PAIA - Informational Officer

December 9, 2023

INFORMATION OFFICER APPOINTMENT LETTER

herewith, and with immediate effect, appoints you as the Information Officer as required by the Protection of Personal Information Act (Act 4 of 2013). The appointment may, at any time, be withdrawn or amended in writing.

Your responsibilities in relation to the POPI Act include:

Taking steps to ensure ’s reasonable compliance with the provision of POPIA.
Report any POPIA related breaches and issues to the members.
Develop, publish and maintain all required POPIA related records, policies, procedures, forms and contracts.
If necessary, creating a Privacy Policy for internal and external purposes.
Ensuring that makes it convenient for data subjects who want to update their personal information or submit POPIA related complaints to the business, to do so. For instance, maintaining a “contact us” facility on ’s website.
Approving any contracts entered with operators, employees and other third parties which may have an impact on the personal information held by . This will include overseeing the amendment of ’s employment contracts and other service level agreements.
Implementing controls to ensure the lawful processing of personal Information.
Ensuring that employees and other persons acting on behalf of are fully aware of the risks associated with the processing of personal information and that they remain informed about the company’s security controls over the course of their employment with periodic awareness updates.
Ensure the training of employees and other individuals involved in the processing of personal information on behalf of .
Ensuring that POPIA Induction training is given to all new members of staff.
Addressing employees’ POPIA related questions.
Addressing all POPIA related requests and complaints made to ’s by data subjects.
Assessing whether disclosures of personal information should be made if requests for same are received.
Ensuring appropriate policies and controls are in place ensuring the acceptable quality of personal information held from data subjects are in line with the POPI Act.
Ensuring the appropriate security safeguards and control measures are in place for all data processed at , in line with the POPI Act.
Liaising with the Information Regulator in relation to any investigations.
In addition, as Information Officer will also need to ensure compliance with Promotion of Access to Information Act (PAIA), as follows:
Developing and maintaining a PAIA Manual which addresses all relevant provisions of the PAI Act, including but not limited to the following:
Meets the requirements for contents of the Manual.
Establishing processing for information requests.
Assisting parties who request information in terms of PAIA.

I, , hereby accept the appointment as Information Officer for .

I confirm that the full content of this letter has been explained to me and I am aware of my duties as Information Officer in relation to the POPI Act and PAI Act.

INFORMATION OFFICER’S SIGNATURE

PAIA MANUAL

Prepared in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 (as amended)

Date of Completion:December 9, 2023

Date of Revision: December 9, 2023

LIST OF ACRONYMS AND ABBREVIATIONS

1.1 “CEO” Chief Executive Officer

1.2 “DIO” Deputy Information Officer;

1.3 “IO“ Information Officer;

1.4 “Minister” Minister of Justice and Correctional Services;

1.5 “PAIA” Promotion of Access to Information Act No. 2 of 2000 (as
Amended;

1.6 “POPIA” Protection of Personal Information Act No.4 of 2013;

1.7 “Regulator” Information Regulator; and

1.8 “Republic” Republic of South Africa

PURPOSE OF PAIA MANUAL

This PAIA Manual is useful for the public to-

2.1 check the categories of records held by a body which are available without a person having to submit a formal PAIA request;

2.2 have a sufficient understanding of how to make a request for access to a record of the body, by providing a description of the subjects on which the body holds records and the categories of records held on each subject;

2.3 know the description of the records of the body which are available in accordance with any other legislation;

2.4 access all the relevant contact details of the Information Officer and Deputy Information Officer who will assist the public with the records they intend to access;

2.5 know the description of the guide on how to use PAIA, as updated by the Regulator and how to obtain access to it;

2.6 know if the body will process personal information, the purpose of processing of personal information and the description of the categories of data subjects and of the information or categories of information relating thereto;

2.7 know the description of the categories of data subjects and of the information or categories of information relating thereto;

2.8 know the recipients or categories of recipients to whom the personal information may be supplied;

2.9 know if the body has planned to transfer or process personal information outside the Republic of South Africa and the recipients or categories of recipients to whom the personal information may be supplied; and

2.10 know whether the body has appropriate security measures to ensure the confidentiality, integrity and availability of the personal information which is to be processed.

KEY CONTACT DETAILS FOR ACCESS TO INFORMATION OF THE

Chief Information Officer

Name:

Tel:

Email:

Fax number:

Deputy Information Officer (NB: if more than one Deputy Information Officer is designated, please provide the details of every Deputy Information Officer of the body designated in terms of section 17 (1) of PAIA.

Name:

Tel:

Email:

Fax:

Access to information general contacts

Email:

3.4 National or Head Office

Postal Address:

Physical Address:

Telephone:

Email:

Website:

GUIDE ON HOW TO USE PAIA AND HOW TO OBTAIN ACCESS TO THE GUIDE

4.1. The Regulator has, in terms of section 10(1) of PAIA, as amended, updated and made available the revised Guide on how to use PAIA (“Guide”), in an easily comprehensible form and manner, as may reasonably be required by a person who wishes to exercise any right contemplated in PAIA and POPIA.

4.2. The Guide is available in each of the official languages and in braille.
4.3. The aforesaid Guide contains the description of-

4.3.1. the objects of PAIA and POPIA;

4.3.2. the postal and street address, phone and fax number and, if available, electronic mail address of-

4.3.2.1. the Information Officer of every public body, and

4.3.2.2. every Deputy Information Officer of every public and private body designated in terms of section 17(1) of PAIA and section 56 of POPIA ;

4.3.3. the manner and form of a request for-

4.3.3.1. access to a record of a public body contemplated in section 11 ; and

4.3.3.2. access to a record of a private body contemplated in section 50 ;

4.3.4. the assistance available from the IO of a public body in terms of PAIA and POPIA;

4.3.5. the assistance available from the Regulator in terms of PAIA and POPIA;

4.3.6. all remedies in law available regarding an act or failure to act in respect of a right or duty conferred or imposed by PAIA and POPIA, including the manner of lodging-

4.3.6.1. an internal appeal;

4.3.6.2. a complaint to the Regulator; and

Section 17(1) of PAIA- For the purposes of PAIA, each public body must, subject to legislation governing the employment of personnel of the public body concerned, designate such number of persons as deputy information officers as are necessary to render the public body as accessible as reasonably possible for requesters of its records.

Section 56(a) of POPIA- Each public and private body must make provision, in the manner prescribed in section 17 of the Promotion of Access to Information Act, with the necessary changes, for the designation of such a number of persons, if any, as deputy information officers as is necessary to perform the duties and responsibilities as set out in section 55(1) of POPIA.

Section 11(1) of PAIA- A requester must be given access to a record of a public body if that requester complies with all the procedural requirements in PAIA relating to a request for access to that record; and access to that record is not refused in terms of any ground for refusal contemplated in Chapter 4 of this Part.

Section 50(1) of PAIA- A requester must be given access to any record of a private body if-
a) that record is required for the exercise or protection of any rights;
b) that person complies with the procedural requirements in PAIA relating to a request for access to that record; and
c) access to that record is not refused in terms of any ground for refusal contemplated in Chapter 4 of this Part.
Section 14(1) of PAIA- The information officer of a public body must, in at least three official languages, make available a manual containing information listed in paragraph 4 above.

Section 51(1) of PAIA- The head of a private body must make available a manual containing the description of the information listed in paragraph 4 above.

Section 15(1) of PAIA- The information officer of a public body, must make available in the prescribed manner a description of the categories of records of the public body that are automatically available without a person having to request access

Section 52(1) of PAIA- The head of a private body may, on a voluntary basis, make available in the prescribed manner a description of the categories of records of the private body that are automatically available without a person having to request access

Section 22(1) of PAIA- The information officer of a public body to whom a request for access is made, must by notice require the requester to pay the prescribed request fee (if any), before further processing the request.

Section 54(1) of PAIA- The head of a private body to whom a request for access is made must by notice require the requester to pay the prescribed request fee (if any), before further processing the request.

Section 92(1) of PAIA provides that –“The Minister may, by notice in the Gazette, make regulations regarding-
(a) any matter which is required or permitted by this Act to be prescribed;
(b) any matter relating to the fees contemplated in sections 22 and 54;
(c) any notice required by this Act;
(d) uniform criteria to be applied by the information officer of a public body when deciding which categories of records are to be made available in terms of section 15; and
(e) any administrative or procedural matter necessary to give effect to the provisions of this Act.”

4.3.6.3. an application with a court against a decision by the information officer of a public body, a decision on internal appeal or a decision by the Regulator or a decision of the head of a private body;

4.3.7. the provisions of sections 14 and 51 requiring a public body and private body, respectively, to compile a manual, and how to obtain access to a manual;

4.3.8. the provisions of sections 15 and 52 providing for the voluntary disclosure of categories of records by a public body and private body, respectively;

4.3.9. the notices issued in terms of sections 22 and 54 regarding fees to be paid in relation to requests for access; and

4.3.10. the regulations made in terms of section 92 .
4.4. Members of the public can inspect or make copies of the Guide from the offices of the public and private bodies, including the office of the Regulator, during normal working hours.

4.5. The Guide can also be obtained-

Section 14(1) of PAIA- The information officer of a public body must, in at least three official languages, make available a manual containing information listed in paragraph 4 above.

Section 51(1) of PAIA- The head of a private body must make available a manual containing the description of the information listed in paragraph 4 above.

upon request to the Information Officer;

from the website of the Regulator (https://www.justice.gov.za/inforeg/).

A copy of the Guide is also available in the following two official languages, for public inspection during normal office hours-

4.6.1 English and Afrikaans

CATEGORIES OF RECORDS OF THE WHICH ARE AVAILABLE WITHOUT A PERSON HAVING TO REQUEST ACCESS

NB: Please specify the categories of records held by the body which are available without a person having to request access by completing Form C, types of the records and how the records can be accessed. These are mostly records that maybe available on the website and a person may download or request telephonically or by sending an email or a letter.

Below is an example of the table that can be used.

Category of records

Types of the Record

Available on Website

Available upon request

DESCRIPTION OF THE RECORDS OF WHICH ARE AVAILABLE IN ACCORDANCE WITH ANY OTHER LEGISLATION

NB: Please specify all the records which are created and available in accordance with any of the South African legislation. Below is an example of the table that can be used in describing the records and applicable legislation.

Category of Records

Applicable Legislation

Memorandum of incorporation

Companies Act 71 of 2008

PAIA Manual

Promotion of Access to Information Act 2 of 2000

DESCRIPTION OF THE SUBJECTS ON WHICH THE BODY HOLDS RECORDS AND CATEGORIES OF RECORDS HELD ON EACH SUBJECT BY THE

NB: Describe the subjects (i.e. Finance, SCM or HR), in respect of which the body holds records and the categories of records held on each subject. Below is an example of the table that can be used. .

Subjects on which the body holds records
Categories of records
Strategic Documents, Plans, Proposals Annual Reports, Strategic Plan, Annual Performance Plan.
Human Resources - HR policies and procedures
- Advertised posts
- Employees records

PROCESSING OF PERSONAL INFORMATION

8.1 Purpose of Processing Personal Information

NB: Describe the purpose or reasons for processing personal information in your organisation.

8.2 Description of the categories of Data Subjects and of the information or categories of information relating thereto

NB: Specify the categories of data subjects in respect of whom the body processes personal information and the nature or categories of the personal information being processed.

Below is the template that can be used to set out the categories of data subjects and the description of the nature or categories of the personal information to be processed. Note that the nature or categories of the personal information is dependent on the purpose of the body in performing its functions or services. .

Categories of Data Subjects
Personal Information that may be processed
Customers / Clients name, address, registration numbers or identity numbers, employment status and bank details
Service Providers names, registration number, vat numbers, address, trade secrets and bank details
Employees address, qualifications, gender and race

8.3 The recipients or categories of recipients to whom the personal information may be supplied

NB: Specify the person or category of persons to whom the body may disseminate personal information. Below is an example of the category of personal information which may be disseminated and the recipient or category of recipients of the personal information.

Category of personal information
Recipients or Categories of Recipients to whom the personal information may be supplied

Identity number and names, for criminal checks South African Police Services
Qualifications, for qualification verifications South African Qualifications Authority

Credit and payment history, for credit information Credit Bureaus

8.4 Planned transborder flows of personal information

NB: Indicate if the body has planned transborder flows of personal information. For example, some personal information may be stored in the cloud outside the Republic. Please specify the country in which personal information will be stored and categories of personal information.

8.5 General description of Information Security Measures to be implemented by the responsible party to ensure the confidentiality, integrity and availability of the information

NB: Specify the nature of the security safeguards to be implemented or under implementation to ensure the confidentiality and integrity of the personal information under the care of the body. This may, for example, include Data Encryption; Anti-virus and Anti-malware Solutions.

AVAILABILITY OF THE MANUAL

9.1 A copy of the Manual is available-

9.1.1 on , if any;

9.1.2 head office of the for public inspection during normal business hours;

9.1.3 to any person upon request and upon the payment of a reasonable prescribed fee; and

9.1.4 to the Information Regulator upon request.

9.2 A fee for a copy of the Manual, as contemplated in annexure B of the Regulations, shall be payable per each A4-size photocopy made.

UPDATING OF THE MANUAL

The head of a will on a regular basis update this manual.

Issued by CEO

December 9, 2023

PRIVACY POLICY

Information Officer:
Deputy Information Officer/s:
Policy Date:	December 9, 2023
Version:

INTRODUCTION
- (", we, us, our") is sensitive to the personal nature of the information you provide to us.
- This Privacy Policy ("this Policy") explains how we protect and use your Personal Information.
- By providing us with your Personal Information, you –
  - agree to this Policy and authorize us to process such information as set out herein; and
  - authorize , its’ Associates, our Service Providers and other third parties to process your Personal Information for the purposes stated in this Policy.
- We will not use your Personal Information for any other purpose than that set out in this Policy and will endeavour to protect your Personal Information that is in our possession from unauthorised alteration, loss, disclosure, or access.
- Please note that we may review and update this Policy from time to time. The latest version of this Policy is available on our Company website and/ or available upon request.
- This Policy applies to all external parties with whom we interact, including but not limited to individual clients, representatives of client organisations, visitors to our offices, and other users of our professional services ("you"). Defined terms used in this Policy are explained in Annexure A.

COLLECTION OF PERSONAL INFORMATION
- We may collect or obtain Personal Information about you –
  - directly from you.
  - during our relationship with you or your organization.
  - when you make your Personal Information public.
  - when you visit and/or interact with our website or our various social media platforms.
  - when you register to make use of any of our professional services including, but not limited to, newsletters and legal updates; or
  - when you visit our offices.
- We may also receive Personal Information about you from third parties (for example, law enforcement authorities).
- In addition to the above, we may create Personal Information about you such as records of your communications and interactions with us, including, but not limited to, your attendance at events or at interviews while applying for a job with us, subscription to our newsletters and other mailings and interactions with you during our digital marketing campaigns.

CATEGORIES OF PERSONAL INFORMATION WE MAY PROCESS

We may process the following categories of Personal Information about you –

personal details: full name or company name.
demographic information: gender; date of birth / age; nationality; salutation; title; and language preferences.
identifier information: company registration number, passport or national identity number; bank details.
contact details: correspondence ; ; email ; and details of your public social media profile(s).
instruction details: details of individuals instructing our Company; Personal Information included in correspondence, documents, or other materials that we process while providing services.
attendance records: details of meetings and other events organized by or on behalf of that you have attended.
consent records: records of any consents you may have given, together with the date and time, means of consent and any related information.
payment details: billing ; payment method; bank account number or card number; invoice records; payment records; IBAN details; payment amount; payment date; and records of cheques.
data relating to your visits to our website: your device type; operating system; browser type; browser settings; IP ; language settings; dates and times of connecting to a website; and other technical communications information.
Employer details: where you interact with us in your capacity as an employee of an organization, the name, , and email of your employer, to the extent relevant; and
content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages displayed to you, and any interaction you may have had with such content or advertising (including, but not limited to, mouse hover, mouse clicks and any forms you complete).

SENSITIVE PERSONAL INFORMATION AND PERSONAL INFORMATION OF CHILDREN
- Where we need to process your Sensitive Personal Information, we will do so in the ordinary course of our business, for a legitimate purpose, and in accordance with applicable law.
- In the unlikely event that we need to process Personal Information of Children, we will do so in the ordinary course of our business, for a legitimate purpose, and in accordance with applicable law.

PURPOSES OF PROCESSING AND LEGAL BASIS FOR PROCESSING
- We will process your Personal Information in the ordinary course of the business of providing our services. We will primarily use your Personal Information only for the purpose for which it was originally or primarily collected. We will use your Personal Information for a secondary purpose only if such purpose constitutes a legitimate interest and is closely related to the original or primary purpose for which the Personal Information was collected. We may subject your Personal Information to processing during various activities, including, without limitation, the following –
  - operating our business.
  - analysis, evaluation, review, and collation of information to fulfil our contracted obligations to our clients and client contracts, and provide professional advice, services, and recommendations (whether in electronic or any other medium whatsoever).
  - compliance with applicable law and fraud prevention.
  - attending to the legitimate interests of Data Subjects.
  - tracking Data Subject activity on the Company websites, various social media platforms and through direct transactions with the business.
  - transfer of information to our Service Providers and other third parties or
- We may process your Personal Information for relationship management and marketing purposes in relation to our services (including, but not limited to, processing that is necessary for the development and improvement of our services), for accounts management, and for marketing activities to establish, maintain and/or improve our relationship with you and with our Service Providers. We may also analyze your Personal Information for statistical purposes.
- We may process your Personal Information for internal management and management reporting purposes, including but not limited to conducting internal audits, conducting internal investigations, implementing internal business controls, providing central processing facilities, for insurance purposes and for management reporting analysis.
- We may process your Personal Information for safety and security purposes.

DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES
- We may disclose your Personal Information to our Associates and Service Providers, for legitimate business purposes, in accordance with applicable law and subject to applicable professional and regulatory requirements regarding confidentiality. In addition, we may disclose your Personal Information –
  - if required by law.
  - to legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation.
  - to third party Operators (including, but not limited to, data processors such as providers of data hosting services), located anywhere in the world, subject to 6.2.
  - where it is necessary for the purposes of, or in connection with, actual or threatened legal proceedings or establishment, exercise, or defense of legal rights.
  - to any relevant party for the purposes of the prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including, but not limited to, safeguarding against, and the prevention of threats to, public security.
  - to any relevant third-party acquirer(s), in the event that we sell or transfer all or any portion of our business or assets (including, but not limited to, in the event of a reorganization, dissolution or liquidation); and
  - to any relevant third-party provider, where our website uses third party advertising, plugins, or content.
- If we engage a third-party Operator to process any of your Personal Information, we recognize that any Operator who is in a foreign country must be subject to a law, binding corporate rules or binding agreements which provide an adequate level of protection similar to POPIA. We will review our relationships with Operators we engage and, to the extent required by any applicable law if force, we will require such Operators to be bound by contractual obligations to –
  - only process such Personal Information in accordance with our prior written instructions; and
  - use appropriate measures to protect the confidentiality and security of such Personal Information.

INTERNATIONAL TRANSFER OF PERSONAL INFORMATION
- We may transfer your Personal Information to recipients outside of the Republic of South Africa.
- Subject to 6.2, Personal Information may be transferred outside of the Republic of South Africa provided that the country to which the data is transferred has adopted a law that provides for an adequate level of protection substantially similar to POPIA, the Operator/third party undertakes to protect the Personal Information in line with applicable data protection legislation and the transfer is necessary in order to provide the legal and other related services that are required by

DATA SECURITY
- We implement appropriate technical and organizational security measures to protect your Personal Information that is in our possession against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, in accordance with applicable law.
- Where there are reasonable grounds to believe that your Personal Information that is in our possession has been accessed or acquired by any unauthorised person, we will notify the relevant regulator and you, unless a public body responsible for detection, prevention or investigation of offences or the relevant regulator informs us that notifying you will impede a criminal investigation.
- Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Information that is in our possession, we cannot guarantee the security of any information transmitted using the internet and we cannot be held liable for any loss of privacy occurring during such transmission.

