1. Introduction

LMTS QA Consulting ("LMTS", "we", "us" or "our") respects your privacy and is committed to protecting personal information entrusted to us.

This Privacy Policy explains how we collect, use, store, disclose, protect and otherwise process personal information when you:

• visit the LMTS QA Consulting website;

• contact or enquire with us;

• subscribe to our newsletter or other communications;

• submit a testimonial;

• browse employment opportunities;

• start or submit a job application;

• communicate with us regarding employment opportunities;

• become a client, prospective client, supplier or business contact;

• interact with our professional services; or

• otherwise engage with LMTS electronically.

This policy applies to the LMTS QA Consulting website and associated web application, including its content-management, recruitment, job-posting and job-application functionality.

LMTS processes personal information primarily in accordance with the Protection of Personal Information Act 4 of 2013 ("POPIA") and other applicable South African laws.

2. Who Is Responsible for Your Information?

Where LMTS determines the purpose and means of processing personal information, LMTS acts as the Responsible Party for purposes of POPIA.

In some professional engagements, LMTS may process personal information on behalf of a client. In those circumstances, LMTS may act as an Operator, and the relevant client may be the Responsible Party.

The applicable contractual arrangements will determine the respective responsibilities of LMTS and the client.

3. Personal Information We Collect

The information we collect depends on how you interact with us.

We aim to collect only information reasonably necessary for a legitimate and identified purpose.

3.1 Website and Technical Information

When you use our website, certain technical information may be collected automatically, including:

• IP address;

• browser type and version;

• operating system;

• device type;

• screen or device characteristics;

• pages visited;

• date and time of visits;

• referring pages or websites;

• interactions with website functionality;

• error and diagnostic information;

• security-related information;

• cookie identifiers; and

• other technical information reasonably required to operate, secure and improve the website.

Some of this information may be collected through cookies, browser storage, server logs or analytics technologies.

4. Enquiries and Contact Forms

When you contact LMTS or submit an enquiry, we may collect:

• your name;

• surname;

• email address;

• telephone number;

• organisation or company;

• position or job title;

• physical or business address, where requested;

• services you are interested in;

• information included in your enquiry;

• project or service requirements; and

• any other information you choose to provide.

We use this information primarily to respond to your enquiry, understand your requirements and communicate with you.

Submitting an enquiry does not automatically subscribe you to marketing communications.

5. Newsletter Subscriptions

Where you subscribe to an LMTS newsletter, mailing list or similar communication, we may process information such as:

• name;

• email address;

• communication preferences;

• date and method of subscription;

• consent records;

• subscription status; and

• unsubscribe information.

Newsletter subscription information is used to send communications you have requested or consented to receive.

Where consent is required, subscribing to one type of communication does not automatically constitute consent to receive unrelated electronic marketing.

You may unsubscribe at any time using an available unsubscribe mechanism or by contacting LMTS.

We may retain a limited suppression record after you unsubscribe so that we can honour your request and avoid inadvertently re-subscribing you.

6. Testimonials

The website may allow customers, clients, candidates or other persons to submit testimonials.

A testimonial submission may contain:

• your name;

• company or organisation;

• position or title;

• contact information;

• rating or feedback;

• written testimonial;

• photograph or profile image, where applicable; and

• other information voluntarily included in your submission.

Submitting a testimonial does not automatically mean that every piece of information you provide will be publicly displayed.

Where LMTS intends to publish identifiable testimonial information, we will rely on an appropriate lawful basis and, where necessary, obtain your consent.

A published testimonial may display information such as your name, organisation, position and testimonial content where you have authorised such publication.

You may contact LMTS if you wish to request correction or removal of a testimonial. Such requests will be considered in accordance with applicable law and any relevant contractual arrangements.

7. Job Vacancies

LMTS may publish current employment, consulting, internship, contract or other opportunities through its website.

Merely browsing a job advertisement does not require you to submit a job application.

Technical website information may nevertheless be processed as described elsewhere in this Privacy Policy.

8. Job Applications

When you apply for a position through the LMTS website, we may collect information necessary to evaluate and administer your application.

