Privacy Policy

1. Introduction and Our Commitment to You

Halogen Greens (Pty) Ltd, Registration Number 2024/297822/07, along with its production facilities and depots ("Halogen Greens," "we," "us," or "our"), is the owner and operator of www.halogengreens.com (the "Website"). We hold a deep respect for your personal information and are dedicated to protecting it through our data handling and security practices.

The purpose of this document is to clearly outline how we gather, utilise, disclose, and secure the information we receive from visitors to our online platform. Our objective is to give you confidence and assurance regarding how your data is treated, thereby building a foundation of trust in your interactions with us. By navigating and using this Website, you indicate your acceptance of the practices detailed in this Privacy Policy. Any capitalised terms used but not defined here shall carry the meaning ascribed to them in our Terms and Conditions, which are accessible on this Website.

2. Purpose of Our Website

This Website serves a purely informational function. Its objective is to present visitors with details concerning Halogen Greens, our Group 3 Bio-Stimulant product for which we are preparing a worldwide patent and registration with the South African Department of Agriculture, our company profile, and our operational presence, including our head office and manufacturing plants across South Africa. We do not actively solicit personal data through the Website for marketing communications, and no newsletters, brochures, or promotional emails are dispatched as a function of this site.

3. Administration and Scope

This Privacy Policy governs the website www.halogengreens.com, which is administered on our behalf by a contracted third-party service provider, NH Studios. The policy applies specifically to information collected through this online channel and not to information gathered offline or via other means.

4. Notification in Terms of Section 18 of POPIA

In compliance with the Protection of Personal Information Act, 2013 (Act 4 of 2013) ("POPIA"), we hereby inform you of the following:

• The information we collect is provided voluntarily by you. There is no legal or contractual obligation to supply your personal data to us in order to browse this Website. The consequence of not providing information is simply that we will be unable to respond to any direct query or request you may wish to submit.
• The collection and processing of your personal information is based solely on your voluntary and informed consent, which you provide by taking the affirmative action of contacting us directly.
• The recipients or categories of recipients of your personal information are limited to our authorised service provider, NH Studios, and internally within Halogen Greens' head office, production facilities, and depots, strictly as needed to address your enquiry.
• You have the right to object to the processing of your personal information, as contemplated in section 11(3) of POPIA, by contacting our Information Officer using the details provided in the "How to Contact Us" section. Should you object, we will cease processing unless we have a legally compelling justification to continue.

5. What Data We Gather and How We Gather It

Several categories of data may be collected for the purposes of operating, maintaining, and improving the Website experience.

a. Information You Voluntarily Supply (Personal Identifiable Data)

Our default setting is not to collect any information that could identify you as a specific individual or entity (such as your name, physical address, email address, or telephone number) unless you choose to share such data with us voluntarily, for instance, by sending a direct email to a contact address listed on the site. You are free to browse the entire Website without submitting any personal identifiable data.

b. Automated Data Collection (Non-Personal & Usage Data)

When you access our Website, certain technical details are automatically logged to ensure functionality and for analytical purposes. This non-personally identifiable data is gathered on an aggregated and anonymous basis and may include:

• The Internet Protocol (IP) address of your device.
• The type and version of your web browser.
• The specific pages you view on our Website.
• The date and time of your visit and the duration spent on pages.
• Unique device identifiers and other diagnostic information.
• If you are using a mobile device, we may note the make and model of that device.

c. Cookies and Tracking Technologies

Our Website employs small data files known as "cookies," as well as similar technologies such as pixel tags and scripts. A cookie is a text file containing a small, anonymous unique identifier that is placed on your device's hard drive by a web server.

We respect your right to choose whether or not to accept cookies. Upon your first visit to our Website, a clearly visible cookie consent banner is presented. You are afforded an explicit choice to Accept or Reject non-essential cookies, with both options being equally prominent. Essential or strictly necessary cookies, required for the core functionality and security of the Website, are set automatically. These are limited to:

• Session Cookies: Essential for the operation of the Website during your visit.
• Security Cookies: Essential for upholding the security of our service.

Non-essential cookies, such as Preference Cookies that remember your choices, will only be activated once you give your affirmative consent by selecting "Accept." No non-essential cookies are placed on your device before such consent is obtained. You may withdraw your consent at any time by adjusting your browser settings.

6. How We Make Use of Collected Information

The limited information we gather serves specific, defined purposes:

• For Personal Identifiable Data provided voluntarily: We will use your contact details solely to respond to a direct query, comment, or specific request for information you have initiated. We will not add your details to any marketing database or use them to send unsolicited promotional content.
• For Non-Personal & Usage Data: This aggregated information is instrumental in helping us analyse user traffic patterns and site metrics. This allows us to refine our Website's architecture, enhance its usability, make the visitor experience more user-friendly, and identify which features are most popular.
• General Business Purposes: To maintain the security and operational integrity of our Service and to adhere to any applicable legal or regulatory requirements.

