COOKIE POLICY
BATA/D-18/COOK/2026/001 v2.2 • May 2026
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Responsible Party
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Bata South Africa (Pty) Ltd
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Websites Covered
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www.bata.co.za • www.toughees.co.za
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Information Officer
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Lorraine Denise Dyer (Director and Country Manager)
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IO Email
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informationofficer@bata.com
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IO Tel
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031 812 3600
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Effective Date
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May 2026
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Replaces
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Bata South Africa Cookie Policy, effective 01 November 2018
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Document Ref
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BATA/D-18/COOK/2026/001 v2.2
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Read With
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Privacy Statement v2.2 (BATA/D-18/PRIV/2026/001 v2.2)
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This Cookie Policy explains what cookies are, what cookies we use on our websites, why we use them, and how you can control them. It should be read together with our Privacy Statement v2.2.
Cookies are small text files placed on your device by a website when you visit it. They are widely used to make websites work more efficiently and to provide website operators with information about how their sites are being used.
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IMPORTANT: COOKIES AND PERSONAL INFORMATION
A cookie identifier that can be used to identify a specific person IS personal information under POPIA s1. Where cookies collect or generate personal identifiers, we treat the resulting information as personal information and apply the full protections of POPIA.
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2. Categories of Cookies We Use
Pending completion of a full technical cookie audit by our IT Security DIO, Allan Graham Randall (Africa Security and Global Data Protection Lead), the following table describes the categories of cookies currently deployed on our websites. This table will be updated on completion of the cookie audit and annually thereafter.
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Category
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Lawful Basis
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Purpose
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Examples / Third Parties
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Strictly Necessary
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Legitimate interests — no consent required
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Essential for the website to function. Cannot be switched off. Include session management, security, and shopping cart functionality.
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[Platform TBC — pending DIO Randall cookie audit A-31/A-35]; SSL session cookies
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Functional / Preference
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Consent
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Remember your preferences and settings (e.g. language, region, logged-in status). The website may not function optimally without these.
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[CMP and platform preferences cookies — provider TBC pending cookie audit A-31]
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Analytics / Performance
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Consent
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Help us understand how visitors use our website, which pages are most popular, and how to improve the user experience. We configure analytics tools to minimise personal data collection. Analytics data that constitutes personal information is subject to POPIA and this Cookie Policy.
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Google Analytics 4 (GA4); [cookie audit to confirm additional providers]
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Marketing / Advertising
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Consent
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Used to deliver advertisements relevant to your interests and to measure the effectiveness of advertising campaigns. May involve tracking across websites. Note: the full direct marketing framework (POPIA s69; IR December 2024 Guidance Note; consent requirements; opt-out rights) is set out in Privacy Statement v2.2, Section 7. This Cookie Policy covers marketing cookies specifically.
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Meta Pixel; Google Ads; [cookie audit to confirm additional providers]
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Children’s Pages (Toughees / Bubblegummers)
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Consent — from competent person (parent/guardian) where visitor is under 18
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Pages directed at children may deploy analytics or personalisation cookies. We are reviewing our age-verification mechanism to ensure compliance with POPIA s35.
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Pending cookie audit — enhanced age-gating under review
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Some cookies on our websites are placed by third parties, including analytics providers (such as Google Analytics and Meta Pixel) and advertising partners. These third parties may independently collect information about your online activities across different websites over time.
Bata SA remains accountable as the responsible party for data flows originating from our websites, including those generated by third-party cookies. We require our third-party cookie providers to:
• Process data only for the purposes disclosed in this Cookie Policy.
• Maintain appropriate security safeguards.
• Comply with POPIA and any applicable data processing agreements with us.
A full list of third-party cookie providers, their data practices, and links to their privacy policies will be published on completion of our cookie audit.
4. How to Manage and Control Cookies
When you first visit our websites, you will see a cookie consent banner. You can choose to accept all cookies, reject non-essential cookies, or customise your preferences by category. Your consent preferences are stored for 12 months and can be updated at any time by clicking the “Cookie Settings” link in the footer of our websites (to be implemented on completion of the cookie audit — A-31).
