, as applicable. The terms “personal information”, “special personal information”, and “processing” or “process”, as used in this Privacy Policy, have the meanings ascribed to them in the Protection of Personal Information Act 4 of 2013 (“POPIA”).

This Privacy Policy must be read together with any other terms and conditions, privacy notices, or policies that we may provide from time to time in relation to specific services, campaigns, or data collection activities. Such notices and policies supplement this Privacy Policy and do not replace or override it unless expressly stated otherwise.

We respect your right to privacy and are committed to safeguarding personal information in accordance with applicable data protection laws. This Privacy Policy explains how we collect, receive, use, disclose, store, and otherwise process personal information relating to you. By accessing or using any of our Platforms, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal information as described herein, where such consent is required by law.

If you are under the age of 18 years, you may only use our Platforms or provide us with personal information with the prior consent of your parent or legal guardian. We reserve the right to take reasonable steps to verify that such consent has been obtained, including requesting the contact details of your parent or legal guardian and verifying the accuracy and legitimacy of those details. Where appropriate, we may contact your parent or legal guardian directly to confirm consent.

Personal Information We Collect

SurgeZirc SA collects and processes personal information that is reasonably necessary to provide, operate, and improve its services as advertised on the Platforms. We are committed to the principles of lawfulness, fairness, and data minimisation, and accordingly collect and use only the minimum personal information required to achieve these purposes.

The categories of personal information that may be collected and processed include, without limitation:

• Identity and contact information, such as your name, email address, physical address, and fixed or mobile telephone number;

• Location information, including approximate or precise geographic data, depending on your device settings and permissions; and

• In limited circumstances, and only where you have provided your explicit consent or where otherwise permitted by law, special personal information (as defined in the Protection of Personal Information Act 4 of 2013), which may include information relating to your race or ethnic origin, gender, age, religious or philosophical beliefs, financial information, health or biometric information, culture, language, and education or employment history.

How We Collect Personal Information

We collect and receive personal information about you through the following sources:

Information You Provide to Us

We collect personal information that you voluntarily provide to us through direct interactions, including when you:

• Subscribe to push notifications on our website;

• Post comments, submit content, or otherwise interact with our Platforms; or

• Contact us via email, online forms, or other communication channels.

Information We Automatically Collect When You Use Our Platforms and Services

When you access or use our services, we may automatically collect certain information relating to your device, usage, and browsing activity. This information is collected through the use of cookies, web beacons, and similar tracking technologies.

A cookie is a small text file that is placed on your device when you visit our Platforms. Cookies enable our systems to recognise returning users, support essential functionality, and improve the performance and usability of the Platforms. You may adjust your browser settings to disable cookies; however, doing so may limit access to certain features or functionality.

A web beacon is a small image file embedded on our Platforms or in email communications. Web beacons allow us to track page access, time of access, and general user location for analytical and operational purposes.

Depending on how you access and use our Platforms, we may automatically collect or receive:

• Log and usage information, including how, when, and for how long you use our Platforms and services, the content you view, and search queries you submit;

• Device and technical information, such as your browser type, operating system, method of access, and Internet Protocol (IP) address; and

• Location information, including data derived from your device’s GPS, Wi-Fi networks, or cell towers, where you use location-enabled services and have granted the necessary permissions.

Further information regarding our use of cookies and similar technologies is set out in our Cookies Policy, available here.

Information from Third-Party Sources

We may receive personal information about you from third-party sources, including service providers, analytics partners, and social networking platforms, where:

• You have consented to such third-party disclosure; or

• The sharing is necessary for our or your legitimate interests and is permitted by applicable law.

This information may be combined with personal information we collect directly from you or automatically through your use of our Platforms. Information received from third-party sources may include location information or other data relevant to the provision and improvement of our services.

In certain circumstances, third-party service providers may process personal information on our behalf using automated technologies, including artificial intelligence tools. All processing of personal information, whether manual or automated, is carried out lawfully, fairly, and in accordance with applicable law and this Privacy Policy.

We may disclose, provide access to, or otherwise make your personal information available to the following categories of recipients, only where necessary and lawful:

• Group and affiliated companies, including SurgeZirc Media and Surjik Holdings, for purposes such as improving our Platforms and services, analytics, operational support, and advertising, subject to appropriate safeguards;

• Service providers and professional advisers that perform services for or on our behalf, or assist us in operating the Platforms or providing services to you, including contractors, information technology providers, consultants, legal advisers, and auditors;

• Regulatory authorities, law enforcement agencies, courts, or other competent bodies, where disclosure is required to comply with applicable law, legal process, or to protect the rights, property, safety, or security of our Platforms, users, or business;

• Prospective or actual buyers or sellers, in connection with any proposed or completed sale, merger, acquisition, restructuring, or transfer of all or part of our business or assets, subject to appropriate confidentiality and data protection safeguards;

• Third parties with whom you choose to interact, where you have consented to the sharing of your personal information, including where you participate in competitions, promotions, or campaigns sponsored by third parties, or where you request further information about a third-party product or service; and

• Content providers, advertising partners, and functionality providers that support our Platforms, including:

• advertising service providers that assist in delivering advertisements tailored to users’ interests;
• audience measurement and analytics providers that help us understand Platform usage and performance; and
• social networking services (such as Facebook, Bluesky, Twitter/X, LinkedIn, Threads, and Instagram) that you may elect to use to register, log in, or share content from our Platforms.

We do not control the private practices of third-party services and are not responsible for their processing of personal information. We encourage you to review the privacy  policies of such third parties before connecting to or using their services. These third parties may collect information about your use of our Platforms, including through cookies, web beacons, and similar technologies, and may combine such information with data collected from other websites or online services.

Processing by Third Parties and Automated Tools

We may share personal information with third-party service providers, including those that use automated processing technologies or artificial intelligence tools, where such providers process personal information on our behalf. In all such cases, we require that the third party:

• Processes personal information only on our instructions; and
• Is bound by contractual obligations or policies that provide a level of protection no less stringent than that set out in this Privacy Policy.

Anonymised Research and Statistics

We may share research, analytical, or statistical information with third parties. Such information is aggregated and anonymised, does not contain personal information, and cannot be used to identify you.

Cross-Border Transfers

Some recipients of personal information may be located outside the Republic of South Africa. We will only transfer personal information to recipients in other jurisdictions where:

• The recipient is subject to data protection laws or binding agreements that provide an adequate level of protection; or
• Appropriate contractual, corporate, or technical safeguards are in place to protect your personal information.

Where required by law, we will obtain your consent before transferring your personal information to a third party outside South Africa.

Our Commitment to Security

SurgeZirc SA is committed to maintaining the confidentiality, integrity, and availability of personal information. We have implemented appropriate administrative, technical, and physical safeguards designed to protect personal information against loss, damage, unauthorised access, unlawful processing, or disclosure.

These safeguards are informed by generally accepted information security practices and standards and are appropriate to the nature of the personal information processed, the purposes of processing, and the risks associated with such processing across our Platforms, products, and services. We regularly review, test, and update our security measures to ensure their continued effectiveness and to address emerging risks or identified vulnerabilities.

While we take reasonable steps to protect personal information, you acknowledge that information transmitted over the internet is not completely secure and is transmitted at your own risk. Once personal information is received by us, it is subject to the security safeguards described in this Privacy Policy.

Where we engage third-party service providers to process personal information on our behalf, we require such parties to be bound by written agreements that obligate them to:

• Implement appropriate security safeguards;
• Process personal information lawfully and confidentially; and
• Collect, use, and process personal information only for the purposes authorised by us and in accordance with applicable law.

Your Rights