Privacy Policy

Grey Collective Inc. (“Grey Collective”, “we”, “us”, or “our”) is committed to protecting the privacy, confidentiality and security of all personal information entrusted to us.

This Privacy Policy explains how we collect, use, process, store, disclose, transfer and protect personal information when you access our website, engage our services, submit enquiries, communicate with us, or otherwise interact with Grey Collective.

Grey Collective Inc. is an international website design and digital development company operating from the Republic of South Africa and providing services to clients worldwide. We recognise that privacy is a fundamental right and are committed to processing personal information lawfully, fairly, transparently and securely.

This Privacy Policy has been prepared with reference to applicable privacy and data protection legislation, including but not limited to:

• The Protection of Personal Information Act, 2013 (Act No. 4 of 2013) (“POPIA”);
• The General Data Protection Regulation (EU) 2016/679 (“GDPR”);
• The United Kingdom General Data Protection Regulation (“UK GDPR”);
• Any other applicable privacy or data protection legislation governing the processing of personal information.

Where local laws provide additional rights or protections, those rights shall apply to the extent required by applicable law.

This Privacy Policy applies to all individuals and organisations who access or interact with Grey Collective, including but not limited to:

• Visitors to our Website;
• Prospective clients;
• Existing clients;
• Business representatives;
• Contractors;
• Suppliers;
• Service providers;
• Job applicants;
• Any individual who communicates or transacts with Grey Collective.

This Privacy Policy applies to all interactions with Grey Collective, including but not limited to:

• Our Website;
• Project enquiry forms;
• Contact forms;
• Email communications;
• Telephone communications;
• WhatsApp communications initiated by users;
• Online consultations;
• Website design and development services;
• Branding services;
• Digital marketing services;
• Search engine optimisation services;
• Website maintenance services;
• Hosting-related services where applicable;
• Any additional products or services offered by Grey Collective.

This Privacy Policy applies regardless of the country from which you access our Website or use our Services.

For the purposes of this Privacy Policy:

“Personal Information” means any information relating to an identified or identifiable natural person or juristic person as defined by applicable privacy legislation.

“Processing” means any operation performed on Personal Information, including collection, recording, organisation, storage, updating, retrieval, consultation, use, disclosure, transmission, distribution, restriction, deletion or destruction.

“Website” means every webpage, domain, subdomain, application or digital platform owned, operated or controlled by Grey Collective.

“Services” means all products and professional services provided by Grey Collective.

“User” means any person accessing or using the Website.

“Client” means any person or organisation engaging Grey Collective to provide Services.

Grey Collective Inc. shall appoint an Information Officer in accordance with applicable South African legislation.

Privacy-related enquiries may be directed to:

Grey Collective Inc.

Email: greycollectiveinc@gmail.com

Country of Operation: Republic of South Africa

Should the contact details of the Information Officer change, this Privacy Policy will be updated accordingly.

By accessing the Website, submitting an enquiry, completing a project brief, requesting information, communicating with Grey Collective or making use of our Services, you acknowledge that you have read and understood this Privacy Policy.

Where your consent is required under applicable law, you expressly consent to the processing of your Personal Information in accordance with this Privacy Policy.

Where consent is not the legal basis relied upon, Grey Collective shall process Personal Information only where another lawful basis exists under applicable legislation.

Nothing contained in this Privacy Policy limits any statutory rights available to you under applicable privacy or data protection legislation.

Grey Collective reserves the right to amend, revise or replace this Privacy Policy at any time to reflect changes in applicable legislation, business operations, technologies or regulatory requirements.

Any revised version of this Privacy Policy shall become effective upon publication on the Website unless otherwise required by applicable law.

Where legally required, Grey Collective shall obtain any additional consent before implementing material changes affecting the processing of Personal Information.

Grey Collective may collect and process the following categories of Personal Information where reasonably necessary for the provision of our Services, the operation of our Website, compliance with legal obligations, or the protection of our legitimate business interests.

The Personal Information we collect may include, but is not limited to:

7.1 Identification Information

• Full name;
• Business name;
• Trading name;
• Company registration details where applicable;
• Job title or position.

7.2 Contact Information

• Email address;
• Telephone number;
• Mobile number;
• WhatsApp number;
• Business address;
• Billing address;
• Postal address.

