Privacy
& Cookies
TWOTWO cares about privacy and protecting the Personal Data handled by us. All Personal Data is Processed in accordance with Applicable Law. In this Policy we describe how and the purposes for which we use your personal information as well as what lawful basis we use and what measures we take to protect Personal data. We also provide information on how you exercise the rights you have linked to our Processing of Personal data.
Why and who?
Rematch AB Reg. No. (559018-0377) ("TWOTWO", "we", "us", "our") is the Controller of all Personal Data listed in this Privacy Policy (the "Policy"). In order to be fully transparent regarding where your Personal Data is stored and Processed, we will also provide a list of all our data Processors. This Policy provides information on how we handle Personal Data when you communicate with us or visit our website www.twotwo-sa.co.za (together the "Functions").
The intended recipient of the information provided in this Policy is:
- Potential customers
- Customers
- Visitors of our website
Definitions
"Applicable Law" refers to the legislation applicable to the processing of Personal Data, including the GDPR, supplementary national legislation, as well as practices, guidelines and recommendations issued by a national or EU supervisory authority.
"Controller" is the company/organisation that decides for what purposes and in what way personal data is to be processed and is responsible for the Processing of Personal Data in accordance with Applicable Law.
"Data Subject" is the living, natural person whose Personal Data is being processed.
"Personal Data" is all information relating, directly or indirectly, to an identifiable natural person.
"Processing" means any operation or set of operations which is performed on Personal data, e.g. storage, modification, reading, handover and similar.
"Processor" is the company/organisation that processes personal data on behalf of the Controller and can therefore only process the Personal Data according to the instructions of the Controller and the Applicable Law.
The definitions above shall apply in the Policy regardless if they are capitalised or not.
TWOTWO's role as a Controller
The information in this Policy covers Personal Data Processing for which TWOTWO is the Controller. As a Controller we are responsible for the Processing for which we decide the purpose of ("the why") and the means for the Processing (what methods, what personal data and for how long it is stored). The Policy does not describe how we Process Personal Data in the role of a Processor - i.e. when we process Personal Data on behalf of our customers.
We process your personal data for the following purposes: To fulfill our responsibilities to you as a user of our web pages, services, or products. To support you in case of problems with our web pages, services, or products. To improve our web pages, services, or products. To communicate informational updates and marketing messages via email or telephone. To collect and make customer, marketing, or other types of analyses. To prevent fraud. To follow applicable laws and regulations.
TWOTWO's processing of personal data
We have a responsibility to describe and demonstrate how we fulfil the requirements that are imposed on us when we Process your Personal Data. This section aims to describe:
- That Processing of Personal Data is necessary is for the purpose
- That we have identified the lawful basis for the Processing
Lawful basis
Consent - TWOTWO may process your personal data after you have given your consent to the Processing. Information regarding the processing is always provided in connection to the request of consent.
Performance of a contract - The Processing is necessary for the performance of a contract entered between us and the Data Subject, or to prepare for entering into an agreement with the Data Subject.
Legitimate interest - TWOTWO may process Personal Data if we have assessed that a legitimate interest overrides the interest of fundamental rights and freedoms of the Data Subject, and if the processing is necessary for the purpose in question.
Legal obligation - We are required by laws and regulations to process Personal Data as a result of our business.
For how long do we store your personal data?
We will keep your personal data as long as it is necessary for the purpose for which it was collected. Depending on the lawful basis on which we support the Processing, this may a) be regulated in a contract, b) be dependent on valid consent, c) be stated in legislation or d) follow by an internal assessment based on a legitimate interest assessment (LIA). In the list below, we indicate, where possible, the period during which the Personal Data will be stored and the criteria used to determine the storage period.
Processing
Processing and purpose of Processing: Device information: Examples of Personal Information collected: version of web browser, IP address, time zone, cookie information, what sites or products you view, search terms, and how you interact with the Site.
