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Privacy PolIcy



Joggle (Pty) Ltd is the provider of a technology platform that delivers a visual and virtual people directory and communication universe for organizations. The Joggle Mobile Application provides various services and in order to do so, we need to process data and specifically personal information from time to time. The purpose of this policy is to inform you about our approach to privacy and the steps we take to ensure that we comply with prevailing privacy laws. 


In this Policy (as defined below), unless the context requires otherwise, the following capitalized terms shall have the meanings given to them — 

Active Processing


Instances where Joggle has directly been provided with the Personal Information/Personal Data of Data Subjects, such as when Data Subjects submit an enquiry in respect of our Services, or when Data Subjects provide Personal Information/Personal Data to Joggle pursuant to concluding any commercial agreement(s) with Joggle. 

Inactive Processing


Instances where Joggle has not actively been provided with the Personal Information/Personal Data of Data Subjects, such as when Joggle deploys Passive Processing Means to collect information from Data Subjects. These Passive Processing Means allow Joggle to Process certain kinds of Non-personally Identifiable Information which can perhaps not be linked to Data Subjects.



The Processing of Personal Information/Personal Data in such a manner that the Personal Information/ Personal Data can no longer be attributed to Data Subjects without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the Personal Information/Personal Data are not attributed to Data Subjects.

Applicable Laws


Any laws applicable to Personal Data and Personal Information and includes any statute, regulation, notice, policy, directive, ruling or subordinate legislation; the common law; any binding court order, judgement or ruling; any applicable industry code, policy or standard enforceable by law; or any applicable direction, policy or order that is given by any regulator, competent authority or organ of state or statutory industry body. 



A technique of personal identification that is based on physical, physiological or behavioral characterisation including blood typing, fingerprinting, DNA analysis, retinal scanning and voice recognition. 



Means Joggle, in circumstances where it Processes Personal Data (as defined in Article 4 of the GDPR). 



Means any voluntary, specific and informed expression of will in terms of which permission is given for the Processing of Personal Information.



Small text files that store Non-personally Identifiable Information/Data about Data Subjects, either temporarily in connection with a Data Subjects Internet Protocol (IP) address or more permanently on the hard drive of a Data Subject’s device.



Any natural person(s), or juristic person(s), who have concluded an agreement with Joggle in terms of which such Customer procures the Services provided by Joggle, including “you” in such capacity. 

Data Subject

Depending on the context, it could mean “you”, any other Joggle’s Customer(s) or any Third Party in respect of whom Joggle Processes Personal Information/Personal Data.

Data Processing


Infrastructure Means any and all systems, networks, servers, workstations, laptops, mobile devices, web applications, mobile applications, cloud storages, websites owned, controlled or operated by Joggle.

Embedded Scripts


Means, programming code that is designed to collect information about a Data Subject’s interactions with the relevant Website(s) or Mobile Application(s). It is temporarily downloaded onto a Data Subject’s device from our web server or a Third-Party Operator. This program is active only while a Data Subject is connected to the relevant Website(s) or Mobile Application(s) and is deleted or deactivated thereafter.

Electronic Means


Means, in relation to the Processing of any Personal Information/Personal Data, the use of any Website(s), Mobile Application(s), electronic mail (email), text, voice, sound or image messages by Joggle.

Non-Electronic Means


Means, in relation to the Processing of any Personal Information/Personal Data, the use of traditional means of Processing, such as hard copy documents, traditional filing systems deployed for the storage and retention of Personal Information/Personal Data and face-to-face personal engagements with Data Subjects.



The General Data Protection Regulation, which is a European law that governs all collection and processing of personal data from individuals inside the European Union. 

Mobile Application


Means the multi-device software application, whether in web-based format or device-native format, to which this Privacy Policy relates and through which Customer(s) and Third Parties gain access to Joggle’s Services. 

Mobile Device Identifier


Means device information if you access our Website(s) or Mobile Application(s) through mobile devices. Certain features of the relevant Website(s) or Mobile Application(s) may require collection of mobile phone numbers and we may associate that phone number with the mobile device identifiers. Additionally, some mobile phone service providers operate systems that pinpoint the physical location of devices that use their service. Depending on the provider, Joggle and/or our Third-Party Operators may receive this information. If Joggle associates any such passively collected information with the Personal Information/Personal Data of Data Subjects, we will treat the combined information as Personal Information/Personal Data as contemplated in this Policy.

