Privacy Policy


Privacy Policy for Centre for Diabetes & Endocrinology (Pty) Ltd (“CDE”)

  1. General Principles of the Privacy Policy
    1. CDE is committed to safeguarding the personal information of the users of its Website and/or App.
    2. CDE respects your privacy and your Personal Information and for this reason, we take care to protect your Personal Information and to keep it confidential.  Our privacy practices have been developed in accordance with The Protection of Personal Information Act 2013 (“POPI”) and in recognition of your right to have your Personal Information processed in accordance with the conditions for lawful processing.
    3. This privacy policy (“the Policy”) covers how we treat your Personal Information collected electronically when you use the CDE Website and/or App and/or Social Media Networks, register or apply online for any CDE products or services, or when you contact CDE electronically.
    4. When dealing with your Personal Information we apply the following:
      1. CDE will only disclose, collate and process (“use”) your Personal Information with your express written permission unless we are otherwise legally required to do so;
      2. CDE will not use your Personal Information for any other purpose, other than that which we disclosed to you, unless you give CDE your express written permission to do so, or unless CDE is permitted or required to do so by law;
    5. By using the CDE website and/or mobile Application, registering or applying online for any CDE products or services, contacting CDE electronically or providing your Personal Information to CDE in any other format other than the CDE Website, you provide CDE with your express written permission to share your Personal Information within the CDE Group of Companies and with the CDE’s partners, in the ordinary course of CDE’s business, including for purposes of providing you with the relevant products and services. You may revoke this consent in writing at any time.
    6. This Policy is incorporated in full into the General Terms and Conditions of Use (“the Terms”).  By accessing and/or using the Website and/or App and/or Social Media Networks and/or providing your Personal Information to CDE in any other format other than via the Website and/or App, you agree that you have read, understood and agree to be bound by the Terms existing at that time. 
    7. If you do not wish to be bound by the Terms, or do not consent to the processing of your Personal Information in accordance with the Policy, please do not continue to use the CDE Website and/or Application and/or provide any Personal Information to the Website or via any other format other than via the Website.

      For purposes of the Policy:
      • “you” or “your” refers to you, the user of the Website and/or mobile Application or any of the Social Media Networks;
      • we” or “us” or “our” or “CDE” refers to Centre for Diabetes & EndocrinologyProprietary Limited, registration number1994/001693/07, a private company incorporated in the Republic of South Africa with registered address 81 Central Street, Houghton Estate, Johannesburg, 2198, South Africa and any developers that CDE may employ from time to time; 
      • Social Media Networks” includes, but is not limited to the following social media networks – Facebook; Twitter; YouTube; Linkedin; Instagram; Pinterest; and Tumblr;
      • the Website” means the CDE website, accessible atwww.cdediabetes.co.za;
      • the App” or “Application” or“CDE Apps” means any online application software that is provided by or is connected with CDE that you install or download from an online application store and access via a mobile device, including any smartphone and/or tablet device; and
      • Site” or “Sites” means collectively our website/s, including this Website, the CDE Apps and any Social Media Networks.

  2. What do we mean by Personal Information
    1. Personal information refers to information that identifies or relates specifically to you, for example, your name, age and identity number or any information you use to register for the website. Any information about your health and wellness interests, your medication, your lifestyle, your diet, your exercise regime and all related information will also be regarded as personal information. (Collectively, “Personal Information”).

  3. What types of Personal Information we collect
    1. You can view certain pages of the Sites without providing any Personal Information. However, should you wish to make use of certain special features or the products and services provided by CDE, you may be required to register and provide us with Personal Information to enable CDE to provide you with the information, services and products you wish to have access to.
    2. When you register on any of the Sites for the purposes of receiving email newsletters, to post content to any of the Sites, to activate your CDE membership or to participate in ant promotional competitions, CDE collects information about you. CDE also collects information about you when you contact us for any reason via email, feedback forms, Social Media Networks, comments and discussion forums. This information may include, but is not limited to the following:
      1. your full name, username, gender, date of birth and location;
      2. your state of health, including your blood results, your medications, your lifestyle, your diet and exercise regime;
      3. your email address;
      4. your physical and postal address;
      5. your contact telephone numbers; and
      6. details of any of the products and services you have used, ordered or enquired about.
    3. The provision of your Personal Information as contemplated in this clause 3 is voluntary, however should you refuse to provide such information, you may not be able to benefit from all the products and services offered by CDE via its Sites for which this information is necessary in the provision of these products and services.

