1.1. As part of your interactions with the Herd Trust, the Herd Trust collects various data from you, both by
your providing it directly, and automatically from, amongst other things, browsing the Herd Trust
website. This Policy Document explains how the Herd Trust collects your data and what can it and
cannot do with such information.

1.2. Personal information

1.2.1. Personal information includes: certain information that the Herd Trust collects automatically when you visit our
website; certain information collected on registration (see below); certain information collected on submission; certain information collected when you make any donation to the Herd Trust; and optional information that you provide to the Herd Trust voluntarily (see below);
but excludes: information that has been made anonymous so that it does not identify a specific
person; permanently de-identified information that does not relate or cannot be traced back
to you specifically; non-personal statistical information collected and compiled by the Herd Trust; and information that you have provided voluntarily in an open, public environment or
forum including any blog, chat room, community, classifieds, or discussion board
(because the information has been disclosed in a public forum, it is no longer
confidential and does not constitute personal information subject to protection
under this policy).

1.2.2. Sensitive personal information
Depending on the services that you require, the Herd Trust may also collect sensitive personal
information including your: financial information – such as your bank account details; biometric information – such as images of your face or fingerprints.

1.3. From Browsers

The Herd Trust automatically receives and records Internet usage information on its server logs from
your browser, such as your Internet Protocol address (IP address), browsing habits, click patterns,
version of software installed, system type, screen resolutions, colour capabilities, plug-ins, language
settings, cookie preferences, search engine keywords, JavaScript enablement, the content and pages
that you access on the website, and the dates and times that you visit the website, paths taken, and
time spent on sites and pages within the website (usage information). Please note that other websites
visited before entering our website might place personal information within your URL during a visit to it,
and we have no control over such websites. Accordingly, a subsequent website that collects URL
information may log some personal information.

1.4. Cookies

1.4.1. The Herd Trust may place small text files called ‘cookies’ on your device when you visit its
website. These files do not contain personal information, but they do contain a personal
identifier allowing the Herd Trust to associate your personal information with a certain device.
These files serve a number of useful purposes for you, including: granting you access to age restricted content; tailoring our website’s functionality to you personally by letting us remember your
preferences; improving how our website performs; allowing third parties to provide services to our website; and helping us deliver targeted advertising where appropriate in compliance with the
applicable laws.
1.4.2. Your internet browser generally accepts cookies automatically, but you can often change this
setting to stop accepting them. You can also delete cookies manually. However, no longer
accepting cookies or deleting them will prevent you from accessing certain aspects of our
website where cookies are necessary.
1.5. Third Party Cookies
Some of our business partners use their own cookies or widgets on our website. We have no access
to or control over them. Information collected by any of those cookies or widgets is governed by the
privacy policy of the company that created it, and not by us.
1.6. Optional Details
You may also provide additional information to us on a voluntary basis (optional information). This
includes content or products that you decide to upload or download from our website or when you enter
competitions, take advantage of promotions, respond to surveys, order certain additional services, or
otherwise use the optional features and functionality of our website.

1.7. Purpose of Collection

1.7.1. The Herd Trust may use or process any services information, or optional information that you
provide to it for the purposes that you indicated when you agreed to provide it to the Herd
Trust. Processing includes gathering your personal information, disclosing it, and combining it
with other personal information. We generally collect and process your personal information
for various purposes, including: services purposes – such as requests for and providing our services; marketing purposes – such as pursuing lawful related marketing activities; business purposes – such as internal audit, accounting, business planning, and
joint ventures, disposals of business, or other proposed and actual transactions;
and legal purposes – such as handling claims, complying with regulations, or pursuing
good governance.
1.7.2. We may use your usage information for the purposes described above and to: remember your information so that you will not have to re-enter it during your visit
or the next time you access the website; monitor website usage metrics such as total number of visitors and pages
accessed; and track your entries, submissions, and status in any promotions or other activities in
connection with your usage of the website.