Non-personally Identifiable Information/Data


Any information/data which cannot be linked to Data Subjects, such as an internet domain name, the type of web browser used by a Data Subject, the type of operating system relied on by a Data Subject, the date and time of a Data Subject’s visit to our Website(s) and Mobile Application(s), the specific pages a Data Subject may have visited, and the address of the website which a Data Subjects may have visited prior to entering or gaining access to Joggle’s Website(s) or Mobile Application(s).



A person or entity who Processes Personal Information/Data for a Responsible Party. 

Passive Processing Means


The use of technologies to facilitate the Inactive Processing of Personal Information/Personal Data, namely the use of Cookies, Web Beacons, Embedded Scripts and/or Mobile Device Identifiers.

Personal Data


Shall (as defined in Article 4 of the GDPR) mean any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, which in the context of Joggle shall comprise of the types of Personal Data recorded in this Policy below.

Personal Information


Shall have the same meaning as is given in section 1 of POPIA, but shall in the context of Joggle comprise of the types of Personal Information recorded in this Policy below. 



This Data Protection and Privacy Policy.  




The Protection of Personal Information Act, No 4 of 2013. 


Means any operation or activity or any set of operations, whether or not by automatic means, concerning Personal Information/Personal Data, including:

• the collection, receipt, recording, organization, collation, storage, updating or modification,   retrieval, alteration, consultation or use;

• dissemination by means of transmission, distribution or making available in any other form by   electronic communications or other means; or

• merging, linking, blocking, degradation, erasure or destruction. For the purposes of this   definition, “Process” has a corresponding meaning. 



The Information Regulator established in terms of POPIA.


Responsible Party


Means in the context of this Policy, Joggle. 



The various services provided by Joggle through, or by means of, the Mobile Application, including, but not limited to the provision of services associated with connecting users of the Mobile Application to one another, establishing a centralized directory and environment within a Customer’s workplace, the particulars of which services are clearly set forth on Joggle’s Website from time to time.

Special Personal Information/Data


Personal Information/Personal Data concerning, amongst other aspects contemplated in terms of section 26 Part B of POPIA, a Data Subject’s, religious beliefs, race or ethnic origin, trade union membership, political persuasion, health or sex life, biometric data, or criminal behaviour.



Any Customer(s), Data Subject(s), employees, independent contractor, agent, consultant or user of Joggle’s Services, Website, Mobile Application or any other digital application interface.  


Unique Identifier


Any identifier that is assigned to a Data Subject and is used by the Responsible Party for the purposes of the operations of that Responsible Party and that uniquely identifies that data subject in relation to the Responsible Party.  



Means Joggle (Pty) Ltd.   

Usage Data


Data collected automatically either generated by the use of Service or from Service infrastructure itself 6 (for example, the duration of a page visit).




The website owned and operated by Joggle sourced at  

Web Beacons


Small graphic images called web beacons, also known as “Internet tags” or “clear gifs,”, which Web Beacons may be deployed in Joggle’s Website(s) pages and e-mail messages. Web beacons may be invisible to Data Subjects, but any electronic image inserted into a web page or e-mail can act as a Web Beacon. Joggle may use web beacons or similar technologies for a number of purposes, including, without limitation, to count the number of visitors to our Websites, Mobile Application, to monitor how users navigate the Website(s) or Mobile Application, to count how many e-mails that we have sent were actually opened or to count how many particular articles or links were actually viewed by Data Subjects in certain circumstances. 



This Policy regulates the Processing of Personal Information/Personal Data by Joggle and sets forth the requirements with which Joggle undertakes to comply when Processing Personal Information/Personal Data pursuant to undertaking its operations and fulfilling its contractual obligations in respect of Data Subjects and Third Parties in general. Joggle places a high premium on the privacy of every person or organisation with whom it interacts or engages with and therefore acknowledges the need to ensure that Personal Information/Personal Data is handled with a reasonable standard of care as may be expected from it. Joggle is therefore committed to ensuring that it complies with the requirements of POPIA, and also with the terms of the GDPR to the extent that the GDPR applies. When a Data Subject or Third Party engages with Joggle, whether it be physically or via any digital, electronic interface such as Joggle’s Website, the Data Subject or Third Party acknowledges that they trust Joggle to Process their Personal Information/Personal Data, including the Personal Information/ Personal Data of their dependents, beneficiaries, customers, members, or employees as the case may be, which further entrenches the importance of Joggle’s compliance with Applicable Laws in regards to the Processing of Personal Information/Personal Data. All Data Subjects and Third Parties have the right to object to the processing of their Personal Information/Personal Data. It should be voluntary to accept the Terms and Conditions to which this Policy relates. However, Joggle does require the Data Subject or Third Party’s acceptance to enable the proper use of Joggle’s Website and/or Services. 



