Last updated: Apr 3rd, 2020
At Thanga, we do everything in our power to protect your data and give you full control over your personal data on our platform. Our aim is that you always feel informed and empowered with respect to safeguarding your own privacy, and the privacy of your subscribers. As a Cloud Communications Platform as a Service (CPaaS), we process personal data in order to deliver our services. This privacy statement contains information about what data we collect, why we collect it, and how we handle that data.
This Privacy Statement gives you a better understanding of how we treat personal data and to call your attention to some of our new features. This document is user-friendly and addresses new data protection regulations, including South Africa’s Protection of Personal Information Act.
Thanga is a Cloud Communications Platform as a Service (CPaaS) that provides fast, reliable and innovative conversational engagement solutions with African reach. Our customers range from entrepreneurs to large enterprises that integrate our services into their business operations.
This Privacy Statement is designed to enable you, as well as the recipients of the communications you send over Thanga’s platform, to make informed decisions about personal data when you make use of our communications services.
We only ask for personal data when we need it for business purposes or to provide you with relevant information. Whether you sign up for our newsletter or sign a Service Agreement, you provide your personal data to us for a particular purpose. You always have the opportunity to explicitly agree to the collection, use, disclosure, and sharing of the information you’ve provided. That applies even when you're browsing our website, where you can manage your cookie preferences. You can review your personal data and change your settings at all times.
Since customers integrate our products into their own software applications, we don’t interact with their end-users directly. When customers do share end-user information with us, we always handle that data in accordance with the data protection regulations, including POPIA. We don’t use that data for any purposes other than those specifically issued by the customer who provides the data.
Throughout this document, you’ll encounter the mention of several roles and responsibilities. Here’s a quick explanation of the different roles, responsibilities, and systems of governance that play an integral part in ensuring your data is protected.
The Controller determines the purpose (why) and means (how) of personal data sharing (e.g. to receive important information or sending invoices) and remains ultimately responsible for the correct handling of the subject’s data. The Controller is often the company that an individual (or data subject) provides their personal data to.
The Processor is the company that provides part of the service of the Controller and needs specific personal data in the control of the Controller in order to do so. To give an example: when one of our customers sends a broadcast through our platform, we need personal data such as a phone number to fulfill the service. The Processor only processes personal data according to the instructions of the Controller.
Depending on your relationship with Thanga, we can be both Controller and Processor. If you have any questions about these terms or more general inquiries about how we handle identifiable data, you can always contact us at [email protected] or send a written inquiry to:
49 Glenhove Road
Just as keeping your data safe is our priority, so is protecting your rights and freedoms as an individual, all in full compliance with global standards of rules and regulations for the protection of personal data. All the personal data we process is lawfully obtained and with a legal basis. The purpose of the information we collect is so we can enable you to use our services and continue to conduct and expand our day-to-day business . Personal data can also help us to improve our products to fit the needs of our customers.
We process personal data based on a limited set of legal bases:
We collect personal data for specific purposes, and we’ll always tell you what those are when we collect it. We’ll use the collected data for the specified purpose alone, as long as our relationship stays the same. If our relationship changes, we may need more information. For example, if you fill out a form to request more information about one of our products, we’ll use your contact data to send the requested product information to you. If you then decide to become a customer, we’ll need additional information including your billing address for the purpose of providing you with the services you are interested in.
Here’s a list of the purposes for which we’ll request or use your data:
You will always have the choice to provide personal data on our domain or not. Please keep in mind that declining to provide personal data might prevent you from using a certain product or service. We will tell you the implications of not providing the information asked for when you choose not to do so.
The exact type of data we collect depends on the related product or service. Applying your privacy settings on our website, signing up for a newsletter, downloading marketing materials, or using any of our products and services all require you to leave appropriate details, specific to that purpose. We never collect more data than we need and may ask for additional data at the appropriate time.
You will always remain to have a choice when it comes to the Thanga products and services you use and the data you share. When we ask you to provide personal data, you can decline. Many of our products require some personal data to provide you with a service. If you choose not to provide data required to provide you with a product or feature, you cannot use that product or feature.
Thanga’s personal data processing activities include three main categories when you use our products and services:
Depending on our relationship the personal data shared by you can include:Customer account and potential customer information
To be thorough, we've listed how we collect personal data and how that data will be used. The information below is not exhaustive and may be updated in accordance to new legislation, or because further clarification is needed based on a new product or service.