7.3 Business Information

Where applicable, we may collect information relating to your business, including:

• Industry sector;
• Products or services offered;
• Existing website information;
• Google Business Profile link;
• Social media profiles;
• Business branding;
• Business objectives;
• Website requirements;
• Project specifications;
• Brand assets supplied to us.

7.4 Project Information

Where you submit a project enquiry or engage Grey Collective, we may collect:

• Project requirements;
• Design preferences;
• Functionality requirements;
• Technical requirements;
• Website references;
• Competitor information;
• Uploaded files;
• Images;
• Logos;
• Brand guidelines;
• Documents;
• Written instructions;
• Communications relating to the project.

7.5 Technical Information

When you access our Website, certain technical information may automatically be collected, including:

• IP address;
• Browser type;
• Browser version;
• Operating system;
• Device type;
• Screen resolution;
• Language preferences;
• Time zone;
• Referring website;
• Pages visited;
• Date and time of access;
• Session information;
• Clickstream data;
• Website usage statistics.

7.6 Cookies and Similar Technologies

Grey Collective may use cookies and similar technologies to:

• Operate the Website;
• Improve Website performance;
• Remember user preferences;
• Measure Website performance;
• Enhance user experience;
• Maintain security.

Further information is contained in our Cookie Policy.

7.7 Communications

We may retain records of communications between you and Grey Collective, including communications made through:

• Email;
• Contact forms;
• Project enquiry forms;
• WhatsApp;
• Telephone calls;
• Online meetings;
• Live chat where available.

7.8 Payment Information

Where applicable, we may collect information required to process payments, including:

• Billing information;
• Invoice information;
• Payment references;
• Transaction history.

Grey Collective does not intentionally store full payment card details unless required for a legitimate business purpose and permitted by applicable law. Payment processing may be performed by authorised third-party payment providers.

7.9 Information You Voluntarily Provide

You may voluntarily provide additional Personal Information when:

• Completing forms;
• Requesting quotations;
• Requesting consultations;
• Applying for employment;
• Providing project feedback;
• Uploading documents or files;
• Communicating with Grey Collective.

7.10 Special Personal Information

Grey Collective does not intentionally collect or process Special Personal Information unless:

• Required by law;
• Necessary for the provision of our Services;
• You have provided explicit consent;
• Another lawful basis exists under applicable legislation.

7.11 Children’s Information

Grey Collective does not knowingly collect Personal Information from individuals under the age required by applicable law without appropriate parental or legal guardian consent.

If we become aware that Personal Information has been collected from a child without lawful authority, we will take reasonable steps to delete such information as soon as reasonably practicable.

7.12 Accuracy of Information

You warrant that all Personal Information provided to Grey Collective is accurate, complete and up to date.

You agree to notify Grey Collective promptly of any changes to your Personal Information to ensure our records remain accurate.

Grey Collective collects Personal Information through lawful and transparent means. Depending on how you interact with us, Personal Information may be collected directly from you, automatically through technology, or from authorised third parties.

We may collect Personal Information through the following methods:

8.1 Information You Provide Directly

We collect Personal Information that you voluntarily provide when you:

• Visit our Website;
• Complete a project enquiry form;
• Submit a contact form;
• Request a quotation;
• Request a consultation;
• Contact us by email;
• Contact us via WhatsApp;
• Communicate by telephone;
• Subscribe to updates where available;
• Submit documents, files, images or other project materials;
• Engage Grey Collective to provide Services.

8.2 Website Usage

When you access our Website, certain information may be collected automatically through your browser or device, including technical information, device information and Website interaction data.

This information assists us in maintaining Website security, improving performance and understanding how our Website is used.

8.3 Cookies and Similar Technologies

Grey Collective may use cookies, pixels, local storage, scripts and similar technologies to improve the functionality, security and performance of the Website.

Where required by applicable law, your consent will be obtained before non-essential cookies are placed on your device.

You may refuse or disable cookies through your browser settings; however, certain Website features may not function correctly as a result.

Further information is available in our Cookie Policy.

8.4 Analytics

Where analytics technologies are used, Grey Collective may collect aggregated and anonymised information relating to Website usage, including visitor behaviour, traffic patterns and Website performance.

Where required by applicable law, analytics technologies will only be activated following your consent.