  4. How we collect your Personal Information
    1. Whenever you use any of the CDE Sites, complete an application form, contact CDE electronically, or use one of the products, services, facilities, tools or utilities offered by CDE on the CDE Sites, CDE will collect your Personal Information.
  5. Information gathered using cookies and other analytical technologies
    1. This Website uses cookies, server logs, and other technologies that allow us to collect information about you and your use of the Website.  Cookies are small files that we transfer to your computer or mobile device, via your web browser, that typically expire after a defined period of time.  They allow us to provide the services you request, tailor advertising to your interests, and aggregate certain analytical information about you.  This information is not associated with a specific personal identity, but rather includes information such as:
      1. your Internet Protocal (IP) address;
      2. device identifying information, such as the type of Internet browser, device and operating system you are using to access the Website;
      3. the location from which you access the Website;
      4. the frequency of visits to the Website; 
      5. details as to the time and duration of your visit to the Website, the page from which you were directed to the Website and the page to which you navigated when you were finished, pages accessed during your visit, the amount of time spent on each page and how you interacted with other site users;  and
      6. details of services, programmes, channels and advertisements that you view and how you view them.
    2. Your acceptance of cookies and other analytical technologies is entirely voluntary.  Most web browser software is initially set up to accept the use of such technologies, however you can reset your web browser software to indicate when they are being used and/or to refuse any such use.  You are also able to delete cookies at any time.
    3. Some parts of the Website will not function properly or may be considerably slower if you refuse cookies. For example, without cookies, you will not be able to set personalised preferences.

  6. How we use your Personal Information
    1. In order to make your use of the CDE Sites and the products, services, facilities, tools or utilities offered on the CDE Sites as informative and successful as possible, it is necessary for CDE to find out exactly what you need and want. The following are some of the reasons, but are not limited to (i.e. disclosed reasons), why CDE would collect your Personal Information:
      1. for CDE to process your instructions or requests relating to the specific products and services you have requested;
      2. to send you notifications and facilitate your communications with the CDE Sites;
      3. establishing and verifying your identity so as to minimise the need for you to re-enter information;
      4. for CDE to ensure that we meet your needs, CDE may collect and analyse your Personal Information and combine all the information that we have about you for research and statistical purposes. We may also use your Personal Information to personalise and tailor our services to meet your needs;
      5. once CDE has collected and analysed your Personal Information, CDE may send you promotional material or details which we think may be of interest to you;
      6. to understand general customer trends and patterns so we can develop and support existing and ongoing marketing strategies for our products and services;
      7. to conduct academic research. This research is conducted to evaluate and improve CDE’s product offerings. You are advised that information may be shared with third parties such as academics, medical funders and researchers. All information collected for research purposes will be kept strictly confidential and all data will be depersonalised.  No Personal Information will be made available to a third party without your written consent given in terms of this Privacy Policy.  If we publish the results of this research, you will not be identified by name.
      8.  to administer, maintain and secure the Sites;
      9. aiding CDE in fulfilling any contractual obligations which we may to you or any third party;and/or
      10. enabling us to comply with any obligations imposed on us by law, code of conduct or any other legal or regulatory requirement.
    2. You accept that we may store your Personal Information outside of the region or country that you may submit or use it in.

