Privacy Policy

NUWKEM HYGIENE SERVICE PROVIDERS CC

STANDARD WEBSITE PRIVACY & COOKIES POLICY

The Protection of Personal Information Act, 2013 (“POPIA”) came into full effect on 1 July 2021. As a responsible service provider within the hygiene, sanitation, pest control, and consumable supply industry, Nuwkem Service Providers CC acknowledges its legal obligations under POPIA and takes the protection of your personal information seriously. Safeguarding your privacy, ensuring confidentiality, and maintaining the integrity of your personal information is a high priority for us.

This document serves both as our Privacy Policy and as a formal notification to you, the Data Subject, as contemplated in section 18 of POPIA. Accordingly, this document explains:

What categories of personal information we collect in the course of delivering hygiene services, pest control solutions, equipment rentals, and consumable products;
Why we collect your personal information;
How we use, store, safeguard, and disclose your personal information;
What safety and technical security measures are implemented to protect your information throughout our operational processes.

Where we refer to “process” or “processing,” this includes any activity relating to the collection, receipt, storage, use, disclosure, destruction, updating, or management of your personal information, whether by electronic, manual, or automated means.

As a general principle, we will only process your personal information if it is necessary to provide or deliver our products, services, rental equipment, pest control treatments, hygiene solutions, or to comply with applicable legislation.

In certain instances, we may combine personal information collected across our various services and platforms and use the combined information for any of the purposes detailed in this Privacy Policy.

For purposes of this document, references to “we,” “us,” or “our” refer to Nuwkem Service Providers CC, its authorised representatives, and subsidiaries engaged in the delivery of hygiene, pest control, consumable supply, and related business activities.

By using our website, purchasing our products, entering into a service agreement, or making use of our hygiene, pest control, or consumable services, you confirm that you have read, understood, and agreed to the processing of your personal information as explained in this Privacy Policy.

We reserve the right to update or amend this Privacy Policy as required by changes to the law, regulatory guidelines, or Nuwkem’s operational practices. The latest version of this Privacy Policy, as published on our website https://www.nuwkem.co.za, will apply at the time of your interaction with us.

WHAT IS PERSONAL INFORMATION?

Personal information refers to any information that identifies you as an individual or relates specifically to you. In the context of Nuwkem Service Providers CC’s hygiene, sanitation, pest control, and consumable product operations, personal information includes, but is not limited to, the following types of information that may be collected, processed, or stored during our engagements with clients, employees, suppliers, and other stakeholders.

Table of Personal Information Collected, Processed, or Stored by Nuwkem Service Providers CC:

Age	Financial history	Personal views
Belief	Gender	Physical address
Birth	Identity number	Physical health
Biometric	Language	Pregnancy
Colour	Location information	Race
Conscience	Marital Status	Religion
Correspondence	Mental Health	Sex
Criminal history	Medical History	Sexual orientation
Culture	Name	Social origin
Disability	National Origin	Symbol
Education	Online identifier	Telephone number
E-mail address	Other particular assignment	Well being
Employment history	Personal opinions
Ethnic origin	Personal preferences

In certain instances, especially where legally required, Nuwkem may collect and process information relating to sensitive categories of personal information to support service delivery, employee administration, health and safety requirements, pest control compliance, or to fulfil contractual obligations.

This definition aligns with the Protection of Personal Information Act, 2013 (POPIA), and applies to all personal information that Nuwkem Service Providers CC processes during the course of business, whether collected directly from you or obtained through lawful third-party sources.

IS THE SUPPLY OF PERSONAL INFORMATION VOLUNTARY OR MANDATORY?

The supply of certain personal information is mandatory, meaning we have to collect this personal information from you by law. If you do not supply this information, we cannot comply with our legal obligations. In this regard, if you do not supply this personal information we cannot do business with you.

