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STEYN CITY PROPERTIES PROPRIETARY LIMITED: PRIVACY POLICY
1 PREAMBLE
1.1 Steyn City Properties Proprietary Limited, its holding company and subsidiaries
("Steyn City, we, us, our"), respect your privacy and your personal
information.
1.2 This privacy policy ("this Policy") explains how we will endeavour to protect
and use your Personal Data.
1.3 By providing us with your Personal Data, you –
1.3.1 agree to this Policy and authorise us to process such data as set out
herein; and
1.3.2 authorise Steyn City, its affiliates, directors, employees, consultants,
service providers and other third parties to Process your Personal Data for
the purposes stated in this Policy.
1.4 We will not use your Personal Data for any purpose other than that set out in
this Policy and will endeavour to protect your Personal Data that is in our
possession from unauthorised alteration, loss, disclosure or access.
1.5 Please note that we may review and update this Policy from time to time. The
latest version of this Policy is available on request.
1.6 This Policy applies to all external parties with whom we interact, including but
not limited to visitors and residents of the Steyn City Parkland Residence,
situated at [INSERT ADDRESS] ("the Residence") and users of our WebSite
and App ("you").
1.7 Defined terms used in this Policy are explained in Annexure A.
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2 CATEGORIES OF PERSONAL DATA WE MAY PROCESS
We may Process the following categories of Personal Data about you -
2.1 personal details: name; and photograph;
2.2 demographic information: gender; date of birth or age; nationality; salutation;
title; and language preferences;
2.3 identifier information: passport or national identity number; vehicle registration
number, utility provider details; bank statements; tenancy agreements;
2.4 contact details: correspondence address; telephone number; email address;
and details of your public social media profile(s);
2.5 consent records: records of any consents you may have given, together with
the date and time, means of consent and any related information;
2.6 payment details: billing address; payment method; bank account number or
credit card number; payment records; payment amount and payment date;
2.7 data relating to your relationship with Steyn City: property ownership
information, pet registration information (where you have registered a pet for
your property) and [STEYN CITY TO INCLUDE ANY FURTHER RELEVANT
INFORMATION];
2.8 data relating to your visits to our WebSite and App: your device type; operating
system; browser type; browser settings; IP address; language settings; dates
and times of connecting to our WebSite and App; and other technical
communications information;
2.9 geo-location data, used for security purposes and to assist you in navigating the
Residence and tailoring our services for you: information obtained through the
App, which is used to identify or describe your actual physical location at the
Residence. Kindly note that the geo-location data will only be collected and
processed while you are physically present at the Residence and while the App
is in use; and
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2.10 content and advertising data: records of your interactions with our online
advertising and content, records of advertising and content displayed on pages
displayed to you, and any interaction you may have had with such content or
advertising (including, but not limited to, mouse hover, mouse clicks and any
forms you complete).
3 SENSITIVE PERSONAL DATA
Where we need to Process your Sensitive Personal Data, we will do so in the ordinary
course of our business, for a legitimate purpose, and in accordance with applicable
law.
4 COLLECTION OF PERSONAL DATA
4.1 We may collect or obtain Personal Data about you -
4.1.1 directly from you;
4.1.2 in the course of our relationship with you;
4.1.3 in the course of providing services to you;
4.1.4 when you make your Personal Data public;
4.1.5 when you visit and/or interact with our WebSite or App or our various social
media platforms;
4.1.6 when you register to use any of our services;
4.1.7 when you interact with any third party content or advertising on our
WebSite or App; or
4.1.8 when you visit the Residence.
4.2 We may also receive Personal Data about you from third parties including, but
not limited to, law enforcement authorities.
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4.3 In addition to the above, we may create Personal Data about you such as records
of your communications and interactions with us, including, but not limited to,
your attendance at events, subscription to our newsletters and other mailings
and interactions with you during the course of our digital marketing campaigns.
5 PURPOSES OF PROCESSING AND LEGAL BASES FOR PROCESSING
5.1 We will Process your Personal Data in the ordinary course of the business of
providing residential and related services to you. We will use your Personal Data
only for the purpose for which it was originally collected. We will use your
Personal Data for a secondary purpose only if such purpose constitutes a
legitimate interest and is closely related to the original or primary purpose for
which the Personal Data was collected. We may subject your Personal Data to
Processing in order to -
5.1.1 identify you;
5.1.2 combine all the information that we have about you to compile a profile for
you in order for us to personalise and tailor our services to meet your
specific needs;
5.1.3 generate statistics and develop strategic and marketing plans;
5.1.4 allow you to participate in interactive features of our services, when you
choose to do so;
5.1.5 carry out any contracts that may exist between us;
5.1.6 track your location in the Residence for security purposes, in order to assist
you in navigating through the Residence and to advise you of services and
events within the Residence that may appeal to you; and/or
5.1.7 notify you about changes to the services we offer or introduce you to new
services.
