ICILY PROPRIETARY LIMITED
PRIVACY POLICY
This Privacy Policy describes how Icily (Pty) Ltd, (“we”, “us”, “our”) collects, uses, stores, shares and discloses your Personal Information. It applies to any person who interacts with us, including website users, customers, suppliers, service providers, business partners and other third parties (“you”).
It is important that you read this Privacy Policy together with our other terms and conditions, agreements or policies we may provide from time to time when we collect or use your Personal Information.
We respect your privacy and take the protection of Personal Information very seriously. We strive to deliver excellent service every time you shop with us, and to do this, we need to use some of your Personal Information.
By using our Platforms, you agree to the processing of your Personal Information as set out in this Privacy Policy.
CHANGES TO THIS NOTICE
We may update this Notice from time to time to introduce new systems, services or products; to comply with changes in the law; to correct any errors; or for any other reasonable purpose. Any changes will take effect when we publish the updated policy on our website or notify you by other reasonable means. Please check periodically for updates.
WHAT PERSONAL INFORMATION WE COLLECT AND PROCESS
We process Personal Information in a manner that is reasonable, adequate, relevant, non-excessive and purpose-specific.
Depending on your relationship with us, we may collect the following types of personal information:
· your name, surname, title, physical and postal addresses, telephone numbers and email addresses;
· records of correspondence or enquiries from you or anyone acting on your behalf;
· details of transactions you carry out with us;
· details of contracts you enter into with us;
· special personal information, including biometric information (such as CCTV footage or photographs) where you visit our stores;
· information about your company or organisation, including registration number, VAT number, and authorised representatives; and
· information collected automatically when you use our websites or social media pages, including:
- log information, through online identifiers, including information on how, when and for how long you use our website and other services, the content you view and search queries you submit;
- information about the equipment you use to access or use our websites, including the type of device you are using, how you access our sites, your browser or operating system and your Internet Protocol address;
- the geographic location from which you accessed our sites, including your device’s global positioning system signal and information about nearby wifi networks and cell towers. We get this information when you use location-enabled services;
o other information about you from third parties, such as social media.
Should your Personal Information change or you wish to amend and/or correct your information, you can do this by updating your registered user information in your account profile or by contacting us at privacy@icily.co.za.
You warrant that the information you have provided is accurate, current, true, and correct and that does not impersonate or misrepresent any person or entity or falsely state or otherwise misrepresent your affiliation with anyone or anything.
WHERE DO WE GET YOUR PERSONAL INFORMATION
We may collect your personal information directly from you when you buy our products or services, enter into a contract with us, request information, or communicate with us in any way (including in writing, in person, by telephone or electronically).
We may also collect your personal information from third parties and publicly available sources.
WHY DO WE PROCESS YOUR PERSONAL INFORMATION?
Under POPIA, we may only process your personal information if we have a lawful reason to do so. We rely on the following legal grounds:
· Consent: you have agreed to the processing;
· Contract: the processing is necessary to enter into or perform a contract with you;
· Legal obligation: the processing is required by law; and/or
· Legitimate interests: the processing is necessary for our legitimate business interests or those of a third party, provided your rights do not override those interests.
We use your personal information for the following purposes:
- providing you with products, services or offerings you have requested, and notifying you of important changes;
- managing your account or relationship with us and responding to your instructions or requests;
- handling complaints and responding to requests;
- internal business purposes, including operational, marketing, auditing, legal and record-keeping activities;
- get feedback from you which we need to develop our products and services and grow our business;
- transferring your personal information outside South Africa where necessary, including for cloud storage;
- complying with applicable laws, including responding to lawful requests from law enforcement, government agencies and tax authorities;
- recording and monitoring telephone calls and electronic communications for quality assurance, training, evidence and crime prevention purposes;
- conducting market research and sending you information about our products or services;
- maintaining suppression lists to ensure we do not send marketing to you if you have unsubscribed;
- sharing your personal information with third parties as described in this Privacy Policy;
- monitoring and recording communications for security, compliance and evidentiary purposes; and
- improving and evaluating the effectiveness of our business, products and services.
Direct marketing: We may contact you about competitions, products, services or offerings that may interest you by email, phone, SMS or other electronic means. You may also receive newsletters from us. We will only send you direct marketing if you have given your prior consent or where we are otherwise permitted to do so by law. You may withdraw your consent or opt out of direct marketing or our newsletters at any time, at no cost, by contacting us at privacy@icily.co.za.
WHO ELSE GETS TO PROCESS YOUR PERSONAL INFORMATION
We do not sell your Personal Information to third parties for their marketing or any other purposes.
