Last updated: 24 March 2025
POLICY STATEMENT
This policy outlines how Modern Influence Society LLC collects, uses, stores, and protects personal information. It applies to all staff, contractors, service providers, and any third party acting on behalf of the company.
Modern Influence Society LLC is committed to safeguarding the privacy of clients, employees, and stakeholders. We take reasonable and appropriate steps to protect personal information in compliance with applicable U.S. privacy laws and industry standards.
All persons handling data on behalf of the company are expected to adhere to this policy and support ongoing protection efforts.
1. INTRODUCTION
The right to privacy is a fundamental principle. While we operate under U.S. law, we recognize the broader importance of data protection, transparency, and responsible data practices.
In delivering AI-powered services, strategy, software, and digital content, Modern Influence Society LLC collects and processes personal information from clients, partners, vendors, contractors, and users. This information is handled with care, stored securely, and only processed for legitimate business purposes.
2. SCOPE
This policy applies to:
• All business units of Modern Influence Society LLC
• All staff, vendors, contractors, and any individuals handling personal data on behalf of the company
• All clients, subscribers, partners, and site users who share personal information with us
Modern Influence Society LLC is considered the data controller for information collected directly through its systems, forms, software, platforms, and service engagements. In select instances, we may also serve as a data processor acting on behalf of client instructions.
The principles in this policy apply regardless of the format or location of the personal information collected (online or offline, U.S. or international).
Perfect—thanks for the clarification. We’ll keep the Protection of Personal Information Policy grounded in POPIA, with acknowledgment of the company’s U.S. registration and global operations. Here’s the next section with that context baked in:
3. DEFINITIONS
The following terms are used in line with the Protection of Personal Information Act 4 of 2013 (“POPIA”):
3.1 Personal Information
Any information that can be used to identify a person, including but not limited to:
• Name, contact details, ID numbers, location data
• Email addresses, phone numbers, physical addresses
• Employment, medical, financial, or educational records
• Opinions, preferences, or confidential correspondence
3.2 Data Subject
The natural or juristic person (individual or company) to whom the personal information relates.
3.3 Responsible Party
Modern Influence Society LLC, as the entity determining the purpose and means for processing personal information.
3.4 Operator
A third party processing personal information on behalf of the Responsible Party under contract or mandate.
3.5 Information Officer
The individual appointed by Modern Influence Society LLC to ensure POPIA compliance, handle data subject requests, and communicate with the South African Information Regulator.
3.6 Processing
Any operation or activity involving personal information, including collecting, recording, organizing, storing, updating, using, distributing, or deleting such data.
3.7 Record
Any recorded information, regardless of format (physical or electronic), that includes personal information.
3.8 Filing System
A structured set of personal information accessible according to specific criteria.
3.9 Unique Identifier
A reference (such as an account or ID number) assigned to uniquely identify a data subject within our systems.
3.10 Consent
Voluntary, specific, and informed agreement by the data subject allowing Modern Influence Society LLC to process their personal information.
3.11 Direct Marketing
Any approach to a data subject (by phone, email, or otherwise) to promote or offer goods/services or solicit donations.
3.12 De-identify / Re-identify
Removing or restoring identifiable links to a data subject within processed personal information.
3.13 Biometrics
Personal identifiers based on physical or behavioral traits (e.g., fingerprinting, voice recognition, retinal scans).
4. POLICY PURPOSE
This policy exists to protect Modern Influence Society LLC from the legal, operational, and reputational risks associated with mishandling personal information. The purpose is to:
• Ensure compliance with the Protection of Personal Information Act (POPIA) in South Africa.
• Promote responsible data governance across all business units and international operations.
• Create internal processes that respect the privacy rights of data subjects, including clients, employees, and contractors.
This policy supports the following outcomes:
• Confidentiality – Preventing unauthorized disclosure of personal information.
• Choice – Allowing individuals to control how their data is collected and used.
• Reputation – Avoiding reputational damage by demonstrating data protection leadership and good governance.
Modern Influence Society LLC is committed to:
• Aligning internal processes with the requirements of POPIA;
• Appointing and empowering an Information Officer to oversee compliance;
• Providing training to employees and stakeholders on data protection practices;
• Managing risk by implementing safeguards, procedures, and regular reviews;
• Giving effect to the privacy rights of data subjects in every relevant interaction.
5. POLICY APPLICATION
This policy applies to the following:
• All divisions, business units, and operations of Modern Influence Society LLC;
• All employees, contractors, freelancers, and consultants;
• All service providers and partners who process personal information on our behalf;
• All stakeholders who submit, share, or interact with personal data through our platforms or systems.
This policy must be read in conjunction with:
• The Protection of Personal Information Act 4 of 2013 (South Africa);
• The Promotion of Access to Information Act (PAIA) where applicable;
• Other global data protection frameworks (e.g., GDPR, CCPA) when dealing with international clients or partners.
POPIA applies when:
• Personal information is processed;
• The information is recorded in any form (digital or physical);
• The Responsible Party (Modern Influence Society LLC) or the data subject is domiciled in South Africa.