We collect personal information as is required by the following legislation:

Basic Conditions of Employment Act, No. 75 of 1997	Labour Relations Act, No. 66 of 1995
Companies Act, No. 71 of 2008	Long-Term Insurance Act, No. 52 of 1998
National Health and Safety Regulations and Industry-Specific Sectoral Guidelines	National Health and Safety Regulations and Industry-Specific Sectoral Guidelines
Competition Act, No. 89 of 1998	Unemployment Insurance Act, No. 63 of 2001
Consumer Protection Act, No. 68 of 2008	Value Added Tax Act, No. 89 of 1991
Constitution of the Republic of South Africa, No. 108 of 1996	Hazardous Substances Act, No. 15 of 1973
Electronic Communication and Transactions Act, No. 25 of 2002	National Environmental Management Act, No. 107 of 1998
Employment Equity Act, No. 55 of 1998	Health Act, No. 63 of 1977
Income Tax Act, No. 58 of 1962	Standards Act, No. 8 of 2008
Insolvency Act, No. 24 of 1936	Pension Funds Act, No. 24 of 1956
Machinery and Occupational Safety Amendment Act, No. 181 of 1993	Compensation for Occupational Injuries and Diseases Act, No. 130 of 1993
National Payment Systems Act, No. 78 of 1998	Prevention of Organised Crime Act, No. 121 of 1998
Occupational Health and Safety Act, No. 85 of 1993	Promotion of Access to Information Act, No. 2 of 2000
Protection of Personal Information Act, No. 4 of 2013	Short-Term Insurance Act, No. 53 of 1998
Skills Development Levies Act, No. 9 of 1999	Trade Marks Act, No. 194 of 1993

In other instances, the supply of personal information is voluntary, which means there is no law imposed on us to collect this personal information. Even though there is no law that imposes the collection of the personal information, we require the personal information to deliver the products and/or services to you. In this regard, if you do not supply the personal information, we cannot do business with you.

WHEN WILL WE PROCESS YOUR PERSONAL INFORMATION?

Nuwkem Service Providers CC is committed to processing your personal information lawfully, reasonably, and only for purposes aligned to our hygiene services, pest control solutions, consumable product supply, equipment rentals, and related business operations.

We will only process your personal information under the following lawful circumstances:

If you have provided your explicit consent.
If a person legally authorised by you, applicable legislation, or a competent court has provided consent on your behalf.
If it is necessary to conclude, administer, or perform under a contract, agreement, or service arrangement entered into with you, including hygiene service agreements, pest control treatments, equipment rental contracts, or product supply transactions.
If processing is required or permitted by applicable laws, regulations, or industry standards, including health, safety, and environmental compliance.
If it is necessary to protect or pursue your legitimate interests, our legitimate interests as a business, or those of a third party, including but not limited to health and safety, legal obligations, operational requirements, service efficiency, or regulatory compliance.

WHAT IS SPECIAL PERSONAL INFORMATION?

Special personal information is personal information about the following:

Biometric information	Philosophical beliefs	Sex life
Criminal behaviour	Political persuasion	Trade union membership
Ethnic origin	Race
Health	Religious beliefs

WHEN WILL WE PROCESS YOUR SPECIAL PERSONAL INFORMATION?

Nuwkem Service Providers CC recognises the sensitivity of special personal information and will only process such information where legally permitted, strictly necessary, and in full compliance with POPIA.

We may process your special personal information in the following circumstances:

if you have consented to the processing.
if the information is being used for any Human resource or payroll requirement.
if the processing is needed to create, use, or protect a right or obligation in law.
if the processing is for statistical or research purposes and all legal conditions are met.
if the special personal information was made public by you.
if the processing is required by law.
if racial information is processed, and the processing is required to identify you; and / or if health information is processed, and the processing is to determine your insurance risk, or to comply with an insurance policy or to enforce an insurance right or obligation.

At all times, Nuwkem Service Providers CC will implement appropriate safeguards to protect special personal information and ensure its processing is strictly limited to lawful, justifiable, and operational requirements within our hygiene, sanitation, pest control, and consumable supply environment.

WHEN AND FROM WHERE WE OBTAIN PERSONAL INFORMATION ABOUT YOU?

