This Policy must, as is appropriate, be read together with our Terms of Service, Return Policy and any other documents or agreements between Goodmind and you (the “Agreements”).
Who Is Responsible For Processing Your Personal Information?
Goodmind is the “responsible party” (i.e., the organisation responsible) of personal information that is collected from you and used for the purposes of data privacy laws, principles and regulations which may apply to you, including the Protection of Personal Information Act (“POPIA”) and any other data protection laws (collectively, “Data Privacy Law”).
This Policy does not apply to –
- the processing of personal information by other third parties relating to or by means of other parties’ websites, products, or services, such as websites linked to, from or advertised on our website or through our products and services, or sites which link to or advertise our website or our products and services. We are not responsible for the privacy practices of such third parties or third party websites, or for any claims, loss or damage arising from these.
What Personal Information Do We Collect?
When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”.
We collect Device Information using the following technologies:
– “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
– “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
– “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.
Additionally when you make a purchase or attempt to make a purchase through the Site or in store, we collect certain information from you, including your name, billing address, shipping address (if you require products to be shipped), payment information (including credit card numbers), email address, and phone number. We refer to this information as “Order Information”.
If you are our supplier or service provider, we collect certain information about the organisation (such as the organisations name, registration number, registered address, financial information including bank account and tax information) and may process some of the organisation’s representatives’ personal information (such as name, contact information, personal information in correspondence). We may also conduct background and credit checks on any existing or prospective suppliers or service providers using a third party service. We refer to this as “Supplier Information“.
When you visit our physical stores, we make use of CCTV (which we make you aware of).
In limited instances we process “special personal information” such as your health data. We only collect and process this health data when you complete our COVID-19 screening questionnaire. We are required by law to process this special personal information.
There may be instances in which the personal information that you provide to us or which we collect constitutes personal information of someone other than yourself. Where you provide a third party’s personal information to us, you warrant that the information is accurate and that you have the necessary consent to share the data with us, unless you have another lawful basis for sharing the data with us.
How Do We Collect Your Personal Information?
Most of the personal information we process about you is information that you knowingly provide to us (i.e., personal information that you provide directly to us). However, in some instances, we process personal information that we are able to infer about you based on other information you provide to us (such as supporting documents) or on our interactions with you, or personal information about you that we receive from a third party using a process that we have told you about.
How We Use Your Personal Information (PURPOSE AND LAWFUL BASIS)?
We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to:
– Communicate with you;
– Screen our orders for potential risk or fraud; and
– When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
Our lawful basis for processing your Order Information is –
- Our legitimate interests: We process your personal information in line with our legitimate business interests, which interests are not overridden by your data protection interests or fundamental rights and freedoms.
- Contract: We process your personal information to the extent it is necessary to conclude or perform under the Agreement we have with you.
- Legal obligation: We have certain legal obligations which require us to process your personal information. This includes processing personal information for tax purposes.
- Consent: In certain limited instances, we will process your personal information, but only with your prior consent.
We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).
Our lawful basis for processing your Device Information is –
- Our legitimate interests: We process your Device Information in line with our legitimate business interests, which interests are not overridden by your data protection interests or fundamental rights and freedoms.
Sharing Your Personal Information
We share your personal information with third party service providers to help us use your personal information for the purposes, as described above. This includes for example, we use Shopify to power our online store–you can read more about how Shopify uses your personal information here: https://www.shopify.com/legal/privacy. We also use Google Analytics to help us understand how our customers use the Site — you can read more about how Google uses your personal information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
Finally, we may also share your personal information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights. We may also share your personal information with our professional advisors (e.g., legal, financial, banking, risk management and others); bankers and auditors as well as our insurers and insurance brokers.
Like many businesses, we have centralised certain aspects of our data processing and administration in accordance with applicable data protection laws and any other applicable laws in order to allow us to better manage our business. That centralisation may result in the transfer of personal information from one country to another or from Goodmind to another entity in the Group. If we disclose the personal information, we hold about you to any other entity in the Group, such other entity must first have agreed (or be deemed to have agreed) to be bound by this Policy with respect to their processing of your personal information.
As we continue to develop our business, we may buy or sell the business or certain assets. In such transactions, contracts with you or your personal information is generally one of the transferred business assets. We may share your personal information with any prospective or actual third-party buyers (and their advisors) in respect of such business transfers, subject to standard confidentiality agreements.
International Data Transfers
Goodmind may transfer your personal information to countries other than the one in which you live. Where your personal information is transferred abroad, Goodmind will ensure that it uses a data transfer mechanism which is compliant with applicable Data Privacy Laws. This includes making use of binding agreements which provide an adequate level of protection that effectively upholds the principles for reasonable processing of your personal information that are substantially similar to POPIA.
Cookies & Behavioral Advertising
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by using the links below:
– Facebook: https://www.facebook.com/settings/?tab=ads
– Google: https://www.google.com/settings/ads/anonymous
– Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
Our website is scanned from time to time for security weaknesses and known vulnerabilities in order to make your visit to our site as safe as possible. We also use regular malware scanning. Your personal information is held on secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential.
Nevertheless, such security measures cannot prevent all loss, misuse or alteration of personal information and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by applicable law and other applicable laws. Where required under law, we will notify you of any such loss, misuse or alteration of personal information that may affect you, so that you can take the appropriate actions for the due protection of your rights.
We may process your personal information for the purpose of direct marketing if (i) you have specifically consented (or “opted in”) to receive such communication; or (ii) you are an existing customer of ours. If you complete any “contact us” field on our website, you agree to receive communication from us. You can, at any time, opt-out or reject such communication.
Do Not Track
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.
In terms of Data Privacy Laws, you have certain rights including, without limitation:
- Access rights: You have the right to request a copy of any record (or in the absence of a record) a description of your personal information held by us.
- Right to rectification: You can require us to have inaccurate personal information corrected.
- Right to object: You have the right to object to the processing of your personal information at any time, on reasonable grounds relating to your particular situation, unless the processing is required by law.
- Right to erasure: You can require us to erase personal information in certain circumstances where there is no lawful basis for us to retain such personal information. Please note, however, that in some instances we must retain your personal information for certain periods of time as required by law.
- Right to restrict: You can require us to restrict our processing of your personal information in certain circumstances.
- Right to withdraw consent: You can withdraw any consents to processing that you have given us and prevent further processing if there is no other legitimate ground upon which we can process your personal information.
- Right to complain: You can raise a complaint about our processing with the data protection regulator in your jurisdiction, or with our Information Officer.
You also have a duty to inform us of changes to your personal information: It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
We keep records of your personal information no longer than is necessary for the purpose for which we obtained them and for any other permitted compatible purposes.
The prohibition listed above will not apply in the following circumstances –
- where the retention of the record is required or authorised by law;
- Goodmind requires the record to fulfil its lawful functions or activities;
- retention of the record is required by a contract between the parties thereto;
- the data subject (or competent person, where the data subject is a child) has consented to such longer retention; or
- the record is retained for historical, research or statistical purposes provided safeguards are put in place to prevent use for any other purpose.
The Site is not intended for individuals under the age of 18. We will not knowingly process the personal information of people under the age of 18 without express consent from a parent or guardian to do so.
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e‑mail at email@example.com or by mail using the details provided below:
Good Psyence (Pty) Ltd
Re: Privacy Compliance Officer
14 Kloof Street, Cape Town, Western Cape, 8001, South Africa
You have the right to complain to the relevant regulator, if you believe that the processing of your personal information by us is in breach of applicable Data Privacy Laws, with the contact information of the South African Information Regulator being provided below:
- JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
This Policy is effective as of [1 July 2021].