The purposes of this Policy are not only to inform Data Subjects of what Personal Information/Personal Data of theirs Joggle may Process, where Joggle may have collected such Personal Information/ Personal Data from (if not directly from them as the Data Subject), how Joggle Processes their Personal Information/Personal Data, but also to establish a standard by which Joggle and its employees,  representatives and operators shall comply in as far as the Processing of Personal Information/Personal Data is concerned.  Joggle, in its capacity as a Responsible Party and/or Operator and/or Controller, as the case may be, shall strive to observe and comply with its obligations under POPIA and the GDPR (as may be applicable and to the extent necessary) when it Processes Personal Information/Personal Data from or in respect of any Data Subject. 



Whenever any Data Subject engages with Joggle, whether it be physically or electronically, or through the use of its Services, Mobile Application, or Website Joggle will in effect be Processing the Data Subject’s Personal Information/Personal Data. It may be from time to time that Joggle has collected a Data Subject’s Personal Information/Personal Data from other sources and in such instances Joggle will inform the Data Subject by virtue of any privacy notices it deploys from time to time. In the event that a Data Subject has shared their Personal Information/Personal Data with any third parties, Joggle will not be responsible for any loss suffered by the Data Subject, their dependents, beneficiaries, customers, representatives, agents or employees (as the case may be). When a Data Subject provides Joggle with the Personal Information of any other Third Party, Joggle will process the Personal Information/Personal Data of such Third Party in line with this Policy, as well as any terms and conditions or privacy notices to which this Policy relates. Joggle will primarily Process Personal Information/Personal Data in order to facilitate and enhance the delivery of Products and/or Services to its Customers, manage and administer its business, foster a legally compliant workplace environment, as well as safeguard the Personal Information/Personal Data relating to any Data Subjects which it in fact holds. In such an instance, the Data Subject providing Joggle with such Personal Information/Personal Data may also be required to confirm that they are a Competent Person and that they have authority to give the requisite consent to enable Joggle to process such Personal Information/Personal Data. Joggle undertakes to process any Personal Information/Personal Data in a manner which promotes the constitutional right to privacy, retains accountability and Data Subject participation. 8Prior to recording the purpose(s) for which Joggle may, or will, process the Personal Information/Personal Data of Data Subjects, Joggle hereby records the types of Personal Information/Personal Data of Data Subjects it may process from time to time:

• Full names;

• Physical and postal address particulars;

• Telephone numbers;

• Email addresses;

• Cookies and Usage Data;

• Unique Identifiers. In supplementation of the above and any information privacy notices provided to any Data Subjects from time to time pursuant to any engagement with them, Joggle may process Personal Information/Personal Data for the following purposes:

• To provide or manage any information or Services requested by or delivered to Data Subjects in  general.

• To establish a Data Subject’s needs, wants and preferences in relation to the Services provided   by Joggle.

• To help Joggle identify Data Subjects when they engage with Joggle.

• To facilitate the delivery of our Services to Customers.

• To monitor the usage of our Services.

• To detect, prevent and address technical issues.

• To allocate to Customers and Data Subjects Unique Identifiers for the purpose of securely   storing, retaining and recalling their Personal Information/Personal Data from time to time.

• To maintain records of Data Subjects and specifically Customer records.

• For general administration purposes.

• For legal and/or contractual purposes.

• To improve the quality of Joggle’s Services.

• To transfer Personal Information/Personal Data to any other relevant Third Parties on whose   behalf Joggle processes Personal Information/Personal Data in its capacity as an Operator.

• To transfer Personal Information/Personal Data to Third Party service providers so as to enable   Joggle to deliver Services to its Customer(s).

• To analyse the Personal Information/Personal Data collected for research and statistical purposes.

• To help recover bad debts.

• To transfer Personal Information/Personal Data across the borders of South Africa to other   jurisdictions if it is required.

• To carry out analysis and Customer profiling.

