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PRIVACY POLICY

(For We Are Imaginary Pty Ltd t/a Novel)

Last Updated: 08 April 2025

1. Introduction

We Are Imaginary Pty Ltd trading as Novel (“Novel,” “we,” “us,” or “our”) is committed to protecting your personal information. This Privacy Policy (“Policy”) outlines how we collect, use, store, disclose, and protect the personal information of our users (including restaurant merchants and customers) when they access and use our restaurant marketing and booking platform (“the Platform”), available via our website, mobile application, or any other digital channels we operate.

We process your personal information in compliance with the Protection of Personal Information Act, 4 of 2013 (“POPIA”) and other applicable South African data protection laws. By using the Platform, you agree to the practices described in this Policy. If you have any questions or concerns about this Policy, please contact us at the details provided in Section 13.

2. Scope

This Policy applies to all personal information that we process in the course of our business operations, including:

  1. Information collected through the Platform
  2. Information collected from our merchants, customers, and website visitors
  3. Information shared with or received from third parties who assist us in delivering our services

3. Information We Collect

  1. Personal Information You Provide
    • Contact Details: Name, email address, phone number, and physical address.
    • Booking Details: Information related to restaurant reservations, such as booking preferences, special requests, and the date/time of bookings.
    • Payment Information: Credit or debit card details, billing address, and other financial information necessary to process deposits and payments.
    • Restaurant Information (For Merchants): Business name, contact information, regulatory documents, and any other data required to create and maintain a merchant profile.
  2. Automatically Collected Information
    • Device and Usage Information: IP address, browser type, device type, operating system, and information about how you use the Platform.
    • Cookies and Similar Technologies: Small data files stored on your device to enhance user experience, enable certain features, and gather usage statistics. (See Section 9 for more on cookies.)
  3. Information from Third Parties
    • Payment Processors: Transaction data and verification details for payment processing and anti-fraud purposes.
    • Advertising and Analytics Providers: We may receive aggregated or de-identified data to help us better understand user demographics and usage patterns.

4. How We Use Your Information

We process personal information for the following purposes:

  1. Service Provision:
    • Facilitating restaurant bookings, managing deposits, and processing payments.
    • Maintaining and personalizing user accounts.
  2. Communication:
    • Sending confirmations, updates, and notifications related to bookings.
    • Responding to customer inquiries, support requests, and feedback.
  3. Merchant Services:
    • Creating and managing merchant (restaurant) profiles, verifying compliance with regulatory requirements, and facilitating payments.
    • Marketing merchant listings and assisting with promotional campaigns.
  4. Compliance and Legal Obligations:
    • Ensuring compliance with POPIA, FICA (Financial Intelligence Centre Act), and other applicable financial and anti-money laundering regulations.
    • Handling legal disputes, responding to governmental or regulatory requests, and enforcing our Terms of Service.
  5. Marketing and Promotions:
    • Sending you promotional materials, newsletters, or offers, where permissible under applicable law.
    • Conducting market research and user satisfaction surveys.
    • You can opt out of marketing communications at any time (see Section 10).
  6. Platform Improvements:
    • Analyzing usage patterns to improve the functionality, performance, and user experience of the Platform.
    • Troubleshooting technical issues and implementing security safeguards.

5. Legal Basis for Processing

We rely on the following legal grounds for processing your personal information:

  1. Consent: Where you have consented to the processing of your personal information.
  2. Contractual Necessity: Where the processing is necessary to provide the services or perform our obligations under a contract (e.g., booking reservations).
  3. Legitimate Interests: Where processing is necessary for our legitimate business interests, provided those interests are not overridden by your rights or interests.
  4. Legal and Regulatory Compliance: Where processing is required for compliance with legal and regulatory obligations, such as obligations under FICA, POPIA, or other applicable laws.

6. Disclosure of Your Information

We may share your personal information with:

  1. Restaurants: Necessary booking details, payment statuses, and additional information to facilitate reservations.
  2. Payment Processors: Third-party service providers who handle transactions and store payment details securely.
  3. Service Providers: Vendors that help us with data analysis, marketing, customer support, hosting, and other operational requirements. These service providers only process information as instructed by us and in accordance with this Policy.
  4. Legal and Regulatory Authorities: Where required by law, regulation, legal process, or governmental request (e.g., for anti-money laundering checks, tax regulations, or law enforcement inquiries).
  5. Business Transfers: In the event of a merger, acquisition, restructuring, or sale of assets, personal information may be transferred subject to confidentiality obligations and applicable laws.

7. International Data Transfers

Where we transfer personal information outside of South Africa, we ensure that the recipient country or entity has appropriate data protection laws or safeguards in place, or that we have suitable contractual obligations to ensure the confidentiality and security of your personal information, in line with POPIA.

8. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, comply with legal and regulatory requirements, resolve disputes, and enforce our agreements. When no longer needed, we securely delete or anonymize your personal information.

9. Cookies and Similar Technologies

We use cookies and similar tracking technologies to:

  1. Remember Your Preferences: Such as language, location, and other settings to improve your user experience.
  2. Analyze Website Usage: Gather data on user interactions to help us improve our services.
  3. Marketing and Advertising: Deliver relevant advertisements and measure their effectiveness.

You can control the use of cookies through your browser settings. However, disabling cookies may limit certain features and functionality of the Platform.

10. Your Rights and Choices

  1. Access and Correction: You have the right to request access to the personal information we hold about you and to correct any inaccuracies.
  2. Deletion: You may request that we delete your personal information where it is no longer necessary for the purposes for which it was collected.
  3. Objection and Restriction: You can object to or restrict the processing of your personal information under certain circumstances.
  4. Marketing Communications: You may opt out of receiving direct marketing communications at any time by following the unsubscribe instructions in emails or contacting us directly.
  5. Data Portability: Where applicable, you may request the transfer of your personal information to another party in a machine-readable format.

To exercise any of these rights, please contact us using the details in Section 13. We may request specific information to verify your identity before processing your request.

11. Security Measures

We implement reasonable technical and organizational security measures to protect your personal information against unauthorized access, disclosure, alteration, or destruction. These measures include encryption, secure servers, and access controls. However, no system is entirely foolproof, and we cannot guarantee absolute security of your personal information.

12. Updates to This Policy

We may update this Policy from time to time to reflect changes in our data practices or applicable laws. Any material changes will be communicated through the Platform or via email before they become effective. Your continued use of the Platform after such notification constitutes acceptance of the updated Policy.

13. Contact Us

If you have any questions, comments, or concerns about this Privacy Policy or our data handling practices, or if you would like to exercise any of your privacy rights, please contact us at:

We Are Imaginary Pty Ltd t/a Novel

+27712622032

jesse@withnovel.com

We are committed to working with you to resolve any concerns and appreciate the opportunity to address your questions or complaints.