Virgo Privacy Policy

Last Updated: 3 September 2026

Virgo Digital Agency (Pty) Ltd (“Virgo”, “we”, “us” or “our”) respects your privacy and is committed to protecting Personal Information that we collect, process, store and use in connection with our websites, applications, platforms, products and services.

This Privacy Policy explains how we collect, use, store, disclose and protect Personal Information and explains the rights available to individuals whose Personal Information we process.

This Privacy Policy applies to websites, applications, subdomains, platforms, digital products and services owned or operated by Virgo Digital Agency (Pty) Ltd, including, where applicable, myvirgo.co.za, Event Schedule, Virgo Social, Traveljoint, Virgo Home & Living, and other Virgo-operated services and platforms.

It applies to visitors, registered users, customers, subscribers, clients, event organisers, artists, venues, event planners, attendees, ticket purchasers, suppliers, business partners and other persons who interact with Virgo or our Services.

Individual Services may provide additional privacy notices where particular processing activities require additional explanation.

By accessing or using our Services, you acknowledge the practices described in this Privacy Policy.

This Privacy Policy should be read together with our Terms of Use & Service, Cookie Policy where applicable, and any product-specific terms or privacy notices presented through the relevant Service.


GENERAL PRIVACY PROVISIONS

1. WHO IS RESPONSIBLE FOR YOUR PERSONAL INFORMATION?

Virgo Digital Agency (Pty) Ltd is the Responsible Party for Personal Information where Virgo determines the purpose and means of Processing that Personal Information.

In certain circumstances, Virgo provides technology or services to another business, organisation, Event Organiser or customer and processes Personal Information according to that party’s instructions.

In those circumstances, Virgo may act as an Operator, while the relevant business, organisation, Event Organiser or customer remains the Responsible Party.

For example, an Event Organiser using Event Schedule may determine why attendee information is collected and how it will be used for its event, while Virgo provides the technology used to collect and process that information.

The respective privacy responsibilities of Virgo and its business customers therefore depend on the particular Service and processing activity involved.


2. DEFINITIONS

For purposes of this Privacy Policy:

“Personal Information” means information relating to an identifiable, living natural person and, where applicable under South African law, an identifiable existing juristic person.

Personal Information may include information such as a person’s name, identification information, contact details, online identifiers, location information, financial information and other information relating to that person.

“Processing” means any operation or activity concerning Personal Information, including collecting, receiving, recording, organising, storing, updating, retrieving, using, distributing, transmitting, combining, restricting, deleting or destroying Personal Information.

“Data Subject” means the person or entity to whom Personal Information relates.

“Responsible Party” means the person or organisation that determines the purpose of and means for Processing Personal Information.

“Operator” means a person or organisation that processes Personal Information for a Responsible Party under a contract or mandate without coming under the direct authority of that Responsible Party.

“Special Personal Information” means categories of information afforded additional protection under applicable law.

“Services” means Virgo websites, applications, platforms, subscriptions, software, agency services, event services, digital products and other services provided or operated by Virgo.

“User” means any person or organisation accessing or using a Virgo Service.


3. INFORMATION WE MAY COLLECT

The Personal Information Virgo collects depends on how you interact with us and which Services you use.

We may collect the following categories of information.

Account and Profile Information

When you create or maintain an account, we may collect:

  • your name;

  • username;

  • email address;

  • telephone number;

  • profile photograph;

  • business or organisation name;

  • business contact details;

  • billing information;

  • account type;

  • profile information;

  • social media profile information;

  • preferences;

  • account settings; and

  • authentication and security information.

Contact and Communication Information

When you contact Virgo, we may collect:

  • your name;

  • email address;

  • telephone number;

  • correspondence;

  • support requests;

  • enquiries;

  • feedback;

  • complaints; and

  • other information you choose to provide.

Transaction and Billing Information

When you purchase or subscribe to Services, we may collect:

  • billing name;

  • billing address;

  • transaction amount;

  • invoice information;

  • subscription information;

  • payment status;

  • transaction reference;

  • payment method information provided by a payment processor; and

  • records relating to refunds, disputes or chargebacks.

Virgo generally relies on third-party payment processors to process card and other electronic payments.

Unless expressly stated otherwise, Virgo does not intentionally store complete payment-card numbers, card security codes or banking credentials that are handled directly by an authorised payment processor.