8.5 Communications

Personal Information may be collected whenever you communicate with Grey Collective, including through:

• Email;
• Telephone;
• WhatsApp;
• Website enquiry forms;
• Project briefing forms;
• Online meetings;
• Customer support communications;
• Future communication channels introduced by Grey Collective.

Such communications may be retained where reasonably necessary for record-keeping, quality assurance, dispute resolution, legal compliance or the provision of our Services.

8.6 Third Parties

Grey Collective may receive Personal Information from third parties where:

• You have authorised the disclosure;
• The information is publicly available;
• Another lawful basis exists under applicable legislation;
• Disclosure is necessary for the provision of our Services.

Such third parties may include:

• Search engines;
• Business directories;
• Google Business Profiles;
• Payment providers;
• Hosting providers;
• Professional advisers;
• Technology providers;
• Public corporate records;
• Service providers engaged by Grey Collective.

8.7 Social Media and External Platforms

Where you interact with Grey Collective through third-party platforms or social media services, we may receive information that you choose to make available in accordance with the privacy settings and policies of those platforms.

Grey Collective has no control over the privacy practices of third-party platforms and encourages users to review their respective privacy policies.

8.8 Accuracy of Information

Grey Collective relies on the accuracy of the information provided to us.

You are responsible for ensuring that all Personal Information submitted to Grey Collective remains accurate, complete and up to date.

Where inaccurate or outdated information is identified, Grey Collective reserves the right to request updated information before continuing to provide Services.

Grey Collective processes Personal Information only where there is a lawful basis to do so and only to the extent reasonably necessary for the operation of our business, the provision of our Services, compliance with applicable legal obligations, or the protection of legitimate business interests.

Personal Information may be processed for the following purposes:

9.1 Provision of Services

To:

• Provide our Services;
• Prepare quotations;
• Manage enquiries;
• Conduct consultations;
• Plan and deliver projects;
• Develop, maintain and support websites;
• Deliver digital products and services;
• Communicate throughout a project.

9.2 Client Relationship Management

To:

• Respond to enquiries;
• Manage ongoing client relationships;
• Provide customer support;
• Schedule meetings;
• Maintain communication records;
• Improve client experience.

9.3 Website Administration

To:

• Operate the Website;
• Monitor Website functionality;
• Improve Website performance;
• Detect technical issues;
• Prevent abuse;
• Protect Website security;
• Maintain Website availability.

9.4 Business Operations

To:

• Maintain internal business records;
• Manage administration;
• Prepare invoices and quotations;
• Process payments where applicable;
• Maintain financial records;
• Conduct internal reporting;
• Manage projects efficiently.

9.5 Legal and Regulatory Compliance

To:

• Comply with applicable legislation;
• Comply with lawful requests from regulatory authorities;
• Maintain legally required records;
• Exercise or defend legal rights;
• Prevent unlawful activities;
• Investigate suspected fraud or misconduct.

9.6 Security

To:

• Detect unauthorised access;
• Prevent fraud;
• Protect confidential information;
• Protect intellectual property;
• Protect our Website, systems and infrastructure;
• Verify user identity where appropriate.

9.7 Marketing Communications

Where permitted by applicable law, Grey Collective may use Personal Information to:

• Send newsletters;
• Provide business updates;
• Inform clients of new Services;
• Send promotional communications;
• Invite users to events or webinars.

Marketing communications will only be sent where:

• You have provided consent where required; or
• Another lawful basis exists under applicable legislation.

You may opt out of marketing communications at any time.

9.8 Recruitment

Where you apply for employment or submit your curriculum vitae, Grey Collective may process your Personal Information to:

• Assess your application;
• Verify qualifications;
• Contact you regarding employment opportunities;
• Maintain recruitment records.

Submission of an application does not guarantee employment.

9.9 Improvement of Services

Grey Collective may analyse aggregated, anonymised or de-identified information to:

• Improve our Services;
• Improve Website functionality;
• Improve user experience;
• Develop new products or services;
• Conduct business analysis;
• Measure operational performance.

Where information has been anonymised or de-identified, it will no longer be treated as Personal Information to the extent permitted by applicable law.

9.10 Artificial Intelligence and Automation

Grey Collective may utilise artificial intelligence, automation tools and other digital technologies to assist in the provision of certain Services, improve operational efficiency and enhance client experience.