7. Information Sharing and Disclosure

Halogen Greens maintains a strict policy against the commercial exploitation of your personal data. We do not sell, rent, or trade your personally identifiable information with unaffiliated third parties for their independent promotional use.

However, information may be shared under the following limited conditions:

• With Service Providers: We may disclose your data to trusted partners like NH Studios who perform administrative, analytical, or technical services for our Website. These vendors are contractually bound to keep such information confidential and are prohibited from using it for any purpose beyond the specific services they render to us.
• With Our Facilities: Information may be accessed internally, within the operational scope of Halogen Greens' head office, production facilities, and depots, solely for handling a request you have made.
• Legal and Protective Disclosures: We may be compelled to divulge your personal data without advance notice if we have a good-faith belief that doing so is necessary to: (a) satisfy a legal obligation, judicial proceeding, or governmental request; (b) safeguard and defend our rights or property, or that of our users; or (c) act in urgent circumstances to ensure the personal safety of our personnel, the public, or users of our Website.

8. Data Storage and Transfer

All personal information collected through this Website is stored and processed exclusively within the Republic of South Africa. We do not transfer any personal data to any third party or server located outside the borders of South Africa.

9. Links to External Websites

For your convenience, our Website may present hyperlinks to external sites operated by independent third parties. We exercise no control over these sites and accept no liability for their content or their independent privacy protocols. We strongly encourage you to examine the privacy statements of every website you visit that collects your personal information.

10. Protecting Children's Privacy

Our Website is not structured or intended to attract individuals under the age of 18, and we do not consciously gather personally identifiable data from children. Should we discover that a child has submitted personal information to us without the consent of a parent or legal guardian, we will take all reasonable measures to promptly purge such data from our records. A parent or guardian who believes their child has provided us with personal data can contact us using the details in the "How to Contact Us" section to request its removal.

11. How We Secure Your Information

The security of your data is a priority for us. We have instituted a blend of physical, electronic, and procedural safeguards to maintain the accuracy of information and defend it against unauthorised access, loss, misuse, or alteration. When you transmit personally identifiable information to us, such as via email, we employ standard encryption protocols. Despite these measures, no method of transmission over the internet or electronic storage is entirely impenetrable, and we cannot offer an absolute guarantee of security.

12. Your Rights as a Data Subject: Managing Your Information

Under POPIA, you are vested with specific rights concerning the personal information we hold about you. We are committed to upholding these rights. You have the right to:

• Access: Request access to your personal data at no cost.
• Rectification: Request the correction or updating of inaccurate or incomplete information.
• Erasure: Request the deletion of your personal information from our records.
• Restriction: Request the restriction of processing of your data under certain circumstances.
• Objection: Object to the processing of your personal information as provided for in section 11(3) of POPIA.
• Non-subjection to Automated Decision-Making: You will not be subject to a decision based solely on automated processing that produces legal effects or similarly significant impacts on you.
• Institute Civil Proceedings: Should you suffer damages as a result of a violation of POPIA, you have the right to seek civil remedies.
• Complain: Lodge a formal complaint with the Information Regulator if you believe we have interfered with the protection of your personal information.

To exercise any of these rights, please submit a detailed request via email to the Information Officer at the contact address listed below. We will acknowledge your request and endeavour to provide a substantive response within 30 days of receipt, in line with the timeframes prescribed by POPIA regulations.

13. Policy Updates and Revisions

We reserve the right to amend this Privacy Policy periodically to reflect changes in our practices, operational needs, or legal obligations. When we do, we will place a prominent notification on our Website prior to the changes taking effect and update the "Effective Date" at the top of this page. We recommend you review this document on a regular basis to stay informed about how we are protecting your information. Modifications become operative the moment they are published on this page.

14. How to Contact Us and Lodging a Complaint

For any questions, comments, or concerns regarding this privacy statement or our data management practices, please contact our duly registered Information Officer:

• Information Officer Email: info@halogengreens.com
• General and Website Enquiries: info@halogengreens.com
• Physical Address: Head Office, Poortview AH, Roodepoort, Gauteng, South Africa
• Telephone: 087 474 6149

We are committed to engaging with you to resolve any complaint or dispute about your privacy and our use of your data in a fair and swift manner. If, however, you are not satisfied with how we have addressed your concern related to the processing of your personal information, you are entitled to lodge a formal complaint with the Information Regulator of South Africa. Their details are: