Privacy Policy & POPIA Notice

This Privacy Policy explains how DKK Publishing collects, uses, stores, protects, shares and otherwise processes personal information.

Because our Platform is specifically designed to enable children to create and publish their own story books, protecting children’s personal information is particularly important to us.

DKK Publishing will process personal information in accordance with the Protection of Personal Information Act 4 of 2013 (“POPIA”) and other applicable South African laws.

This Privacy Policy applies to:

• Parents and Legal Guardians who register for the Platform;
• Children who use Child Accounts;
• customers purchasing books;
• Child Authors whose books are published;
• persons receiving royalties on behalf of Child Authors;
• visitors to the DKK Publishing website;
• persons contacting DKK Publishing;

persons subscribing to communications from DKK Publishing; and

other persons whose personal information is lawfully processed in connection with our business.

For purposes of POPIA, the responsible party is:

Registered in the Republic of South Africa

• Website:

www.dkkpublishing.com

Email:

info@dkkpublishing.com

Telephone:

+27 645158628

Business Hours:

08:30 to 16:30Monday to Friday

DKK Publishing will designate and, where required, register an Information Officer in accordance with applicable South African law.

• Information Officer:

Name: Keshree Naidoo

Email: compliance@dkkpublishing.com

Telephone: +27 64 515 8628

The Information Officer is responsible for overseeing DKK Publishing’s compliance with POPIA and handling appropriate privacy-related enquiries.

When a Parent or Legal Guardian registers, purchases a package or uses the Platform, we may collect information including:

• full name;
• surname;
• identity or verification information where reasonably required;
• residential or postal address;
• country;
• email address;
• mobile telephone number;
• account username;
• encrypted or securely protected authentication credentials;
• purchase information;
• package information;
• billing information;
• transaction information;
• communication history;
• customer support enquiries;
• royalty payment information;
• bank account information where necessary for royalty payments;
• tax-related information where legally required;
• consent records;
• proof approvals;

publishing instructions; and

technical information relating to use of the Platform.

DKK Publishing will endeavour to collect only information reasonably necessary for the relevant purpose.

Because children use the Platform, DKK Publishing may process limited personal information relating to a Child.

Depending on the services selected, this may include:

• first name;
• surname;
• age or date of birth where required;
• Child Account username;
• story title;
• written stories;
• sentences and words entered by the Child;
• creative ideas;
• selected story themes;
• original story concepts;
• book information;
• author information;
• publishing information;
• illustrations associated with the Child’s story;
• Child’s book purchase and sales information;

information necessary for royalty administration; and

technical information generated through use of the Child Account.

DKK Publishing will seek to minimise the amount of personal information collected directly from Children.

Children may not independently register for the Platform.

Registration must be completed by a Parent or Legal Guardian.

The Parent or Legal Guardian creates the Child’s username and password.

The Parent or Legal Guardian is responsible for authorising the Child’s use of the Platform.

The Child Account is designed as a restricted creative environment.

A Child Account is intended to provide access only to appropriate book-creation and educational functionality.

The Child will not have access through the Child Account to:

• the Parent’s residential address;
• the Parent’s payment details;
• bank account information;
• payment card information;
• billing information;
• Parent Account management;
• Parent password;

royalty banking details; or

other private Parent Account information that is not necessary for the Child to create a story.

Children’s personal information may be processed for purposes including:

• creating and operating the Child Account;
• allowing the Child to create a story;
• saving the Child’s story;
• allowing the Child to use picture-guided storylines;
• providing Educational Aids;
• preparing illustrations;
• editing and formatting a book;
• communicating with the Parent about the book;
• producing proofs;
• publishing the completed book;
• identifying the Child as the Author where authorised;
• ISBN administration where applicable;
• printing and manufacturing;
• distribution;
• book sales;
• royalty administration;
• protecting the security of the Platform;
• preventing misuse;

complying with legal obligations; and

other purposes reasonably necessary to provide the service requested by the Parent.

Children are not permitted to make payments through their Child Account.

Payment transactions must be completed through the Parent Account or another approved adult-controlled payment process.

The Child Account will not display the Parent’s payment credentials.

Payments may be processed through third-party payment service providers.

Depending on the payment method, DKK Publishing may not directly receive or store complete payment card details.

Payment providers may process personal information according to their own privacy policies and legal obligations.

DKK Publishing will select service providers using reasonable due diligence appropriate to the service being provided.

DKK Publishing will process the creative content submitted through the Platform in order to provide the publishing service.

This may include:

• titles;
• stories;
• descriptions;
• character ideas;
• written instructions;
• selected themes;
• custom story concepts;

uploaded content where permitted; and

communications concerning the story.

The Child’s original written story remains subject to the copyright provisions contained in DKK Publishing’s Terms and Conditions and Child Author Publishing & Royalty Agreement.

