PRIVACY POLICY

Babas and Brasse respects the privacy of its readers, contributors, commenters and other users of the platform.

This Privacy Policy explains how Babas and Brasse may collect, use, store, protect and otherwise process personal information through www.babasandbrasse.co.za.

Babas and Brasse aims to handle personal information in accordance with applicable South African law, including the Protection of Personal Information Act 4 of 2013 (“POPIA”), where applicable.

By using the website or voluntarily providing personal information to Babas and Brasse, you acknowledge the practices described in this Privacy Policy.

Babas and Brasse is an independent online creative platform and collective.

It is not currently represented as a registered company or registered non-profit entity.

The editorial team currently includes:

Editor in Chief: Zubayr Charles

Junior Editor: Mia Winters

Privacy enquiries and requests may be directed to:

Editor in Chief: Zubayr Charles

Email: submissions@babasandbrasse.co.za

Website: www.babasandbrasse.co.za

Babas and Brasse does not currently identify a separately appointed Information Officer in this Privacy Policy.

The information collected depends on how a person interacts with the platform.

3.1Contact Form Information

When you contact Babas and Brasse through the website, information may include:

• name;
• surname;
• email address;
• subject;
• message; and
• any information voluntarily included in the message.

3.2Contributor Information

When creative work is submitted for consideration, Babas and Brasse may process information including:

• contributor name;
• email address;
• chosen author name or byline;
• biography;
• profile photograph;
• social-media information where voluntarily supplied;
• submitted articles or creative work;
• supporting files;
• correspondence relating to submissions;
• editorial communications; and
• other information voluntarily provided by the contributor.

Babas and Brasse does not currently pay contributors through the website and therefore does not collect contributor payment information for that purpose.

3.3Comment Information

Where users submit comments, information processed may include:

• name or display name;
• email address where required;
• comment content;
• date and time of submission;
• moderation status; and
• limited technical information reasonably required for security, moderation or spam prevention.

3.4Technical Information

When the website is accessed, certain technical information may automatically be generated by the website or its technical service providers.

This may include:

• IP address;
• browser type;
• device type;
• operating system;
• pages accessed;
• date and time of access;
• error logs; and
• basic security or server information.

Such information may be used where reasonably necessary to operate, protect and maintain the website.

3.5Correspondence

Babas and Brasse may retain information contained in:

• emails;
• contributor communications;
• copyright complaints;
• plagiarism complaints;
• privacy requests;
• correction requests;
• legal enquiries; and
• other communications sent to the platform.

Babas and Brasse may collect personal information:

• directly from you;
• through the contact form;
• when you submit creative work;
• when you submit a comment;
• when you communicate with the editorial team;
• when you submit a complaint;
• through reasonable website-security and server logs;
• from publicly available information where relevant and lawful; or
• from another person where there is a lawful and appropriate reason to receive the information.

Babas and Brasse may process personal information for purposes including:

• responding to enquiries;
• receiving and reviewing contributor submissions;
• communicating with contributors;
• editing and publishing accepted contributions;
• correctly identifying and crediting contributors;
• displaying contributor biographies where agreed or intended;
• operating the website;
• moderating comments;
• preventing spam and abuse;
• maintaining website security;
• investigating technical problems;
• investigating copyright or plagiarism complaints;
• processing correction requests;
• handling privacy complaints;
• maintaining appropriate editorial records;
• complying with applicable legal obligations;
• establishing, exercising or defending legal rights; and
• improving the functionality and reliability of the platform.

Personal information will not intentionally be collected for purposes that are unrelated to the operation of Babas and Brasse without an appropriate reason.

Contributors should understand that some information is intentionally made public when their contribution is published.

Depending on the information provided and the contributor’s chosen presentation, publicly visible information may include:

• contributor name;
• chosen byline;
• biography;
• profile photograph;
• profession or creative discipline;
• publicly supplied social-media profile;
• article or creative work; and
• information intentionally included by the contributor in their published contribution.

Private contact information supplied for administrative or editorial purposes, such as personal email addresses, will not ordinarily be published unless the person has specifically intended or authorised publication or another lawful basis exists.

Comments approved for publication may become publicly visible on the website.

Users should therefore avoid including information in a comment that they do not want to make public.

Babas and Brasse may moderate comments before they become visible.

Comments may be rejected or removed where they contain inappropriate personal information, unlawful material, harassment, spam, copyright infringement or other content contrary to the website’s Terms and Conditions.

Where POPIA applies, Babas and Brasse will process personal information only where there is an appropriate lawful basis for doing so.

Depending on the circumstances, this may include:

• the person’s consent;
• processing necessary in connection with a request or submission made by the person;
• processing necessary to perform an arrangement involving the person;
• compliance with a legal obligation;
• protection of a legitimate interest of the person concerned;
• pursuit or protection of the legitimate interests of Babas and Brasse or another person; or
• another basis permitted under South African law.

Where processing depends solely on consent, the person may generally withdraw that consent for future processing, subject to any other lawful basis for continued processing or retention.

Babas and Brasse does not sell personal information.

Personal information may be accessible to members of the editorial or technical team where reasonably necessary for their role.

Information may also be processed by service providers that support the operation of the website, such as providers of:

• website hosting;
• databases;
• email services;
• security services;
• spam protection;
• technical infrastructure; or
• website maintenance.

Only information reasonably required for the relevant service should be made available.