Where Personal Information is processed using such technologies, Grey Collective shall take reasonable steps to ensure that such processing remains lawful, proportionate and subject to appropriate safeguards in accordance with applicable privacy legislation.

Grey Collective does not use automated decision-making that produces legal or similarly significant effects on individuals unless permitted by applicable law or with appropriate safeguards in place.

9.11 No Sale of Personal Information

Grey Collective does not sell, rent, trade or otherwise commercially exploit Personal Information for monetary consideration.

Personal Information will only be disclosed where authorised by this Privacy Policy, required by law, or with the consent of the relevant individual where applicable.

Grey Collective processes Personal Information only where a lawful basis exists under applicable privacy and data protection legislation.

Depending on the circumstances, Personal Information may be processed on one or more of the following lawful bases:

10.1 Consent

Where required by law, Grey Collective will process Personal Information only after obtaining your voluntary, specific, informed and unambiguous consent.

You may withdraw your consent at any time; however, such withdrawal shall not affect the lawfulness of any processing carried out prior to the withdrawal.

Withdrawal of consent may affect Grey Collective’s ability to provide certain Services.

10.2 Performance of a Contract

Grey Collective may process Personal Information where such processing is necessary to:

• Enter into a contract;
• Perform contractual obligations;
• Deliver requested Services;
• Manage projects;
• Process payments;
• Provide customer support;
• Fulfil obligations arising from agreements between Grey Collective and its clients.

10.3 Compliance with Legal Obligations

Grey Collective may process Personal Information where necessary to comply with legal or regulatory obligations, including but not limited to:

• Tax legislation;
• Financial reporting obligations;
• Court orders;
• Regulatory investigations;
• Law enforcement requests;
• Applicable privacy legislation.

10.4 Legitimate Business Interests

Where permitted by applicable law, Grey Collective may process Personal Information where reasonably necessary for its legitimate business interests, provided that such interests are not overridden by your fundamental rights and freedoms.

Legitimate interests may include:

• Operating and improving the Website;
• Preventing fraud;
• Maintaining cybersecurity;
• Protecting confidential information;
• Protecting intellectual property;
• Conducting internal administration;
• Maintaining client relationships;
• Responding to enquiries;
• Improving our Services;
• Business planning;
• Risk management;
• Internal reporting;
• Defending or enforcing legal rights.

10.5 Vital Interests

Grey Collective may process Personal Information where necessary to protect the vital interests of an individual or another natural person where permitted by applicable law.

10.6 Public Interest

Where authorised by applicable legislation, Grey Collective may process Personal Information where necessary for reasons of public interest or where otherwise required by law.

Grey Collective treats Personal Information as confidential and will not sell, rent or trade Personal Information to third parties.

Personal Information may only be disclosed where reasonably necessary for the operation of our business, the provision of our Services, compliance with legal obligations or with your consent where required.

Personal Information may be disclosed to:

11.1 Employees and Contractors

Authorised employees, contractors and consultants of Grey Collective who require access to Personal Information for the proper performance of their duties.

Such persons are subject to confidentiality obligations.

11.2 Technology Service Providers

Grey Collective may engage reputable third-party providers to assist with the operation of our business, including but not limited to:

• Website hosting providers;
• Cloud infrastructure providers;
• Email providers;
• Domain registrars;
• Payment processors;
• Website security providers;
• Analytics providers;
• Customer relationship management systems;
• Communication platforms;
• Productivity software providers;
• Artificial intelligence service providers;
• Technical support providers.

Such providers shall only receive the information reasonably necessary to perform their services.

11.3 Professional Advisers

Grey Collective may disclose Personal Information to:

• Attorneys;
• Accountants;
• Auditors;
• Insurers;
• Financial advisers;
• Regulatory consultants;
• Other professional advisers.

Where such disclosure is reasonably necessary.

11.4 Regulatory Authorities

Grey Collective may disclose Personal Information where required by law or where requested by:

• Courts;
• Law enforcement agencies;
• Regulatory authorities;
• Government departments;
• Supervisory authorities;
• Other competent public bodies.

11.5 Business Transactions

If Grey Collective undergoes a merger, acquisition, restructuring, investment transaction, sale of assets or similar corporate transaction, Personal Information may be transferred as part of that transaction, subject to applicable legal requirements.