Depending on the application form and the position, this may include:

• full name;

• surname;

• email address;

• telephone number;

• residential or postal address;

• location;

• identification or work-authorisation information where lawfully required;

• CV or résumé;

• employment history;

• previous employers;

• job titles and responsibilities;

• education;

• qualifications;

• certifications;

• professional registrations;

• skills;

• technical experience;

• portfolio or professional profile information;

• salary or remuneration expectations where requested;

• notice period;

• availability;

• preferred employment arrangements;

• answers to job-specific questions;

• references or referee information;

• supporting documents;

• cover letter;

• links to professional profiles or portfolios;

• correspondence relating to your application; and

• other information that you voluntarily provide.

Please provide only information that is relevant to your application.

9. Saved Job Application Drafts

The LMTS job-application system may allow you to save application progress in your browser so that you can return and continue later.

Unsubmitted application draft information saved through this functionality is stored locally in your browser or device using browser local storage.

It is not transmitted to LMTS's servers merely because it has been saved as a draft.

LMTS generally receives the application information when you actively submit the application.

This distinction means:

Before submission:
Supported draft information remains on the device and browser in which you entered it.

After submission:
The information included in the submitted application is transmitted to LMTS and processed as recruitment information under this Privacy Policy.

Clearing your browser's local storage, using certain browser-cleaning functions, changing browsers or devices, or using private/incognito browsing may remove your unsaved application draft.

LMTS may not be able to recover an application draft that existed only in your browser.

If you use a shared or public computer, you should consider clearing saved application information after use.

Further details are provided in our Cookie Policy.

10. How We Use Job Application Information

Recruitment information may be processed to:

• receive and administer applications;

• assess qualifications and experience;

• determine suitability for a vacancy;

• shortlist candidates;

• conduct interviews;

• communicate application progress;

• verify information supplied in an application;

• contact references where lawfully appropriate;

• perform authorised employment-related screening;

• manage offers and onboarding;

• comply with employment and other legal requirements;

• protect LMTS and applicants against fraud;

• maintain recruitment records; and

• establish, exercise or defend legal rights.

Submitting an application does not guarantee:

• an interview;

• shortlisting;

• employment;

• placement;

• appointment; or

• any other engagement with LMTS.

11. Applications for Future Opportunities

An application submitted for a particular position will primarily be used in connection with that position.

Where LMTS wishes to retain your application for unrelated future vacancies beyond what is otherwise legally justified, we may request your consent or rely on another lawful basis where permitted.

Where you have consented to consideration for future opportunities, you may withdraw that consent by contacting LMTS.

12. References and Information About Other People

If you provide personal information about another person, such as a professional referee, you should ensure that you are permitted to provide their information to LMTS.

LMTS may contact referees where this is reasonably necessary and lawfully permitted for recruitment purposes.

13. Special Personal Information

LMTS does not ordinarily request special personal information through general website forms unless it is reasonably necessary and lawfully permitted.

Special personal information under POPIA can include certain information concerning:

• religious or philosophical beliefs;

• race or ethnic origin;

• trade-union membership;

• political persuasion;

• health;

• sex life;

• biometric information; and

• criminal behaviour.

Where such information is required for a legitimate purpose, LMTS will process it only in accordance with applicable legal requirements and appropriate safeguards.

Applicants should avoid voluntarily including unnecessary special personal information in CVs or application documents.

14. Client and Business Information

Where you interact with LMTS as a client, prospective client, supplier, contractor or professional contact, we may process information including:

• name;

• contact details;

• job title;

• employer;

• business address;

• correspondence;

• quotation information;

• proposal information;

• contractual records;

• project information;

• invoicing and payment information;

• meeting records; and

• other information necessary to manage the business relationship.

15. Why We Process Personal Information

Depending on the circumstances, LMTS may process personal information for purposes including:

• operating our website and web application;

• providing CMS and website functionality;

• publishing and administering vacancies;

• managing job applications;

• recruitment and candidate assessment;

• responding to enquiries;

• delivering professional services;

• preparing proposals and quotations;

• managing client relationships;

• providing customer support;

• managing suppliers and contractors;

• processing testimonials;

• administering newsletter subscriptions;

• sending authorised communications;

• protecting website and system security;

• preventing fraud and abuse;

• analysing website performance;

• improving our website and services;

• maintaining business records;

• complying with legal obligations;

• managing disputes;

• establishing, exercising or defending legal rights; and

• performing other legitimate business activities compatible with the purpose for which the information was collected.

16. Lawful Grounds for Processing

LMTS processes personal information only where a lawful basis exists.

Depending on the circumstances, processing may occur because:

• you have consented to the processing;

• processing is necessary to carry out actions for the conclusion or performance of a contract;

• processing complies with an obligation imposed by law;

• processing protects a legitimate interest of the data subject;

• processing is necessary for the proper performance of a public-law duty where applicable;

• processing is necessary to pursue the legitimate interests of LMTS or a third party, where permitted; or

• another lawful basis under applicable legislation exists.

Consent is therefore not the only lawful basis upon which personal information may be processed.

Where processing depends specifically on your consent, you may withdraw that consent, subject to applicable law.

17. Direct Marketing

LMTS may market its services electronically only where permitted by applicable law.

Where prior consent is required for unsolicited electronic direct marketing, LMTS will seek appropriate consent.

We will not treat:

• silence;

• failure to untick a box;

• failure to unsubscribe; or

• an unrelated website interaction

as consent where affirmative consent is legally required.

You may object to direct marketing or unsubscribe from marketing communications at any time.

This does not prevent LMTS from sending communications required for:

• an active job application;

• an existing client engagement;

• a requested enquiry;

• transactional purposes;

• contractual administration; or

• legal or security purposes.

18. Cookies, Analytics and Browser Storage

The LMTS website uses cookies and browser local storage.

These technologies may be used to:

• operate website functionality;

• protect the website;

• remember cookie choices;

• retain job-application progress locally;

• measure website performance;

• understand how visitors use the website; and

• improve our services.

Our use of these technologies is explained in greater detail in the LMTS QA Consulting Cookie Policy.

19. When We Share Personal Information

LMTS does not sell personal information.

We may disclose personal information where reasonably necessary to:

• authorised LMTS personnel;

• employees involved in recruitment;

• hiring managers;

• authorised consultants or contractors;

• IT and hosting service providers;

• website infrastructure providers;

• email and communication providers;

• recruitment service providers;

• professional advisers;

• auditors;

• insurers;

• payment or financial service providers;

• clients where relevant to an authorised professional engagement;

• regulators;

• law-enforcement agencies;

• courts; or

• other parties where disclosure is required or authorised by law.

We seek to disclose only information reasonably necessary for the relevant purpose.

20. Service Providers and Operators

LMTS may use third parties to process information on our behalf.

These providers may support functions such as:

• website hosting;

• cloud infrastructure;

• email;

• website maintenance;

• analytics;

• backups;

• cybersecurity;

• recruitment;

• document storage; and

• business administration.

Where a provider acts as an Operator under POPIA, LMTS will seek to implement appropriate contractual and security arrangements consistent with applicable requirements.

21. International Transfers

Some technology, hosting, cloud or other service providers may process information outside South Africa.

Where personal information is transferred outside South Africa, LMTS will seek to ensure that the transfer complies with applicable law, including the cross-border transfer requirements contained in POPIA.

Appropriate protections may include:

• adequate foreign data-protection requirements;

• contractual protections;

• binding corporate rules;

• consent where appropriate;

• contractual necessity; or

• another legally permitted transfer mechanism.

22. Information Security

LMTS implements reasonable technical and organisational safeguards appropriate to the nature of the information and associated risks.

These may include:

• access controls;

• authentication;

• secure password practices;

• role-based permissions;

• network security controls;

• encryption where appropriate;

• secure hosting;

• backups;

• logging and monitoring;

• malware protection;

• vulnerability management;

• secure software configuration;

• access reviews;

• confidentiality obligations;

• incident response;

• staff awareness; and

• supplier security controls.

No internet-connected system can be guaranteed to be completely secure.

LMTS therefore continuously considers and manages reasonably foreseeable risks to personal information.

23. Personal Information Security Compromises

Where LMTS has reasonable grounds to believe that personal information has been accessed or acquired by an unauthorised person, we will investigate and respond in accordance with applicable law.

Where legally required, LMTS will notify the Information Regulator and affected data subjects.

Where LMTS processes the affected information as an Operator for another Responsible Party, we will notify the Responsible Party as required by law and applicable contractual arrangements.

24. Data Retention

LMTS keeps personal information only for as long as reasonably necessary for the purpose for which it was collected or as otherwise authorised or required by law.

