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Legal.

Privacy Policy

How Thiink Pty Ltd collects, uses and protects your personal information when you use www.thiink.co.za.

Effective 6 August 2026

POPIA compliant

Reg No. 2015/430052/07

On this page

Thiink Pty Ltd ("Thiink", "us", "we", or "our") operates the website www.thiink.co.za (the "Service"). This page informs you of our policies regarding the collection, use and disclosure of personal information when you use the Service, and your choices associated with that information, in accordance with the Protection of Personal Information Act 4 of 2013 (POPIA).

By using the Service, you agree to the collection and use of information in accordance with this policy.

Definitions

Definitions

The website www.thiink.co.za, operated by Thiink Pty Ltd.

Personal Information

Information relating to an identifiable, living natural person, and where applicable, an identifiable, existing juristic person, as defined in section 1 of POPIA.

Usage Data

Data collected automatically, either by use of the Service or from the Service infrastructure itself, for example the duration of a page visit.

Cookies

Small files stored on your device, whether computer or mobile device.

Responsible Party

Thiink Pty Ltd is the responsible party for personal information collected via the Service, as defined in POPIA.

Operator

A person who processes personal information for a responsible party in terms of a contract or mandate, without coming under the direct authority of that party, as defined in POPIA.

Data Subject

The person to whom personal information relates.

Information collection and use

We collect several different types of information for various purposes to provide and improve the Service to you.

Personal Information

While using the Service, we may ask you to provide certain personally identifiable information that can be used to contact or identify you, including but not limited to:

  • Full name
  • Company name and job title
  • Email address
  • Telephone number
  • Physical or postal address
  • Any other information you voluntarily submit through a contact, enquiry, or registration form

Usage Data

We may also collect information on how the Service is accessed and used. This may include your device's Internet Protocol address, browser type and version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

Cookies and tracking data

We use Cookies and similar tracking technologies to track activity on our Service and hold certain information. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. If you do not accept Cookies, some portions of the Service may not function properly.

Lawful basis for processing

We will only process your personal information where we have a lawful basis to do so under section 11 of POPIA. Depending on the context, we rely on one or more of the following:

  • Consent. Where you have given clear consent for us to process your personal information for a specific purpose.
  • Contractual necessity. Where processing is necessary to enter into, or perform, a contract with you.
  • Legal obligation. Where processing is necessary to comply with a legal obligation to which Thiink is subject.
  • Legitimate interest. Where processing is necessary for the legitimate interests pursued by Thiink or a third party, provided such interests are not overridden by your interests, fundamental rights and freedoms.
  • Protection of a legitimate interest of the data subject. Where processing is necessary to protect a legitimate interest of yours.

Use of data

Thiink Pty Ltd uses the collected data for various purposes, including to:

  • Provide, operate and maintain the Service
  • Notify you about changes to the Service
  • Allow you to participate in interactive features of the Service when you choose to do so
  • Provide customer support
  • Gather analysis or valuable information so that we can improve the Service
  • Monitor the usage of the Service
  • Detect, prevent and address technical issues
  • Comply with our legal and regulatory obligations

Direct marketing

In accordance with section 69 of POPIA, we will not process your personal information for the purpose of direct marketing by means of any electronic communication, including email, SMS or automated calling, unless you have given your consent, or you are an existing customer of Thiink and the direct marketing relates to similar products or services offered by us, in which case you were given a reasonable opportunity to object, free of charge, both at the time your information was collected and on the occasion of each subsequent communication.

You may withdraw your consent, or object to direct marketing, at any time by contacting us using the details in the "Contact us" section below, or by using the unsubscribe mechanism provided in the relevant communication.

Data subject rights

Subject to the provisions of POPIA, including sections 23 to 25 and 69(4), you have the right to:

Access

Request confirmation of whether we hold personal information about you, and access to that information, including the identity of any third parties who have had access to it.

Correction

Request the correction, updating or deletion of any inaccurate, irrelevant, excessive, out of date, incomplete, misleading or unlawfully obtained personal information.

Objection

Object, on reasonable grounds relating to your particular situation, to the processing of your personal information, unless legislation authorises the processing.