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6 DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
6.1 We may disclose your Personal Data to our Service Providers, for legitimate
business purposes, in accordance with applicable law and subject to applicable
professional and regulatory requirements regarding confidentiality. In addition,
we may disclose your Personal Data to -
6.1.1 legal and regulatory authorities, upon request, or for the purposes of
reporting any actual or suspected breach of applicable law or regulation;
6.1.2 third party Operators (including, but not limited to, data processors such
as providers of data hosting services and document review technology and
services), located anywhere in the world, subject to 6.2;
6.1.3 any relevant party, law enforcement agency or court, to the extent
necessary for the establishment, exercise or defence of legal rights;
6.1.4 any relevant party for the purposes of the prevention, investigation,
detection or prosecution of criminal offences or the execution of criminal
penalties, including, but not limited to, safeguarding against and the
prevention of threats to public security;
6.1.5 any relevant third party acquirer(s), in the event that we sell or transfer all
or any portion of our business or assets including, but not limited to, in the
event of a reorganization, dissolution or liquidation; and
6.1.6 any relevant third party provider, where our WebSite or App uses third
party advertising, plugins or content.
6.2 If we engage a third party Operator to Process any of your Personal Data, the
Operator will be subject to binding contractual obligations to -
6.2.1 only Process such Personal Data in accordance with our prior written
instructions; and
6.2.2 use measures to protect the confidentiality and security of such Personal
Data.
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7 FROM WHOM WE COLLECT PERSONAL INFORMATION
Personal Data will be collected directly from you, or our affiliates, except if -
7.1 the information is contained in a public record or has deliberately been made
public by you;
7.2 you have consented to the collection of the information from another source,
including our social media platforms;
7.3 collection of the information from another source would not prejudice a
legitimate interest you may have;
7.4 collection of the information from another source is necessary –
7.4.1 to avoid prejudice to the maintenance of the law by any public body,
including the prevention, detection, investigation, prosecution and
punishment of offences;
7.4.2 to enforce a law imposing a pecuniary penalty;
7.4.3 to enforce legislation concerning the collection of revenue as defined in
relevant local legislation;
7.4.4 for the conduct of proceedings in any court or tribunal that have
commenced or are reasonably contemplated; or
7.4.5 in the legitimate interests of national security.
8 PROTECTION OF PERSONAL DATA
8.1 We implement reasonable technical and organisational security measures to
protect your Personal Data that is in our possession against accidental or
unlawful destruction, loss, alteration, unauthorised disclosure or unauthorised
access.
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8.2 AS THE INTERNET IS AN OPEN SYSTEM, THE TRANSMISSION OF INFORMATION
VIA THE INTERNET IS NOT COMPLETELY SECURE. ALTHOUGH WE WILL
IMPLEMENT ALL REASONABLE MEASURES TO PROTECT YOUR PERSONAL DATA
THAT IS IN OUR POSSESSION, WE CANNOT GUARANTEE THE SECURITY OF ANY
INFORMATION TRANSMITTED TO US USING THE INTERNET. ANY SUCH
TRANSMISSION IS AT YOUR OWN RISK AND YOU ARE RESPONSIBLE FOR
ENSURING THAT ANY INFORMATION THAT YOU SEND TO US IS SENT
SECURELY.
8.3 STEYN CITY WILL NOT BE RESPONSIBLE FOR UNAUTHORISED ACCESS TO
YOUR PERSONAL DATA AND, TO THE EXTENT PERMITTED IN TERMS OF THE
APPLICABLE LAW, ANY LIABILITY TO YOU WHICH MAY OTHERWISE HAVE BEEN
ATTRIBUTABLE TO STEYN CITY AS A RESULT OF OR IN CONNECTION WITH
SUCH UNAUTHORISED ACCESS, IS HEREBY EXCLUDED.
9 INTERNATIONAL TRANSFER OF PERSONAL DATA
9.1 We may transfer your Personal Data to recipients outside of the Republic of
South Africa.
