Please review this Privacy Policy carefully.

This Privacy Policy will inform you about the information we may collect from you, how we use or store it, the choices you have regarding our use of it, your ability to review and correct it and how to opt out from any of our services and/or from receiving any promotional material.

The data we may collect may be personal information about you or by which you can be identified e.g. your full name, address (email and/or postal), mobile number/MSISDIN (mobile station integrated services digital network number), date of birth, gender etc. (“Personal Information”) as well as other non-personal information for analytical purposes to monitor trends and statistical data: URL/internet protocol address, mobile device location, browser type, pages of the service accessed, viewed search terms, your online service behaviour e.g. subscriptions, product/service purchases, widget/app downloads, social media sharing, comments, reviews etc.

This Privacy Policy is supplemental to the terms and conditions for our services available via our web application at URL:, which form an integral part of this Privacy Policy.

Who We Are:
Buongiorno South Africa (Pty) Ltd, trading as “BunnyKulcha”, a limited liability company registered in the Republic of South Africa, operating under company number 1990/04637/07,with its registered office address at: 5th Floor Auto Atlantic Building,Cnr Heerengracht and Hertzog Boulevard, Cape Town 8001 (the “Company”), provides you with the best curated content for your mobile, for a daily subscription fee, on your supported smart device through our web application (“Service(s)”).
In this Privacy Policy references to “we”, “us”, “our” and any similar expression shall include the Company and any of its affiliates and references to the customer shall include “you” or “your”.
Privacy Commitment
We understand and recognise the importance of safeguarding the Personal Information received from our customers and so we have formulated this Privacy Policy to reflect our commitment to maintaining the confidentiality of the Personal Information received from you via your selected Service.

We respect your privacy and we will handle your Personal Information in an ethical manner. We will also ensure that we are compliant with the privacy laws in the Republic of South Africa, including, the Protection of Personal Information Act 2013, as amended from time to time (“POPI”).
Information Collected and Used
Generally, you can access your chosen Service without telling us who you are or revealing any of your Personal Information, although we may collect certain data about your visit to the Service to help us improve Service quality. Before you are able to fully access any of the content, our web application (“App”) or use the Services you will be required to subscribe to the chosen Service via the App

We may gather the Personal Information to allow us to process your subscription to your chosen Service, process any requests or payments you may make, administer your contract, process refunds, communicate with you, award prizes and provide marketing or promotional materials. We may also collect the Personal Information so that you can access the online Services, monitor your usage of a Service and/or participation in online activities including reviews, testimonials or competitions, if any, or for other purposes outlined in this Agreement.

You may at any time withdraw your consent to us collecting some of the Personal Information or other data you provided but this could limit your access to part of the Services. 

Every time you visit a Service, our system automatically recognises the mobile device type used to communicate with us (where possible). Individual users will remain anonymous unless you tell us who you are. 

Children and Minors
We do not knowingly collect or solicit Personal Information or other data from children and minors. Anyone under the age of 18 will not be knowingly allowed to register to any of the Services. 

If you are under 18, please do not attempt to register to any Service or any part of it or send any Personal Information or other data to us. If you are a parent or guardian and you are aware that your child has provided us with Personal Information, please contact us immediately. In the event that we become aware or informed that we have collected Personal Information from anyone under the age of 18 without verification of parental consent, we will promptly delete such Personal Information from our servers. 

Information to Third Parties
We will not rent, sell or share your Personal Information with other organisations or non-affiliated companies for commercial purposes unless you have expressly consented to this. 

However, by law or for regulatory reasons or at the request of a MNO (mobile network operator), we may have to reveal any Personal Information to certain third parties if required to investigate or deal with any complaints relating to you or your use of a Service. Your Personal Information may be revealed to other businesses within our group of companies and to reputable third parties who will help process your subscription to a Service if necessary such as our supply and service agents and data processors.

If all or part of our business is sold, (whether by sale of shares or assets) or integrated with another business, your Personal Information may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business. Following completion of any such sale or transfer your Personal Information shall be disclosed to and transferred to such new owner or third party.

We do ask our third parties to confirm that their privacy practices are consistent with ours to ensure maximum protection of your privacy.

Linking to third party sites
If a Service, App and/or any content contain a link to any websites outside of our control, these websites are not under our control and we are not responsible for those websites or the conduct of companies who own or control those websites. Your use of those other websites is subject to any terms of use and/or privacy policies on those websites.

Your Consent

You agree to us collecting, using and processing your Personal Information or other data you may provide as set out in this Privacy Policy. 

Transfer of Personal Information outside South Africa
Owing to the global nature of the internet infrastructure and our business, the Personal Information you provide may be transferred in transit outside of South Africa to a foreign country. Personal Information may be stored on servers located outside of South Africa in a foreign country whose laws protecting personal information may not be as stringent as the laws in South Africa. By submitting your Personal Information, you consent to us processing your Personal Information in a foreign country whose laws regarding processing of personal information may be less stringent. However, every effort will be made to ensure that your Personal Information is processed only for the purposes set out above and for no other purposes and we have taken the steps outlined in this Privacy Policy to try to improve the security of your Personal Information.

Your Right to Opt-Out
You are free to cancel your Subscription, at any time, by clicking on to the unsubscribe option and following the instructions via the account section of our WebApp portal.
You can also unsubscribe by sending an SMS with the keyword below to 36692 to unsubscribe from a Service at any time:
SMS “NO” to 36692 to stop receiving promotional and marketing offers from us.