Thanga uses the data that you share with us to provide you with the best experience of our brand, the services and people connected to them. Most notably, we use data to:
Personal data is predominantly shared with us by you as a (potential) customer or website visitor; additionally, as a customer making use of our CPaaS products you share information of the end-user with us to enable the transmission of the communications services. In some cases additional information related to the business you work for, your position and the industry it operates in will be gathered via online sources or enrichment providers to be able to address your business needs best.
When browsing our website based on your cookie preference, we automatically collect data by placing cookies and trusted tracking technologies on your browser. The information we collect helps us maintain and improve our website and business. It usually includes your IP address, browser type, the pages you've visited and in what order, and whether you’re a new or recurring visitor.
We use this data to ensure that the website works correctly and store any preferences you may have. It also helps us generate and review data, and generate reports on our website user base and usage patterns.
When filling out a form on our website, you directly interact with us. When you ‘Talk to Sales’, ‘Suggest an Integration’, ‘Talk to Support’ through our live chat window or WhatsApp channel, send us an email, or subscribe to our newsletter, we use the data you provide.
When you sign up on our website, we ask for some personal data like your email address, company, name, and the content of your inquiries. The particular fields to fill in may differ per form, we'll never ask you for irrelevant information, and we'll always use the data for the purpose you submitted it for.
If you're already a customer, we'll use the data collected from your account. That gives us relevant insight into how you’re using our platform and our products, what your business needs are, past support issues, and so on. Pulling this information allows us to tailor our assistance, product offers and provide the best possible assistance support via our support, tech and sales teams.
When creating a free trial account, you’ll need to fill out some personal data. The information we ask for is limited to what we need to provide you with the trial account. If you sign up by linking a third party account, you allow that third party to share the basic profile information needed to create a personal account with Thanga.
We always ask you to authenticate yourself by verifying the email address and phone number that you have provided upon signup. All you have to do next is log in with your username and password and you're ready to get started. Activating your account by confirming your email address and phone number proves to us that you created the account and that you're human. It also makes sure you have a valid phone number to test our services with if you like to. Your number is used to send test messages, allows our support team to contact you, and allows for two-factor authentication on your account.
When buying credits or subscribing to a plan, we need more information than just your name and password. In order to start billing, we need information including your company details, billing address and preferred payment method(s). You’re assigned an Account ID automatically that’s used to process your orders, assign invoices, and track API requests. If you integrate our APIs into your software application, you'll be given an authentication token that allows us to identify you when you send API requests.
Your credentials will help us to improve our internal processes and services. We keep account credentials on record to identify the account that assigns the API commands, and to make sure the account manager and our support team can store and access relevant information about your account.
When using our products and services, we collect the commands your application communicates to Thanga. This includes your IP addresses, information on your usage, and routing information.
In order to develop our business, we make use of third parties that supply us with information collected from publicly available sources and data enrichment providers. The information we collect is based on personas created by automated processes. The purpose of enriching profiles is to assess that only relevant leads and customers are processed and the additional information helps to address the specific needs, based on type of industry, company scale and is done so on the basis of the company’s legitimate interest. In order to make sure we only approach the right audience, we only retain information that will help us reach out to people and companies that would benefit from the use of our services and products. If you no longer want to be contacted by our sales team, you can always object by contacting your account manager or Thanga’s support team via [email protected].
The categories of personal data below are involved. As you will see most of them are business related; nevertheless, even in a business relationship some information might be considered personal data; company name, company description and website, company (estimated) revenue and employee range, company industry, employment role and title, seniority, full name, phone number.
The information will not be retained longer than is necessary to fulfill the purpose, or if an objection is made by you that will take away the legal basis of consent or legitimate interest. The retention period may vary between a couple of weeks for leads, up to the duration of the services for existing customers.
Categories of recipients will be solely Thanga internal teams working with our CRM provider HubSpot. For more information on these companies please see the Approved Processors section.
Rest assured that all third parties involved in Thanga’s day-to-day business will have to comply with the appropriate cross-border transfer mechanisms.
