We regard the privacy of our users as very important and any personal information which you provide to us will be dealt with in accordance with this Privacy and Cookies Policy.

This Privacy Policy sets out how we use and protect any personal information that you give us when you use this Site. By submitting your details and/or using our Site you accept this Privacy Policy and expressly consent to the use and disclosure of your personal information in a manner described below. If you object to any of the potential uses described in this Privacy Policy, please do not register on our Site.

Changes to this Privacy Policy

We reserve the right, in our sole discretion to amend (including without limitation, by the addition of new terms and conditions) this Privacy Policy from time to time. You agree to review the Privacy Policy whenever you visit the Site for any such amendments. Save as expressly provided to the contrary in this Privacy Policy, the amended version of the Privacy Policy shall supersede and replace all previous versions thereof.

What is personal information?

Personal information is information that identifies or relates specifically to you, for example, your name, age and identity number and your payment records. In short, any information that we know about you will be regarded as your personal information.

What personal information do we collect?

In general, and unless you register with us and create an account, you can use this Site without giving us any personal information. However, we may gather certain (non-personal) information such as records of your activity on the Site without you registering with us and giving us personal information. We also voluntarily subscribe to the principles, outlined in Section 51 of the Electronic Communications and Transactions Act 2002 (‘ECT Act’), which govern your right to having your personal information kept private.

We briefly outline these principles below:

• We will only collect, collate, process and store (‘use’) your personal information with your permission unless legally required to do so, and will only use such information for the lawful purpose for which it is required.

• We will disclose in writing, the specific purpose for which we use, request and store your personal information. We will also keep a record of that personal information and the specific purpose for which we collect it.

• We will not use your personal information for any purpose, other than that which we disclosed to you, unless you give us your express written permission to do so, or unless we are permitted to do so by law. Further to the requirements of the ECT Act; we will disclose your personal information without your consent:

• If we are required to do so by law or a court order;

• If disclosure is in the public interest

 • If disclosure is in our interest;

• With your implied consent. Additional services may be available if we have certain information about you and we will collect certain information from you when you register with us. We may collect and use the following information:

• your name and contact information (including postal address, e-mail address and telephone number) and any other contract details you provide to us;

• financial information including card payment details;

• personal information that you provide when you register and create an account with us;

• information you provide if you report a problem with our Site;

• records of any orders for products and/or services that you place through the Site;

• records of any correspondence when you contact us;

• records of any Retail Box competitions or promotions that you enter; and

• details of your visits to the Site including, but not limited to, traffic data, location data and communication data and the resources that you access.

What do we do with the personal information we collect?

We use your personal information to provide you with a better service, and in particular for the following reasons:

• to facilitate use of the products and services we may provide to you;

• to process and collect payments from you where you purchase products from the Site

• internal record keeping;

• to improve our products and services;

• to improve and personalise your experience when you visit the Site;

• to advertise certain products which we think you might be interested in to you when you visit the Site or other external sites;

• to communicate with you by e-mail, telephone or post if you have ordered or purchased products from us, either regarding the order or purchase or other matters regarding transactions between us or your customer relationship or account (if you have one) with us;

• to contact you regarding any specific enquiry you make;

• statistical analysis;

• to contact you by e-mail, telephone or post in order to share information with you about products, services, promotions and events which we believe may be of interest to you or to request your feedback on our products and services from time to time;

• to carry out direct marketing or e-mail marketing; and • to contact you for market research purposes, if you have not objected to such use.

Whom do we share this information with?

Your personal information will be used for the above purposes by relevant staff in Retail box and by those who support them in their roles. It will also be made available to our authorised service providers who work with us and who perform certain services on our behalf e.g. providing IT support and maintenance, providing customer services, providing hosting services, providing marketing services and providing online payment services. These service providers may have access to personal information needed to perform their functions on our behalf but are not permitted to share or to use such information for any other purpose. Retail Box may also share limited personal information with other companies within the Retail Box group of companies or any affiliates e.g. to the extent needed for proper management and parental analysis and decision making, promotional and marketing opportunities. Retail Box may also disclose your personal information:

• In response to a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise its legal rights; to defend legal claims; or as otherwise required or permitted by applicable laws and/or regulations;

• When Retail Box believes that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding illegal activity, suspected fraud, or other wrongdoing; to protect and defend the rights, property or safety of Retail Box, its customers, staff, suppliers or others; to comply with applicable law or co-operate with law enforcement; or to enforce its terms or other agreements; and

• To prospective or actual buyers in the event that Retail Box sells any of its business or assets. Other than as set out above, we will not transfer, disclose, sell, distribute or lease your personal information to third parties unless we have your permission to do so or are otherwise required or permitted to do so by law.

Direct marketing and your preferences Retail Box and other members of the Retail Box group of companies may wish to provide you with information about new products, promotions, special offers and other which may be of interest to you and invite you to take part in market research.