Nuwkem Service Providers CC collects personal information necessary to deliver hygiene services, pest control solutions, washroom rental equipment, and consumable products in a lawful, transparent, and responsible manner.

We may obtain your personal information from the following sources:

Directly from you, whether in person, through our website, during service engagements, or when you complete forms, requests, or applications with us.
From publicly accessible records or official registers.
From platforms or locations where you have deliberately made your information public, such as social media, websites, or public forums.
Based on your use of our products, services, equipment rentals, or service channels, including maintenance records, pest control reports, or consumable supply transactions.
From your engagement with Nuwkem Service Providers CC via our support desk, emails, written correspondence, telephonic communications, or customer satisfaction surveys.
From third parties who are legally entitled to share your personal information with us, provided that lawful conditions are met.
From any other authorised source where you have provided consent for the collection of your personal information.

Where required by law, we will obtain your consent before collecting personal information about you from third parties.

The third parties from whom we may collect your personal information include, but are not limited to:

Authorised partners, suppliers, or contractors of Nuwkem Service Providers CC assisting with service delivery, product supply, pest control, or equipment rentals.
Your spouse, dependents, authorised representatives, employer, or other relevant sources where necessary for service or contract performance.
Attorneys, tracing agents, debt collection specialists, or other persons involved in enforcing contractual rights.
Payment processors, financial institutions, EFT service providers, or banking partners facilitating payment transactions.
Insurers, brokers, or related service providers assisting with insurance underwriting, policy administration, claims assessments, or risk management.
Law enforcement agencies, regulatory bodies, and fraud prevention authorities tasked with detecting and prosecuting unlawful activity.
Government departments, tax authorities (local and international), industry ombudsman, or other regulatory institutions.
Court-appointed trustees, executors, curators, or legally authorised representatives.
Nuwkem’s approved service providers, sub-contractors, courier companies, IT service providers, or other parties involved in product and service delivery.
Courts of law, tribunals, or dispute resolution bodies where required to comply with legal processes.

REASONS WE NEED TO PROCESS YOUR PERSONAL INFORMATION.

Nuwkem Service Providers CC processes your personal information strictly for lawful, legitimate, and business-related purposes necessary to support our hygiene services, pest control treatments, washroom rental equipment, and consumable supply operations.

We will process your personal information for the following purposes:

To provide you with our hygiene, pest control, sanitation, rental equipment, consumable products, and related services.
To market and promote our hygiene solutions, pest control services, product offerings, and rental equipment to you.
To respond to your enquiries, service requests, quotations, or complaints.
To comply with applicable laws, regulatory frameworks, risk management requirements, and industry codes of conduct, including health and safety standards, pest control regulations, environmental obligations, and reporting duties.
To conduct market research, service analysis, and behavioural research to assess your qualifications for our products or services, or to evaluate business risk, including credit or insurance considerations where relevant.
To develop, test, and enhance our hygiene products, pest control solutions, equipment rental services, and operational processes to better serve your needs.
For historical, statistical, and research purposes, including market segmentation and service performance analysis.
To process payment transactions and administer financial documentation related to your accounts, service agreements, or product purchases.
To create, issue, and manage payment instruments or supporting documentation, including payslips for employees or invoices for customers.
To facilitate the safe and efficient delivery of goods, consumables, documentation, equipment, or legally required notices to you.
For security purposes, identity verification, access control, and to confirm the accuracy and completeness of your personal information.
To communicate with you, fulfil your service instructions, and process your requests efficiently.
To conduct customer satisfaction surveys, service quality assessments, and promotional campaigns relevant to your interests.
For insurance underwriting, administration, and claims processing where applicable to Nuwkem Service Providers CC’s operational risks or employee benefits.
To assess, manage, and process insurance claims, policies, or related products necessary for operational or compliance purposes.
To offer, administer, or manage any insurance products, policies, or related services linked to our business operations or required under contracts.
To enable your participation in loyalty programmes, promotional offerings, or value-added services, where applicable, including monitoring service usage to allocate rewards, assess eligibility, or inform you of relevant product or service offerings.
To assess financial, operational, lending, or insurance risks related to the delivery of our products, services, or contractual obligations.
For any other lawful, related, or operational purpose necessary to support Nuwkem Service Providers CC’s business functions, service excellence, and legal compliance.