Purpose of collection: to load the Site accurately for you, and to perform analytics on Site usage to optimize our Site.
Source of collection: Collected automatically when you access our Site using cookies, log files, web beacons, tags, or pixels
Disclosure for a business purpose: shared with our processor Shopify
Order information: Examples of Personal Information collected: name, billing address, shipping address, payment information (including credit card numbers, email address, and phone number).
Purpose of collection: to provide products or services to you to fulfill our contract, to process your payment information, arrange for shipping, and provide you with invoices and/or order confirmations, 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.
Source of collection: collected from you.
Disclosure for a business purpose: shared with our processor Shopify
Behavioural 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 example:
We 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://policies.google.com/privacy?hl=en. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
We share information about your use of the Site, your purchases, and your interaction with our ads on other websites with our advertising partners. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other similar technologies (which you may consent to, depending on your location).
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.
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/.
Minors: The Site is not intended for individuals under the age of 12. We do not intentionally collect Personal Information from children. If you are the parent or guardian and believe your child has provided us with Personal Information, please contact us at the address below to request deletion.
Personal Data: Personal Information collected includes, but are not limited to: name, billing address, email address, phone number, shipping address and order information. Version of web browser, IP address, time zone, cookie information, what sites or products you view, search terms, and how you interact with the Site.
Source: Collected from you and collected automatically when you access our Site using cookies, log files, web beacons, tags, or pixels.
Lawful basis: Consent
Storage period: As long as there is a valid consent. Information on how long the consent is valid is provided in connection with obtaining the consent.
Your rights
You are the one in control of your Personal data and we always strive to ensure that you can exercise your rights as efficiently and smoothly as possible.
Access - You always have the right to receive information about the Processing of data that concerns you. We only provide information if we have been able to verify that it is you that are requesting the information.
Rectification - If you find that the Personal Data we process about you is incorrect, let us know and we will fix it!
Erasure - Do you want us to completely forget about you? You have the right to be forgotten and request deletion of your Personal Data when the Processing is no longer necessary for the purpose for which it was collected. If we are required to retain your information under applicable law or a contract that we have entered with you, we will ensure that it is processed only for the specific purpose set forth in such applicable law or contract. We will thereafter erase the information as soon as possible.
Objections - Do you disagree with our assessment that a legitimate interest for Processing your Personal Data overrides your interest in protecting your privacy? Don’t worry - in such case, we will review our legitimate interest assessment. Of course, we add your objection to the balance and make a new assessment to see if we can still justify our Processing of your Personal Data. If you object to direct marketing, we will immediately delete your personal information without making an assessment.
Restriction - You can also ask us to restrict our Processing of your Personal Data
Whilst we are Processing a request from you for any of your other rights;
If, instead of requesting erasure, you want us to limit the Processing of Personal Data for a specific purpose. For example, if you do not want us to send advertising to you in the future, we still need to save your name in order to know that we should not contact you; or
In cases where we no longer need the information in relation to the purpose for which it was collected, provided that you do not have an interest in retaining it to make a legal claim.
Data portability - We may provide you with the data that you have submitted to us or that we have received from you in connection with a contract that we have entered with you. You will receive your information in a commonly used and machine-readable format that you can transfer to another personal data manager.
Withdraw consent - If you have given consent to one or several specific processing(s) of your Personal Data, you have the right to withdraw your consent at any time and thus ask us to terminate the Processing immediately. Please note that you can only withdraw your consent for future processing of Personal Data and not for Processing that has already taken place.
How you use your rights
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: hello@twotwo-sa.co.za
Transfer of personal data
In order to run our business, we may need help from others who will process Personal Data on our behalf, so-called Processors.