Where a Child uses a DKK Publishing preset theme, DKK Publishing may record:

• the selected theme;
• progress through the theme;

story text entered for each page; and

completed book information.

Preset illustrations, themes, templates and associated DKK content remain subject to DKK Publishing’s intellectual property rights.

Where a Child selects the Create Your Own Story/Theme option, DKK Publishing may process the Child’s written storyline so that illustrations and the completed book can be created.

The Parent acknowledges that relevant DKK Publishing personnel and approved service providers may need to access the story for production purposes.

Publishing a book normally requires certain information to become publicly associated with the publication.

With the Parent or Legal Guardian’s authorisation, information displayed publicly may include:

• Author name;
• book title;
• book cover;
• book description;
• ISBN;

publication details; and

information necessary to sell and identify the book.

The Parent may request, where reasonably possible, that the Child be identified using:

• first name only;

initials; or

an approved pen name.

The availability of these options may depend on publishing, ISBN, distribution and platform requirements.

DKK Publishing will not treat consent to publish a Child’s story as automatic consent to use photographs or video recordings of that Child for general promotional purposes.

Where DKK Publishing wishes to use an identifiable photograph or video of a Child for advertising, social media, testimonials or promotional campaigns, additional appropriate Parent or Legal Guardian consent should be obtained where required.

Where the Parent has authorised publication and marketing, DKK Publishing may use information relating to the book for purposes such as:

• displaying the book on the DKK Publishing website;
• displaying the cover;
• displaying the title;
• identifying the Author in the agreed manner;
• promoting the book;
• creating catalogue listings;
• promoting the book on social media;

supplying information to retailers or distributors; and

advertising availability of the book.

The extent of public Author information will be subject to the Parent’s selected author-identification option and applicable publishing requirements.

DKK Publishing may communicate with Parents concerning:

• account administration;
• purchases;
• story progress;
• proof approval;
• publication;
• book orders;
• royalty matters;
• security;

changes affecting the service; and

customer support.

Where required by law, separate consent will be obtained for direct electronic marketing.

Parents may opt out of marketing communications using the unsubscribe or opt-out mechanism provided.

Service-related communications necessary to administer an active account, transaction or publication may still be sent where lawful.

DKK Publishing does not intend to use Child Account contact information to send direct commercial marketing to Children.

Marketing communications relating to packages, upgrades, payments or commercial offers should be directed to the Parent or Legal Guardian.

The Platform may make Educational Aids available to paid users.

Information concerning downloads or access may be processed for purposes including:

• providing the resource;
• account administration;
• security;
• licence enforcement;

Platform improvement; and

determining which educational resources are useful to users.

When the website or Platform is used, certain technical information may be collected automatically, including:

• IP address;
• browser type;
• device type;
• operating system;
• date and time of access;
• pages accessed;
• session information;
• security logs;

error logs; and

cookie or similar technology information.

Such information may be used for security, fraud prevention, Platform operation, analytics and improvement.

The DKK Publishing website may use cookies and similar technologies.

Cookies may be used for:

• authentication;
• security;
• remembering preferences;
• Platform functionality;

analytics; and

other lawful purposes.

Where legally required, users will be provided with appropriate information and choices concerning non-essential cookies.

Further information may be contained in DKK Publishing’s Website, Cookie & Electronic Communications Policy.

DKK Publishing may process personal information for legitimate and lawful purposes including:

• creating accounts;
• authenticating users;
• providing purchased services;
• processing payments;
• producing books;
• communicating with Parents;
• providing customer support;
• publishing books;
• managing ISBN applications;
• printing;
• distribution;
• processing sales;
• calculating royalties;
• paying royalties;
• complying with tax and accounting obligations;
• maintaining business records;
• preventing fraud;
• securing the Platform;
• investigating misuse;
• improving the service;

complying with applicable laws; and

establishing, exercising or defending legal rights.

DKK Publishing will not sell personal information as a commodity.

Information may, however, be disclosed where reasonably necessary to service providers such as:

• website hosting providers;
• cloud service providers;
• software providers;
• payment processors;
• printers;
• book manufacturers;
• couriers;
• distributors;
• online marketplaces;
• retailers;
• accounting providers;
• professional advisers;

IT security providers; and

government or regulatory authorities where legally required.

Only information reasonably necessary for the relevant service should be shared.

Where another party processes personal information on behalf of DKK Publishing, DKK Publishing will take reasonable steps to ensure that appropriate confidentiality and security arrangements are in place as required by applicable law.

Some technology, hosting, cloud, payment, distribution or other service providers may operate outside South Africa.

Where personal information is transferred internationally, DKK Publishing will take reasonable steps to ensure that the transfer is handled in accordance with applicable requirements of POPIA.

