Privacy Policy

Gab Holdings CC, T/A Jacana Properties – Protection of Personal Information Act manual. Company Registration No CK 86/11185/23

The Information Regulator Office duties includes providing education, monitor and enforce compliance, handle complaints and facilitate cross-border cooperation in the enforcement of privacy laws.

In the context of this Statement this is the office of individuals appointed by the President of South Africa in terms of POPIA

The individual who is the head of or CEO of Jacana Properties who is registered with the Information Regulator in terms of the POPIA and is responsible for ensuring that we comply with the Acts

The individual/s who is/are registered with the Information Regulator in terms of the POPIA and have been delegated responsibilities in driving required activities on behalf of the Information Officer

Any natural or juristic person who is identifiable by means of an identifier such as a name, an ID number, location data, or via factors specific to the persons physical, physiological, genetic, mental, economic, cultural or social identity.

In the context of this Statement this is the person (aka supplier or customer)whose information is being processed by Jacana Properties

The party who determines the purpose of and means for processing personal information and is also responsible for protecting (safeguarding) the information of the data subject

The party who processes (collect, receive, record, collate, store, anonymize, retrieve, alter, use, distribute, erase or delete) information for a responsible party in terms of a contractual agreement or mandate on behalf of a responsible Party

Jacana Properties acknowledges and supports consumer rights and the right to privacy. Accordingly, our customers’ privacy and trust are extremely important to us! We will ensure that personal information (data) is collected and handled in a transparent and lawful manner in alignment with the Protection of personal information Act, 2013 (POPIA). It is important that you read this Statement carefully before submitting any information to Jacana Properties:

By submitting any information to Jacana Properties, you provide consent to the processing and storage of your personal information as set out in this Statement.

• The provisions of this Statement are subject to mandatory, unalterable provisions of applicable legislation.
• Please do not submit any information to Jacana Properties if you do not agree to any of the provisions of this Statement.
• If you do not consent to the provisions of this Statement, or parts of the Statement, Jacana Properties may not be able to provide certain of its services to you.

We respect privacy, we promise:

• To implement reasonable computer (logical), physical and procedural(process) safeguards to protect the security and confidentiality of the information we collect
• To limit the information collected to the minimum required to provide the required service.
• To permit only properly trained, authorised employees to access information
• Not to disclose your information to external parties unless consent has been provided or we are required or permitted by law to do so.

This Statement explains how we use the information we collect from you when you use our services and by using our services and/or by providing information to us you agree to the information being processed as set out in this Statement.

this statement also:

• sets out the types of information that we collect;
• explains how and why we collect and use your information;
• explains whom we share your information with; and
• explains the rights and choices you have when it comes to your information
• explains how to contact us or the relevant authorities
• Our business may need to collect and use personal information to provide you with our services. In most cases we will refer to this Statement, but you must also read their specific terms and conditions. Jacana Properties websites may contain links to websites operated by other organisations that have their own privacy policies. Please make sure you read their terms and conditions and privacy policies carefully before providing any personal information on other websites as we do not accept any responsibility or liability for other organisations.

“Jacana Properties”, “us”, “our” or “we” refers to Jacana Propertiesonly.

This Statement is subject to the laws of the Republic of South Africa, in particular OPI and the Consumer Protection Act, 2008 (“CPA”) as well as other relevant data protection legislation. Any dispute arising shall, to the extent permitted by law,first be attempted to be settled internally and, if this is not possible, be referred to arbitration at a venue to be determined by us applying the Uniform Rules of the high court of South Africa.

Based on POPIA, the following role players, as defined by the office of the information Regulator, are relevant to this Statement:

To make use of Jacana Properties services, such as property rentals, property sales,etc you are required to provide us with your personal information including but not limited to your South African ID number or passport number (for non-South African citizens), name, surname, contact information and other personal details.

You may provide personal information to us either directly or indirectly (through a person acting on your behalf), by completing an email or online enquiry form or requesting further information about our services, whether in writing, through our website, over the telephone or any other means.Unless you consent, we only collect information that is necessary for our business functions and activities and related purposes.

The type of information we collect and hold, will depend on the purpose for which it is collected and used. Where possible,we will inform you what information you are required to provide to us and what information is optional. The information we process is limited to only what is necessary to provide you with the services you require.We may also collect your personal information from a person acting on your behalf,any regulator, or other third parties that may hold such information.

You agree to give accurate and current information about yourself to JacanaProperties and to maintain and update such information when necessary.

We do make every effort not to collect any information of persons (minors) under the age of 18 years without the consent of their parents or guardians. If you are under the age of 18 years, you must not provide any information to us without the written consent of your parent or guardian.

Jacana Properties websites do not make use of cookies or embedded scripts, therefore no records of your browsing are retained by us.

Jacana Properties does not utilise Closed Circuit Television (CCTV) at any of its sites

We use your information for the purposes for which it was collected or agreed with you to facilitate the provision of our services to you, and for purposes that are within reasonable expectations and where permitted by law. Examples of information collected from you or other sources and processed by us are detailed below (which is not an exhaustive list) and linked to the purpose thereof.