1.8. Consent to Collection

1.8.1. The Herd Trust will obtain your consent to collect personal information: in accordance with applicable law; when you provide the Herd Trust with any registration information or optional
information voluntarily.

2. USE

We may use your personal information to fulfil our obligations to you.


3.1. Sharing
The Herd Trust may share your personal information with:

3.1.1. other divisions or companies within the group of companies to which the Herd Trust belongs
so as to provide joint content and services like registration, for transactions and customer
support, to help detect and prevent potentially illegal acts and violations of its policies, and to
guide decisions about its products, services, and communications (they will only use this
information to send you marketing communications if you have requested their services);
3.1.2. an affiliate, in which case the Herd Trust will seek to require the affiliates to honour this privacy
3.1.3. the Herd Trust services providers under contract who help provide certain services or help with
parts of our business operations, including fraud prevention, bill collection, marketing,
technology services (the Herd Trust contracts dictate that these services providers only use
your information in connection with the services they supply or services they perform for the
Herd Trust and not for their own benefit);
3.1.4. credit bureaus to report account information, as permitted by law;
3.1.5. banking partners as required by credit card association rules for inclusion on their list of
terminated merchants (in the event that you utilise the services to receive payments and you
meet their criteria); and
3.1.6. other third parties who provide the Herd Trust with relevant services where appropriate.

3.2. Regulators
The Herd Trust may disclose your personal information as required by law or governmental audit.

3.3. Law enforcement
The Herd Trust may disclose personal information if required:
3.3.1. by a subpoena or court order;
3.3.2. to comply with any law;
3.3.3. to protect the safety of any individual or the general public; and
3.3.4. to prevent violation of our customer relationship terms.

3.4. No selling
The Herd Trust will not sell personal information. No personal information will be disclosed to anyone
except as provided in this privacy policy.

3.5. Marketing purposes
The Herd Trust may disclose aggregate statistics (information about the customer population in general
terms) about the personal information to advertisers or business partners.

3.6. Employees
The Herd Trust may need to disclose personal information to our employees that require the personal
information to do their jobs. These include our responsible management, human resources, accounting,
audit, compliance, information technology, or other personnel.

3.7. Change of ownership
If the Herd Trust disposes of its assets or is wound up, the current trustees may assign any rights to
the personal information they have processed to any successors. The Herd Trust will disclose any
changes on the website. If you are concerned about your personal information migrating, you may
request the Herd Trust to delete your personal information.


4.1. Protocols
The Herd Trust adheres to strict security protocols in respect of data protection laws. The Herd Trust’s
website is hosted in a secure server environment that uses a firewall in addition to other advanced
security measures aimed to prevent any interference or access from unwarranted outside third parties.

4.2. Access
Access to any personal information is only authorised for employees who require such information in
order to fulfil their employment responsibilities.


5.1. The Herd Trust aims to ensure that all personal information collected is accurate, complete and up to
date as is necessary for the purposes defined in this policy. In order to maintain accurate information,
the Herd Trust may request that you update your information on our website.

5.2. Updating Information
You are able to review and update any personal information that may be held by the Herd Trust by
accessing your account online, emailing the Herd Trust, or phoning the Herd Trust. The identity of any
person wishing to update any information is required to be verified prior to the granting of any access
to the respective person’s account or making any changes to any personal information.


6.1. Period of Retention
The Herd Trust will only retain personal information for as long as it is necessary to fulfil the purposes
explicitly set out in this policy, unless:

6.1.1. retention of the record is required or authorised by law; or
6.1.2. consent for the retention of the record is given to the Herd Trust.

6.2. Obligations
During the period of retention, the Herd Trust will continue to abide by all its obligations stipulated in
this policy.

6.3. The Herd Trust reserves the right to retain information in physical or electronic records at its discretion.


The Herd Trust undertakes not to transfer any personal information across any country border without
prior written consent.


8.1. Liability
The Herd Trust is not responsible for, gives no warranties and makes no representations whatsoever
in respect of any privacy policy and/or practice belonging to linked or third-party websites.


View POPIA Manual