Privacy policy

Websites and mobile applications

1. Introduction

  1. This document embodies the Privacy Policy of Caxton and CTP Publishers and Printers Limited’s websites and mobile applications. (Caxton and CTP Publishers and Printers Limited is hereinafter referred to as “Caxton/The Company”/”us”/”we”).
  2. This Privacy Policy describes how we access, collect, handle, store, use, share and protect Personal Data, and limits the use of data to the policy-compliant purposes disclosed below. We are serious about protecting your private information. To that end, this policy details how we handle your data securely.
  3. This policy has been updated to comply with the Europen Union’s General Data Protection Regulation (GDPR), South Africa’s Protection of Personal Information Act (“POPIA”) and Google’s Privacy Policy and Guidelines on user data. This Privacy Policy should be read and understood together with our Terms and Conditions.
  4. Click here to access Caxton’s POPIA Policy.

2. Application

  1. This policy applies to users of www.citizen.co.za and its associated mobile application. The policy also applies to anyone who has registered for, uses, or ordered our products or services. Those to whom the Privacy Policy applies, are herein referred to as “you” or “users”.

3. Key Definitions

For purposes of this policy, the following words will have the following meanings:

  1. Application (“App”): An application is a software program designed to perform a specific function directly for a user or, in some instances, for another software program.
  2. Browser Tracking: Other websites you or platforms you visit before ours may place Personal Data within your URL. When other sites and platforms do so, Caxton has no control over this. This Browser Tracking may cause Caxton’s server logs to automatically receive and record internet usage information from your browser. This usage information may include your IP address, location, browsing habits, click patterns, and details relating to your software. Usage information also includes your system type, screen resolution, colour capabilities, JavaScript enablement and plug-ins. It also includes your language settings, cookie preferences, search engine keywords you have used, and content and pages you had accessed online, as well as the dates, times, and duration of your website visits.
  3. Caxton/The Company/us/we: refers to Caxton and CTP Publishers and Printers Limited, all of its stakeholders, subsidiaries the subsidiaries of Caxton’s subsidiaries and respective holding companies, the subsidiaries of such holding companies, divisions and affiliates and partners (“Caxton”). Reference to Caxton in this Privacy Policy shall also be deemed to be a reference to the relevant legal entity which operates the website concerned.
  4. Cookies: Cookies (a type of Tracking Technology) are text files that are transferred to your digital device whenever you visit a website or App. Cookies ‘remember’ information about you. The information helps Caxton to understand how our Users are utilising our services, assisting us in improving them. With it, we can remember your preferences, previous website usage and browsing history, and keep this in mind when providing you with content. In so doing, we can bring you an enhanced experience and customised content and services. With Cookies, we are able to provide our advertisers with the ability to direct relevant advertisements to their audiences. We are also able to track responses to advertising.
  5. Gated Data: refers to restricted access to sensitive user information, requiring explicit authorisation for Apps to use it.
  6. GDPR: The European Union’s General Data Protection Regulation.
  7. Data Collection and Processing Purposes: Caxton may collect and process your Personal Data for the purpose of conducting its day-to-day activities that include publishing, news reporting, advertising, marketing, and related business activities. Caxton’s Data Collection and Processing Purposes also include collecting, possessing, processing, and sharing Personal Data for the purpose of simplifying and enhancing your user experience. This includes Caxton’s remembering your information for easier logins, monitoring of your website usage metrics, and tracking your submissions in any promotions or other website activities. Caxton’s Data Collection Purposes further include legal, auditing, and administrative purposes related to its goods and services, as well as the purposes of gathering and sharing business intelligence, industry research, statistics, and information exchanges with third parties regarding Caxton’s goods and services.
  8. Google Ads Policy: Refers to Google’s Ads Policy available here.
  9. Google Developer Policies: Refers to the Google Policies available here.  
  10. Personal Data: means any information that can be used to identify either a natural or juristic person. It includes, but is not limited to, personally identifiable information, and personal and sensitive user data. Examples include financial and payment information, authentication information, phonebook, contacts, device location, SMS and call-related data, inventory of different apps on a device, a device’s microphone, camera, and other sensitive device or usage data.  In the context of this policy, the term includes the definition of “Personal Information” in Section 1 of POPIA, which defines the term as: “information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person, including, but not limited to— (a) information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth of the person; (b) information relating to the education or the medical, financial, criminal or employment history of the person; (c) any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier or other particular assignment to the person; (d) the biometric information of the person; (e) the personal opinions, views or preferences of the person; (f) correspondence sent by the person that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence; (g) the views or opinions of another individual about the person; and (h) the name of the person if it appears with other personal information relating to the person or if the disclosure of the name itself would reveal information about the person;”
  11. Platform: refers to www.citizen.co.za and its associated mobile App.
  12. POPIA: South Africa’s Protection of Personal Information Act, 4 of 2013.
  13. Data Usage and Processing: This term refers collectively to accessing, collecting, using, handling, sharing, and processing Personal Data.
  14. Tracking Technologies: Tracking Technologies are online methods by which information about you and your web usage is collected. Such data collection happens, for example, via Browser Tracking, Cookies, or Web Beacons.
  15. User/You: Anyone who has registered for, uses, or ordered our products or services.
  16. Web Beacons: Web Beacons keep track of your activities on specific web pages. These trackers record details like which pages you viewed, how long you stayed on a site, and whether you clicked on any links. Tracking pixels, therefore, provide owners with data on the website visits of its different Users.
  1. Users who use this Platform or any of our goods and services confirm that they have actively consented[HV1]  to Data Usage and Processing as per this policy. They also confirm that they have the legal capacity to contract, that they are 18 or older, and that they have read, understood, accepted, and agreed to the terms of this policy.  
  2. Users who share Personal Data with us or via this Platform, warrant that they have the right and required consent to do so.
  3. We may change the terms of this policy at any time by updating this Platform. Users are responsible for ensuring that they are up to date on its contents.