This communication may occur by post (unless you have asked us not to do so), by telephone, email or SMS. Retail Box will ensure that any direct marketing or market research that you receive or are contacted about by electronic means will provide a simple means for you to refuse further marketing. For example, in emails it may provide you with an ‘unsubscribe’ link, or an email address to which you can send an opt-out request. Retail Box and members of the Retail Box group of companies will stop any marketing to which you object or withdraw your consent to within a reasonable period, in order to allow sufficient time for the change to be administered.

You can change your mind at any time about marketing by informing Retail Box using the contact details set out at the top of this notice. In such cases Retail Box would not necessarily remove all your personal information from its database(s) but would note and respect your changed direct marketing preferences.

How to get copies of or amend the information we have collected

If you believe that any information we have about you is incorrect or incomplete, please write to or e-mail us as soon as possible so that we can correct or update any information as soon as possible. Alternatively, you may correct any inaccuracies in the information you have provided to us by signing in to your online account. Security and storage Please remember that the internet is not a secure medium. Communications over the internet such as e-mails are not secure unless they have been encrypted. We have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. We use industry standard encryption technologies when collecting or transferring customer credit card information exchanged with our Site server – all your card details are passed from your browser to our secure payment gateway using secure sockets layer (SSL) encryption. Our payment gateway provider use secure sockets layer (SSL) encryption system. All other information transferred is conducted through a secure connection. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. All information provided through the Site, telephone, catalogue and in store is stored on servers located in South Africa. It will be processed by staff operating in South Africa who work for our company. Such staff may be engaged in, among other things, the processing of your payment details and the provision of support services. By submitting your personal information, you agree to this transfer, storing or processing. Retail Box will take all steps reasonably necessary to ensure that your personal information is treated securely in accordance with this Privacy Policy.

Cookies

We use cookies for certain areas of our Site, including but not limited to session cookies, third party cookies and persistent cookies. Cookies are files that store information on your hard drive or browser that mean that our Site can recognise that you have visited the Site before and which are used to facilitate access to the Site, to tailor your experience of the Site and to allow you to move through processes including the payment processes on the Site. They make it easier for you to maintain your preferences on the Site (including by renumbering your log in details when you access restricted areas of our Site), and by seeing how you use the Site, we can tailor the Site around your preferences and measure usability of the Site. Your can find out more information about the different types of cookies atwww.allaboutcookies.org. Please refer to the paragraph and link below for further detailed information about the cookies that we use on our Site. The purpose of “cookies” is to enhance your future visits to our Site. You can set your browser to notify you if “cookies” are to be transferred or to reject “cookies” but this may prevent your use of some of our web pages.

We use cookies to:

• place advertisements for our products on other external sites. We do this by allowing third parties including Google and Adserve to place cookies on our Site which allows them to identify your visit to our Site and preferences shown whilst on it, and your visits to subsequent third party websites in their adserving network. This allows us to serve tailored advertisements to you on those third party websites based on the information we have collected on your interests whilst you were visiting our Site.

• help the Site to function correctly and ensure that the ‘add to basket’, navigation and country site settings are maintained. • monitor the Site’s performance and ensure that we deliver a fast browsing experience. • allow you to share content with social networks, express interest in content and connect with your social media networks.

• to allow us to collect anonymous data about Site usage to help us improve the usability, content and user experience of the Site. This includes site analytics cookies such as Google Analytics. We also use Google Analytics to collect information about your online activity on the Site, such as the web pages you visit, the links you click, and the searches you conduct on the Site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the Site, where visitors have come to the site from and the pages they visited.

For more information about the information gathered using Google Analytics please visit http://www.google.com/intl/en_uk/analytics/tos.html • to assess third party conversion by allowing us to collect anonymous data about how our marketing is performing. Please click here for more detailed information about each type of cookie used on the Site, its purpose and whether it operates as a session or persistent cookie. Most browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies. You may delete or decline cookies by changing your browser settings. (Click “Help” in the toolbar of most browsers for instructions or review the cookie management guide produced by the Interactive Advertising Bureau – www.allaboutcookies.org.) If you do so, some of the features and services of the Site may not function properly.

To opt out of being tracked by Google Analytics across all Sites visit http://tools.google.com/dlpage/gaoptout. Your continued use of the Site will be treated as consent to the use of these cookies for the purposes described.

Will my personal data be transferred abroad?

If we transfer your personal information to a person, company, office, branch, organisation, service provider or agent in another country, we will make sure that we have appropriate security and privacy measures in place with such third parties covering how they hold and maintain any personal information on our behalf.

Which laws apply?

This Privacy Policy will be governed by and construed and interpreted in accordance with the laws of South Africa. To the extent that a court has jurisdiction over any dispute which may arise out of or in connection with this Privacy Policy, we both submit to the jurisdiction of the appropriate South African court.