Retention may depend on:

• the nature of the information;

• the reason it was collected;

• whether a business relationship exists;

• employment and recruitment requirements;

• contractual obligations;

• statutory recordkeeping obligations;

• dispute or litigation requirements;

• security requirements; and

• consent to continued processing.

Examples include:

Job applications: retained for the relevant recruitment process and, where lawfully appropriate, for a reasonable period afterwards for recruitment administration, disputes or future opportunities.

Newsletter subscriptions: retained while the subscription remains active, together with appropriate records of consent and unsubscribe instructions where required.

Enquiries: retained for as long as reasonably necessary to manage the enquiry and associated business records.

Testimonials: retained while used for the authorised purpose or until removal is required or agreed, subject to lawful recordkeeping requirements.

Local application drafts: remain in your browser rather than LMTS's recruitment database until submitted and are controlled principally through your browser/device.

Once information is no longer required, LMTS may securely delete, destroy or de-identify it.

25. Your POPIA Rights

Subject to applicable law, you may request:

• confirmation of whether LMTS holds personal information about you;

• access to personal information held about you;

• correction of inaccurate or incomplete information;

• deletion or destruction of information where appropriate;

• information concerning the processing of your personal information; or

• correction of information that is outdated, misleading or unlawfully obtained.

You may also:

• object to processing in circumstances permitted by POPIA;

• withdraw consent where processing relies on consent;

• object to direct marketing; and

• lodge a complaint with the Information Regulator.

Some requests may be limited where LMTS is legally entitled or required to retain or process the relevant information.

26. Identity Verification

Before granting access to, correcting or deleting personal information, LMTS may take reasonable steps to verify the identity and authority of the person making the request.

This is intended to protect personal information from unauthorised disclosure or modification.

LMTS may require completion of applicable prescribed forms where required under POPIA or PAIA.

27. Information About Children

LMTS's general website, consulting services and recruitment platform are not intended to collect personal information directly from children unless a particular lawful programme or employment-related activity requires it.

Where personal information relating to a child is processed, LMTS will do so only where permitted by law and subject to appropriate safeguards.

28. Automated Recruitment Decisions

Unless expressly communicated otherwise for a specific recruitment process, LMTS does not intend to make employment decisions producing legal or similarly significant effects solely through automated processing without appropriate human involvement.

Technology may nevertheless be used to organise, search, route or support recruitment information.

29. Third-Party Websites

The LMTS website may contain links to external websites, social networks or third-party services.

LMTS does not control the privacy practices of those third parties.

When you leave our website, you should review the privacy policies applicable to the third-party service you access.

30. Accuracy of Your Information

You are responsible for providing information that is reasonably accurate and current.

Job applicants should update LMTS if materially relevant information supplied during an active recruitment process changes.

31. Changes to This Privacy Policy

LMTS may amend this Privacy Policy when:

• our website changes;

• recruitment functionality changes;

• new services are introduced;

• data-processing practices change;

• technology providers change;

• legal requirements change; or

• regulatory guidance changes.

The current version will be made available through the website and identified by its "Last updated" date.

Material changes may be communicated through additional measures where appropriate.

32. Contacting LMTS About Privacy

Privacy requests and enquiries should be directed to LMTS through the contact information published on our website.

The following information should be included in the final published version where applicable:

Responsible Party:
LMTS QA Consulting / [Registered Legal Entity]

Information Officer:
[Name or Designation]

Privacy / POPIA Email:
[Email Address]

Telephone:
[Telephone Number]

Physical Address:
[Business / Registered Address]

Registration Number:
[Company Registration Number]

33. Complaints to the Information Regulator

You have the right to lodge a complaint with the Information Regulator of South Africa if you believe your personal information has been processed contrary to POPIA.

At the date of this policy, the Information Regulator provides an electronic complaints service and other official complaint channels.

LMTS encourages you to contact us first where appropriate so that we have an opportunity to investigate and address your concern, although doing so does not remove any statutory right to approach the Information Regulator.

34. Related Documents

This Privacy Policy should be read together with the:

• LMTS QA Consulting Terms of Service;

• LMTS QA Consulting Cookie Policy;

• applicable job advertisement;

• application-specific notices or consents;

• applicable client or service agreement; and

• any other privacy notice presented when information is collected.

Last updated: 5 September 2026