5. Data Usage and Processing

  1. We use and process your Personal Data for lawful Data Collection and Processing Purposes only.
    1. Such Data Collection and Processing Purposes include:
      1. We collect your Personal Data when you use our Platform, complete an application form, contact Caxton electronically, or use our products, services, facilities, tools, or utilities.
      1. Caxton may remember your information for easier log-ins, monitor your website usage metrics and track your submissions in any promotions or other website activities. We may use your personal information for administrative purposes, to contact you, and to provide you with personalised targeted content.
      1. Caxton may make use of third parties, affiliates and business partners for its Data Collection and Processing Purposes. 
      1. Caxton may also use your personal information for any other purposes set out in this policy, and for purposes we reasonably deem appropriate. You accept that we may store or process your personal information outside of the region or country that you submit or use it in.
  2. We do not sell Personal Data.
  3. When making use of third-party providers of any goods or services that entail Data Usage and Processing, we require these third parties to be compliant with Google Developer Policies and applicable privacy law. Similarly, when making use of any App that may extend the usage of personal and sensitive user data for advertising purposes, we require these Apps to comply with the Google Play Ads Policy.
  4. When accessing Gated Data protected by, for example, Android Permission, we request access to device resources like cameras or location during App usage. On Android devices, this access is obtained via runtime permission.  

6. We use Tracking Technology

  1. Tracking Technologies are online methods by which information about you

and your web usage. Such data collection happens, for example, via your browser (Browser Tracking), Cookies, or Web Beacons. Schedule 1 below explains how Users can turn off Cookies and Web Beacons.

7. Limitations on Data Usage and Processing

  1. We limit our Data Usage and Processing to what is required for our Data

Collection and Processing Purposes. We will not use or process your

Personal Data for purposes other than those listed herein.

  1. This Platform does not publicly disclose any Persona Data related to financial or payment activities or any government identification numbers without authorisation.
  2. This Platform does not allow for the unauthorised publication or disclosure of non-public contacts.

8. Data retention and deletion

  1. We will only retain your Personal Data for as long as it is necessary to fulfil the Data Collection and Processing Purposes, unless:The law allows lengthier data retention; orYou have consented to a lengthier data retention;

You agree that account and subscription data is retained for five years after the most recent transaction.

  1. In the event that a User creates an account from within the Platform, that User will have the right to request account deletion.