In cases where our Processors transfer Personal Data outside South Africa, the EU/EEA, we have ensured that the level of protection is adequate, and in compliance with Applicable Law, by controlling that either of the following requirements are fulfilled:
the EU Commission has determined that the level of protection is adequate in the third country where the data is processed;
the Processor has signed up to the EU Commission's standard contract clauses (SCCs) for data transfer to non-EU/EEA countries; or
the Processor has taken other appropriate safeguards prior to the transfer and that such safeguards comply with Applicable law.
We have entered into Data Processing Agreements (DPA) with all our Processors. The DPA sets out, among other things, how the Processor may process the Personal Data and what security measures are required for the Processing.
We may also need to disclose your personal information to certain designated authorities in order to fulfill obligations under applicable law or legally binding judgements.
Our processors
Processor: Shopify. Personal data being processed: name, billing address, shipping address, payment information (including credit card numbers, email address, and phone number). version of web browser, IP address, time zone, cookie information, what sites or products you view, search terms, and how you interact with the Site.
Instructions: We share your Personal Information with Shopify to help us provide our services and fulfill our contracts with you.
Processor: ParcelNinja. Personal data being processed: name, billing address, shipping address, payment information (including credit card numbers, email address, and phone number).
Instructions: We share your Personal Information with ParcelNinja to help us provide our services and fulfill our contracts with you.
Security measures
TWOTWO has taken technical and organisational measures to ensure that your Personal Data is processed securely and protected from loss, abuse and unauthorised access.
Our security measures
Organisational security measures are measures that are implemented in work methods and routines within the organisation.
Internal governance documents (policys/instructions)
Login and password management
Information security policy
Technical security measures are measures implemented through technical solutions.
Secure network
Two-step verification
Cookies
TWOTWO uses cookies and similar tracking techniques to analyse the use of the Functions so that we can give you the best user experience. For more information on how we use cookies, see our Cookie Policy (www.twotwo-official.com/pages/privacy-cookies).
If we don’t keep our promise
Should you have any issues with the way in which we are processing your personal information, you are entitled to lodge a complaint with the Information Regulator, whose contact details are:
33 Hoofd Street
Forum III, 3rd Floor Braampark
P.O Box 31533
Braamfontein, Johannesburg, 2017
Complaints email: complaints.IR@justice.gov.za
General enquiries email: inforeg@justice.gov.za.
We trust however that our processing of your personal information will be handled in a way that complies with all the relevant laws and that your rights to privacy will be protected as required by law.
Changes to this policy
We reserve the rights to make changes to this Policy. In the event that the change affects our obligations or your rights, we will inform you about the changes in advance so that you are given the opportunity to take a position on the updated policy.
Contact
Please contact us if you have questions about your rights or if you have any other questions about how we process your personal information:
hello@twotwo-sa.co.za
Cookie Policy
Why and who?
Rematch AB Reg. No. 559018-0377 ("TWOTWO", "we", "us", "our") is using cookies and other tracking technologies ("Cookies") in order to improve your user experience.
This Cookie Policy ("the Policy") describes TWOTWO’s usage of Cookies by explaining what Cookies are, why we use them and how you can control the usage of Cookies when you use our service - webshop TWOTWO – and/or our Webpage www.twotwo-sa.co.za (commonly referred to as "Webpage"). The Policy does not inform about the usage of Cookies that are essential in order to provide the Webpage and its services to you (so-called strictly necessary cookies).
For more information about how we process your personal data in relation to Cookies, see our Privacy Policy.
What are Cookies?
A Cookie is a text file that is sent from the Webpage and stored on your computer, cell phone or any other device that you use to visit the Webpage.
Cookies allow us to e.g. recognise the device you use next time you visit the Webpage, provide certain essential functions and to monitor user behaviour on the Webpage.
How long is the Cookie stored?
There are two types of Cookies; Session cookies and Permanent cookies.
Session cookies are deleted when you close the browser (e.g. Internet explorer, Safari or Google Chrome).
Permanent cookies remains on your device after you have closed the browser. The Cookie will be stored for as long as it is indicated in the Cookie or until you remove it.