DATA ACCURACY

The Personal Information provided to our business should be accurate, complete, and up to date. Should Personal Information change, the onus is on the provider of such data to notify of the change and provide us with accurate data. We will endeavour to monitor and keep Personal Information relevant and up to date, wherever possible, to the best of our knowledge.

DATA MINIMISATION

will restrict its’ processing of Personal Information to data which is sufficient for the fulfilment of the primary purpose and applicable legitimate purpose for which it was collected.

DATA RETENTION

shall only retain and store Personal Information for the period for which the data is required to serve its primary purpose or a legitimate interest or for the period required to comply with an applicable legal requirement, whichever is longer.

YOUR LEGAL RIGHTS (ACCESS TO YOUR PERSONAL INFORMATION)
- Data Subjects have rights under the South African POPI Act, and other laws, to have access to your Personal Information and to ask us to rectify, erase and restrict use of, any of it. You may also have rights to object to your Personal Information being used, to ask for the transfer of Personal Information you have made available to us and to withdraw consent to the use of your Personal Information.
- If you would like to access, amend, erase, or restrict use of any of your Personal Information, please contact the Information Officer by emailing .
- The Information Officer will provide you with a Personal Information Request Form to complete. Once the completed form has been received, the Information Officer will make every effort to verify the identity of the Data Subject prior to handing over any personal information. All requests will be processed and considered on an individual basis, and within a reasonable time.

COOKIES AND SIMILAR TECHNOLOGIES

We may process your Personal Information by our use of Cookies and similar technologies but only for the necessary function of our website. When you visit our website we may place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law.

DIRECT MARKETING
- We may process your Personal Information for the purposes of providing you with information regarding services that may be of interest to you. You may unsubscribe for free at any time.
- If you currently receive marketing information from us which you would prefer not to receive in the future, please email us at requesting to opt-out of all future communications.

COMPLAINTS, FEEDBACK AND INCIDENTS OR DATA BREACHES
- You may direct any feedback, complaints, data breach notifications, incident notifications and any requests to access, amend, erase, or restrict use of your Personal Information to the following:

The Information Officer

Attention:

Physical :

Telephone:

Email:

Where there is a complaint, incident or data breach identified, it should be brought to the attention of our Information Officer immediately. We will endeavour to investigate the data breach, incident and/ or complaint as a matter of priority.
Should you have any issues with the way in which we are processing your personal information, you are entitled to lodge a complaint with the Information Regulator, whose contact details are:

Complaint’s email: complaints.IR@justice.gov.za

General enquiries email: inforeg@justice.gov.za

Physical : JD House, 27 Stiemans Street, Braamfontein, Johannesburg, 2001

ANNEXURE A - DEFINITIONS

"Associates" means shareholders, subsidiaries and the directors, employees, and consultants of or of any of its subsidiaries.

"Cookie" means a small file that is placed on your device when you visit a website. In this Policy, a reference to a "Cookie" includes analogous technologies such as web beacons and clear Graphic Interchange Format files ("GIFs").

"Operator" means any person or entity that processes Personal Information on behalf of the Responsible Party.

“Person” means any natural or juristic person.

A “Record” is any recorded information regardless of the form or medium, in the possession or under the control of the entity irrespective of whether or not it was created by themselves.

A “Data Subject” means the person to whom personal information identifies.

"Personal Information" means information that is about any individual, or from which any individual is directly or indirectly identifiable, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that individual.

"POPIA" means the Protection of Personal Information Act 4 of 2013.

"Process", "Processing" or "Processed" means anything that is done with any Personal Information, whether by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

"Responsible Party" means the entity that decides how and why Personal Information is processed.

"Sensitive Personal Information" means Personal Information about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that may be deemed to be sensitive under applicable law.

"Service Provider" – third party providers of various services whom we engage, including, but not limited to, providers of information technology, communication, file storage, data storage, copying, printing, accounting, or auditing services, human resource consultation services, translators, taxation consultants and our insurers and professional advisors.

"Website" means any website operated, or maintained, by us or on our behalf.

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