Business and Client Information

Where Virgo provides professional, agency, hosting, website development, consulting or other B2B Services, we may process:

  • company information;

  • contact-person details;

  • project information;

  • website information;

  • domain information;

  • technical credentials provided by the client;

  • billing records;

  • correspondence;

  • project files; and

  • other information necessary to provide the contracted Service.

Technical and Usage Information

When you use our websites or Platforms, we may automatically collect information such as:

  • IP address;

  • browser type;

  • browser version;

  • device type;

  • operating system;

  • approximate geographic region derived from technical information;

  • referring website;

  • pages or features accessed;

  • date and time of access;

  • session information;

  • application activity;

  • error logs;

  • diagnostic information; and

  • security-related events.

Content You Provide

Depending on the Service, we may process Content you upload, create, publish or transmit, including:

  • text;

  • photographs;

  • graphics;

  • videos;

  • audio;

  • documents;

  • event information;

  • schedules;

  • social media content;

  • marketing material; and

  • other User-generated Content.


4. HOW WE COLLECT PERSONAL INFORMATION

We may collect Personal Information:

  • directly from you;

  • when you create an account;

  • when you purchase or subscribe to a Service;

  • when you register for or purchase access to an event;

  • when you complete a form;

  • when you communicate with us;

  • when you upload Content;

  • when you connect a third-party account or integration;

  • automatically through your use of our websites or applications;

  • through cookies and similar technologies;

  • from Event Organisers or business customers using our Platforms;

  • from payment processors;

  • from social media or third-party platforms where you authorise an integration;

  • from service providers acting on our behalf;

  • from publicly available sources where lawful; or

  • where otherwise permitted or required by law.


5. WHY WE PROCESS PERSONAL INFORMATION

Virgo processes Personal Information for legitimate and lawful business purposes, including to:

  • create and administer accounts;

  • authenticate Users;

  • provide our Services;

  • process purchases and subscriptions;

  • facilitate event registrations and ticketing;

  • generate invoices and transaction records;

  • communicate with Users;

  • provide customer and technical support;

  • operate websites and applications;

  • personalise Services and User experiences;

  • process and publish User Content;

  • provide social media management functionality;

  • provide AI-assisted functionality;

  • maintain and improve our Services;

  • analyse Service performance;

  • diagnose technical problems;

  • maintain security;

  • prevent fraud and abuse;

  • enforce our Terms;

  • comply with legal obligations;

  • maintain accounting and business records;

  • respond to lawful requests from authorities;

  • establish, exercise or defend legal claims;

  • send Service-related communications;

  • send marketing communications where lawfully permitted; and

  • develop new products, features and Services.

We will not process Personal Information in a manner incompatible with the purpose for which it was collected unless permitted by applicable law.


6. LAWFUL PROCESSING

Virgo processes Personal Information only where there is a lawful basis or justification for doing so.

Depending on the circumstances, this may include where:

  • you have provided consent;

  • Processing is necessary to perform a contract with you;

  • Processing is necessary to take steps requested by you before entering into a contract;

  • Processing is required to comply with a legal obligation;

  • Processing protects a legitimate interest of the Data Subject;

  • Processing is necessary for Virgo’s legitimate interests or those of a third party, subject to applicable law; or

  • another lawful justification applies.

Where Processing is based specifically on consent, you may withdraw that consent subject to applicable law and any Processing that remains necessary for another lawful reason.


7. WHEN PROVIDING INFORMATION IS REQUIRED

Some Personal Information is necessary for Virgo to provide particular Services.

For example, an email address may be required to create an account, payment information may be required to purchase a paid Service, and attendee details may be required to issue or verify an event registration or ticket.

Where providing Personal Information is optional, we will endeavour to make this reasonably clear.

If you choose not to provide information necessary for a particular Service, we may be unable to provide that Service or certain functionality.


EVENT SCHEDULE PRIVACY

8. EVENT SCHEDULE

Event Schedule is a technology platform operated by Virgo that enables artists, venues, event planners, promoters and other Event Organisers to create and manage events, schedules, registrations, RSVPs, attendees, tickets and related activities.

Personal Information processed through Event Schedule may include:

  • attendee names;

  • email addresses;

  • telephone numbers;

  • registration information;

  • ticket information;

  • RSVP status;

  • check-in information;

  • event preferences;

  • responses to registration questions;

  • transaction information;

  • event communications; and

  • other information requested by an Event Organiser.