Personal information may also be disclosed where:

• required by applicable law;
• required by a lawful court order;
• required by an authorised regulatory process;
• reasonably necessary to investigate unlawful activity;
• reasonably necessary to establish or defend legal rights; or
• the person concerned has authorised the disclosure.

Babas and Brasse may use essential cookies or similar technologies that are reasonably necessary for:

• website functionality;
• website security;
• administrative functionality;
• remembering essential settings; or
• protecting forms against abuse.

Users may control or delete certain cookies through their browser settings.

If Babas and Brasse later introduces additional analytics, advertising or tracking technologies, this Privacy Policy and any appropriate cookie notice should be updated accordingly.

Babas and Brasse publishes journalism, interviews, essays, commentary, photography, literature, artwork and other forms of creative expression.

Some published material may refer to identifiable people, organisations, experiences or events.

Where personal information forms part of journalistic, literary or artistic expression, Babas and Brasse will endeavour to balance privacy and dignity with freedom of expression and other applicable rights under South African law.

This Privacy Policy should not be interpreted as requiring the removal of legitimate journalism, criticism, commentary, literature or artistic expression merely because an identifiable person is mentioned.

Each complaint will be considered according to its circumstances and applicable law.

Babas and Brasse does not intentionally use ordinary website forms to collect unnecessary personal information from children.

Particular care should be taken where an article, interview, photograph or creative contribution concerns a child.

Where consent or another safeguard is legally required before information concerning a child is collected or published, Babas and Brasse will endeavour to obtain the appropriate consent or comply with the relevant legal requirement.

Babas and Brasse will aim not to retain personal information for longer than reasonably necessary for the purpose for which it was collected, unless continued retention is:

• required by law;
• reasonably necessary for editorial records;
• reasonably necessary for dispute resolution;
• reasonably necessary to deal with copyright or plagiarism issues;
• reasonably necessary for security purposes;
• required to establish or defend legal rights;
• authorised by the person concerned; or
• otherwise permitted under applicable law.

Information that no longer needs to be retained should be deleted, destroyed or appropriately de-identified where reasonably practicable and legally appropriate.

Published articles and creative work may remain part of the Babas and Brasse archive even after their initial publication date, subject to applicable law and legitimate correction, copyright or privacy concerns.

Babas and Brasse will take reasonable technical and organisational measures appropriate to the nature of the information processed to reduce the risk of:

• unauthorised access;
• unauthorised disclosure;
• loss;
• misuse;
• alteration;
• destruction; or
• unlawful processing.

Measures may include, where appropriate:

• password-protected administration;
• access controls;
• restricted administrative privileges;
• secure website infrastructure;
• software updates;
• database protections;
• backups; and
• security monitoring.

No internet-based website or storage system can be guaranteed to be completely secure.

Users should therefore exercise reasonable care when sending sensitive information electronically.

If Babas and Brasse becomes aware of a security incident involving personal information, it will take reasonable steps to:

• investigate the incident;
• limit further unauthorised access where possible;
• secure affected systems;
• assess the information involved; and
• take any notification or other action required by applicable South African law.

Subject to applicable South African law, a person may request that Babas and Brasse:

• confirm whether personal information concerning them is held;
• provide access to personal information where legally required;
• correct inaccurate or outdated personal information;
• update incomplete personal information;
• delete or destroy information where there is no lawful reason to retain it;
• stop certain processing where a valid objection applies; or
• consider a complaint concerning the way their personal information is being processed.

A request may be subject to reasonable identity verification before information is disclosed, corrected or deleted.

Certain information may lawfully need to be retained despite a deletion request, including where necessary for legal, evidentiary, editorial, security or other lawful purposes.

Requests concerning personal information should be sent to:

Editor in Chief: Zubayr Charles

Email: submissions@babasandbrasse.co.za

Please provide sufficient information to identify:

• who you are;
• the information concerned;
• the nature of your request; and
• how Babas and Brasse can contact you regarding the request.

Additional information may reasonably be requested to confirm your identity before private information is disclosed.

Copyright and plagiarism concerns are primarily governed by intellectual-property law and the Babas and Brasse Terms and Conditions rather than this Privacy Policy.

If you believe that your article, photograph, artwork, writing or other creative work has been copied, plagiarised or used without appropriate permission, contact:

submissions@babasandbrasse.co.za

Please identify the original work, the allegedly infringing material and any supporting evidence reasonably available.

Babas and Brasse may investigate the complaint and take appropriate editorial action.

Babas and Brasse may link to independent websites, social-media platforms or other third-party resources.

Those services have their own privacy policies and practices.

Babas and Brasse does not control how independent third parties collect or process personal information after a user leaves the Babas and Brasse website.

Users should review the privacy practices of any third-party service they choose to use.

Babas and Brasse may update this Privacy Policy from time to time to reflect:

• changes to the website;
• changes to the information collected;
• changes to platform functionality;
• changes to operational practices; or
• changes to applicable legal requirements.

The latest version will be published on the Babas and Brasse website with its most recent update date.

Questions, requests or concerns relating to privacy or personal information should be directed to:

Editor in Chief: Zubayr Charles

Email: submissions@babasandbrasse.co.za

Website: www.babasandbrasse.co.za

Where a privacy concern cannot be resolved directly with Babas and Brasse, individuals may also have the right to approach the Information Regulator of South Africa in accordance with applicable law.