1. Introduction

Welcome to Change Outreach. We are committed to protecting your privacy and ensuring the security of your personal information in accordance with the Protection of Personal Information Act (POPIA) of South Africa and other applicable laws. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our website or use our services as a responsible party under POPIA.

By accessing or using our services, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with our policies and practices, please do not use our services.

2. Definitions

For the purposes of this policy:

• Personal Information: Information relating to an identifiable, living, natural person, and where applicable, an identifiable, existing juristic person
• Processing: Any operation performed on personal information, including collection, receipt, recording, organization, collation, storage, updating, modification, retrieval, alteration, consultation, use, dissemination, merging, linking, restriction, degradation, erasure or destruction
• Data Subject: The person to whom personal information relates
• Responsible Party: Change Outreach as the entity that determines the purpose and means of processing personal information

3. Information We Collect

3.1 Personal Information

We may collect personal information that you voluntarily provide to us when you:

• Contact us through our contact forms or other communication channels
• Book counseling sessions or services
• Subscribe to our newsletter or communications
• Make donations or payments
• Participate in our outreach programs or events
• Apply to become a partner organization or volunteer
• Register for our services or create an account

3.2 Types of Personal Information

The personal information we may collect includes:

• Names, surnames, and contact information (email addresses, phone numbers, physical addresses)
• Identity numbers and demographic information (age, gender, race, language preferences)
• Health information and mental health data (for counseling services only)
• Financial information and payment details (processed securely through third-party providers)
• Communication preferences and history
• Professional information (for partnerships and employment)
• Online identifiers (IP addresses, cookies, device information)
• Biometric information (if applicable for security purposes)
• Any other information you choose to provide

2.3 Automatically Collected Information

When you visit our website, we may automatically collect certain information, including:

• IP address and browser information
• Device information and operating system
• Pages visited and time spent on our site
• Referring website information
• Cookies and similar tracking technologies

4. Lawful Basis for Processing (POPIA Conditions)

We process your personal information in accordance with the eight conditions for lawful processing under POPIA:

• Accountability: We ensure responsible processing and can demonstrate compliance
• Processing Limitation: We process information lawfully, reasonably, and only for specific purposes
• Purpose Specification: We collect information for specific, explicitly defined, and lawful purposes
• Further Processing Limitation: We don't process information for secondary purposes incompatible with the original purpose
• Information Quality: We ensure information is complete, accurate, not misleading, and updated
• Openness: We maintain documentation and provide information about processing
• Security Safeguards: We implement appropriate technical and organizational measures
• Data Subject Participation: We respect your rights as a data subject

5. How We Use Your Information

We use the information we collect for the following specific purposes:

• Providing and maintaining our counseling and outreach services
• Processing appointments, bookings, and service delivery
• Communicating with you about our services and programs
• Sending newsletters and updates (with your explicit consent)
• Processing donations and payments securely
• Improving our website, services, and user experience
• Complying with legal obligations and regulatory requirements
• Protecting against fraud, security threats, and illegal activities
• Conducting research and analysis for service improvement (anonymized data)
• Managing partnerships and volunteer programs

6. Information Sharing and Disclosure

We do not sell, trade, or otherwise transfer your personal information to third parties without your consent, except in the following circumstances:

• Service Providers: We may share information with trusted third-party service providers who assist us in operating our website and providing services
• Legal Requirements: We may disclose information when required by law or to protect our rights and safety
• Business Transfers: In the event of a merger or acquisition, your information may be transferred as part of the business assets
• Consent: We may share information with your explicit consent

8. Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of sensitive data in transit and at rest
• Regular security assessments and updates
• Access controls and authentication measures
• Staff training on data protection practices
• Secure hosting and backup procedures

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

9. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on our website. Cookies are small data files stored on your device that help us:

• Remember your preferences and settings
• Analyze website traffic and usage patterns
• Improve website functionality and performance
• Provide personalized content and recommendations

You can control cookie settings through your browser preferences. However, disabling cookies may affect the functionality of our website.

7. Your Rights as a Data Subject (POPIA Rights)

Under POPIA, you have the following rights regarding your personal information:

• Right to Access: Request confirmation of whether we hold your personal information and access to such information
• Right to Correction: Request correction, updating, or completion of inaccurate or incomplete information
• Right to Deletion/Destruction: Request deletion of your personal information (subject to legal requirements and retention periods)
• Right to Object: Object to the processing of your personal information on reasonable grounds
• Right to Restrict Processing: Request restriction of processing in certain circumstances
• Right to Data Portability: Request a copy of your information in a structured, commonly used format
• Right to Withdraw Consent: Withdraw consent for processing where consent was the lawful basis
• Right to Complain: Lodge a complaint with the Information Regulator of South Africa

If you are not satisfied with our response, you may lodge a complaint with the Information Regulator at: www.justice.gov.za/inforeg/

10. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Factors that influence our retention periods include:

• The nature of the information and services provided
• Legal and regulatory requirements
• The need to resolve disputes or enforce agreements
• Your consent and preferences

11. Third-Party Links

Our website may contain links to third-party websites or services. We are not responsible for the privacy practices or content of these external sites. We encourage you to review the privacy policies of any third-party sites you visit.

12. Children's Privacy

Our services are not intended for children under the age of 13. We do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13, we will take steps to delete such information promptly.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any material changes by posting the updated policy on our website and updating the "Last updated" date. Your continued use of our services after such changes constitutes acceptance of the updated Privacy Policy.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Information Officer: