1. Introduction

Broadband Infraco SOC Limited (“BBI”) recognises the importance of privacy and the protection of personal information provided to it and is committed to the safeguarding of such information. This privacy notice explains how BBI collects and uses your personal information. It contains information regarding the rights of natural persons (and juristic persons, where applicable) to whom personal information relates (“data subjects” or “you”).

BBI reserves the right to amend this Privacy Notice or add provisions to it at any time by publishing an updated version on our website.

2. Collection of Information

BBI collects personal information in various instances, including when: you contact BBI or request information or services; BBI provides services to you; when you use BBI’s websites; or engage with BBI through social media. BBI does not engage in any automated decision-making.

BBI may collect the information directly from you or from third parties (such as regulators, government authorities and registries, or attorneys representing our customers’ counterparties). In some instances, it is necessary for you to provide us with the information so that we can provide services to you. In other instances, providing the information is optional, such as choosing to subscribe to or opt out from a newsletter.

If you do not provide the information when it is necessary, we will not be able to provide services to you. If you do not provide the information when it is optional, you will not receive the benefit of providing the information (e.g., a newsletter).

Your interaction with BBI on its website will result in the collection of information regarding your activities on the website. Similarly, when you engage with BBI via any one of BBI’s social media platforms. This information includes, but is not limited to, your name, contact details, and information regarding the service you may require.

While engaging with customers, BBI will naturally be exposed to and collect personal information which includes your name, contact details, financial information, as well as information regarding the service that BBI assists you with.

In the course of providing services to you, we rely on the determination that we are acting in your legitimate interests, as we are following your instruction(s) in providing our services. As with all firms, we may need to collect your information in terms of various laws. Some examples of such laws include:

• Legal Practice Act 28 of 2014
• Broad-Based Black Economic Empowerment Act 53 of 2003
• Companies Act 71 of 2008
• Consumer Protection Act 68 of 2008
• Copyright Act 98 of 1978
• Financial Intelligence Centre Act 38 of 2001
• Patents Act 57 of 1978
• Trade Marks Act 194 of 1993

Additional Acts may be found in our PAIA Manual, available on our website.

3. Basis and Purpose for Processing Personal Information

The bases on which BBI processes personal information include (but are not limited to):

• To provide services to customers (i.e., we are relying on a verbal or service provisioning contract with you).
• In your legitimate interests (i.e., we are acting on your instructions).
• In our legitimate interests (e.g., to bill you for our services).
• To comply with legal or regulatory obligations.
• If you have provided your explicit consent.
• Or if the processing is allowed by law.

The purposes for which BBI processes personal information include, but are not limited to:

• Marketing and promotion of BBI’s services.
• Providing and improving services to customers.
• Improving users’ experience when using BBI’s website.
• Communicating with persons for BBI’s internal purposes.
• Enabling BBI’s internal operations.
• Exercising and defending legal rights.

4. Disclosure of Personal Information

BBI may release personal information or disclose it to third parties in certain circumstances. These include, but are not limited to: if BBI is required or authorised to do so by law or a court order; in order for BBI to enforce its rights; or in order for BBI to provide services to its customers.

The third parties to whom BBI discloses personal information include, but are not limited to:

• Equipment suppliers and other parties involved in the provision of ICT services.
• Third-party service providers to BBI or its customers (sometimes in other countries).
• Third parties who provide research services to BBI or its customers.
• Government authorities and registries, other organs of state, regulators, courts, tribunals and law enforcement agencies.

5. Transfer of Personal Information

Personal information collected by BBI may be transferred to natural or juristic persons in other countries, such as for services related to the West African Cable System, where BBI has international partners associated with the cable’s operations and maintenance. We would do so to provide services to you and would only transfer the information necessary for that service.

We may also transfer information where some of our service providers are cloud-based. Depending on the services we provide to you, this may include some or all of your information. Those countries’ laws might not protect personal information in the same way or on the same level as the law in your country. However, BBI will take reasonable steps to ensure that recipients in other countries have appropriate privacy measures in place, for example, by entering into a contract with the recipient.

6. Retention of Personal Information

BBI retains personal information for as long as may be reasonably necessary in accordance with applicable law, and/or in order to provide services to you. Our first obligation is to keep information as long as may be required by law. Thereafter, we would only keep information in order to provide services or other requested information to you, or for specific business purposes.

7. Cookies

BBI’s websites make use of cookies. Cookies store information regarding website visitors. Cookies have various purposes, such as improving the visitor’s experience on the website and facilitating their use of the website. A website visitor may disable or decline cookies. However, if the visitor does so, their user experience on the site may be diminished.

8. Security

BBI takes all reasonable steps to protect and avoid unauthorised access to personal information. We have implemented various policies, procedures, hardware and software to safeguard personal information, and routinely review our operations in order to ensure that personal information is adequately protected.

9. Your (Data Subject) Rights

The law might provide you with rights to access, amend or delete personal information that is in the possession of BBI. However, BBI may, in certain instances, legally refuse or decline such requests. If applicable, you might also have the right to object to BBI’s processing of your personal information or to file a complaint with a regulator; however, we encourage you to address your complaint to us first.

In South Africa, the Information Regulator can be contacted at:

In some cases, you may withdraw your consent for processing. This withdrawal has no effect on lawful processing conducted up to that point. If you wish to exercise your rights, you can contact BBI at the details provided below. BBI may charge you a fee for accessing, amending or deleting your personal information. You will be advised of this fee in advance, if applicable.

Keep your details up to date: You are encouraged to contact BBI in order to update your personal information as and when necessary.

10. Contact Details

In order to contact BBI for purposes relating to this privacy policy, please use these contact details: