Privacy Notice

Last updated: [Insert publication date]

1. Who we are

This Privacy Notice explains how Noctis Incorporated (“Noctis”, “we”, “us” or “our”) collects, uses, stores and protects personal information through our website and related communications.

Our website is: https://noctis.co.za

Our business address is:
13 Umgazi Street
Menlo Park
Pretoria
0081
South Africa

For privacy-related queries, requests or concerns, please contact:
Information Officer: [Insert name]
Email: info@noctis.co.za
Subject line: Privacy Request

This Privacy Notice applies to website visitors, prospective clients, clients, job applicants and other people who contact us through the website.

Additional notices, engagement letters or professional terms may apply where you become a client of Noctis or use any of our professional services.

2. What personal information means

Personal information is information that identifies you or can reasonably be linked to you. This may include information relating to an individual or, where applicable, a business or other legal entity.

It does not include information that has been properly anonymised or de-identified so that it can no longer reasonably be linked to a specific person or organisation.

3. Information we collect

We collect personal information that you choose to provide when you contact us through this website.

Depending on the form you complete or the information you send to us, this may include:

• Your name
• Email address
• Contact number
• Entity type
• Service area or reason for enquiry
• The contents of your message
• Information included in a CV or job application
• Documents uploaded with a vacancy application, including PDF, DOC or DOCX files
• Any other information you choose to include in your enquiry, message or application

We may also collect limited technical information needed to operate, secure and protect the website and its forms. This may include the date and time of a submission, browser information, IP address, server logs and spam-prevention signals where available through the website, hosting environment or form system.

4. How we collect personal information

We generally collect personal information directly from you when you complete a form on our website, contact us by email or telephone, submit an enquiry, or provide information as part of a vacancy application.

We may also receive or collect personal information from other lawful sources where necessary and appropriate, including public records, professional or regulatory bodies, service providers, referrals, or other parties involved in a matter, enquiry or application.

Where we collect personal information from a source other than you, we will do so only where permitted by law and where reasonably necessary for a lawful purpose.

5. Why we use your information

We use personal information to:

• Respond to enquiries and requests for information
• Assess whether Noctis may be able to assist with the service you require
• Communicate with you about your enquiry, application or existing relationship with us
• Process and assess vacancy applications
• Administer, secure and improve our website and forms
• Detect and prevent spam, misuse, fraud or other security risks
• Maintain appropriate business, legal, tax, audit and professional records
• Comply with legal, regulatory and professional obligations
• Protect our rights, property, systems and personnel where reasonably necessary

We do not sell or rent personal information.

6. Lawful grounds for processing

We process personal information only where there is a lawful reason to do so.

Depending on the circumstances, this may include:

• Responding to your request or enquiry
• Taking steps at your request before entering into a professional engagement
• Performing or administering an agreement with you
• Complying with legal, regulatory or professional obligations
• Protecting our legitimate business, website and security interests
• Your consent, where consent is required

Where we rely on consent, you may withdraw it at any time. Withdrawal will not affect processing that took place lawfully before the withdrawal.

7. Providing information to us

You are not generally required to provide personal information when browsing our website.

However, where you choose to submit an enquiry, request information or apply for a vacancy, we may need certain information to respond properly. If you do not provide the required information, we may be unable to deal with your enquiry or application.

Please do not send highly sensitive personal information through our website unless it is necessary and appropriate for the purpose of your enquiry or application.

8. Vacancy applications and CVs

Where you apply for a vacancy through the website, we use your CV and related information to assess your application and communicate with you about relevant recruitment opportunities.

Please avoid including information that is not necessary for us to assess your application, including highly sensitive personal information, unless it is specifically relevant and requested.

Unless we are required to retain it for a longer period, CVs and recruitment records will be retained for [insert agreed period, for example 12 months] after the relevant recruitment process has ended.

9. Direct marketing

We do not currently use personal information collected through this website for unsolicited direct marketing.

Should we introduce marketing communications in future, we will do so only where permitted by applicable law. You will be able to opt out of marketing communications at any time.

We will not automatically add you to a marketing list merely because you submitted a website enquiry.

10. Who we may share information with

We may share personal information only where reasonably necessary with:

• Authorised Noctis personnel who need the information to perform their duties
• Website hosting, email-delivery, backup, website-maintenance, security and technical-support providers
• Service providers that help us operate website forms, data storage or communications
• Professional advisers, including legal, accounting, tax or insurance advisers
• Regulators, law-enforcement bodies, courts or other parties where disclosure is required by law or reasonably necessary to protect our rights

Any service provider that processes personal information for us must be authorised to do so and is expected to protect that information appropriately.