Whether we fulfil the role of Controller, Processor, or even as a mere conduit, we always make sure that the parties we work with adhere to similar Data Protection and Security Standards as we agreed upon with you. Thanga engages three categories of recipients:
Here's who we share information with and why:
Telecom operators, aggregators and other communications service providers for proper routing and connectivity. We reach people’s smartphones through telecom operators and other communication service providers. In order to make sure the message you send will reach the intended recipient, independent of their location, we make use of a global network of telecom providers. When it comes to the contents of electronic communications transmitted by communication providers, these operators, aggregators and service providers qualify neither as controllers nor as processors insofar as they act as mere conduits in transmitting the content. If they process content data for their own purposes (e.g. undertaking their own filtering or data retention activities), they act as controllers.
Third party service and technology providers who perform necessary actions on our behalf. We can share personal data with third party service providers, like our payment processor and hosting providers. We never share information without prior vetting, due contracts or for specific purposes that can be fulfilled in-house. An overview of third party service providers can be found under Approved Processors.
Payment Service Providers (PSPs) of Thanga provide our customers with two ancillary services, besides the regular provision of payment services: Saved Payment Methods, and Auto Recharge. Peach Payments, Flutterwave and Very Good Security are the PSPs collecting, processing and storing the payments requests of our customers and are doing so as controllers in their own right.
Saved Payment Methods allows our customers to save the financial information of a specific payment method on a consent basis for their own convenience. The information necessary to provide the service differs depending on the selected payment method (credit card or Paypal) but for a credit card, it consists of the last four digits of a credit card number, the expiration date, and the name of the cardholder. For PayPal, the account email address.
With Auto Recharge, Thanga and its Payment Service Providers enable our customers to automatically top up their account balance if it falls below a minimum threshold. This ancillary service is enabled by means of a toggle button, by which you provide your consent to use the required information to automatically recharge the credits on your balance. Thanga requests extra authentication from its customers by means of an email that requires you to complete an extra authentication, when the bank or PSP requires it for these transactions.
For both of these ancillary payment services you can withdraw your consent at any time on the Settings page here.
Thanga Beleggings (Pty) Ltd. will only ever use the data as described in this statement.
We don't sell any information to or from third parties for advertising or marketing purposes. We use direct marketing ourselves through Google Adwords, LinkedIn, Instagram and Facebook. Find out more on how to manage your advertising preferences by visiting the advertising settings in your browser.
We won’t share your information with third parties without your permission, except when we’re required to by law and in accordance with Thanga’s Disclosure Requests Policy.
Part of the policy requires thanga to only respond to government requests when we are legally obliged to do so. Accordingly, the request needs to:
We do everything in our power to keep your data safe. We invest in state-of-the-art technology and thorough security screenings of our infrastructure and employees to minimise security risks.
Since all our accounts are password (and possibly two-factor authentication) protected, the only person with access to your account should be you. If your login information is stolen or used without your permission, it's imperative you notify us immediately so we can secure your account. You can do so by sending an email to [email protected] with the subject 'Urgent: account credentials'.
If you want to know more about the measures we take to keep your data secure, check out our Security Statement. It contains information about the industry standard, administrative, technical, physical, and organizational safeguards designed to prevent unauthorized access and use of personal data.
How long we keep personal data depends on its nature and the purpose for which it was obtained. We retain personal data to fulfill contractual or legal obligations which may vary depending on the geographical location you are residing in, the service is procured or the communications services are terminated.
Personal data related to our communications services, such as leasing telephone numbers, email addresses, location related information, and message body, all have a default retention period of six months to fulfil our POPIA (Section 14 Retention and restriction of records) obligations to actively prevent misuse of our services and when formally requested disclose information to further a criminal investigation. We solely retain end-user communication data, including recipients' phone numbers and/or email addresses, for the purpose of preventing misuse of the Thanga services for the period of six months.
We provide all of our customers with ancillary services which, among others, include the possibility of maintaining an online address book for your convenience, and insights in the communication usage and transmission history, specific to your account and for the duration of the services. In relation to these ancillary services, the customer ensures that any end-user (communication recipient) personal data, such as phone numbers, email addresses, etc, are solely controlled by you as a controller and any data protection rights exercised by your end-users must be executed by you as a customer. We will neither access nor delete any such personal data on behalf of you as a controller and it is your responsibility as a customer to ensure compliance with your obligations towards the end-users whose personal data you control.
We keep information for marketing and sales purposes up to 12 months, or when applicable, for the duration of the service to you as a customer.