HOW WE USE YOUR PERSONAL INFORMATION FOR MARKETING.

Nuwkem Service Providers CC may use your personal information to market and promote our hygiene services, pest control treatments, consumable products, washroom rental equipment, and related offerings, strictly in line with Section 69 of the Protection of Personal Information Act, 2013 (POPIA) and the latest guidance from the Information Regulator.

We may market to you using the following communication channels:

In person, during consultations, service visits, or product demonstrations
By post or courier
By telephone, including mobile calls or VoIP systems
By electronic communications, including SMS, email, fax, push notifications, and private messages via social media platforms

ELECTRONIC DIRECT MARKETING TO NON-CUSTOMERS.

If you are not an existing customer, we may contact you only once to obtain your consent for future marketing using a legally prescribed or substantially similar consent form (Form 4). No further electronic marketing will follow unless you provide your clear, voluntary, and explicit consent for specific products, services, and communication channels.

MARKETING TO EXISTING CUSTOMERS.

If you are an existing customer of Nuwkem Service Providers CC, we may market similar products or services to you using your existing contact details, provided that:

We obtained your details during a sale, service engagement, or agreement
You were given a clear, free opportunity to opt out at the time of collection and in every subsequent communication
You have not objected to receiving such marketing

SOCIAL MEDIA MARKETING.

Unsolicited direct marketing via social media platforms (such as private messages) is treated as electronic communication under POPIA and will only occur where lawful consent has been obtained, or where you are an existing customer, and legal requirements are met.

THIRD-PARTY MARKETING.

We will not share your personal information with third-party marketing partners without your explicit consent, unless permitted by law for service delivery or contractual purposes.

RIGHT TO OBJECT OR WITHDRAW CONSENT.

You may object to receiving any marketing from us or withdraw your consent at any time, free of charge. You can do this by:

Using the “unsubscribe” link or opt-out instructions provided in each marketing communication
Contacting us directly via telephone or email

Once you object or withdraw your consent, we will promptly update our records and place your details on our suppression list to ensure no further marketing is sent to you.

RECORD-KEEPING.

We maintain records of all marketing consents, objections, opt-outs, and suppression requests in compliance with POPIA and legal prescription periods.

REGULATORY COMPLIANCE.

Our marketing practices are fully aligned with POPIA, Section 69, and the Information Regulator’s guidance. We continuously monitor legal developments to ensure our marketing remains lawful, responsible, and respectful of your privacy rights.

WHEN HOW AND WITH WHOM WE SHARE YOUR PERSONAL INFORMATION?

In general, we will only share your personal information if any one or more of the following apply:

if you have consented to this.
if it is necessary to conclude or perform under a contract, we have with you;
if the law requires it; and / or
if it’s necessary to protect or pursue your, our or a third party’s legitimate interest.

Under what circumstances will we transfer your information to other countries?

We will only transfer your personal information to third parties in another country in any one or more of the following circumstances:

where your personal information will be adequately protected under the other country’s laws or an agreement with the third-party recipient.
where the transfer is necessary to enter into or perform under a contract with you, or a contract with a third party that is in your interest.
where you have consented to the transfer; and / or
where it is not reasonably practical to obtain your consent, the transfer is in your interest.

This transfer will happen within the requirements and safeguards of the law. Where possible, the party processing your personal information in the other country will agree to apply the same level of protection as available by law in your country or if the other country’s laws provide better protection the other country’s laws would be agreed to and applied.

HOW WE SECURE YOUR PERSONAL INFORMATION.

We will take appropriate and reasonable technical and organisational steps to protect your personal information according to industry best practices. Our security measures (including physical, technological, and procedural safeguards) will be appropriate and reasonable.

