Privacy Policy
Last Updated on 31st August 2018
1. Scope of This Privacy Policy
This privacy policy only applies to speargen.com or speargen.biz, where a link to this privacy policy is provided (the “Websites”).
Speargen operates worldwide through subsidiary and affiliate companies. The Websites are controlled by Speargen Limited, unless a Website identifies (in its terms of use or otherwise) that it is controlled by another Speargen Limited entity. 
Websites and specific web pages linked from speargen.com or speargen.biz may be subject to separate terms of use (including separate privacy policies). You must not provide Personal Information if you do not accept such terms of use.
Where links from our Websites are provided to non-speargen.com or non-speargen.biz websites, Speargen Limited is not responsible for those websites. The inclusion of a link to a third-party website does not imply endorsement of the linked site or service by us or our affiliates. These third-party websites will be governed by different terms of use (including privacy notices) and you are solely responsible for viewing and using each such website in accordance with the applicable terms of use. Speargen Limited is not responsible for how your Personal Information is handled by such third-party websites.
If you are a job applicant, please note that a separate privacy policy will apply to Personal Information collected through our job application portal. This can be viewed here.

2. Cross-Border Transfer
The Websites are controlled and operated by us from South Africa and it is not intended that we will be subject to the laws or jurisdiction of any state, country or territory other than that of the South Africa. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Websites you consent to the transfer of information to countries outside of your country of residence, including South Africa, which may have data protection rules that are different from those of your country. We have established safeguards to protect Personal Information that is transferred to other countries, including appropriate contractual protections.

3. Personal Information We May Collect From You
"Personal Information" is information that identifies you as an individual or relates to an identifiable individual. Personal Information we may collect through our Websites includes:
• your name, postal address, email address, phone number, occupation and other contact information;
• information regarding your dealings with us;
• any interest you have in relation to our services or our practice areas; and
• any information you may voluntarily submit to us by completing any form on our Websites; and
• details of your visits to and usage of our Website.
We may collect Personal Information in various ways:
• from any form you may complete and submit through our Websites, for example information collected from the “Contact Us” page of our Websites;
• from the content of surveys that you may complete on our Websites;
• from session ‘cookies’ and other similar tools deployed on parts of our Websites that can only be accessed by authenticated users who are logged into the Website (for further information regarding cookies used on our Websites, please see Section 6 below)
• when you provide information as a client in connection with us providing professional services to you. Such information may be collected through speargen.com or speargen.biz when clients access Speargen Limited client links within this Website. Access will be subject to the terms of business we have with clients and any additional terms and conditions of use attached to those sites; and
• from other sources, such as public databases, joint marketing partners, social media platforms (including from people with whom you are friends or otherwise connected) and from other third parties.

4. How We May Use Your Personal Information
We may use Personal Information about you for our legitimate business interests, including the following:
• to facilitate your participation in interactive features you may choose to use on our Websites and personalise your experience on the Websites by presenting content tailored to you;
• to correspond with you, notify you of events or changes to our service, or otherwise to fulfill your requests and respond to your queries and requests for information, which may include marketing to you; and
• for the purposes of providing professional services to you via Speargen Limited applications; such services will be subject to additional terms and conditions of use including privacy;
• for our business purposes, such as data analysis, audits, fraud monitoring and prevention, and developing new products, enhancing, improving or modifying our Websites, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.

5. Disclosure of Your Personal Information
Speargen Limited may disclose your Personal Information to any Speargen Limited affiliate company for the uses and purposes set out above. We may also disclose your Personal Information to third parties for the following reasons:
• to third party service providers such as entities providing customer service, email delivery, auditing, hosting our website and other services;
• to third parties involved with events that you register for, to facilitate your participation in those events;
• if we are obliged to disclose your Personal Information under applicable law or regulation, which may include laws outside your country of residence;
• in order to enforce or apply our Website terms of use, or to protect the rights, privacy, safety or property of Speargen Limited, our clients, affiliates or other parties;
• to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence;
• in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings);
• in accordance with the separate terms and conditions of use that may attach to Speargen Limited website links.