9. EVENT ORGANISERS AND ATTENDEE DATA

An Event Organiser may determine what attendee information is required for its event and how that information will be used.

Where an Event Organiser determines the purpose and means of Processing attendee Personal Information, that Event Organiser may be the Responsible Party for that Processing.

Virgo may act as an Operator by providing the Event Schedule infrastructure through which the information is collected, stored and processed.

Event Organisers are responsible for ensuring that:

  • they collect Personal Information lawfully;

  • they request only information reasonably required for their event or legitimate purposes;

  • they provide any additional privacy notices required by law;

  • they obtain consent where required;

  • they protect attendee information;

  • they do not unlawfully sell or distribute attendee information;

  • marketing communications comply with applicable law; and

  • attendee information is not used for incompatible or unlawful purposes.

Virgo may separately act as Responsible Party for information that Virgo requires for operation, security, billing, fraud prevention, legal compliance and administration of the Event Schedule Platform.


10. ACCESS TO EVENT INFORMATION

Event Organisers may have access to Personal Information relating to persons who register for, RSVP to or purchase tickets for their events.

Attendees should therefore understand that information submitted when registering for an independently organised event may be provided to the relevant Event Organiser.

Virgo does not authorise Event Organisers to use attendee information unlawfully.

Questions concerning an Event Organiser’s independent use of attendee Personal Information should generally be directed to that Event Organiser.

If you believe an Event Organiser is misusing information obtained through Event Schedule, you may also report the matter to Virgo.


11. EVENT CHECK-IN AND ATTENDANCE INFORMATION

Event Schedule may process information relating to ticket validation, QR-code scanning, registration status, attendance and check-in.

This information may be made available to the applicable Event Organiser for event administration, attendance management, security, reporting and related legitimate purposes.


12. EVENT PAYMENTS

Where Event Schedule supports paid ticketing, payment transactions may be processed through third-party payment providers.

Payment providers may independently collect Personal Information required to process payments, prevent fraud, comply with financial regulations and administer transactions.

Their Processing is also governed by their own privacy policies and legal obligations.

Virgo may receive limited payment-related information such as transaction identifiers, amounts, payment status, payer information and refund or dispute status.


VIRGO SOCIAL AND CONNECTED ACCOUNTS

13. SOCIAL MEDIA SERVICES

Virgo Social and other Virgo Services may allow Users to connect third-party social media accounts.

Depending on the permissions authorised by the User and functionality provided by the third-party platform, Virgo may process information such as:

  • social account identifiers;

  • profile information;

  • access tokens;

  • page or account information;

  • posts;

  • media;

  • comments;

  • engagement information;

  • analytics;

  • publishing permissions; and

  • other information made available through the relevant platform’s API.

Virgo processes this information to provide the functionality requested by the User, such as publishing, scheduling, account management, reporting and analytics.

The third-party social platform remains responsible for its own Processing practices.

Users may be able to revoke Virgo’s access through the relevant social platform or Virgo Service.


14. THIRD-PARTY ACCOUNT CONNECTIONS

Where you choose to connect a third-party account to a Virgo Service, you authorise Virgo to receive and process information permitted by the permissions you grant.

We do not intentionally request access beyond what is reasonably required to provide the requested integration.

Changes made by third-party providers to their APIs, permissions or privacy practices may affect the information Virgo can access and the functionality we can provide.


ARTIFICIAL INTELLIGENCE

15. AI-ASSISTED FEATURES

Certain Virgo Services may use artificial intelligence or machine-learning technologies.

When you use an AI-assisted feature, information you submit to that feature may be processed to generate the requested output.

Depending on the Service, this information may include:

  • prompts;

  • text;

  • documents;

  • images;

  • event information;

  • social media Content;

  • marketing information; and

  • other Content submitted for processing.


16. THIRD-PARTY AI PROVIDERS

Some AI functionality may rely on third-party AI or machine-learning providers.

Information necessary to generate a requested result may therefore be transmitted to and processed by an applicable AI provider.

We seek to limit such Processing to information reasonably necessary to provide the requested functionality.

Users should avoid submitting unnecessary confidential, sensitive or Special Personal Information to AI functionality unless the Service expressly supports such Processing and they are legally authorised to do so.