Particular care will be taken where children’s information is involved.

DKK Publishing may use technology-assisted or artificial-intelligence-assisted tools for appropriate parts of the production process, including:

• illustration assistance;
• editing;
• layout;
• design;

quality control; and

production.

Where personal information or Child Content is processed through an external technology provider, DKK Publishing will consider the nature of the information, purpose of processing, contractual protections and applicable privacy requirements.

DKK Publishing should avoid providing unnecessary identifying information about a Child to an external AI service where the task can reasonably be completed without it.

DKK Publishing will take appropriate and reasonable technical and organisational measures designed to protect personal information against:

• loss;
• unauthorised access;
• unauthorised disclosure;
• destruction;

misuse; and

unlawful processing.

Security measures may include appropriate:

• access controls;
• passwords;
• encryption;
• secure hosting;
• backups;
• system monitoring;

staff confidentiality requirements; and

security procedures.

No internet-based system can guarantee absolute security.

Where DKK Publishing has reasonable grounds to believe that personal information has been accessed or acquired by an unauthorised person, DKK Publishing will respond in accordance with applicable POPIA requirements, including notifications where legally required.

DKK Publishing will retain personal information only for as long as reasonably necessary for the purpose for which it was collected or as required or permitted by law.

Different retention periods may apply to:

• Parent Accounts;
• Child Accounts;
• completed books;
• publishing records;
• ISBN information;
• sales records;
• royalty records;
• tax records;
• accounting records;
• consent records;

contracts; and

customer communications.

Information no longer required will be deleted, destroyed, de-identified or otherwise handled in accordance with applicable law and DKK Publishing’s retention procedures.

Closing an account does not necessarily require the deletion of every record associated with a published book.

DKK Publishing may need to retain information relating to:

• publication history;
• copyright;
• ISBN records;
• transactions;
• royalties;
• accounting;
• disputes;

legal compliance; and

previously manufactured or distributed copies.

Requests to withdraw a published book will be handled in accordance with the Child Author Publishing & Royalty Agreement.

Subject to applicable law, a person may request confirmation of whether DKK Publishing holds personal information about them and may request access to applicable records.

Requests should be directed to DKK Publishing’s Information Officer.

Where the information concerns a Child, DKK Publishing may require the Parent or Legal Guardian to verify their identity and authority before releasing information.

Parents may request correction or updating of inaccurate personal information.

Certain information may also be editable through the Parent Account.

Where an Author name or other information has already been incorporated into a printed or published book, changes may require a new production process, revised edition or other publishing action and may involve additional costs.

Subject to POPIA and other applicable laws, persons may have rights to:

• object to certain processing;
• request correction;

request deletion or destruction of information in appropriate circumstances; and

withdraw consent where processing depends upon consent.

Withdrawal of consent does not necessarily invalidate processing that lawfully occurred before withdrawal.

Certain information may have to be retained where DKK Publishing has a legal obligation or other lawful basis to retain it.

A Parent or Legal Guardian may contact DKK Publishing regarding personal information processed about their Child.

DKK Publishing may require verification of:

• the Parent’s identity;

the Child’s identity; and

the Parent or Guardian’s authority

before acting upon a request.

DKK Publishing does not intend to make significant legal or similarly significant decisions about Children solely through automated processing without appropriate safeguards where applicable.

Parents are responsible for providing accurate and current information.

Parents should update DKK Publishing when important account information changes.

The website may contain links to third-party websites.

DKK Publishing does not control the privacy practices of independent third-party websites.

Users should review the privacy policies of those services.

DKK Publishing may update this Privacy Policy from time to time to reflect:

• legal changes;
• regulatory requirements;
• new Platform functionality;

security requirements; or

changes to our business practices.

The latest version will be made available through the DKK Publishing website or Platform.

Where a material change affects previously granted consent or children’s information, DKK Publishing will take additional steps where required by law.

Privacy concerns should first be directed to:

Information OfficerDKK Publishing (PTY) Ltd

Email: complaints@dkkpublishing.com

A person may also have the right to lodge a complaint with the Information Regulator of South Africa in accordance with POPIA.

• Website:

www.dkkpublishing.com

Email:

info@dkkpublishing.com

Telephone:

+27 64 515 8628

Business Hours:

08:30 to 16:30Monday to Friday

This Privacy Policy should be read together with:

• Terms and Conditions of Use;
• Parental/Legal Guardian Consent;
• Child Author Publishing & Royalty Agreement;
• Copyright, Intellectual Property & User Content Policy;

Refund, Cancellation, Production & Delivery Policy; and

Website, Cookie & Electronic Communications Policy.

If there is an inconsistency, mandatory South African law will prevail to the extent of the inconsistency.