6. Other Information We May Collect
"Other Information" is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. Speargen Limited may collect Other Information in various ways.
For instance, when you visit our Websites, our server may record your IP address. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Websites. We may also derive your approximate location and company details from your IP address. Speargen Limited may also gather Other Information such as the type of your internet browser, your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, and the name and version of the Websites you are using, which Willis Towers Watson uses to provide you with a more effective service.

Cookies: Additionally, when you visit our Websites, Speargen Limited may store a ‘cookie’ on the hard drive of your computer. Cookies are small text files that a website transfers to your hard drive to store and sometimes collect information about your usage of websites, such as time spent on the Websites, pages visited, language preferences, and other anonymous traffic data. We use the information for security purposes, to facilitate navigation, to display information more effectively, to personalize your experience while using the Websites and to recognize your computer in order to assist your use of the Websites. We also gather statistical information about use of the Websites in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them.
You can control the way in which cookies are used by altering your browser settings. You may refuse to accept cookies by activating the setting on your browser that allows you to reject cookies. However, if you select such a setting, this may affect the functioning of our Websites. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you access or log on to our Websites. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.

Google Analytics: Our Websites use Google Analytics, which uses cookies and similar technologies to collect and analyse information about use of the Websites and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and you can opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Do Not Track signals: Please note that our Websites do not recognize or respond to any signal which your browser might transmit through the so-called ‘Do Not Track’ feature your browser might have. Enabling such feature on your browser will not necessarily affect the way in which our Websites operate, and if you wish to disable cookies on our Websites, you should not rely on any ‘Do Not Track’ feature your browser might have.
Pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Websites to, among other things, track the actions of users of the Websites (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Websites and response rates.

From you: Information such as your preferred means of communication is collected when you voluntarily provide it.

By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the Websites (for example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code).

7. How We May Use and Disclose Other Information
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information (such as combining your name with your location). If we do, we will treat the combined information as Personal Information as long as it is combined.

8. Security
Speargen Limited maintains appropriate technical and organisational security measures to protect the security of your data against loss, misuse, unauthorised access, disclosure or alteration. Despite this, the security of the transmission of information via the Internet cannot always be guaranteed and you acknowledge this in your access and use of our Websites. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us via support@speargen.com.

9. Choices and Access
You may opt out from receiving marketing-related emails from us on a going-forward basis by using the unsubscribe mechanism contained in each such email. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt out.
You may withdraw your consent to this privacy policy at any time by sending us an email at support@speargen.com. Please note that even if you withdraw your consent, we may still have the right or obligation under applicable law to collect, use, transfer or disclose Personal Information without your consent and we reserve the right to undertake that activity when appropriate.
If you would like to review, correct, update, suppress, or restrict the processing of your Personal Information or request a copy of Personal Information about you, you may contact us by sending us an email at support@speargen.com.
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.

10. Retention Period
We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this privacy policy unless a longer retention period is required or permitted by law.

11. Use of Websites By Minors
The Websites are not directed to individuals under the age of thirteen (13), and we request that they not provide Personal Information through the Websites.

12. Sensitive Information
We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Websites.

13. Changes to Our Privacy Policy
From time to time, we may change our privacy policy. The effective date of this privacy policy, as indicated at the beginning of this privacy policy, indicates the last time this privacy policy was revised. Checking this effective date allows you to determine whether there have been changes since the last time you reviewed the policy. We will notify you of changes to this privacy policy by posting the revised privacy policy on our Websites. Your use of the Websites following these changes means that you accept the revised privacy policy.

14. Contact & Comments
If you have any questions or comments regarding this privacy policy, please contact us via support@speargen.com.
We do not accept requests via the telephone or by facsimile. We are not responsible for notices that are not labelled or sent properly, or do not have complete information.
Speargen Limited
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