9. Security

  1. Caxton takes reasonable steps to protect your personal information from loss, misuse or unauthorised alteration. This includes practices like encryption, access control, data minimization, secure storage and regular auditing and monitoring.
    1. Encryption entails utilising strong encryption algorithms to secure personal and sensitive data both at rest and during transmission.
    1. We implement robust access controls to limit who can access, view, obtain, modify, or delete Personal Data, and ensure that only authorised users have access.
    1. Data minimisation entails that we collect, retain and process only the minimum amount of Personal Data necessary for the intended purpose.
    1. Store Personal Data in secure, protected environments such as encrypted databases or secure cloud storage platforms, with appropriate backup and disaster recovery measures in place.
    1. Regular Auditing and Monitoring to detect and respond to any unauthorized access or suspicious activities promptly.
    1. Personal Data is stored in databases that have built-in safeguards to ensure the privacy and confidentiality of that information.
    1. Data Usage and Processing is done securely and using modern cryptography (for example, over HTTPS).
    1. Where our app needs to access Gated Data, it will do so via a runtime permission.
    1. Applications or platforms that extend the usage of personal data are, as a standard practice, required to comply with data security standards such as those set out in Google Play’s Ad Policy.
    1. When you use the products, services, facilities, tools or utilities provided by Caxton on the Site, you may, in certain cases, be given an access number, username, password and/or personal identification number (“PIN”). If this is the case, you must always keep your username, access card, password and/or PIN a secret and ensure that you do not disclose it to anyone.

10. Liability limitation

  1. Caxton cannot be held responsible for security breaches occurring on your electronic device (personal computer or other electronic device used to browse the Platform), which may result due to the lack of adequate virus protection software or spyware that you may inadvertently have installed on your device.
  2. Caxton is not responsible for the contents of any third-party website (including third party websites linked to the Platform, websites facilitated by us or websites that serve as social networks like Facebook or Twitter).
  3. Caxton does not exercise control over the privacy policies of these third parties and you should refer to the privacy policy of these third parties to see how they protect your privacy.
  4. You fully indemnify Caxton, and hold us harmless, against any damages that may by incurred by yourself or any third party resulting from, or in connection with, the usage of this Platform.
  1. You can update your Personal Data, change your Data Usage and Processing preferences or withdraw your consent at any time by clicking the “Privacy” button on this Platform[HV2] .

12. Queries and complaints

  1. Queries or complaints about the way we handle your personal data may be submitted to webadmin@citizen.co.za. You may also submit such complaints to the relevant supervisory authority where you are located.

13. Jurisdiction

  1. You consent to the jurisdiction of the South African courts in respect of any dispute which may arise out of or in connection with the formation, interpretation, substance or application of this privacy policy.

SCHEDULE 1: How to turn off Cookies or Web Beacons

Cookies

How to turn cookies off/opt-out:

You are able to control advertising cookies and remove them through the tools on your web browser.

Chrome

1. Click the Customize and control Google Chrome menu button in the upper right-hand corner of the browser bar.
2. Click “Settings.”
3. Scroll down to the Privacy and Security section.
4. Click “Site Settings”.
5. Click “Cookies and site data”.
6. In the Privacy and Security section, click Content Settings.
7. Customise settings so as to block cookies.

Edge

1. Click the Settings and more button in the upper right-hand corner of the browser bar.
2. Click Settings.
3. Click Privacy & Security.
4. In the Cookies section, turn on “Block third-party cookies” or add desired sites in the “Block” section to block the cookies.

Internet Explorer 11

1. Click Tools or the gear icon in the upper right-hand corner of the top of the browser bar.
2. Select Internet Options.
3. Click the Privacy tab and then the Advanced button on that tab.
4. Customise settings so as to reflect your preferences.

Firefox

1. Click the Open menu button in the upper right-hand corner of the browser bar.
2. Click Options.
3. Click Privacy & Security.
4. Customise settings so as to reflect your preferences.

Safari

1. Click Safari > Preferences.
2. Click on the Privacy tab.
3. In the “Cookies and website data” section, customise settings according to your preferences.

For help with your browser’s cookie settings, visit its “Help” or “Support” section.

Web Beacons

How to turn Web Beacons off/opt-out:

Do Not Track is a browser setting that requests sites, web apps or services to cease tracking a user’s online activities. This setting is available in Chrome, Mozilla Firefox, Microsoft Edge, Internet Explorer, and Safari.