TWOTWO’s usage of Cookies
We use the following types of Cookies:
Preference: These Cookies remembers your choices on the Webpage (e.g. username, language etc.) and tells us how you have interacted with the Webpage so that we can personalise the service.
Performance: These Cookies analyse how you use the Webpage and monitors the Webpage’s performance. This helps us to identify and manage eventual problems. A performance cookie can e.g. keep track of the traffic on different pages and give us information on how long it takes for a page to load.
Operation and optimisation: These Cookies help us ensure that the Webpage is working as it should. It also gives us information which allow us to test new ideas and improve the Webpage.
Marketing: By collecting information on how you interact with the Webpage, these Cookies helps us to be more relevant in our communication with you and improve your experience.
These Cookies are often placed by a third party with the intent to handle performance for ads, show ads and / or build user profiles in order to display ads elsewhere.
First party Cookies
First party cookies are set by the Webpage on your device and can therefore only be read by you or us.
Name: _ab
Type: Necessary for the functioning of the Store, standard via Shopify
Purpose: Used in connection with access to admin.
Duration: 2 years
Name: _secure_session_id
Type: Functional
Purpose: Used in connection with navigation through a storefront, standard via Shopify
Duration: 1 day
Name: Cart
Type: Functional
Purpose: Used in connection with shopping cart.
Duration: 2 weeks
Name: cart_currency
Type: Functional
Purpose: Used in connection with shopping cart.
Duration: 2 weeks
Name: cart_sig
Type: Functional
Purpose: Used in connection with checkout.
Duration: 2 weeks
Name: cart_ts
Type: Functional
Purpose: Used in connection with shopping cart.
Duration: 2 weeks
Name: cart_ver
Type: Functional
Purpose: Used in connection with shopping cart.
Duration: 2 weeks
Name: checkout
Type: Functional
Purpose: Used in connection with checkout.
Duration: 2 weeks
Name: checkout_token
Type: Functional
Purpose: Used in connection with checkout.
Duration: 2 weeks
Third party cookies
The Cookie is set by another party than us when you visit the Webpage.
TWOTWO only uses reliable third parties. Third-party cookies can e.g. help us understand the needs of our users and give us information on how effective our marketing is. Third-party cookies may in some cases be used on websites other than the Website. Information collected by these third parties cannot identify your name, contact information or other personal information unless you choose to provide it. Since we can't provide detailed information we refer to their respective policies.
We use these service providers:
Provider: Google Analytics
What is it doing? Site statistic web data is collected with tools such as Google Analytics to analyse the performance of our site and monitor user trends on the site. Analytical data such as hits to our server, traffic patterns and page views shows us where our audience is coming from and how they interact with the site.
More info: www.support.google.com/analytics/answer/6004245
Provider: Facebook pixel
What is it doing? Used for tracking, analytics, remarketing, and overall ad optimization.
More info: www.facebook.com/policies/cookies
Provider: Klaviyo
What is it doing? Gather information to improve conversion rates and email performance.
More info: www.help.klaviyo.com/hc/en-us/articles/360034666712-About-Cookies-in-Klaviyo
Provider: Shopify
What is it doing? As a Shopify merchant using their platform to power our online store, Shopify place functional cookies for visitors of the store.
More info: www.shopify.com/legal/cookies
Managing Cookies
When you visit the Webpage for the first time, we ask for your consent to use non-necessary cookies. You can withdraw your consent at any time. If you no longer wish to store the Cookies you have accepted, you can go to your web-browser settings and accept, deny or remove cookies (usually under "Help", "Settings" or "Edit"). Note that you will likely not be able to use all services on the Webpage if you choose to deny Cookies.
Changes to this Policy
We reserve the right to make changes in this Policy. If a change affects our obligations or your rights, we will inform you about the changes in advance in order to give you the possibility to accept the updated policy.
Contact
Contact us if you have any questions about Cookies: hello@twotwo-sa.co.za