11.6 Protection of Rights

Grey Collective may disclose Personal Information where reasonably necessary to:

• Protect legal rights;
• Enforce agreements;
• Investigate fraud;
• Prevent unlawful activity;
• Protect the safety of individuals;
• Protect Grey Collective’s systems, Website or intellectual property;
• Defend legal proceedings.

11.7 Consent

Where required by applicable law, Personal Information will only be disclosed with your prior consent or at your direction.

Grey Collective provides services to clients located in multiple jurisdictions. As a result, Personal Information may be transferred to, stored in, processed in or accessed from countries outside your country of residence, including outside the Republic of South Africa.

Where Personal Information is transferred internationally, Grey Collective shall take reasonable steps to ensure that such transfers are carried out in accordance with applicable privacy and data protection legislation.

Where required by law, Grey Collective will implement appropriate safeguards, including but not limited to:

• Contractual data protection obligations;
• Transfers to jurisdictions recognised as providing an adequate level of protection;
• Technical and organisational safeguards;
• Encryption and security measures;
• Other lawful transfer mechanisms recognised by applicable legislation.

By interacting with Grey Collective or using our Services, you acknowledge that your Personal Information may be transferred internationally where reasonably necessary for the provision of our Services or the operation of our business.

Grey Collective is committed to protecting Personal Information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access or any other unlawful processing.

We implement reasonable technical, physical and organisational security measures appropriate to the nature of the Personal Information processed and the risks associated with such processing.

Such measures may include:

• Encryption where appropriate;
• Secure hosting environments;
• Secure communication protocols;
• Firewalls;
• Access controls;
• Authentication mechanisms;
• Password protection;
• Principle of least privilege access;
• Monitoring and logging;
• Regular software updates;
• Security testing;
• Confidentiality obligations for authorised personnel.

Despite implementing reasonable safeguards, no method of electronic transmission or storage can be guaranteed to be completely secure.

Accordingly, Grey Collective cannot warrant or guarantee the absolute security of any Personal Information transmitted over the internet or stored electronically.

Users transmit information to Grey Collective at their own risk.

Grey Collective retains Personal Information only for as long as reasonably necessary to fulfil the purposes for which it was collected, including:

• Providing Services;
• Managing client relationships;
• Maintaining project records;
• Complying with legal obligations;
• Resolving disputes;
• Enforcing contractual rights;
• Maintaining legitimate business records.

Retention periods may vary depending on:

• The type of Personal Information;
• The nature of the Services provided;
• Applicable legal requirements;
• Regulatory obligations;
• Accounting and taxation requirements;
• Limitation periods applicable to legal claims.

Where Personal Information is no longer required, Grey Collective shall take reasonable steps to securely delete, destroy, anonymise or de-identify such information unless continued retention is required or permitted by law.

Subject to applicable legislation, you may have the right to:

• Request confirmation that Grey Collective processes your Personal Information;
• Request access to your Personal Information;
• Request correction of inaccurate or incomplete Personal Information;
• Request deletion of Personal Information where legally permissible;
• Request restriction of processing;
• Object to certain processing activities;
• Withdraw consent where processing is based on consent;
• Request portability of Personal Information where applicable;
• Lodge a complaint with a competent supervisory authority;
• Exercise any additional rights available under applicable privacy legislation.

Grey Collective reserves the right to verify your identity before responding to any request relating to Personal Information.

Where permitted by law, Grey Collective may refuse or limit requests where such refusal is authorised under applicable legislation.

Requests relating to Personal Information should be submitted in writing to:

Grey Collective Inc.

Email: greycollectiveinc@gmail.com

Grey Collective may require sufficient information to verify your identity before processing any request.

We will respond within the time periods required by applicable law.

Where legally permitted, Grey Collective reserves the right to charge a reasonable administrative fee for requests requiring extensive retrieval, reproduction or administrative processing.

If you believe Grey Collective has processed your Personal Information unlawfully or in a manner inconsistent with this Privacy Policy or applicable legislation, you are encouraged to contact us in the first instance so that we may attempt to resolve the matter promptly.

If the matter cannot be resolved, you may lodge a complaint with the relevant privacy regulator or supervisory authority in your jurisdiction.