POPIA does not apply when:
• The data is de-identified; or
• The information is processed in a purely personal or household context.
6. RIGHTS OF DATA SUBJECTS
Modern Influence Society LLC is committed to respecting and enforcing the rights of data subjects under the Protection of Personal Information Act (POPIA). Where applicable, we will ensure the following rights are upheld:
6.1 The Right to Access Personal Information
Data subjects have the right to know whether we hold their personal information and, if so, to request access to it. Upon request, we will provide confirmation of the information held and the purpose for which it is processed.
6.2 The Right to Have Personal Information Corrected or Deleted
Data subjects may request correction or deletion of their personal information if it is inaccurate, irrelevant, excessive, outdated, incomplete, or obtained unlawfully—or if the company is no longer authorized to retain it.
6.3 The Right to Object to Processing
A data subject has the right to object—on reasonable grounds—to the processing of their personal information. If such an objection is raised, we will evaluate it in the context of legal and contractual obligations and may cease processing if justified.
6.4 The Right to Object to Direct Marketing
Data subjects have the right to object to their personal information being used for direct marketing purposes. Once a data subject has opted out, Modern Influence Society LLC will stop sending marketing communication.
6.5 The Right to Lodge a Complaint
Data subjects have the right to lodge a complaint with the Information Regulator of South Africa if they believe that any of their rights under POPIA have been infringed upon.
6.6 The Right to Be Informed
Data subjects have the right to be notified when:
• Their personal information is being collected;
• Their personal information has been accessed or acquired by an unauthorized person (data breach).
7. GENERAL GUIDING PRINCIPLES
All employees, contractors, and third parties acting on behalf of Modern Influence Society LLC are expected to follow these core principles when processing personal information. These principles are aligned with POPIA and support a culture of compliance and trust.
7.1 Accountability
The company accepts full responsibility for ensuring that personal information is processed in compliance with POPIA. Each individual involved in data handling is expected to adhere to this policy, and disciplinary or contractual consequences may apply for negligence or willful non-compliance.
7.2 Processing Limitation
We will only process personal information:
• In a lawful, fair, and minimal way;
• For clearly defined and legitimate purposes;
• When relevant to the stated objective of the data collection.
We will not process personal information for unrelated or secondary purposes without proper legal justification or data subject consent.
7.3 Purpose Specification
Data will be collected only for specific, explicitly defined, and lawful purposes that are clear to the data subject. Where required, consent will be obtained before or during collection.
7.4 Further Processing Limitation
Personal information will not be processed further in a manner incompatible with the original purpose of collection. If additional processing is necessary, we will ensure the new purpose is reasonably related or obtain fresh consent from the data subject.
7.5 Information Quality
We take reasonable steps to ensure personal information is complete, accurate, not misleading, and updated where necessary. Where possible, we will confirm information directly with the data subject.
7.6 Openness and Communication
Modern Influence Society LLC promotes transparency by informing data subjects when their information is collected, how it will be used, and with whom it may be shared. A publicly accessible “Contact Us” mechanism is maintained for privacy-related queries, access requests, and updates.
7.7 Security Safeguards
We implement reasonable technical and organizational security measures to protect personal information from:
• Loss or destruction;
• Unauthorized access, use, modification, or disclosure.
Security controls are reviewed regularly, and more stringent measures are applied to sensitive personal information.
7.8 Data Subject Participation
We provide mechanisms for data subjects to access, update, correct, or delete their personal information. Unsubscribe links are provided in marketing communications, and correction/update processes are available via our contact portal or support team.
8. INFORMATION OFFICERS
Modern Influence Society LLC will appoint an Information Officer, and where necessary, Deputy Information Officers, responsible for ensuring the organization’s compliance with POPIA.
The responsibilities of the Information Officer include:
• Monitoring and enforcing this policy;
• Serving as the main contact for all POPIA-related inquiries;
• Overseeing employee training and awareness efforts;
• Managing data subject access and complaint processes;
• Liaising with the Information Regulator in South Africa;
• Ensuring third-party agreements involving data processing include adequate privacy clauses.
The Information Officer will be registered with the Information Regulator prior to executing any official duties under POPIA.
9. SPECIFIC DUTIES AND RESPONSIBILITIES
9.1 Governing Body
The company’s leadership remains ultimately accountable for POPIA compliance. While tasks may be delegated, accountability for enforcement, risk oversight, and resourcing remains with the governing body.
The governing body ensures:
• Appointment of an Information Officer;
• Adequate supervision of all data processing activities;
• Awareness among employees of their privacy responsibilities;
• Mechanisms for handling data access and breach notifications;
• A recurring review process to assess compliance and risk exposure.
9.2 Information Officer
The Information Officer is responsible for:
• Ensuring the organization meets all legal requirements under POPIA;
• Reporting breaches to both the Regulator and affected data subjects;
• Regularly reviewing and updating privacy policies and processes;
• Approving contracts and service agreements involving data sharing;
• Ensuring internal controls for lawful data processing are functioning;
• Providing training and responding to employee or public inquiries.