9.2 Personal Data may be transferred to a third party outside of the Republic of
South Africa provided that the third party is subject to a law, binding corporate
rules or a binding agreement that seeks to protect the Personal Data in line with
this Policy and the transfer is necessary in order to provide the services that are
required by you.
10 DATA ACCURACY
The Personal Data provided to Steyn City should be accurate, complete and up-to-
date. Should Personal Data change, the onus is on the provider of such data to notify
Steyn City of the change and provide Steyn City with the accurate data.
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11 DATA MINIMISATION
Steyn City will restrict the processing of Personal Data to data which is sufficient for
the fulfilment of the primary purpose and applicable legitimate purpose for which it
was collected, subject to the provisions of this Policy.
12 DATA RETENTION
Steyn City shall only retain and store Personal Data for the period for which the data
are required to serve their primary purpose or a legitimate interest or for the period
required to comply with an applicable legal requirement, whichever is longer.
13 YOUR LEGAL RIGHTS
You have rights under the South African and other laws to access your Personal Data
and to ask us to rectify, erase and restrict use of, your Personal Data. You also have
the right to object to your Personal Data being used, to ask for the transfer of Personal
Data you have made available to us and to withdraw consent to the use of your
Personal Data.
14 COOKIES AND SIMILAR TECHNOLOGIES
14.1 Cookies are a small file that are placed on your device when you visit a website
or application. In this Policy, a reference to a "Cookie" includes analogous
technologies such as web beacons and clear graphic interchange format files.
14.2 We may Process your Personal Data by our use of Cookies and similar
technologies.
14.3 When you visit our WebSite or App we may place Cookies onto your device, or
read Cookies already on your device, subject always to obtaining your consent,
where required, in accordance with applicable law. We use Cookies to record
information about your device, your browser and, in some cases, your
preferences and browsing habits. We may Process your Personal Data through
Cookies and similar technologies.
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15 DIRECT MARKETING
15.1 We will Process your Personal Data for the purposes of providing you with
information regarding services that may be of interest to you only if you provide
us with your consent to do so or if such Processing is permitted in terms of the
applicable laws.
15.2 You may sign up for our newsletter and consent to receiving marketing
information by registering on the WebSite or App and by ticking the opt-in box
that states "I want to receive news and marketing information from Steyn City".
15.3 If you no longer want wish to receive our newsletters or marketing information,
you may unsubscribe for free at any time by notifying us by e-mail or
telephonically using the details reflected in clause 17.
16 HYPERLINKS TO OTHER WEBSITES
Third party operators of websites, which may be accessed via hyperlinks from our
WebSite or App, may gather and store Personal Data as soon as you access their
websites. We do not accept any liability for those Operators in the event that your
Personal Data is collected, used, disclosed or shared by them. We encourage you to
read their privacy policies separately.
17 HOW DO YOU CONTACT US?
If you have questions about this Privacy Policy, or wish to amend or update any of
your Personal Data you may log into [NOTE: CLIENT TO INSERT] or contact us at
[NOTE: CLIENT TO INSERT].
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ANNEXURE A
Definitions
"App" means any mobile application operated, or maintained, by us.
"Operator" means any person or entity that Processes Personal Data on behalf of the
Responsible Party.
"Personal Data" means information that is about any individual, or from which any
individual is directly or indirectly identifiable, in particular by reference to an identifier
such as a name, an identification number, location data, an online identifier or to one
or more factors specific to the physical, physiological, genetic, mental, economic,
cultural or social identity of that individual.
"Process", "Processing" or "Processed" means anything that is done with any
Personal Data, whether or not by automated means, such as collection, recording,
organisation, structuring, storage, adaptation or alteration, retrieval, consultation,
use, disclosure by transmission, dissemination or otherwise making available,
alignment or combination, restriction, erasure or destruction.
"Responsible Party" means the entity that decides how and why Personal Data is
Processed.
"Sensitive Personal Data" means Personal Data about race or ethnicity, political
opinions, religious or philosophical beliefs, trade union membership, physical or
mental health, sexual life, any actual or alleged criminal offences or penalties, national
identification number, or any other information that may be deemed to be sensitive
under applicable law.
"Service Provider" – third party providers of various services whom we engage,
including, but not limited to, providers of information technology, communication, file
storage, data storage, copying, printing, transport, delivery, accounting or auditing
services and our insurers and professional advisors;
"WebSite" means any website operated, or maintained, by us or on our behalf.
