Afeleton Proprietary Limited trading as “Howler”, with registration number 2009/016028/07 (“Company”, “Howler”, “we”, “us” or “our”), a limited liability company registered in and acting in accordance with the laws of South Africa, respects your privacy and is committed to protecting your personally identifiable information (“Personal Information”).
Howler International Limited trading as “Howler”, with company number 12735853 (“Company”, “Howler”, “we”, “us” or “our”), limited by shares and acting in accordance with the laws of England and Wales, respects your privacy and is committed to protecting your Personal Information.
Howler Europe B.V., with company number 90098951 (“Company”, “Howler”, “we”, “us” or “our”), limited liability and acting in accordance with the laws of the Netherlands, respects your privacy and is committed to protecting your Personal Information.
This Privacy Policy informs you how we look after and process your Personal Information when you provide it to us, or when it is collected from you, for example when using our Website, mobi-sites, software applications accessible at www.howler.co.za or www.howler.events (the “Website”), ticketing and product platform (“Platform”) and mobile application (“App”). It also applies when you have subscribed to any of the services we offer (“Services”), whether as ‘Howler User Account’ users (“Users”) or ticket or product sellers.
This Privacy Policy also explains your privacy rights and how the law protects your Personal Information. By accepting this Policy, accessing our Website or using our Services, you are regarded as having read, understood and agreed to be bound by this Policy.
This Policy was last updated on 03 August 2020.
This Privacy Policy complies with the European Commission’s General Data Protection Regulation (GDPR) and the South African Protection of Personal Information Act (POPI).
Due to the nature of our services as a payment and facilitation platform, we process both general and special categories of Personal Information, including Financial Data.
You should read this Policy together with any other privacy notices we provide on specific occasions when collecting or processing your Personal Information. This Privacy Policy supplements those notices and does not override them.
You may not submit any other person’s Personal Information to Howler and warrant that any data you provide is your own and lawfully yours to provide.
Howler is the data controller and responsible for your Personal Information when we decide how and why it is processed. Sometimes, we also operate as a data processor on behalf of third-party data controllers, in which case that party’s privacy terms will apply.
Full Name of Legal Entity:
Afeleton Proprietary Limited, Howler International Limited t/a Howler, and Howler Europe B.V.
Data Representative:
Chris Reeves
Addresses:
Oxford Gate, Hyde Lane Office Park, Hyde Park, Gauteng, South Africa, 2194
GRB115-14 2 Eastbourne Terrace, London, United Kingdom, W2 6LG
Jacob Van Lennepkade 28-0, 1053 MK Amsterdam, Netherlands
Telephone: +27 (11) 880 2199
Email: data@howler.co.za
You have the right to lodge a complaint with your local data protection authority (such as the Information Regulator of South Africa or the UK Information Commissioner’s Office). However, please contact us first so that we can address your concerns.
We may amend this Policy at any time by posting a revised version on our Website. The revised version applies to all Data Subjects once published.
This version was last updated on 03 August 2020. Previous versions can be requested from us.
Please ensure that the Personal Information we hold about you is accurate and current.
Our Website may include links to third-party websites, plug-ins and applications. Clicking on these links may allow third parties to collect or share data about you. We are not responsible for these websites or their privacy policies. We encourage you to read each third-party privacy policy you interact with.
Personal Information refers to any information about an individual that can identify them. We collect various types of Personal Information, including:
Identity Data: Names, ID numbers, date of birth, passport numbers, company details, and authentication tokens.
Contact Data: Addresses, email addresses, phone numbers, and social media contacts.
Financial Data: Payment details, card data, bank information, and transaction identifiers.
Transaction Data: Details about payments, contracts, fees, invoices, and subscriptions.
Social Media Data: Publicly available profile data, posts, photos, likes, and followers.
Technical Data: IP addresses, browsing activity, cookies, system information, and device data.
Profile Data: Usernames, preferences, feedback, and survey responses.
