The 1938 Group

The 1938 Group

Privacy Policy

Privacy Policy

Privacy Policy

This policy explains how The 1938 Group, a South African organisation, collects and uses personal information, how Google may collect usage data through our website, and how CookieYes helps manage cookie consent for EU and other visitors.

This policy explains how The 1938 Group, a South African organisation, collects and uses personal information, how Google may collect usage data through our website, and how CookieYes helps manage cookie consent for EU and other visitors.

Last updated: 21 July 2026

Last updated: 21 July 2026

The 1938 Group is based in South Africa and is committed to protecting personal information in line with the Protection of Personal Information Act, 2013 (POPIA). Where our website is accessed from the European Union or European Economic Area, we also aim to manage consent and related privacy choices in line with applicable EU data-protection and ePrivacy requirements.

The 1938 Group is based in South Africa and is committed to protecting personal information in line with the Protection of Personal Information Act, 2013 (POPIA). Where our website is accessed from the European Union or European Economic Area, we also aim to manage consent and related privacy choices in line with applicable EU data-protection and ePrivacy requirements.

1. Information we collect

1. Information we collect

We may collect personal information that you provide directly, such as your name, email address, phone number, organisation name, and the contents of messages submitted through our contact forms. We may also collect technical and usage information, including browser type, device information, approximate location derived from technical data, pages visited, referral sources, and interactions with the website. Google services used on the site may collect usage, device, and analytics data in accordance with Google’s own policies and settings.

We may collect personal information that you provide directly, such as your name, email address, phone number, organisation name, and the contents of messages submitted through our contact forms. We may also collect technical and usage information, including browser type, device information, approximate location derived from technical data, pages visited, referral sources, and interactions with the website. Google services used on the site may collect usage, device, and analytics data in accordance with Google’s own policies and settings.

2. How we use your information

2. How we use your information

We use personal information to respond to enquiries, provide advisory and training services, manage client relationships, improve our website, understand service demand, measure website performance, and meet legal or administrative obligations. We do not sell personal information. Google-generated analytics and measurement data may be used to understand traffic patterns and improve the site experience.

We use personal information to respond to enquiries, provide advisory and training services, manage client relationships, improve our website, understand service demand, measure website performance, and meet legal or administrative obligations. We do not sell personal information. Google-generated analytics and measurement data may be used to understand traffic patterns and improve the site experience.

3. Legal basis and POPIA

3. Legal basis and POPIA

Where POPIA applies, we process personal information only where there is a lawful basis to do so. This may include your consent, a contractual relationship, a legal obligation, or our legitimate interest in operating and improving our business while protecting your rights. Where EU privacy rules apply, we rely on consent for non-essential cookies and similar tracking technologies unless another lawful basis is available under applicable law.

Where POPIA applies, we process personal information only where there is a lawful basis to do so. This may include your consent, a contractual relationship, a legal obligation, or our legitimate interest in operating and improving our business while protecting your rights. Where EU privacy rules apply, we rely on consent for non-essential cookies and similar tracking technologies unless another lawful basis is available under applicable law.

4. Sharing information

4. Sharing information

We may share information with trusted service providers who help us operate our website, manage communications, host data, measure performance, or deliver services. These may include Google for analytics, measurement, or related website services, and CookieYes for cookie-consent management. These providers may process information under their own terms and privacy notices. We may also disclose information where required by law.

We may share information with trusted service providers who help us operate our website, manage communications, host data, measure performance, or deliver services. These may include Google for analytics, measurement, or related website services, and CookieYes for cookie-consent management. These providers may process information under their own terms and privacy notices. We may also disclose information where required by law.

5. Retention

5. Retention

We keep personal information only for as long as reasonably necessary for the purpose for which it was collected, unless a longer retention period is required or permitted by law.

6. Security

6. Security

We take reasonable technical and organisational measures to protect personal information from loss, misuse, unauthorised access, disclosure, alteration, or destruction. No online system is completely secure, but we work to reduce risk responsibly.

7. Your rights

7. Your rights

Subject to applicable law, you may request access to your personal information, ask us to correct or delete it, object to certain processing, withdraw consent where processing is based on consent, or lodge a complaint with the Information Regulator in South Africa. EU visitors may also have rights under GDPR, including rights of access, rectification, erasure, restriction, objection, portability, and complaint to a supervisory authority.

Subject to applicable law, you may request access to your personal information, ask us to correct or delete it, object to certain processing, withdraw consent where processing is based on consent, or lodge a complaint with the Information Regulator in South Africa. EU visitors may also have rights under GDPR, including rights of access, rectification, erasure, restriction, objection, portability, and complaint to a supervisory authority.

8. Cookies and analytics

8. Cookies and analytics

Our website may use cookies or similar technologies for essential functionality, analytics, performance measurement, and related site services. We use CookieYes as our consent-management platform to present cookie choices and record consent preferences. Non-essential cookies, including Google analytics or measurement cookies where applicable, should only run based on the consent choices available through the CookieYes banner, especially for visitors covered by EU regulations. You can also manage cookies through your browser settings.

Our website may use cookies or similar technologies for essential functionality, analytics, performance measurement, and related site services. We use CookieYes as our consent-management platform to present cookie choices and record consent preferences. Non-essential cookies, including Google analytics or measurement cookies where applicable, should only run based on the consent choices available through the CookieYes banner, especially for visitors covered by EU regulations. You can also manage cookies through your browser settings.

9. Third-party links

9. Third-party links

Our website may link to third-party websites or services. We are not responsible for the privacy practices, content, or security of those third parties. Please review their privacy policies before sharing information with them.

10. Contact us

10. Contact us

If you have questions about this Privacy Policy, cookie consent, Google data collection on this website, or how we handle personal information, contact The 1938 Group at info@the1938group.co.za

If you have questions about this Privacy Policy, cookie consent, Google data collection on this website, or how we handle personal information, contact The 1938 Group at info@the1938group.co.za