• To identify other products and services which might be of interest to our Customers and Data   Subjects in general, as well as to inform them of such products and/or services. 9

• To comply with any Applicable Laws applicable to Joggle.


When collecting Personal Information/Personal Data from a Data Subject, Joggle shall comply with the notification requirements as set out in Section 18 of POPIA, and to the extent applicable, Articles 13 and 14 of the GDPR. Joggle will collect and Process Personal Information/Personal Data in compliance with the conditions as set out in POPIA and/or the Processing principles in the GDPR (as the case may be), to ensure that it protects the Data Subject’s privacy. Joggle will not Process the Personal Information/Personal Data of a Data Subject for any purpose other than for the purposes set forth in this Policy or in any other privacy notices which may be provided to Data Subjects from time to time, unless Joggle is permitted or required to do so in terms of Applicable Laws or otherwise by law. Joggle may from time-to-time Process Personal Information/Personal Data by making use of automated means (without deploying any human intervention in the decision-making process) to make decisions about the Data Subject or their application. In this instance it is specifically recorded that the Data Subject may object to or query the outcomes of such a decision. 



Usage Data


We may also collect information that your browser sends whenever you visit our Mobile Application and or our Services (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Mobile Application or Website(s) that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. When you access our Services with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Tracking Cookies Data


We use cookies and similar tracking technologies to track the activity on our Services and we hold certain information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service. 10


Examples of Cookies we use:

Session Cookies: We use Session Cookies to operate our Services.

Preference Cookies: We use Preference Cookies to remember your preferences and various settings.

Security Cookies: We use Security Cookies for security purposes.



Joggle acknowledges that it may only use Personal Information/Personal Data to contact Data Subjects for purposes of direct marketing where Joggle has complied with the provisions of POPIA and GDPR (where applicable) and when it is generally permissible to do so in terms of Applicable Laws. In the event that Joggle may lawfully direct market to a Data Subject in terms of section 69 of POPIA, Joggle will ensure that a reasonable opportunity is given to such Data Subjects to object (opt-out) to the use of their Personal Information/Personal Data for Joggle’s marketing purposes when collecting the Personal Information/Personal Data and on the occasion of each communication to the Customer for purposes of direct marketing. 



Personal Information/Personal Data will only be retained by Joggle for as long as necessary to fulfil the legitimate purposes for which that Personal Information/Personal Data was collected in the first place and/or as permitted or required in terms of Applicable Law. It is specifically recorded that any Data Subject has the right to object to the Processing of their Personal Information and Joggle shall retain and store the Data Subject’s Personal Information/Personal Data for the purposes of dealing with such an objection or enquiry as soon and as swiftly as possible. 



Where Joggle is required to collect Personal Information/Personal Data from a Data Subject by law or in order to fulfil a legitimate business purpose of Joggle and the Data Subject fails to provide such Personal Information/Personal Data, Joggle may, on notice to the Data Subject, decline to render services without any liability to the Data Subject. 



Joggle will always implement appropriate, reasonable, physical, organisational, contractual and technological security measures to secure the integrity and confidentiality of Personal Information/ copying, use or modification of Personal Information/Personal Data in compliance with Applicable Laws. Personal Data, including measures to protect against the loss or theft, unauthorised access, disclosure, 11In further compliance with Applicable Laws, Joggle will take steps to notify the relevant Regulator(s) and/or any affected Data Subjects in the event of a security breach and will provide such notification as soon as reasonably possible after becoming aware of any such breach. Notwithstanding any other provisions of this Policy, it should be acknowledged that the transmission of Personal Information/Personal Data, whether it be physically in person, via the internet or any other digital data transferring technology, is not completely secure. Whilst Joggle has taken all appropriate, reasonable measures contemplated above to secure the integrity and confidentiality of the Personal Information/Personal Data its Processes, in order to guard against the loss of, damage to or unauthorized destruction of Personal Information/Personal Data and unlawful access to or processing of Personal Information/Personal Data, Joggle in no way guarantees that its security system(s) are 100% secure or error-free. Therefore, Joggle does not guarantee the security or accuracy of the information (whether it be Personal Information/Personal Data or not) which it collects from any Data Subject. Any transmission of Personal Information/Personal Data will be solely at the own risk of a Data Subject. Once Joggle has received the Personal Information/Personal Data, it will deploy and use strict procedures and security features to try to prevent unauthorised access to it. As indicated above, Joggle reiterates that it restricts access to Personal Information/Personal Data to Third Parties who have a legitimate operational reason for having access to such Personal Information/Personal Data. Joggle also maintains electronic and procedural safeguards that comply with the Applicable Laws to protect your Personal Information from any unauthorized access. Joggle shall not be held responsible and by accepting any terms and conditions to which this Policy relates, any Data Subject agrees to indemnify and hold Joggle harmless for any security breaches which may potentially expose the Personal Information/Personal Data in Joggle’s possession to unauthorized access and or the unlawful processing of such Personal Information/Personal Data by any Third-Party. 