  7. How we share your Personal Information
    1. Your privacy is important to us and we will therefore not sell, rent or provide your Personal Information to unauthorised third parties for their independent use, without your consent. If at any stage after you have given CDE your consent you no longer wish CDE to use or share your Personal Information, you may at any stage withdraw your consent.
    2. For purposes of providing you with the benefit and use of the CDE Sites, products and services, we may share your Personal Information with or to third parties as follows:
      1. We may share your Personal Information with companies that form part of the same group of companies as us. These companies will be bound by this Policy and will handle your Personal Information in accordance with this Policy;
      2. We may share your Personal Information with our employees, contractors or agents for purposes of and to the extent necessary to provide you with the CDE products and services and to fulfil the purposes set out in clause 6;
      3. We may share your information with our partners or other third party suppliers that we have partnered with in order to provide you with the services and products requested by you through the CDE Sites. Where Personal Information is shared with partners, such information will not be used for any other purpose other than to carry out the services they are performing for and on our behalf. We have entered into written agreements with all third parties that are authorised to process you information on our behalf, in terms of which the security and confidentiality of you information is protected;
      4. CDE may enter into arrangements with its partners or other third party suppliers which will require us to disclose your Personal Information to these third parties for the purpose of transferring data to us from a device(s) that measures bodily functions or fluids. You hereby consent to CDE disclosing your Personal Information to these third parties for this purpose and you also consent to receiving data about yourself from these third parties. If at any time after you have given CDE your consent you no longer wish to disclose your Personal Information to these third parties, you may at any time withdraw your consent;
      5. There may be instances where you have the option to share your Personal Information with CDE and Linked Sites (as set out in the Terms). If you elect to share your Personal Information in this manner, we will share your Personal Information with Linked Sites;
      6. We may share your Personal Information where it is necessary in order to enforce or apply this Policy, the Terms or any other contract between us, as well as where it is necessary to protect out rights, property or safety of that of our customers, employees, contractors, agents or any third party, or to limit any actual or reasonably perceived risk to us or any such parties;
      7. We may share your Personal Information in accordance with our Cookie policy set out in clause 5;
      8. We will share your Personal Information where required to do so by law, or in response to any law enforcement action, subpoena or warrant; and
      9. We may share your Personal Information with any successor or proposed successor of our business or any entity that acquires control or ownership of CDE or any of our group of companies. We may also share your Personal Information with any third party whose business, assets or shares we acquire or propose to acquire.
    3. CDE is not responsible for any representations or information or warranties or content on any third party website (including third party websites linked to this Site, Sites facilitated by us or Sites that serve as Social Media Networks like Facebook or Twitter). CDE does not exercise control over the privacy policies of these third parties and you should refer to the privacy policy of these third parties to see how they protect your privacy.

  8. Protection of your Personal Information
    1. CDE values the information that you choose to provide and will take reasonable steps to protect your Personal Information from loss, misuse or unauthorised alteration. The information CDE has concerning CDE’s clients is stored in databases that have built-in safeguards to ensure the privacy and confidentiality of that information.
    2. When you use the products, services, facilities, tools or utilities provided by CDE on the CDE Website, you may be given or required to provide an access number, user name, password and/or personal identification number (PIN). You must always keep your user name, access card, password and/or PIN a secret and ensure that you do not disclose it to anyone.

  9. Your rights
    1. Nothing contained in this Policy shall be interpreted or construed as a waiver, restriction, limitation or deprivation of your rights in terms of the POPI Act.  In particular, you have the right at any time to object to what you believe to be the unlawful processing of your Personal Information.
    2. You may at any time withdraw your consent to the processing of your information in terms of this Policy and request us to cease such processing and delete all records of your Personal Information.   You can do so by contacting us atsiphiwel@cdediabetes.co.za and +27 11 053 4400.  You can also click the “Unsubscribe” link contained in all emails that you have consented to receive from us, which will automatically unsubscribe you from such service.
    3. You may request us at any time to correct, destroy or delete any of your Personal Information that may be in our possession or under our control where such information is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or unlawfully obtained. Any such deletion may impact on your ability to utilise the full functionality of the Sites and any other services and products.
    4. You have the right to object to the processing of your Personal Information on reasonable grounds relating to your particular situation, unless processing is required by law.
    5. You have the right to submit a compliant to the Information Regulator regarding an alleged interference with the protection of personal information in accordance with this Policy.  The Information Regulator’s contact details will be published by the Government in due course in terms of POPI.

  10. Accuracy and Correction of Personal Information
    1. We will take all reasonable practicable steps to ensure your Personal Information is complete, accurate and not misleading. In order to do this, you may from time to time be requested to confirm that the Personal Information we have collected about you is up to date and correct.
    2. Please notify us of any updates or correctionsto your Personal Information held by CDE, by contacting us at siphiwel@cdediabetes.co.za or +27 11 053 4400.

  11. Access to Information
    1. We will at all times and to the fullest extent possible provide you with online access to your information and profile.
    2. You have the right at any time to request us:
      1. to confirm, free of charge, whether we hold any of your Personal Information;
      2. to provide you with a record or description of any of your Personal Information that is held by us;
      3. to provide information about the identities of all third parties, or categories of third parties, who have or have had access to your Personal Information.
    3. You may be required to pay a fee (or part deposit) in order to enable us to respond to any request made in terms of clause 11.2.  If so, we will provide you with a written estimate of the fee before proceeding with the disclosure.