We may provide or make your Personal Information available to:
- our employees, in order to enable them to assist us to interact with you for the marketing, ordering or delivery of goods;
- law enforcement, government officials, fraud detection agencies, regulators or other third parties, where required by law;
- third parties (such as a potential buyers and its professional advisors) in the event of any reorganisation, merger, consolation, sale, joint venture, or other disposition of any or all of our assets;
- our service providers who provide products or services to us or on our behalf, including our supplier, IT providers, cloud storage providers, payment processors, marketing agencies, and professional advisers;
RETENTION AND RESTRICTION OF RECORDS
We keep your personal information only for as long as necessary to fulfil the purposes for which it was collected, or as required or permitted by law. When deciding how long to keep your information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorised use or disclosure, the purposes for processing, and applicable legal requirements. Once we no longer need your information, we will securely delete or anonymise it.
CROSS-BORDER TRANSFERS
We may transfer your personal information to service providers or other third parties located outside South Africa. We will only transfer your personal information outside South Africa if one or more of the following applies:
· the recipient is subject to a law, binding corporate rules or agreement that provides adequate protection similar to POPIA;
· you have consented to the transfer;
· the transfer is necessary to perform a contract with you;
· the transfer is necessary for a contract between us and a third party, in your interest; or
· the transfer benefits you, it is not reasonably practicable to obtain your consent, and you would likely consent if asked.
WHAT ARE YOUR RIGHTS?
Access: You have the right to request a copy of the personal information we hold about you. You may also request confirmation of whether we hold personal information about you (this is free of charge). To request a copy of your information, please review our PAIA Manual, which is available on our website or from the Information Officer. A fee may apply for copies of personal information, as prescribed under the Promotion of Access to Information Act 2 of 2000 (“PAIA”).
Correction: You have the right to request that we correct any inaccurate or incomplete personal information we hold about you. Please help us keep your information up to date by notifying us of any changes.
Deletion: In certain circumstances, you have the right to request that we delete your personal information. This right applies where, for example, the information is no longer necessary for the purpose for which it was collected, or where you withdraw your consent (and we have no other lawful basis for processing).
Objection: You have the right to object, on reasonable grounds, to the processing of your personal information where we rely on our legitimate interests (or those of a third party) as the legal basis for processing.
Automated decision-making: You have the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you, unless permitted by law or you have consented.
Restriction: In certain circumstances, you have the right to request that we restrict the processing of your personal information (for example, while we verify the accuracy of information you have disputed).
How to exercise your rights: To exercise any of these rights, please contact us at privacy@icily.co.za or refer to our PAIA manual at https://www.icilylive.co.za › pages › paia-manual. We may need to verify your identity before responding to your request. We will respond within a reasonable period and in any event within the timeframes required by law.
HOW CAN YOU COMPLAIN
If you believe that we have used your personal information in a way that does not comply with the law, we encourage you to contact us first so that we can try to resolve your concerns. Please contact us at privacy@icily.co.za.
If you are not satisfied with our response, you have the right to lodge a complaint with the Information Regulator.
The Information Regulator’s contact details are:
Address: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191
Telephone: 010 023 5200 | Toll Free: 0800 017 160
Email: POPIAComplaints@inforegulator.org.za
Website: https://inforegulator.org.za
USER TRACKING AND COOKIES
When you access and use our websites we may use various technological tools to improve your experience on our websites through the use of cookies and/or user tracking.
Cookies are small text files downloaded to your computer or device when you visit our site. We use a number of different cookies, including functional, performance, advertising, and social media or content cookies.. These files do not contain your Personal Information but allow us to associate you with a particular device. Many websites use cookies and we use cookies to:
- make our sites more user friendly;
- personalise your interactions with our sites, tailor our services and sites to your interests and needs, and ensure they work on your device;
- provide advertising that is relevant to you, limit the number of times you see the same advertisement and measure the effectiveness of the advertisements on our sites and other websites, based on your online activities such as the websites and apps you use or content you view, and information we have about you;
- send Opt-In marketing communication if you are not a registered user.
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://www.google.com/intl/en/policies/privacy/. 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).
- We use Shopify Audiences to help us show ads on other websites with our advertising partners to buyers who made purchases with other Shopify merchants and who may also be interested in what we have to offer. We also share information about your use of the Site, your purchases, and the email address associated with your purchases with Shopify Audiences, through which other Shopify merchants may make offers you may be interested in.
For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at https://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
SECURING YOUR PERSONAL INFORMATION
We secure the integrity and confidentiality of your Personal Information in our possession or under our control by taking appropriate, reasonable technical and organisational measures to prevent loss of, damage to or unauthorised destruction of Personal Information; and unlawful access to or processing of Personal Information.
In order to implement and maintain such measures, we have in place policies, controls and related processes, which are reviewed and updated on a regular basis. Our policies, controls and procedures cover for example:
- physical, technical and network security.
- access controls and monitoring of access.
- secure storage, destruction and encryption of records of Personal Information.
- Personal Information breach reporting and remediation.
- by way of written agreements, imposition of security and confidentiality obligations on third parties who process Personal Information as part of rendering services to us.
Update 1 Sept 2026
