Halvorial
Privacy Policy
This Privacy Policy applies to all natural persons whose personal information is collected, processed, or otherwise dealt with by Halvorial Broadcasting (Pty) Ltd (Pty Ltd), trading as Halvorial, in connection with the website at halvorial.com and the television broadcasting and related services offered by Halvorial ("the Services"). This Policy is issued in accordance with the Protection of Personal Information Act, 4 of 2013 ("POPIA") and takes effect from 2026. It governs all interactions between Halvorial and visitors, subscribers, and correspondents through the website, including the contact form and the email subscription facility described below.
1. Introduction and Application
1.1. Halvorial Broadcasting (Pty) Ltd is committed to protecting the personal information of individuals who interact with it and to processing such information lawfully, reasonably, and in a manner that does not infringe the privacy of the data subject, as required by POPIA.
1.2. This Policy describes what personal information Halvorial collects, the purposes for which it is collected, the legal bases relied upon, how long it is retained, with whom it may be shared, and the rights available to data subjects, together with the manner in which those rights may be exercised.
1.3. Where this Policy refers to "personal information," it bears the meaning given to that term in section 1 of POPIA, being information relating to an identifiable, living natural person and, where applicable, an identifiable, existing juristic person.
2. Personal Information Collected Through the Contact Form
2.1. Halvorial operates a contact form on its website through which visitors may submit enquiries relating to the Services, programming, partnerships, or other business matters. The contact form requires the submission of a name, an email address, and the content of the message, and may optionally request a telephone number where the visitor wishes to be contacted by phone.
2.2. The information submitted through the contact form is processed for the purpose of responding to the enquiry, administering the resulting correspondence, and, where relevant, taking such further steps as are necessary to give effect to any request made by the visitor.
2.3. The processing of contact form data is undertaken on the legal basis that it is necessary for the conclusion or performance of a contract to which the data subject may become party, or, where no contract is contemplated, on the basis of the legitimate interest of Halvorial in responding to correspondence directed to it, weighed against the reasonable expectations of the data subject.
3. Personal Information Collected Through the Email Subscription
3.1. Halvorial offers visitors the option to subscribe to an email mailing list in order to receive programming updates, scheduling changes, and promotional communications relating to the Services. Subscription requires, at minimum, the submission of a valid email address, and may optionally include a first name for the purpose of personalising correspondence.
3.2. Subscription to the mailing list is voluntary and is effected only upon the data subject's affirmative action in submitting their details through the subscription form. Halvorial relies on the consent of the data subject as the legal basis for sending marketing and informational communications by email, in accordance with section 11 of POPIA and section 69 of the Electronic Communications and Transactions Act, 25 of 2002.
3.3. Every email communication sent pursuant to the subscription includes a clear and functional mechanism by which the recipient may unsubscribe or otherwise withdraw consent at any time, without charge and without the need to provide reasons.
4. Automated Collection and Cookies
4.1. In the course of operating the website, Halvorial and its service providers may collect certain information automatically through cookies and similar technologies, including IP address, browser type, device identifiers, pages visited, and time spent on the website. Such information is used for necessary website functionality and, where consent has been given, for analytics and marketing purposes.
4.2. Full details of the categories of cookies used, their purposes, duration, and the manner in which consent is obtained and withdrawn are set out in the separate Cookie Policy published at halvorial.com, which forms part of the website's data protection arrangements and should be read together with this Policy.
5. Hosting and Cross-Border Considerations
5.1. The website and the data collected through it, including contact form submissions and subscriber email addresses, are stored and processed on servers operated by Halvorial's hosting and email service providers, which may be located within or outside the Republic of South Africa.
5.2. Where personal information is transferred to a recipient in a foreign country, Halvorial shall ensure that such transfer takes place only where the recipient is subject to a law, binding corporate rules, or a binding agreement affording an adequate level of protection substantially similar to that provided under POPIA, or where one of the other conditions set out in section 72 of POPIA is satisfied, or where the data subject has consented to the transfer.