Third-party AI providers may process information according to contractual arrangements with Virgo and/or their applicable privacy terms.


17. AUTOMATED PROCESSING

Virgo may use automated systems for functions such as:

  • spam prevention;

  • fraud detection;

  • security monitoring;

  • Content processing;

  • recommendations;

  • analytics;

  • AI-generated Content; and

  • Service automation.

Where applicable law provides rights concerning decisions based solely on automated Processing that produce legal or similarly significant effects, Virgo will comply with those requirements.

Virgo does not intend to make legally significant decisions about individuals solely through automated Processing unless appropriate safeguards and a lawful basis exist.


COOKIES, ANALYTICS AND TRACKING

18. COOKIES AND SIMILAR TECHNOLOGIES

Virgo websites and Services may use cookies, local storage, pixels, SDKs and similar technologies.

These technologies may be used to:

  • operate websites and applications;

  • keep Users signed in;

  • remember preferences;

  • maintain security;

  • prevent fraud;

  • understand Service usage;

  • measure performance;

  • diagnose technical issues;

  • provide analytics;

  • measure marketing effectiveness; and

  • provide advertising where applicable.


19. TYPES OF COOKIES

Depending on the particular Service, we may use the following categories.

Strictly Necessary Cookies

These are required for core functions such as authentication, security, account access, shopping carts or transaction processing.

Functional Cookies

These remember preferences and improve functionality.

Analytics Cookies

These help us understand how Users interact with our websites and Services.

Advertising and Marketing Cookies

Where used and lawfully permitted, these may help measure advertising campaigns, limit repeated advertisements or provide more relevant advertising.


20. THIRD-PARTY ANALYTICS AND ADVERTISING

Virgo may use third-party analytics, measurement and advertising services.

These providers may process technical information such as:

  • IP addresses;

  • device information;

  • browser information;

  • pages viewed;

  • interactions;

  • referring information; and

  • campaign information.

Where required by applicable law, non-essential cookies or similar tracking technologies will be subject to appropriate consent mechanisms.

Users can also manage certain cookie preferences through their browser or device settings.

Blocking cookies may cause some Service functionality to operate incorrectly.


21. PUSH NOTIFICATIONS

Some Virgo Services may offer browser, mobile or application push notifications.

Where you choose to enable push notifications, information required to deliver those notifications may be processed by Virgo and/or a push-notification service provider.

You can generally disable push notifications through your browser, device or application settings.


COMMUNICATIONS AND MARKETING

22. SERVICE COMMUNICATIONS

Virgo may send communications necessary for operation of our Services, including:

  • account notifications;

  • security alerts;

  • password-related communications;

  • transaction confirmations;

  • invoices;

  • subscription notices;

  • ticket information;

  • event-related system messages;

  • technical notices; and

  • important changes to our Services or legal terms.

These communications may be necessary for performance of the Service and may not always be treated as optional marketing.


23. DIRECT MARKETING

Where permitted by applicable law, Virgo may send information about products, Services, promotions or opportunities that may be relevant to you.

Where consent is legally required, we will seek the necessary consent.

You may opt out of electronic marketing communications by using the unsubscribe mechanism provided in the communication or by contacting us.

Opting out of marketing does not prevent Virgo from sending necessary transactional, account, security or Service communications.


24. EVENT ORGANISER MARKETING

Event Organisers are independently responsible for ensuring that marketing communications sent using attendee information comply with applicable law.

Registration for an event does not automatically give an Event Organiser unlimited permission to send unrelated marketing communications.

Virgo may restrict the use of Event Schedule where we reasonably believe the Platform is being used for unlawful spam or direct marketing.


SHARING AND DISCLOSURE

25. WHEN WE MAY SHARE PERSONAL INFORMATION

Virgo does not sell Personal Information as a general business practice.

We may disclose or make Personal Information available to third parties where reasonably necessary for the purposes described in this Privacy Policy, including to:

  • hosting and cloud infrastructure providers;

  • payment processors;

  • email service providers;

  • SMS or messaging providers;

  • push-notification providers;

  • analytics providers;

  • cybersecurity providers;

  • customer-support systems;

  • accounting and invoicing systems;

  • AI service providers;

  • social media platforms;

  • domain registrars;

  • software and API providers;

  • professional advisers;

  • contractors and service providers;

  • Event Organisers where an individual registers for their event;

  • business customers where Virgo acts as their Operator;

  • regulators or government authorities where legally required; and

  • law-enforcement authorities where disclosure is lawfully required.

