Privacy Policy

Responsible party	NOVATRONIC (PTY) LTD trading as Novatronic PCB
Registration number	2021/673316/07
Physical / registered address	75 KLIPKOP, TIERPOORT, PRETORIA, GAUTENG, 0056
Privacy / POPIA email	info@novatronic.co.za
Website	www.novatronic.co.za
Effective date	01 November 2026

1. PURPOSE AND SCOPE

This Privacy and POPIA Policy explains how Novatronic PCB (“Novatronic”, “we”, “us” or “our”) collects, uses, stores, shares, protects and otherwise processes personal information. It is intended to serve as a privacy notice in terms of the Protection of Personal Information Act 4 of 2013 (“POPIA”) and should be read together with our Website Terms & Conditions and any project-specific privacy or confidentiality notices.

This Policy applies to visitors to our website, prospective and existing customers, customer representatives, suppliers and manufacturer representatives, laboratory and logistics contacts, professional advisers, applicants, and other persons whose personal information we process in the course of our business.

POPIA may protect information relating to both natural persons and identifiable existing juristic persons. Novatronic applies this Policy accordingly where POPIA applies.

2. OUR PRIVACY PRINCIPLES

Accountability: we take responsibility for processing personal information lawfully and appropriately.
Minimality: we aim to collect only information that is adequate, relevant and not excessive for the stated purpose.
Purpose specification: information is collected for specific, defined and legitimate business purposes.
Further processing: secondary use should be compatible with the original purpose or otherwise permitted by law.
Information quality: reasonable steps are taken to keep relevant information complete, accurate and updated where necessary.
Openness: we aim to explain what we collect, why we collect it and how it is used.
Security safeguards: reasonable technical and organisational safeguards are used to protect information.
Data-subject participation: eligible persons may exercise applicable rights of access, correction, deletion and objection.

3. PERSONAL INFORMATION WE MAY COLLECT

Identity and contact information: name, surname, job title, employer/company, business address, telephone number and email address.
Account and commercial information: customer/supplier number, quotation and order history, invoices, payment status, VAT and billing information, and relevant business correspondence.
RFQ and project information: contact details contained in quotation requests, manufacturing files, drawings, specifications, BOMs, technical queries, quality records, test reports and project communications.
Supplier and qualification information: contact persons, capability questionnaires, certifications, audit/qualification records and supporting evidence.
Website and device information: IP address, browser/device information, website activity, referral information and cookie/analytics data where enabled.
Communication information: emails, enquiries, meeting records, support requests, feedback and marketing preferences.
Recruitment or contractor information, if applicable: CV, qualifications, experience, references and other information voluntarily provided for a legitimate recruitment or contracting purpose.

Novatronic does not intentionally seek special personal information or children’s personal information through its ordinary B2B website and RFQ process. If such information is required for a lawful purpose, it will be handled in accordance with applicable POPIA requirements.

4. HOW WE COLLECT INFORMATION

Directly from you when you use our website, contact us, submit an RFQ, upload files, request information, place an order, complete a supplier questionnaire, subscribe to communications or otherwise correspond with us.
From the organisation you represent, where your details are supplied as a business contact.
From Manufacturers, laboratories, logistics providers and other project participants where necessary to manage a quotation, order, quality matter or delivery.
From publicly available business sources, professional directories, company websites and lawful business-development sources.
Automatically through website technologies such as server logs and, where configured, cookies or analytics tools.

5. WHY WE PROCESS PERSONAL INFORMATION

To respond to enquiries and RFQs and communicate with prospective customers.
To prepare quotations, assess manufacturability and coordinate technical reviews.
To perform contracts, manage purchase orders, procure/manufacture PCBs, coordinate testing, quality documentation, logistics and delivery.
To qualify and manage PCB Manufacturers, laboratories, suppliers and other service providers.
To administer accounts, invoicing, payments, tax, audit and record-keeping obligations.
To protect confidential information, intellectual property, systems, website security and business operations.
To investigate quality issues, non-conformances, complaints, warranty matters and disputes.
To improve our website, services, technical resources and customer experience.
To send permitted business communications and marketing, subject to applicable law and communication preferences.
To comply with legal, regulatory, contractual, export-control, sanctions, security and lawful information-request obligations.