6. Purposes and Lawful Bases of Processing Summarised
6.1. Personal information collected through the contact form and the email subscription is processed for the following purposes: responding to enquiries, providing and administering the Services, sending requested informational and promotional communications, maintaining accurate business records, and complying with applicable legal obligations, including those arising under tax and consumer protection legislation.
6.2. Each purpose of processing is undertaken on one or more of the following bases recognised under section 11 of POPIA: the consent of the data subject; the necessity of processing for the conclusion or performance of a contract; compliance with a legal obligation; or the legitimate interests pursued by Halvorial or a third party to whom the information is supplied, provided such interests are not overridden by the data subject's interests, rights, or freedoms.
7. Retention of Personal Information
7.1. Halvorial does not retain personal information for longer than is necessary to achieve the purpose for which it was collected, unless a longer retention period is required or permitted by law. The table below sets out the standard retention periods applied to the categories of personal information described in this Policy.
| Category of Personal Information | Retention Period |
|---|---|
| Contact form submissions (name, email, phone, message) | 24 months from the date of last correspondence, thereafter deleted or anonymised |
| Email subscription data (email address, name) | For the duration of the subscription, and deleted within 30 days of unsubscription |
| Cookie and analytics data | As specified in the Cookie Policy, generally not exceeding 26 months |
| Records required for tax or legal compliance | 5 years, or such longer period as prescribed by applicable legislation |
8. Disclosure to Third Parties
8.1. Halvorial may disclose personal information to third-party service providers engaged to support the operation of the website and the Services, including hosting providers, email delivery platforms, and analytics providers, each of which acts as an operator within the meaning of POPIA and is contractually bound to process personal information only in accordance with Halvorial's instructions and to apply appropriate security safeguards.
8.2. Halvorial does not sell, rent, or trade personal information to third parties for their own independent marketing purposes.
8.3. Personal information may further be disclosed where required by law, in response to a lawful request by a competent authority, or where necessary to protect the rights, property, or safety of Halvorial, its users, or the public.
9. Security Measures
9.1. Halvorial has implemented appropriate, reasonable technical and organisational measures, as contemplated in section 19 of POPIA, to secure the integrity and confidentiality of personal information in its possession or under its control, and to prevent loss, damage, unauthorised destruction, and unlawful access to or processing of such information.
10. Rights of the Data Subject
10.1. Every data subject whose personal information is processed by Halvorial has the right, in accordance with POPIA, to:
- be notified that personal information about them is being collected;
- establish whether Halvorial holds personal information relating to them and to request access to that information;
- request the correction, destruction, or deletion of personal information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or obtained unlawfully;
- object, on reasonable grounds, to the processing of their personal information;
- object to the processing of their personal information for purposes of direct marketing at any time, without penalty;
- withdraw consent previously given, where processing is based on consent, without affecting the lawfulness of processing carried out prior to withdrawal;
- submit a complaint to the Information Regulator regarding an alleged interference with the protection of their personal information; and
- institute civil proceedings regarding the alleged non-compliance by Halvorial with the provisions of POPIA.
10.2. Any data subject wishing to exercise any of the rights set out in this clause may do so by writing to Halvorial at [email protected] or by telephoning +27 53 414 7290. Requests will be dealt with promptly and, in any event, within the timeframes prescribed by POPIA.
10.3. A data subject who remains dissatisfied with the manner in which a request has been dealt with, or with Halvorial's processing of their personal information generally, may lodge a complaint with the Information Regulator of South Africa, whose contact details are published at www.justice.gov.za/inforeg.
11. Contact Details
11.1. Enquiries regarding this Policy or the processing of personal information by Halvorial should be directed to:
Halvorial Broadcasting (Pty) Ltd (Pty Ltd)
47 Du Toitspan Road, 8300 Kimberley, South Africa
Email: [email protected]
Telephone: +27 53 414 7290
Registration Number: 3471483041
12. Amendments to this Policy
12.1. Halvorial reserves the right to amend this Policy from time to time to reflect changes in its processing activities or in applicable law. The version published at halvorial.com at any given time shall be the version in force, and material changes will, where appropriate, be brought to the attention of subscribers by email.