Objection to direct marketing

Object at any time, free of charge and without needing to provide reasons, to the processing of your personal information for purposes of direct marketing.

Withdrawal of consent

Withdraw any consent on which processing is based, without affecting the lawfulness of processing carried out before such withdrawal.

Complaint

Submit a complaint to the Information Regulator regarding an alleged infringement of your rights. See the Complaints section below.

To exercise any of these rights, contact us using the details in the "Contact us" section. We may need to verify your identity before giving effect to your request.

Retention of data

Thiink Pty Ltd will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy, or as otherwise required to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

Usage Data is generally retained for a shorter period, except where it is used to strengthen the security of the Service or to improve its functionality, or where we are legally obliged to retain it for a longer period.

Once the applicable retention period has expired, we will securely delete or de-identify your personal information in accordance with section 14 of POPIA.

Transfer of data

Your information, including Personal Information, may be transferred to and maintained on computers located outside of South Africa, where data protection laws may differ from those in South Africa.

In accordance with section 72 of POPIA, we will only transfer your personal information to a third party in a foreign country where:

  • You have consented to the transfer.
  • The transfer is necessary for the performance of a contract between you and Thiink, or for the implementation of pre-contractual measures taken in response to your request.
  • The transfer is necessary for the conclusion or performance of a contract concluded in your interest between Thiink and a third party.
  • The recipient of the information is subject to a law, binding corporate rules, or binding agreement which provides an adequate level of protection that effectively upholds principles for the reasonable processing of personal information that are substantially similar to POPIA, and includes provisions substantially similar to section 72 relating to the further transfer of personal information from the recipient to third parties in a foreign country.

Disclosure of data

We may disclose your Personal Information in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of Thiink Pty Ltd
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of users of the Service or the public
  • Protect against legal liability

We may also disclose Personal Information to a purchaser or prospective purchaser in connection with a merger, acquisition, reorganisation, or sale of some or all of Thiink's assets, subject to appropriate confidentiality safeguards.

Security of data

The security of your data is important to us. We implement appropriate technical and organisational measures, in accordance with section 19 of POPIA, to secure the integrity and confidentiality of personal information in our possession or under our control, and to prevent loss of, damage to, or unauthorised destruction of personal information, and unlawful access to or processing of personal information.

No method of transmission over the Internet, or method of electronic storage, is completely secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

Service providers and operators

We may engage third-party companies and individuals to facilitate our Service ("Operators"), to provide the Service on our behalf, to perform Service-related tasks such as hosting, analytics, email delivery, or customer support, or to assist us in analysing how our Service is used.

These Operators have access to your Personal Information only to perform these tasks on our behalf, are contractually bound to process such information only in accordance with our instructions and this Privacy Policy, and are obligated not to disclose or use it for any other purpose, in accordance with section 20 of POPIA.

Links to other sites

Our Service may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of every site you visit.

We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party websites or services.

Children's privacy

Our Service is not directed at children, and we do not knowingly collect personal information from children without the consent of a competent person, such as a parent or legal guardian, as required under section 34 read with section 35 of POPIA.

If you become aware that a child has provided us with Personal Information without appropriate consent, please contact us. If we become aware that we have collected Personal Information from a child without verified parental or guardian consent, we will take steps to remove that information from our servers.

Complaints

You have the right to lodge a complaint with the Information Regulator (South Africa) if you believe your personal information has been processed unlawfully, or that we have failed to comply with the provisions of POPIA. The Information Regulator may be contacted as follows:

Information Regulator (South Africa)

ADDRESS

JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001

We encourage you to contact us first using the details in "Contact us" below, so that we may attempt to resolve your concerns directly.

Changes to this policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the updated Privacy Policy on this page and updating the effective date at the top of this policy. We encourage you to review this Privacy Policy periodically for any changes.

Changes to this Privacy Policy are effective when they are posted on this page.

Contact us

If you have any questions about this Privacy Policy, or wish to exercise any of your rights as a data subject, please contact us at:

Thiink Pty Ltd

REG NO.

2015/430052/07

EMAIL

legal@thiink.co.za