We may also use aggregated or de-identified information for business, website-performance or reporting purposes. This information does not identify you personally.

11. International transfers

Some website, hosting, email, backup or technology service providers may process information outside South Africa.

Where this happens, we will take reasonable steps to ensure that the transfer is permitted under applicable data-protection law and that appropriate safeguards are in place.

12. How long we keep information

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, unless a longer period is required or permitted by law.

As a general guide:

• Website enquiries may be retained for [insert agreed period, for example 24 months after the last communication]
• CVs and recruitment records may be retained for [insert agreed period, for example 12 months after the recruitment process]
• Spam, security and technical logs may be retained for a shorter period where practical, unless needed for security, investigation or legal purposes
• Information may be retained for longer where required for legal, regulatory, tax, audit, security or dispute-resolution purposes

When information is no longer needed, we will delete, destroy or de-identify it where reasonably practicable.

Personal information may remain in secure website backups until those backups are replaced or deleted in line with our normal backup cycle.

13. Cookies, website functionality and spam protection

This website may use essential technical cookies, local storage, server logs and form-related data needed to operate the site, support security and prevent spam.

Our website forms may use spam-protection measures designed to identify automated or suspicious submissions. These measures may process limited technical information needed to protect the website and its forms.

We do not currently use personal information collected through the website for behavioural advertising or profiling.

We do not currently use Google Analytics, Meta Pixel, LinkedIn Insight Tag or similar advertising-tracking technologies through this website.

If we introduce analytics, advertising pixels, Cloudflare Turnstile, Google services, LinkedIn services, Meta services or other non-essential tracking technologies in future, we will update this Privacy Notice and any related cookie controls where appropriate.

You may usually control or delete cookies through your browser settings. Please note that disabling essential cookies may affect certain website functions.

14. Links to other websites

This website may contain links to third-party websites, including map, social-media or service-provider websites.

Those websites are operated independently and have their own privacy practices. Noctis is not responsible for the privacy policies, security or content of third-party websites.

15. Keeping information accurate

We take reasonable steps to keep personal information accurate, complete and up to date where necessary for the purposes for which it is used.

Please let us know if your information changes or if you believe information we hold about you is inaccurate.

We may need to verify your identity before providing access to, correcting or deleting personal information.

16. Your rights

Subject to applicable law, you may request to:

• Access personal information we hold about you
• Correct inaccurate or incomplete information
• Request deletion of information where there is no lawful reason for us to retain it
• Object to certain processing of your information
• Withdraw consent where processing is based on consent
• Raise a concern about how your information has been handled

To make a request, contact us at info@noctis.co.za with the subject line Privacy Request.

We may need to verify your identity before acting on a request.

17. Security

We take reasonable technical and organisational steps to protect personal information against loss, unauthorised access, misuse, disclosure, alteration or destruction.

Access to personal information is limited to authorised persons and service providers who require it for legitimate business purposes.

However, no website, email system or internet transmission can be guaranteed to be completely secure. You should avoid sending highly sensitive information through the website unless it is necessary and appropriate to do so.

18. Security incidents

If we become aware of a security incident that may have compromised personal information, we will take reasonable steps to assess the incident, limit potential harm, and notify affected persons and/or the Information Regulator where required by law.

19. Children’s personal information

This website is not directed at children and we do not intentionally collect personal information from children through the website.

If you are submitting information on behalf of a child or minor, you must have the necessary authority to do so.

20. Business changes

If Noctis undergoes a restructuring, merger, acquisition, sale of assets or similar business transaction, personal information may be transferred to the relevant successor or purchaser where permitted by law.

Any such recipient will be required to use the information only for lawful purposes and in accordance with applicable data-protection requirements.

21. Complaints

If you believe that your personal information has been processed unlawfully or that we have not handled a privacy request appropriately, please contact us first so that we can try to resolve the matter.

You may also lodge a complaint with the Information Regulator of South Africa.

Information Regulator contact details:
Website: https://inforegulator.org.za/
POPIA complaints: POPIAComplaints@inforegulator.org.za
General enquiries: enquiries@inforegulator.org.za

22. Changes to this Privacy Notice

We may update this Privacy Notice from time to time to reflect changes to our website, services, legal obligations or processing practices.

The latest version will always be available on this website together with its effective date.