6. LAWFUL JUSTIFICATION FOR PROCESSING

Depending on the circumstances, Novatronic may process personal information with consent; where processing is necessary to conclude or perform a contract; where processing complies with an obligation imposed by law; where processing protects a legitimate interest of the data subject; or where processing is necessary to pursue the legitimate interests of Novatronic or a third party, subject to POPIA.

Where consent is the basis for processing, consent may generally be withdrawn, but withdrawal does not invalidate lawful processing already undertaken and may affect our ability to provide a service where the information is necessary.

7. RFQ, PCB MANUFACTURING AND TECHNICAL FILES

Novatronic’s RFQ and managed-manufacturing process may involve the submission of technical files that contain names, email addresses, approval details or other personal information. Technical design data itself may also be confidential or commercially sensitive even where it is not personal information.

We use project information only as reasonably necessary to quote, review, manufacture, test, inspect, qualify, document, deliver and support the relevant project, or for another compatible or legally permitted purpose.

Customers should not include unnecessary personal information in Gerber, ODB++, IPC-2581, drill, drawing, BOM, CAD or related manufacturing files. Classified, export-controlled or unusually sensitive data should not be submitted through ordinary website or email channels unless an appropriate transfer and handling method has first been agreed.

8. SHARING OF INFORMATION

Novatronic may share relevant information with parties who reasonably need it to perform the applicable business purpose, including:

qualified or proposed PCB Manufacturers and other production suppliers;
independent test and inspection laboratories;
couriers, freight forwarders, customs and logistics providers;
website hosting, cloud storage, email, cybersecurity, analytics, CRM, accounting and IT service providers;
banks, payment providers, auditors, accountants, insurers, legal advisers and other professional advisers;
regulators, law-enforcement authorities, courts or other persons where disclosure is required or permitted by law.

We aim to limit disclosures to information reasonably necessary for the purpose and to use appropriate contractual, confidentiality and security measures where required.

9. OPERATORS AND SERVICE PROVIDERS

Where a third party processes personal information for Novatronic as an operator, Novatronic will seek to use providers capable of applying appropriate safeguards and, where required, contractual terms addressing confidentiality and security. Service providers may only process information within the scope of their authorised service, subject to applicable law.

10. CROSS-BORDER PROCESSING

Because Novatronic may work with international PCB Manufacturers, laboratories, cloud or technology providers, information may in some circumstances be transferred to or accessed from countries outside South Africa.

Cross-border transfers of personal information will be managed in accordance with section 72 of POPIA, including where the recipient is subject to adequate protection, the data subject consents, or another lawful basis for the transfer applies. Where appropriate, contractual safeguards and due diligence may be used.

Customers must identify before submission any project data subject to defence, dual-use, export-control, classified-information or other restrictions that could prohibit or limit international transfer.

11. INFORMATION SECURITY

Novatronic uses reasonable and appropriate technical and organisational measures designed to protect personal information against loss, damage, unauthorised destruction, unlawful access, interference, modification or disclosure. Measures may include access controls, authentication, endpoint and network security, backups, secure cloud/service-provider controls, confidentiality obligations, restricted file access and security-aware operating procedures.

No electronic transmission or storage system is completely risk-free. Customers and suppliers should use agreed secure channels for sensitive information and maintain their own source-data backups.

12. SECURITY INCIDENTS

If Novatronic has reasonable grounds to believe that personal information has been accessed or acquired by an unauthorised person, we will assess and manage the incident and provide notifications to the Information Regulator and affected data subjects where required by POPIA, subject to lawful restrictions on notification.