4.2 Your Browser Settings
You can control and delete cookies through your internet browser settings. The following links explain how to do this in the most common browsers:
• Google Chrome: support.google.com/chrome/answer/95647
• Mozilla Firefox: support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
• Microsoft Edge: support.microsoft.com/en-us/search?query=cookies+edge
• Apple Safari: support.apple.com/en-za/guide/safari/sfri11471/mac
Please note that disabling or blocking certain cookies may affect the functionality of our websites. Strictly necessary cookies cannot be disabled through our consent banner as they are essential for the website to operate.
4.3 Opt-Out Tools for Analytics and Advertising
• Google Analytics: Install the Google Analytics opt-out browser add-on at tools.google.com/dlpage/gaoptout.
• Meta (Facebook) Pixel: Manage your advertising preferences at www.facebook.com/settings/?tab=ads.
• Industry opt-out: Use the Your Online Choices tool at www.youronlinechoices.com.
5. Consent Records and Withdrawal
We maintain records of cookie consent obtained through our consent banner in compliance with POPIA. These records include the date, time, and nature of consent given, and are retained for a minimum of 3 years.
You may withdraw your cookie consent at any time by:
• Clicking “Cookie Settings” in the footer of our website and updating your preferences.
• Clearing your cookies through your browser settings.
• Contacting our Information Officer at informationofficer@bata.com.
Withdrawal of consent does not affect the lawfulness of any processing carried out before you withdrew consent.
6. Session Duration and Cookie Lifetimes
Cookies may be either “session cookies” (which expire when you close your browser) or “persistent cookies” (which remain on your device for a defined period). The following general cookie lifetimes apply on our websites (full detail to be provided on completion of cookie audit):
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Category
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Duration
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Notes
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Strictly Necessary
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Session / up to 24 hours
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Expire at end of session or when session timeout occurs.
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Functional
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Up to 12 months
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Stored to remember your preferences across visits.
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Analytics
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Up to 14 months (target — configured to minimum per ROPA P-05)
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Configured to 14-month retention target in accordance with ROPA P-05 (minimum recommended).
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Marketing
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Up to 12 months
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Advertising cookies typically expire after 12 months.
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Consent record
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Up to 12 months
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Cookie preference settings stored for 12 months before re-consent is requested.
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If you have any questions about our use of cookies or this Cookie Policy, please contact:
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Contact
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Detail
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Information Officer
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Lorraine Denise Dyer (Director and Country Manager)
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Email
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informationofficer@bata.com
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Telephone
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031 812 3600
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Postal
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5A Rydall Vale Crescent, Rydall Park, La Lucia, KZN 4051
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Version
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Date
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Summary of Changes
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v2.2
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May 2026
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QA corrections applied to Cookie Policy: (1) WordPress platform assumptions removed from s2 Strictly Necessary and Functional rows (provider TBC pending cookie audit A-31); (2) Analytics retention 26 months → 14 months target (ROPA P-05); (3) Analytics description corrected — no longer claims data is anonymised; (4) Cookie Settings footer note added (pending A-31 implementation); (5) Publication Instructions Randall title corrected to Africa Security and Global Data Protection Lead (CF-SNN-17 / CF-B-127 — effective 25 May 2026; prior titles "Global Data Privacy Officer" and "Africa Regional IT Security Leader" retired).
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v2.1
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May 2026
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Full rewrite. Previous document (November 2018) replaced in its entirety. IO and DIO contact details updated to current officers (Lorraine Denise Dyer — informationofficer@bata.com). POPIA-compliant personal information definition. Cookie categories defined. Third-party accountability stated. Consent banner described. Consent records undertaking. Withdrawal mechanism described. Children’s pages (Toughees/Bubblegummers) addressed. Cookie audit noted as pending. Full cookie provider list to follow audit.
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v1.0
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01 Nov 2018
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Original document — superseded in its entirety by v2.1.
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BATA/D-18/COOK/2026/001 v2.2 • May 2026 • Bata South Africa (Pty) Ltd • Reg. M1985000219