Joggle may disclose Personal Information/Personal Data to Third-Party service providers and any Joggle Group Company where necessary and to achieve the purpose(s) for which the Personal Information/ Personal Data was originally collected and Processed. Joggle will enter into written agreements with such Third-Party service providers and Joggle Group Company, to ensure that they comply with Applicable Laws pursuant to the Processing of Personal Information/Personal Data provided to it by Joggle from time to time. 



Joggle may, under certain circumstances, transfer Personal Information/Personal Data to a jurisdiction outside of the Republic of South Africa in order to achieve the purpose(s) for which the Personal 12Information/Data was collected and Processed, including for Processing and storage by Third-Party service providers. If it is required, Joggle will obtain the Data Subject’s consent to transfer the Personal Information/ Personal Data to such foreign jurisdiction. The Data Subject should also take note that, where the Personal Information/Personal Data is transferred to a foreign jurisdiction, the Processing of Personal Information/Personal Data in the foreign jurisdiction may be subject to the laws of that foreign jurisdiction. 



A Data Subject has the right to a copy of the Personal Information/Personal Data which is held by Joggle (subject to a few limited exemptions as provided for under Applicable Law). The Data Subject must make a written request (which can be by email) to the Information Officer designated by Joggle from time to time and whose contact details can be sourced in Joggle’s PAIA Manual. Joggle will provide the Data Subject with any such Personal Information/Personal Data to the extent required by Applicable Law and subject to and in accordance with the provisions of Joggle’s PAIA Manual (published in terms of section 51 of the Promotion of Access to Information Act, 2000 (“PAIA”), which PAIA Manual can be sourced either at Joggle’s premises upon request or on Joggle’s Website. The Data Subject can challenge the accuracy or completeness of his/her/its Personal Information/ Personal Data in Joggle’s records at any time in accordance with the process set out in Joggle’s PAIA Manual.



Joggle will take reasonable steps to ensure that Personal Information/Personal Data that it Processes is kept updated where reasonably possible. For this purpose, Joggle shall provide Data Subjects with the opportunity to update their information at appropriate times. Joggle may not always expressly request the Data Subject to verify and update his/her/its Personal Information/Personal Data and expects that the Data Subject will notify Joggle from time to time in writing:

• of any updates or amendments required in respect of his/her/its Personal Information/ Personal Data;

• where the Data Subject requires Joggle to delete his/her/its Personal Information/Personal Data;  or

• where the Data Subject wishes to restrict the Processing of his/her/its Personal Information/  Personal Data. 



Our Services may contain links to other sites that are not operated by Joggle. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.



Our Services are not intended for use by children under the age of 18 (“Child” or “Children”). We do not knowingly collect personally identifiable information from Children under 18. If you become aware that a Child has provided us with Personal Information/Personal Data, please contact us. If we become aware that we have collected Personal Information/Personal Data from Children without the consent of a competent person we take steps to remove that information from Data Processing Infrastructure. 



We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Mobile Application and through the use of our Services. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.



All comments, questions, concerns or complaints regarding Personal Information/Personal Data or this Policy, should be forwarded to Joggle’s Information Officer at the following email address



If any Data Subject or Third Party is of the view or belief that Joggle has Processed their Personal Information/Personal Data in a manner or for a purpose which is contrary to the provisions of this Policy, the Data Subject is requested to first attempt to resolve the matter directly with Joggle, failing which the Data Subject or Third Party shall have the right to lodge a complaint with the Information Regulator, under the provisions of POPIA.


The current contact particulars of the Information Regulator are: The Information Regulator (South Africa) Website: JD House 27 Stiemens Street Braamfontein Johannesburg, 2001 PO Box 31533 14 Braamfontein, Johannesburg, 2107

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