This includes the following:

keeping our systems secure (like monitoring access and usage);
storing our records securely.
controlling the access to our buildings, systems and/or records; and
safely destroying or deleting records.
Ensure compliance with best practice standards.

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

We will keep your personal information for as long as:

the law requires us to keep it.
a contract between you and us requires us to keep it.
you have consented for us keeping it.
we are required to keep it to achieve the purposes listed in this Privacy Policy.
we require it for statistical or research purposes.
a code of conduct requires us to keep it; and / or
we require it for our lawful business purposes.

Take note: We may keep your personal information even if you no longer have a relationship with us, for the historical data that may be required by your employer or employee.

OUR COOKIE POLICY.

A cookie is a small piece of data sent from our websites or applications to your computer or device hard drive or Internet browser where it is saved. The cookie contains information to personalise your experience on our websites or applications and may improve your experience on the websites or applications. The cookie will also identify your device, like the computer or smart phone.

By using our websites or applications you agree that cookies may be forwarded from the relevant website or application to your computer or device. The cookie will enable us to know that you have visited the website or application before and will identify you. We may also use the cookie to prevent fraud and for analytics.

Your duties and rights about the personal information we have about you.
You must provide proof of identity when enforcing the rights below.
You must inform us when your personal information changes.

Please contact our Information Officer to give effect to any of the below rights.

You have the right to request access to the personal information we have about you by contacting us. This includes requesting:

confirmation that we hold your personal information.
a copy or description of the record containing your personal information; and
the identity or categories of third parties who have had access to your personal information.

We will attend to requests for access to personal information within a reasonable time. You may be required to pay a reasonable fee to receive copies or descriptions of records, or information about third parties. We will inform you of the fee before attending to your request.

Please note that the law may limit your right to access information.

You have the right to request us to correct or delete the personal information we have about you if it is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, obtained unlawfully or we are no longer authorised to keep it. You must inform us of your request in writing. It may take up to 15 business days for the change to reflect on our systems. We may request documents from you to verify the change in personal information.

A specific agreement that you have entered into with us may determine how you must change your personal information provided at the time when you entered into the specific agreement. Please adhere to these requirements. If the law requires us to keep the personal information, it will not be deleted upon your request. The deletion of certain personal information may lead to the termination of your business relationship with us.

You may object on reasonable grounds to the processing of your personal information.

We will not be able to give effect to your objection if the processing of your personal information was and is permitted by law; you have provided consent to the processing and our processing done according to your consent or the processing is necessary to conclude or perform under a contract with you.

Where you have provided your consent for the processing of your personal information, you may withdraw your consent. If you withdraw your consent, we will explain the consequences to you. We may proceed to process your personal information even if you have withdrawn your consent if the law permits or requires it. It may take up to 15 business days for the change to reflect on our systems, during this time we may still process your personal information. You must inform us of any objection in writing.

You have a right to file a complaint with us or any Regulator with jurisdiction about an alleged contravention of the protection of your personal information by us. We will address your complaint as far as possible.

The contact details for the Information Regulator is as follows:

Postal Address:	P O Box 31533, Braamfontein, Johannesburg, 2017
Telephone:	+27 (10) 023-5200
Website:	https://inforegulator.org.za/
Email:	POPIAComplaints@inforegulator.org.za

HOW CAN YOU GET IN TOUCH WITH US?

For any queries in relation to this letter or our processing of your persona information in general, you can contact our Information Officer and/or Deputy Information Officer at the following details:

Business Name	Nuwkem Service Providers (PTY) Ltd.
Registration Number	2024/265033/07
Registered Office	497 Pinnacle Road, Tunney Ridge, Germiston, Johannesburg 1401
Postal Address	497 Pinnacle Road, Tunney Ridge, Germiston, Johannesburg 1401
Contact Number	011 455 6307
Information Officer	Veronica Vivienne Vivier
Deputy Information Officer/s	Cindie Watson Neethie Chetty
Email address/es	admin@nuwkem.co.za