• ID number/passport number to identify you as a unique person for us to validate who you are.
• Contact information - to facilitate essential support where you have opted in for such communications, including:o In support of facilitating required services i.e. invoices, statements, etc;
• Request your feedback and opinion in the form of surveys, should you wish to participate;o Contact you in relation to customer complaints or other feedback you wish to give us where you agree to us contacting you. Share information with 3rd (third) parties such as associated companies to enable them to communicate with you only where necessary. Examples of information collected are as follows:-

Facilitate required communications such as invoices, statements, appointment inquiries full Name Email address contact Numbers (Fixed and Mobile)

Provision of the relevant services as set out in the respective Terms &Conditions for the relevant Services subscribed to by the Data Subject Process payments email address contact Numbers (Fixed and Mobile)ID or Passport Number Date of Birth Physical Address

Maintain traceability in event of contact with Covid 19, in line with government legislation full NamesContact numbers Duration of stay in St LuciaNext destination date of return home.

Assist us to categorise your complaint or compliment Provide feedback to you regarding the complaint or compliment first Name and Surname Email address contact Numbers (Fixed and Mobile).

We may also use your information for the following reasons:

• complying with statutory and regulatory requirements in respect of the storage and maintenance of documents and information;
• complying with valid requests for information, including subject access requests;
• complying with information requests by regulators or bodies lawfully requesting the information (e.g. tax authorities);
• providing customer service and assessing customer complaints;
• assisting in law enforcement, fraud investigations, anti-money laundering and counter-terrorist financing initiatives;
• providing you with the services you have requested, and notifying you about any important changes to these services.
• operational, auditing, legal and record keeping requirements;
• complying with applicable laws;
• monitoring, keeping record of and having access to all forms of correspondence or communications received by or sent from.
• conducting internal investigations; and
• prevention and control of any disease.

At this stage, Jacana Properties does not undertake any direct marketing. Should this aspect change in the future, this policy shall be updated to reflect the manner in which such direct marketing shall be undertaken.

Information that we collect is kept in a form which permits your identification for no longer than is necessary for the purposes for which it was collected and processed in each specific case, and in any case not longer than as specified by the relevant applicable legislation unless we have your consent to process it indefinitely.

We will take all reasonable steps to protect the information we collect, hold and process from misuse, loss and from unauthorised access, modification or disclosure. We hold information both at our own premises and with the assistance of our service providers, such as Internet Service Providers (ISPs) because no data transmission over the internet is completely secure, and no system of physical or electronic security is impenetrable, we cannot guarantee the security of the information you send to us or the security of our servers or databases. Having noted that, we do take every reasonable step within our control, to protect our IT systems and your information and preserve the accuracy thereof. Quality of information means that the information we use must be appropriate, complete andreliable.

Notwithstanding anything to the contrary in this Statement, we reserve the right to disclose any information about you if we are required to do so by law, and if we believe that such action is necessary to:

• Fulfil a government request
• Conform with the requirements of the law or legal process;
• Protect or defend our legal rights and intellectual property;
• In an emergency to protect the health and safety of our website’s users or the general public.

Only authorised employees will have access to some or all your information. We may also disclose your information to associated companies, but only where necessary to fulfil a service request on your behalf.

We do use service providers to provide services and maintain our systems, including but not limited to maintenance, security, analysis, audit, payments, customer serviceand system development. As an Estate Agency, we must provide your personal information to certain third parties to allow requested transactions to be completed, such as Bond Originators, Conveyancing Attorneys, Deeds Offices, etc. These parties will have access to your information as reasonably necessary to perform these tasks on our behalf. Where we contract with service providers, and wherever possible, we impose contractual obligations on them to ensure that your information is handled and secured in accordance with relevant laws and industry best practise.

However, please check the privacy policies of these companies, as our company is not responsible for their policies. We will never sell your personal information.

You have the right:

• free of charge, to confirm with us whether we hold any information about you;
• at a prescribed fee, which we will give you a written estimate of,o to request the record of information held by uso to request a description of the information held by us, including information about the identity of all third parties, or categories of thirdparties, who have, or have had, access to the information to update and correct any out-of-date or incorrect information we holdabout you;
• destroy or delete a record of information of you which we are no longer authorised to retain; and

Before we provide you with access to your information, we may require proof of identity. We may require up to 21 (twenty-one) days to respond to any requests for information. If you require us to delete all the information that we hold about you, please contact our Information Officer. We may also refuse to delete some of your information if we are required by law to retain it or if we need it to protect our rights.

A security compromise or data breach can be described as a threat to the privacy of IT systems and/or information. In the unlikely event of such a breach occurring, weshall keep all impacted stakeholders informed and updated. When there are reasonable grounds to believe that your information has been accessed, altered, deleted or acquired by any unauthorised person, we will notify theInformation Regulator and yourself in cases where your identity can be established. This notification shall be done in accordance with the provisions of POPIA and as soon as reasonably possible after the discovery of the compromise, considering the legitimate needs of law enforcement or any measures necessary to determine the scope of the compromise and to restore the integrity of our systems.

• We may amend this Statement from time to time for any of the following reasons:
• to provide for the introduction of new systems, methods of operation, services or facilities;
• to comply with changes to any legal or regulatory requirement;
• to rectify any mistake that may be discovered from time to time.

for any other reason which Jacana Properties, in its sole discretion, may deem reasonable or necessary. Any such amendment will come into effect and become part of any agreement youhave with us when notice is given by the update of this document on our website. Please check the website prior to communicating with us.

If you have questions about this Privacy Statement or wish to exercise your rights in terms of access to, correction, or deletion of your information, please contact our information/Deputy Information Officer at: -carla@jacanaproperties.com Please write “POPI Act query” in the subject line of your email, if using email.

Should you believe that we have utilised information contrary to applicable law, youundertake to first attempt to resolve any concerns with us. If you are not satisfied with such process, you have the right to lodge a complaint with the Information Regulator of South Africa.