  12. Retention
    1. We will retain your Personal Information only for as long as is necessary in order to fulfil the purpose for which it was collected. In general, and unless otherwise determined, we do not consider it necessary to retain your Personal Information for a period of more than six years from the date on which you last accessed the Website or provided your Personal Information through any other format other than via the Website.
    2. We may retain some or all of your Personal Information beyond the time period contemplated in clause 12.1, where:
      1. you explicitly consent to the further retention of such information;
      2. we reasonably require such information to be retained for lawful purposes related to our business functions or activities;
      3. such information is necessary to be retained for historical, statistical or research purposes;
      4. we are required by law to retain such information (for example, we are required in terms of the Consumer Protection Act 2008 to retain all information relating to promotional competitions for a period of three years);
      5. we are required to retain such information for evidentiary purposes;  or
      6. we are required to retain such information by virtue of a contract entered into between us.
    3. Any information retained pursuant to clause 12.2shall be retained only for so long as is required to fulfil the purposes for which it was retained for any additional period.
    4. Upon us no longer being entitled to retain it, we will delete, destroy or de-identify all of your Personal Information held by us.

  13. Security
    1. CDE cannot guarantee the security of your information in the course of its transmission from you to us online and you agree that you do this at your own risk. We will however take all appropriate, reasonable technical and organisational measures to ensure the security, integrity and confidentiality of the Personal Information collected and stored by us.  These measures are aimed at preventing:
      1. loss of, damage to or unauthorised destruction of your Personal Information;  and
      2. unlawful access to or processing of your Personal Information.
    2. Subject to certain exceptions provided for in terms of the law, we will notify you as soon as reasonably possible after becoming aware that your Personal Information has been unlawfully disclosed, accessed, acquired or otherwise compromised.
    3. You accept that you are responsible for keeping your account login information (including your username and password) and the security for your mobile device (in the form of a device auto-lock feature, pin access control etc) secure and confidential.   Should you become aware that your account password has or may have become compromised, it is your responsibility to immediately change your password.

  14. Direct marketing
    1. By providing your name and email address in connection with any optin, newsletter, login or any other call to action on any of the CDE Sites, you consent to the use of your Personal Information for purposes of direct marketing of our products and services, and on behalf of our affiliates and other selected third parties.
    2. You are entitled to request that we desist from using our Personal Information for the purposes of direct marketing, and we will provide you with the necessary functionality for you to do so with ease, each time we market to you.
    3. Should you make a request in terms of clause 14.2, we will immediately desist from sending you any direct marketing communications, although we may send you written or electronic confirmation before doing so.

  15. Children
    1. This Website is accessible to children under the age of 18.
    2. We require children to consult with their parents before providing Personal Information. We also encourage parents to supervise their children’s online activities by, for example, adopting parental control tools available from online services and software manufacturers that help provide a child-friendly online environment. These tools can also prevent children from disclosing online their name, address, and other Personal Information without parental permission.
    3. We encourage parents to talk to their children about the use of the Internet and information they disclose to websites.

  16. Changes to this Privacy Policy
    1. CDE may amend this privacy policy from time to time. You are therefore encouraged to review the Policy at the inception of each visit to any of the CDE Sites and/or each time you provide your information to CDE in any other format other than via the CDE Sites.
    2. The latest version of the Policy will always be displayed on the CDE Website. A copy of the Policy can be obtained from our offices. You can also request a copy by emailing us at [siphiwel@cdediabetes.co.za] or calling [+27 11 053 4400].
    3. The current version of this privacy policy will govern the respective rights and obligations between you and CDE each time that you access and use the CDE Website.

  17. Which laws apply to this Privacy Policy
    This privacy policy is governed by the laws of the Republic of South Africa, and you consent to the jurisdiction of the South African courts in respect of any dispute which may arise out of or in connection with the formation, interpretation, substance or application of this privacy policy.

  18. Contacting US
    1. Please direct any queries, comments or about this Privacy Policy, or any requests that you are entitled to make in terms of either this Policy or the POPI Act to siphiwel@cdediabetes.co.za and +27 11 053 4400.
    2. Please note that we may reject requests that are vexatious or frivolous, that require disproportionate technical effort or impracticality to address, or that would risk or infringe the privacy of others.