For individuals within the Republic of South Africa, complaints may be submitted to:

The Information Regulator (South Africa)

Grey Collective will cooperate with competent regulatory authorities where required by applicable law.

Grey Collective may use cookies and similar technologies to improve the functionality, security, performance and user experience of the Website.

Cookies are small text files stored on your device that enable the Website to recognise your browser or device during future visits.

Cookies may be used for purposes including:

• Maintaining Website functionality;
• Remembering user preferences;
• Improving Website performance;
• Measuring Website usage;
• Enhancing security;
• Preventing fraudulent or malicious activity;
• Supporting essential Website features.

Where required by applicable law, Grey Collective will obtain your consent before placing non-essential cookies on your device.

You may refuse or disable cookies through your browser settings; however, doing so may affect the availability or functionality of certain features of the Website.

Further information regarding cookies is available in our Cookie Policy.

The Website may contain links to third-party websites, platforms, applications or services for your convenience.

Grey Collective does not own, control or accept responsibility for the privacy practices, security measures, content or availability of any third-party websites.

Your use of third-party websites is entirely at your own risk and is subject to the terms and privacy policies of those third parties.

Grey Collective encourages all users to review the privacy policies of any third-party websites they visit.

Grey Collective recognises the confidential nature of information shared by clients during the course of a project.

Subject to applicable law, contractual obligations and this Privacy Policy, Grey Collective shall take reasonable steps to maintain the confidentiality of Personal Information and confidential business information provided by clients.

Nothing contained in this Privacy Policy shall prevent Grey Collective from complying with lawful requests from regulatory authorities, courts or law enforcement agencies where disclosure is legally required.

Grey Collective maintains policies and procedures designed to identify, investigate and respond to actual or suspected personal information security incidents.

Where Grey Collective becomes aware of a personal information breach that is likely to result in a risk to the rights and freedoms of affected individuals, Grey Collective shall take reasonable steps to:

• Investigate the incident;
• Contain the incident where reasonably practicable;
• Mitigate potential harm;
• Notify affected individuals where required by applicable law;
• Notify relevant regulatory authorities where required by applicable legislation;
• Review and improve security measures to reduce the likelihood of future incidents.

This Privacy Policy forms part of the legal documentation governing the use of the Grey Collective Website.

Unless otherwise stated, all intellectual property rights relating to this Privacy Policy and the Website, including text, graphics, branding, logos, designs and other content, are owned by or licensed to Grey Collective.

Nothing contained in this Privacy Policy grants any licence or right to use Grey Collective’s intellectual property without prior written consent.

If any provision of this Privacy Policy is found to be unlawful, invalid or unenforceable by a court or competent authority, that provision shall, to the extent necessary, be severed from this Privacy Policy.

The remaining provisions shall continue in full force and effect.

Failure by Grey Collective to enforce any provision of this Privacy Policy shall not constitute a waiver of any right or remedy available to Grey Collective.

Any waiver shall only be effective if made expressly in writing.

This Privacy Policy shall be governed by and interpreted in accordance with the laws of the Republic of South Africa.

Subject to any mandatory rights afforded under applicable international legislation, any dispute arising out of or relating to this Privacy Policy shall be subject to the jurisdiction of the competent courts of the Republic of South Africa.

Nothing contained herein limits any mandatory rights available to individuals under applicable privacy or consumer protection legislation in their jurisdiction where such rights cannot lawfully be excluded.

For any questions, requests or concerns relating to this Privacy Policy or the processing of Personal Information, please contact:

Grey Collective Inc.

Email: greycollectiveinc@gmail.com

Website: www.greycollective.co

Country of Operation: Republic of South Africa

Grey Collective will endeavour to respond to all legitimate privacy enquiries within a reasonable period and in accordance with applicable law.

This Privacy Policy constitutes the entire privacy policy governing the collection, processing, storage, disclosure and protection of Personal Information by Grey Collective through its Website and Services.

This Privacy Policy should be read together with Grey Collective’s:

• Terms and Conditions;
• Cookie Policy;
• Website Terms of Use;
• Any applicable Service Agreement;
• Any additional legal notices published on the Website.

In the event of any inconsistency between this Privacy Policy and a separate written agreement entered into between Grey Collective and a client, the written agreement shall prevail to the extent of that inconsistency.