Service providers are expected to process information only as permitted by applicable law and applicable contractual arrangements.


26. LEGAL DISCLOSURES

Virgo may disclose Personal Information where we reasonably believe disclosure is necessary to:

  • comply with applicable law;

  • comply with a valid court order;

  • respond to a lawful request from a competent authority;

  • investigate fraud or unlawful activity;

  • enforce our legal rights;

  • protect Users or third parties;

  • protect the security of our Services; or

  • establish, exercise or defend a legal claim.

We will not voluntarily disclose Personal Information to authorities merely because it is requested where Virgo is legally entitled and reasonably required to refuse the request.


27. BUSINESS TRANSFERS

If Virgo undergoes a merger, acquisition, restructuring, financing, sale of assets or transfer of a business or Service, Personal Information may form part of the assets or operations transferred.

Any such Processing will remain subject to applicable privacy law.

Where legally required, affected persons will be notified of material changes concerning responsibility for their Personal Information.


INTERNATIONAL AND CROSS-BORDER PROCESSING

28. CROSS-BORDER TRANSFERS

Virgo is based in the Republic of South Africa, but some of our technology providers, cloud infrastructure, APIs, social networks, payment providers, AI providers and other service providers may operate or store information outside South Africa.

Personal Information may therefore be transferred to or processed in other countries.

Where Personal Information is transferred outside South Africa, Virgo will take reasonable steps to ensure that the transfer complies with applicable requirements, including the requirements governing transborder information flows under POPIA.

Depending on the circumstances, this may include transfers:

  • to jurisdictions providing adequate protection;

  • under contractual protections;

  • where the Data Subject consents where appropriate;

  • where necessary for performance of a contract; or

  • under another lawful transfer mechanism.


INFORMATION SECURITY

29. SECURITY SAFEGUARDS

Virgo implements reasonable technical and organisational safeguards appropriate to the nature of the information we process.

These may include, where appropriate:

  • access controls;

  • authentication;

  • encryption in transit;

  • secure server configurations;

  • software updates;

  • security monitoring;

  • logging;

  • backups;

  • restricted administrative access;

  • password protection; and

  • security procedures.

No internet-connected system or method of electronic storage can guarantee absolute security.

Users are also responsible for protecting their passwords, devices, API keys, connected accounts and other credentials.


30. SECURITY INCIDENTS AND DATA BREACHES

If Virgo becomes aware of a security compromise involving Personal Information, we will investigate and respond appropriately.

Where required by applicable law, Virgo will notify the Information Regulator and/or affected Data Subjects as soon as reasonably possible in accordance with applicable legal requirements.

Where Virgo acts solely as an Operator, we will notify the applicable Responsible Party as required by law or contractual obligations so that the Responsible Party can fulfil its obligations.


RETENTION AND DELETION

31. HOW LONG WE KEEP PERSONAL INFORMATION

Virgo retains Personal Information only for as long as reasonably necessary for the purpose for which it was collected or as permitted or required by applicable law.

Retention periods may depend on:

  • the nature of the information;

  • the Service involved;

  • the duration of an account or subscription;

  • contractual obligations;

  • accounting and tax requirements;

  • transaction records;

  • fraud-prevention requirements;

  • security requirements;

  • dispute-resolution periods;

  • legal claims;

  • statutory retention requirements; and

  • legitimate business needs.

Different categories of information may therefore have different retention periods.


32. ACCOUNT DELETION

Where available, Users may request deletion or deactivation of their accounts through account settings or by contacting Virgo.

Deleting an account does not necessarily result in immediate deletion of every associated record.

Virgo may retain information where necessary to:

  • comply with law;

  • maintain financial or transaction records;

  • prevent fraud;

  • resolve disputes;

  • enforce agreements;

  • establish or defend legal claims;

  • maintain security records; or

  • satisfy another lawful retention requirement.


33. BACKUPS

Information deleted from active systems may remain temporarily in secure backup systems until those backups are overwritten or expire according to our backup and retention processes.

Backup copies are not intended to be used for ordinary business Processing after information has been deleted from active systems, except where restoration is reasonably necessary for disaster recovery, security or legal purposes.


