At Clickpatrol, we recognize the importance of privacy and the protection of personal data. With the enforcement of South Africa’s Protection of Personal Information Act (POPIA), effective 1 July 2021, we are dedicated to ensuring that all personal information processed within our systems constitutes a lawful, transparent, and secure activity.

This statement outlines our commitment to the rights and principles enshrined in POPIA and explains how we handle data relevant to South African citizens and entities.

1. Our Role: Responsible Party vs. Operator

Under POPIA, it is crucial to distinguish between the two primary roles regarding data processing. Clickpatrol operates in two capacities depending on the context:

As a Responsible Party: When you sign up for a Clickpatrol account, subscribe to our newsletter, or request support, we act as the Responsible Party. We determine the purpose and means of processing your account data (e.g., your name, business email, billing details).
As an Operator: When you use the Clickpatrol software to monitor traffic, detect fraud, or analyze clicks on your campaigns, we act as an Operator. We process data (such as IP addresses and device fingerprints of your site visitors) on your behalf. In this instance, you (the Client) remain the Responsible Party, and we execute processing based on your mandate.

2. What Personal Information Do We Collect?

“Personal Information” under POPIA is broad. Clickpatrol limits collection to what is strictly necessary for our services to function effectively (“Minimality”).

Client Account Data: Company name, registration number, contact person details, email addresses, and payment information.
Traffic & Analysis Data: To provide our fraud protection services, we may process end-user data including IP addresses, User-Agent strings, geolocation data, and device identifiers.

3. Purpose of Processing

We process personal information based on the following legal grounds provided in POPIA:

Contractual Obligation: To provide the Clickpatrol services you have signed up for (e.g., filtering bot traffic).
Legitimate Interest: To protect our clients and the digital ecosystem from ad fraud and malicious activity.
Consent: Where applicable, for marketing communications (which you can opt out of at any time).

4. Security Measures (Condition 7)

POPIA requires that we take appropriate, reasonable technical and organizational measures to prevent loss of, damage to, or unauthorized destruction of personal information. Clickpatrol employs:

Encryption: Data is encrypted in transit (TLS/SSL) and at rest where applicable.
Access Control: Strict authentication protocols ensure only authorized personnel have access to data.
Regular Audits: We adhere to industry-standard security practices to identify and mitigate risks.

5. Cross-Border Data Transfer

Clickpatrol is a global service. If we store or process data outside of South Africa, we ensure that the destination country adheres to data privacy laws that are substantially similar to POPIA (such as the GDPR in Europe), or that we have binding corporate rules/agreements in place to uphold the protection of your data.

6. Rights of Data Subjects

Under POPIA, South African data subjects have the right to:

Notification: Know when their data is being collected.
Access: Request a record of the personal information we hold about them.
Correction: Request the correction or deletion of inaccurate, irrelevant, or unlawfully retained data.
Objection: Object to the processing of personal information on reasonable grounds.

7. Information Officer Contact

If you have questions regarding this statement, or if you wish to exercise your rights under POPIA, please contact our Information Officer.

- Email: hello@clickpatrol.com
- Address: Physical Address

This document outlines Clickpatrol’s approach to POPIA compliance. It is provided for informational purposes and does not constitute legal advice. Clients are encouraged to consult with their own legal counsel regarding their specific obligations as a Responsible Party under POPIA.

Protection of Personal Information Act (POPIA) Compliance