13. RETENTION AND DELETION

Personal information is retained only for as long as necessary to achieve the purpose for which it was collected, to meet legal, tax, contractual, quality, traceability, warranty, dispute or legitimate record-keeping requirements, or as otherwise permitted by law.

Retention periods may differ by record type. PCB project and quality records may need to be retained for longer periods where required by customer contract, applicable standards, traceability obligations or high-reliability industry requirements.

When information is no longer required and there is no lawful reason to retain it, Novatronic will take reasonable steps to delete, destroy or de-identify it.

14. INFORMATION QUALITY

We take reasonably practicable steps to maintain accurate, complete and relevant personal information, having regard to the purpose for which it is processed. Please notify us when important contact or account information changes.

15. COOKIES AND WEBSITE ANALYTICS

The Novatronic website may use essential cookies required for website operation and may use analytics, preference or marketing technologies if configured. A cookie is a small data file stored or accessed by a website through a browser or device.

Where legally required, non-essential cookies or similar tracking technologies should be activated only in accordance with the user’s choices. The website should provide an appropriate cookie notice or consent mechanism reflecting the technologies actually deployed.

Browser settings can often be used to block or delete cookies, although disabling essential cookies may affect website functionality.

16. DIRECT MARKETING

Novatronic may communicate with business contacts about relevant PCB services, technical resources, events or company updates where permitted by law. Electronic direct marketing will be conducted in accordance with POPIA and other applicable South African law.

Where consent is required, Novatronic will seek it in the prescribed manner. Marketing communications should provide a reasonable method to opt out or unsubscribe, and valid objections or opt-out requests will be respected.

17. YOUR RIGHTS UNDER POPIA

Subject to POPIA and any applicable limitations, a data subject may have the right to:

ask whether Novatronic holds personal information about them and request access to that information;
request correction or deletion of personal information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or unlawfully obtained;
object, on reasonable grounds where applicable, to certain processing;
withdraw consent where processing is based on consent;
object to direct marketing and request that marketing communications stop;
request information about third parties or categories of third parties that have had access to their personal information where POPIA provides for this;
lodge a complaint with the Information Regulator.

Requests may be subject to identity verification and the procedures or grounds for refusal permitted under POPIA and PAIA. Certain records may need to be retained despite a deletion request where retention is required or permitted by law.

18. HOW TO EXERCISE YOUR RIGHTS

Privacy requests should be sent to the Privacy / POPIA email address stated at the beginning of this Policy and marked for the attention of the Information Officer. Please provide enough information for us to identify you, understand the request and locate the relevant records.

Novatronic may request reasonable proof of identity or authority before disclosing or changing personal information. We will respond in accordance with applicable legal requirements.

19. INFORMATION OFFICER

Novatronic’s Information Officer is responsible for encouraging and overseeing compliance with POPIA and PAIA within the organisation. The Information Officer details shown at the beginning of this Policy must be completed before publication and the applicable Information Officer must be registered with the Information Regulator as required.

20. COMPLAINTS TO THE INFORMATION REGULATOR

If you believe your personal information has been processed in breach of POPIA, you may first contact Novatronic so that we can investigate the matter. You also have the right to lodge a complaint with the Information Regulator (South Africa).

Information Regulator (South Africa): Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg; telephone 010 023 5200; email enquiries@inforegulator.org.za. Current contact details and complaint channels should be confirmed on the Information Regulator’s official website before use.

21. THIRD-PARTY WEBSITES

Our website may link to third-party websites. Their privacy practices are governed by their own policies, and Novatronic is not responsible for third-party privacy or security practices merely because a link appears on our website.

22. CHANGES TO THIS POLICY

Novatronic may update this Policy when our services, systems, legal obligations or privacy practices change. The current version and effective date will be published on the website. Material changes may be communicated through an appropriate additional notice where reasonably required.

23. CONTACT

For privacy questions, access/correction requests, objections, consent withdrawal or other POPIA matters, contact the Novatronic Information Officer using the details at the beginning of this Policy.