34. ANONYMISED AND AGGREGATED INFORMATION

Virgo may retain information that has been appropriately anonymised or aggregated so that it no longer identifies a Data Subject.

Such information may be used for analytics, statistics, product development, security, performance analysis and other lawful business purposes.


YOUR PRIVACY RIGHTS

35. RIGHTS UNDER POPIA

Subject to applicable law and any lawful limitations, Data Subjects may have the right to:

  • be informed when Personal Information is collected;

  • request confirmation of whether Virgo holds Personal Information about them;

  • request access to their Personal Information;

  • request correction of inaccurate or incomplete Personal Information;

  • request deletion or destruction where legally appropriate;

  • object to certain Processing;

  • withdraw consent where Processing relies on consent;

  • object to certain direct marketing;

  • complain about unlawful Processing;

  • request information concerning the identity of third parties who have had access to their information where applicable; and

  • lodge a complaint with the Information Regulator of South Africa.

Some rights are subject to exceptions or procedures established by applicable law.


36. ACCESS REQUESTS

You may request confirmation of whether Virgo processes Personal Information relating to you and, where permitted by law, request access to that information.

Virgo may require sufficient information to verify your identity before responding to a request.

Requests may also be subject to applicable procedures under POPIA and the Promotion of Access to Information Act (“PAIA”).

Where legally permitted, a prescribed fee may apply to certain formal access requests.


37. CORRECTION AND DELETION

You may request correction or deletion of Personal Information that is:

  • inaccurate;

  • irrelevant;

  • excessive;

  • out of date;

  • incomplete;

  • misleading;

  • unlawfully obtained; or

  • no longer authorised to be retained.

Virgo will consider such requests in accordance with applicable law.

We may decline deletion where retention remains lawfully required or permitted.


38. OBJECTION TO PROCESSING

Where applicable law provides a right to object to particular Processing, you may submit an objection to Virgo.

We will assess the objection and cease Processing where legally required.

An objection may affect our ability to continue providing a Service where the relevant Processing is necessary for that Service.


39. WITHDRAWAL OF CONSENT

Where Virgo relies specifically on consent to process Personal Information, you may withdraw that consent.

Withdrawal does not invalidate Processing lawfully carried out before consent was withdrawn.

Virgo may continue Processing where another lawful justification permits or requires it.


40. IDENTITY VERIFICATION

To protect Personal Information, Virgo may need to verify the identity and authority of a person making a privacy request.

We may request reasonable verification information before providing access, correcting information or processing a deletion request.

We will not intentionally request more verification information than reasonably necessary.


CHILDREN AND MINORS

41. CHILDREN’S PERSONAL INFORMATION

Commercial accounts, paid seller accounts and other contractual accounts requiring legal capacity are generally intended for persons aged 18 years or older, unless expressly stated otherwise.

However, some Virgo Services, including events managed through Event Schedule, may involve attendees who are under 18.

Where children’s Personal Information is processed, Virgo and applicable Event Organisers must comply with legal requirements concerning the Processing of children’s information.

Where required, appropriate consent or authorisation from a competent person, parent or guardian must be obtained.

Event Organisers must not use Event Schedule to unlawfully collect children’s Personal Information.

If you believe a child’s Personal Information has been collected or processed unlawfully through a Virgo Service, please contact us.


SPECIAL PERSONAL INFORMATION

42. SENSITIVE AND SPECIAL INFORMATION

Users should avoid submitting Special Personal Information unless it is reasonably necessary for the applicable Service and there is a lawful basis for Processing it.

Where Virgo processes Special Personal Information, we will apply safeguards appropriate to the sensitivity of the information and applicable legal requirements.

Business customers and Event Organisers must not use Virgo Platforms to collect unnecessary Special Personal Information.


THIRD-PARTY SERVICES

43. THIRD-PARTY WEBSITES AND SERVICES

Virgo Services may contain links to or integrations with third-party websites and services.

Virgo is not responsible for the independent privacy practices of those third parties.

When you leave a Virgo Service or interact directly with a third-party provider, you should review that provider’s privacy policy.

The inclusion of a link or integration does not mean Virgo controls the third party’s Processing practices.


44. PAYMENT PROVIDERS

Payments may be processed by independent payment gateways, banks or financial service providers.

These providers may collect and process information independently for purposes including:

  • transaction processing;

  • authentication;

  • fraud prevention;

  • regulatory compliance; and

  • dispute management.