9.3 IT Manager
The IT Manager is responsible for implementing and maintaining secure systems that handle personal information. This includes:
• Ensuring that servers, storage, and cloud platforms meet security best practices;
• Backing up personal data regularly and protecting backups against loss or unauthorized access;
• Encrypting sensitive data and securing transmission channels;
• Limiting system access to authorized users;
• Detecting and reporting attempted breaches;
• Supporting the Information Officer during audits or investigations;
• Performing due diligence when contracting with external platforms or processors.
9.4 MARKETING & COMMUNICATION MANAGER
The Marketing & Communication Manager is responsible for ensuring that all communications and public-facing materials comply with POPIA. This includes:
• Reviewing and maintaining privacy notices, disclaimers, and consent language across all marketing channels;
• Ensuring that all email campaigns, forms, and promotional materials include appropriate consent mechanisms;
• Coordinating with service providers to ensure compliance in outsourced marketing activities;
• Responding to data privacy inquiries from media or public-facing platforms.
9.5 EMPLOYEES AND OTHER PERSONS ACTING ON BEHALF OF THE ORGANIZATION
All employees, contractors, or third parties working with or on behalf of Modern Influence Society LLC are responsible for upholding the confidentiality and security of personal information.
Key responsibilities include:
• Only accessing personal information as necessary for specific job-related tasks;
• Never storing personal data on personal devices or unauthorized platforms;
• Locking screens, devices, and storage when unattended;
• Avoiding informal sharing (e.g., over unsecured email);
• Encrypting sensitive data before transmission;
• Reporting suspected breaches immediately to the Information Officer;
• Ensuring that consent is properly obtained before processing;
• Participating in training sessions related to privacy and data protection.
Failure to adhere to this policy may result in disciplinary action, including termination of contract or employment.
10. POPI REVIEW
The Information Officer will coordinate annual POPI reviews to:
• Audit data collection, usage, and storage practices;
• Identify gaps in compliance;
• Assess new risks or changes in the business structure;
• Confirm ongoing employee and contractor adherence to policy;
• Adjust internal controls and technical safeguards as needed.
These reviews will involve input from relevant managers (e.g., IT, legal, HR, marketing) and be reported to the company’s leadership. Any significant findings will be acted upon immediately.
11. REQUEST TO ACCESS PERSONAL INFORMATION PROCEDURE
Data subjects have the right to:
• Request details about the personal information Modern Influence Society LLC holds about them;
• Understand why the data is collected and how it is used;
• Request correction, update, or deletion of inaccurate or outdated information.
Access Request Process:
• Requests must be submitted via email to the Information Officer.
• The Information Officer will provide a Personal Information Request Form to the data subject.
• Once completed, the requester must return the form with sufficient verification of identity.
• The Information Officer will process the request within a reasonable timeframe and in accordance with the Promotion of Access to Information Act (PAIA).
12. POPI COMPLAINTS PROCEDURE
Data subjects may submit a complaint if they believe that their rights under POPIA have been violated.
Complaints Process:
1. Complaints must be submitted in writing to the Information Officer.
2. The Information Officer will confirm receipt within 2 working days.
3. The complaint will be reviewed and investigated fairly and thoroughly.
4. A response, including a proposed resolution or justification for dismissal, will be issued within 7 working days of receiving the full complaint.
5. Where applicable, remedial action may include an apology, correction of records, or disciplinary measures.
6. If the complainant is not satisfied with the outcome, they may escalate the matter to the Information Regulator of South Africa.
13. DISCIPLINARY ACTION
Non-compliance with this policy may result in serious consequences, including:
• For employees: Disciplinary action up to and including termination of employment;
• For contractors and third parties: Termination of agreements and legal claims for damages;
• For incidents involving gross negligence or willful misconduct: Immediate dismissal or contract cancellation.
Examples of disciplinary triggers:
• Unauthorized sharing or disclosure of personal information;
• Accessing or storing data without valid purpose;
• Failure to report a known breach;
• Misuse of company systems to bypass safeguards.
The organization may also refer serious breaches to law enforcement or pursue recovery of damages where applicable.
14. AMENDMENTS TO THIS POLICY
Modern Influence Society LLC reserves the right to update or amend this policy as needed to:
• Reflect changes in legislation, including amendments to POPIA or other applicable privacy laws;
• Respond to operational, structural, or technological changes within the company;
• Improve data protection practices based on review findings or incident responses.
Policy reviews will take place at least annually, or more frequently if required. The most recent version of the policy will always be available on our official website.
Material changes will be communicated via email, website notification, or other appropriate channels. By continuing to engage with our services after any amendments, you agree to the revised terms.
15. REFERENCES
This policy is based on and aligns with the following legislation and best practice guidelines:
• Protection of Personal Information Act 4 of 2013 (South Africa)
• Promotion of Access to Information Act 2 of 2000 (South Africa)
• Electronic Communications and Transactions Act 25 of 2002 (South Africa)
• Internal procedures and compliance standards of Modern Influence Society LLC