Biometric Data: Age, gender, and derived profile information.
Usage Data: Information on how you use our Website, tools, and events.
Marketing and Communications Data: Preferences in receiving marketing and communications from us.
We may also process aggregated or non-personal statistical data for analytical purposes.
We collect certain Special Categories of Personal Information, such as Financial Data and data relating to minors, with your express consent and in compliance with applicable laws.
If you fail to provide data we require by law or contract, we may not be able to offer our Services to you.
We may use cookies to collect usage data and enhance your experience. You can modify cookie settings in your web browser at any time.
We collect data in several ways:
You may provide Personal Information by filling in forms, subscribing to Services, making payments, or corresponding with us directly.
We automatically collect certain Technical Data through cookies and analytics tools when you interact with our Website or App.
We may receive Personal Information from third-party service providers such as analytics, payment, and marketing partners, or from public sources.
We only use your Personal Information when permitted by law, typically to perform a contract, comply with legal obligations, or for legitimate business interests. By accepting this Policy, you expressly consent to our processing of your data.
We use your Personal Information to:
Provide and improve our Services
Process payments and transactions
Manage user relationships and communication
Conduct market research and analytics
Deliver marketing communications and advertisements
Maintain Website security and system integrity
We may process your data for multiple legal bases depending on context.
We may use your data to inform you about Howler events, services, or offers that may interest you. You can opt-out of marketing messages at any time through your profile settings or via opt-out links.
We will not share your data with external companies for public marketing purposes without your express consent.
We may share your Personal Information with:
Other companies within the Howler group
Third-party service providers who process data on our behalf
Regulators, auditors, or professional advisors when legally required
Business partners or successors in the event of a merger or acquisition
We require all third parties to process your data lawfully and securely.
Your data may be transferred outside South Africa or the EU within the Howler group or to trusted partners. We ensure equivalent protection through approved safeguards such as European Commission standard contractual clauses or adequacy decisions.
We maintain industry-standard physical, electronic and procedural safeguards to protect your Personal Information.
Access is restricted to employees and agents who require it for legitimate business purposes and who are bound by confidentiality obligations.
You are responsible for keeping your password secure. We will never ask for your password via unsolicited communication.
You can review or edit your Personal Information through your Howler account at any time.
To delete your profile or account:
Mobile App: Delete the App from your device(s).
Website Account: Email us at data@howler.co.za to request deactivation.
Some data may remain viewable or must be retained to comply with legal obligations (e.g. financial regulations).
We retain your Personal Information only as long as necessary for legal, contractual, and operational purposes. Retention duration depends on data type and applicable laws.
You may request deletion of your data, subject to legal retention requirements.
Non-personal or de-identified data that cannot identify you may be collected and used freely for analytics or reporting. Information disclosed publicly (e.g. on forums or social media) is not covered by this Policy.
You have the following rights regarding your Personal Information:
Access and receive a copy of your data
Request correction or erasure
Object to processing
Restrict or transfer processing
Withdraw consent at any time
We may need to verify your identity before fulfilling requests. We aim to respond within one month.
There is generally no fee for exercising your rights unless the request is excessive or repetitive.
Legitimate Interest: Our lawful interest in conducting and managing our business while respecting your rights.
Performance of Contract: Processing required to perform our contractual obligations to you.
Legal Obligation: Processing required for compliance with applicable laws.
Express Consent: Your confirmed consent to the processing of your data by accepting this Privacy Policy.
Internal Third Parties: Other Howler entities acting as controllers or processors that provide IT, system, or reporting services.
External Third Parties:
Service providers, credit bureaus, banking partners, financial institutions, regulators, legal authorities, and professional advisors as required by law or contract.
If you have any questions or concerns about this Policy, please contact us at data@howler.co.za or call +27 (11) 880 2199.
We will notify you promptly of any unauthorized use or breach of your Personal Information.
If you become aware of such a breach, contact us immediately at data@howler.co.za