Their privacy policies apply to their independent Processing.


B2B AND PROFESSIONAL SERVICES

45. BUSINESS CUSTOMERS

Where Virgo provides Services to another business, that business may provide Virgo with Personal Information concerning its employees, customers, suppliers or other persons.

The business customer is responsible for ensuring that it has a lawful basis to provide that information to Virgo.

Where Virgo processes such information solely according to the customer’s instructions, Virgo may act as an Operator.


46. CLIENT SYSTEMS AND CREDENTIALS

Professional Services may require Virgo personnel to access a client’s:

  • website;

  • hosting environment;

  • domain account;

  • database;

  • software platform;

  • API;

  • analytics account;

  • advertising account; or

  • other technology systems.

Virgo will use such access only as reasonably necessary to provide the requested Service, troubleshoot issues, maintain systems or perform other authorised work.

Clients remain responsible for ensuring that they are authorised to provide Virgo with access to those systems and information.


CHANGES AND GOVERNANCE

47. CHANGES TO THIS PRIVACY POLICY

Virgo may update this Privacy Policy to reflect:

  • changes to our Services;

  • changes to technology;

  • changes to third-party providers;

  • new legal requirements;

  • regulatory guidance; or

  • changes to our Processing activities.

The “Last Updated” date at the top of this Privacy Policy indicates when it was most recently revised.

Where a change materially affects how we process Personal Information, we may provide additional notice through our website, Platform, email or another appropriate method.


48. INFORMATION OFFICER

Virgo Digital Agency (Pty) Ltd has an Information Officer responsible for overseeing applicable privacy and information-access obligations.

Privacy enquiries, Data Subject requests and complaints may be directed to Virgo through the contact channels published on our website.

Where required, formal requests may need to follow procedures prescribed under POPIA, PAIA or regulations issued by the Information Regulator.


49. COMPLAINTS

If you believe Virgo has processed your Personal Information unlawfully or has not appropriately addressed a privacy request, please contact us so that we can investigate the matter.

You also have the right, where applicable, to submit a complaint to the:

Information Regulator (South Africa)

The Information Regulator is the independent authority responsible for monitoring and enforcing POPIA and PAIA in South Africa.

Current contact and complaint-submission information is available from the Information Regulator’s official channels.


50. PAIA

Where applicable, requests for access to records held by Virgo may be governed by the Promotion of Access to Information Act 2 of 2000 (“PAIA”).

Virgo may maintain a PAIA Manual or other access-to-information documentation as required by law.

Formal PAIA requests must follow the applicable statutory procedure.


51. GOVERNING PRIVACY LAW

Virgo Digital Agency (Pty) Ltd is established in the Republic of South Africa and primarily processes Personal Information in accordance with South African law, including the Protection of Personal Information Act 4 of 2013 (“POPIA”).

Other privacy or data-protection laws may also apply where Virgo provides Services to persons in other jurisdictions.

Nothing in this Privacy Policy is intended to remove rights that a Data Subject cannot lawfully waive.


52. CONTACT US

For questions regarding this Privacy Policy, requests concerning your Personal Information or other privacy-related matters, please contact Virgo Digital Agency through the contact channels published on our website.

Virgo Digital Agency (Pty) Ltd
South Africa

Privacy and General Enquiries:
services@myvirgo.co.za

Website:
https://myvirgo.co.za/

Please include sufficient information for us to understand and respond to your request.

Do not send passwords, complete payment-card details or other unnecessary sensitive credentials by email.


53. RELATED POLICIES

This Privacy Policy should be read together with Virgo’s other applicable policies and agreements, including:

Terms of Use & Service:
https://myvirgo.co.za/terms-terms/

Copyright / DMCA Policy:
https://myvirgo.co.za/terms-dmca/

Virgo Home & Living Return Policy:
https://myvirgo.co.za/return-policy/

Additional product-specific notices or policies may be displayed within the relevant Virgo Service.


54. ACCEPTANCE AND ACKNOWLEDGEMENT

By using Virgo Services or providing Personal Information to Virgo, you acknowledge that you have been given access to this Privacy Policy and information concerning Virgo’s Processing practices.

Where consent is legally required for a particular Processing activity, Virgo will seek that consent separately where appropriate.

Use of a Service does not constitute consent to Processing for which applicable law specifically requires separate consent.


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