Updating Your Information
If you wish to correct your Personal Information please use the contact details listed in the Contact Information section below.

Withdrawal of Consent
You may at any time withdraw your consent to us collecting and processing your Personal Information in accordance with this Privacy Policy by giving us written notice to us, please see the Contact Information section below. Upon receipt of the withdrawal notice we shall cease (and cause our third parties to cease) collecting, using or disclosing any Personal Information, as applicable, unless such collection, use or disclosure, as the case may be, without your consent, is required or authorised under POPI or other written law.

Our Services use ‘cookies’ to distinguish you from other users of a Service. A cookie is a small amount of data or parcels of text that is sent to your browser from a web server and stored on your mobile device’s hard drive, if you consented to this. Generally, a 'cookie' being a file in your web browser enables the website to recognise your mobile device when you visit the website.

Cookies help us to enhance your experience when you access a Service and also allows us to improve it. We may obtain information about your general internet usage by using such cookie files which are stored on the browser of your mobile device type. Cookies contain information that is transferred to your mobile device type.

They enable us to: 
•    estimate our audience size and usage pattern. 
•    store information about your preferences, and so allow us to customise our site according to your individual interests. 
•    speed up your searches. 
•    recognise you when you return to our site.
•    provide a more convenient browsing experience for you.

You may refuse to accept all cookies, reject all cookies, or modify your browser to alert you of any new cookies by activating these settings on your browser. However, if you select any of these settings you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you access a Service. Please note that our advertisers may also use cookies, over which we have no control.

You can also discover independent information about cookies by researching the internet or carrying out online searches. 

Security Statement
The security internal procedures are designed to cover the storage, access and disclosure of your Personal Information. We are committed to online security. We maintain security measures to protect any sensitive data submitted via a Service and to prevent unauthorised access of customer information that is transmitted to our databases. We cannot however guarantee the security of any data sent over the internet. Details of our security policy and measures can be found below. 

This Security Statement explains how we store and safeguard the data we collect about you, and procedures that we have in place to safeguard your privacy generally. 

We always use industry-standard encryption technologies when transferring and receiving customer data exchanged with our Services. We have appropriate security measures in place in our physical facilities to protect against the loss, misuse or alteration of data that we have collected from you on our Services. Unfortunately, however, no data transmission over the internet can be guaranteed to be 100% secure. 

To prevent unauthorised access, maintain accuracy of our records and data to ensure proper use of data, we have put in place appropriate physical, electronic and managerial procedures to protect, secure and safeguard your Personal Information that we collect or on through our website.
The following provisions and arrangements are in place: 

1. We have a management and corporate commitment to data security within the organisation and provide clear direction, guidance and responsibilities and procedures in this respect. 
2. We have a designated or nominated compliance officer who deals with security of your Personal Information together with relevant compliance with the POPI. 
3. All employees are briefed on the importance of personal data and security and confidentiality of data obtained. Employees may attend training programmes and are provided with updates or practical guidance under the POPI. 
4. We control physical security in relation to your Personal Information that is contained at our facilities and restrict access to the site, buildings, computer rooms, office desk, technology areas, equipment and other facilities where unauthorised access by people could compromise our security. 
5. All proprietary or confidential information, including your Personal Information, is contained or stored on computer and any that is contained and stored on manual files are locked up and secure. 
6. We may seek to control access to your Personal Information, including existing procedures for authorising and authenticating users as well as software controls for restricting access and techniques for protecting data such as encryption. Encryption is used in connection with our payment facilities for customers, which ensures that any communications between your computer and ourselves is unreadable by anyone else. 
7. We monitor and log access so as to assist in detection and investigation of security breaches and any attempted breaches where they occur. 
8. We maintain a business continuity plan as a contingency plan which identifies our business functions and assets (including your Personal Information) which would need to be maintained in the event of disaster and set out the procedures for protecting and restoring them if necessary. 
9. In respect of detection and investigation of breaches where they occur, we have in place relevant controls which should alert us to a breach in security. We endeavour to investigate every notified breach of security. 
10. The Personal Information held by us are currently stored on a relevant technology system, mass email programme data base, individual account contact manager’s systems together with the training booking spread sheet, invoicing spread sheet, Excel spread sheets, paper form. 
11. Our security measures are reviewed and updated from time to time. 


Changes to Our Privacy Policy
From time to time, it may be necessary for us to review and revise our Privacy Policy.  We reserve the right to change our Privacy Policy at any time, and we may notify you about changes to this Privacy Policy by posting an updated version of the policy on our App By continuing to access or use any of the Services after we have posted an updated Privacy Policy or have provided you with notice of any material modifications of the same, you are agreeing to be bound by the modified Privacy Policy. If the modified Privacy Policy is not acceptable to you, your only recourse is to cease using our Services.
Contact Information
If you have any questions concerning this Privacy Policy please contact us via our address, email or by using the helpline stated below:

Address: Buongiorno South Africa (Pty) Ltd, 5th Floor Auto Atlantic Building,Cnr Heerengracht and Hertzog Boulevard, Cape Town 8001
Helpline: 021 415 2166 (local call charge rate)
Update: last update February 2017