Additionally, we are under an obligation to demonstrate compliance with the applicable national financial and tax laws and regulations. To do so, data related to a customer’s account such as name, email address, (company) address, (company) bank details and position within the company will be kept for a period up to 10 years. Proof that consent has been given will be retained for five years.
If you would like to review, amend, transfer or request to delete personal data during the default retention period, you can submit a request through easily accessible forms on our Dashboard. Please note that we are not always in a position to follow up on an erasure request in the case that it conflicts with one of our legal retention obligations.
After the required retention period expires, we might keep data in a non-identifiable form for archival, statistical and/or other legitimate purposes. None of it will be able to identify you as an individual.
Even though we collect your data to conduct business, your data stays your own. You stay in control of your, and the recipients' of your communications, personal data and can at any time choose what you want us to do with it. You can : change your cookie settings as a website visitor, withdraw consent to our processing of your data when this applies, control and review your data, and object to and restrict the processing of data if you deem that necessary.
When you visit our website for the first time, you can either allow us to place all the cookies we use on your browser, decide to accept specific ones or deny all our cookies. You can always change your preferences both in your browser settings and in the cookie settings on our website. Within our cookie settings, we outline each cookie type in use on our site and provide an explanation of the implications of accepting it.
If for whatever reason you no longer want us to use your personal data, and you have provided that data to us on a consent basis, you’re free to change your mind. We will always comply with your request, unless we're legally required to keep your data. Which basically means that if there is any legal obligation, about (for example) our responsibility to demonstrate we have acted upon a withdrawal of consent request, we must keep information that includes personal data in order to do so.
You can always view, amend, delete, and transfer the personal data you control. As a Thanga customer, if you want to exercise control over your or your end-users’ personal data, you must do so on your online account. We provide all of our customers with reasonable assistance to fulfill your obligations as a data controller towards the recipients of the communications you have sent over our platform. In order to verify your identity, or the genuinity of the request you make on behalf of the end-user whose data you control, we have made technical and organizational measures available that allow you to fulfil these obligations via your online account or a dedicated API.
Unfortunately requests sent by you as a customer via email are therefore not considered as a valid means to exercise these rights and as a result we are not in a position to process such requests. For the avoidance of doubt, you as a customer acting as a controller are responsible for processing any requests or complaints on behalf of your end-users whose personal data you control.
If you are not a customer and therefore don’t use the dashboard or have access to the API, you can exercise your rights by sending a request to [email protected], our support staff, or via written request.
We’ll process your request as soon as possible with a maximum of one month after receiving it. If a request is complicated or we get too many requests to process at a given time period, our response time can be increased by two months. You’ll be informed when such an extension period applies. When you choose to delete your personal data, we hold the right to hold onto anonymised and aggregated data. If we do so, nothing will be able to identify you as a person in any way. If we’re required to retain your information for legal reasons, we will let you know in response to your request.
When your personal data is being processed to fulfill a legitimate interest to us, such as direct marketing to existing customers, you’re able to object and unsubscribe. You can always exercise your right to restrict processing, and we’ll make sure to process your data in the way you specify. We will assess each request on a case-by-case basis according to the rules set out by the applicable data protection laws, often the POPI Act. If we override your request, we need to demonstrate that we have compelling grounds to do so, or that there’s a legal claim which allows us to retain personal data. If you don’t agree with how we’ve handled your request, you can file a complaint with the Information Regulator of The Republic of South Africa.
Our services and products are not directed to children under the age of 18. We never knowingly collect and/or process any personal data from children under this age directly. If we discover we’ve received personal data from a child without parental or legal consent, we will immediately take reasonable steps to delete that information as quickly as possible. If you believe we have any information from or about a child, please contact us at [email protected] with the subject: ‘Children’.
Our online services and communications may embed hyperlinks to websites that are not owned or controlled by Thanga. We’re not responsible for the privacy practices, policies, notices or content that are not on our website or domain, even if we’ve embedded a link to them. We encourage you to read and understand the privacy practices, policies, notices, and content of any linked sites that you visit.
If you have any dispute with us relating to our privacy practices, please contact our legal team at [email protected] with the subject: ‘Dispute’. If we can’t reach an understanding via email, please refer to the Terms, which describes how disputes will be resolved between us. Please be sure to review the Terms before you use any of our products and services.
Google Cloud Platform, G Suite, Mailgun, Peach Payments, Flutterwave, Very Good Security, Mixpanel, HubSpot.