Security And Privacy Policy

1. SCHEDULE

1.1.1 The Company - Trafalgar Property Management (Pty) Ltd
1.1.2 Registration number - 1989/003378/07
1.1.3 Email address - popia@trafalgar.co.za
1.2.1 The Company - Trafalgar Financial Services (Pty) Ltd
1.2.2 Registration number - 1963/002026/07

2. COMMITMENT TO YOUR PRIVACY

Welcome to the website of Trafalgar Property Management and Financial Services (“Website”), owned and operated by the Company set out in item 1.1 of the Schedule (“Company”). The Company is committed to protecting the privacy of the user of the Website. The Company values the trust of its subscribers and all others who work with it, and the Company recognises that maintaining your trust requires transparency and accountability in how the Company handles your Personal Information. This privacy policy (“Policy”) is incorporated into and is subject to the Company’s standard terms and conditions and the general terms relating to the use of the Website.
In performing the Company’s services in the ordinary course of business, the Company may collect, use and disclose Personal Information. Anyone from whom the Company collects such information can expect that it will be appropriately and lawfully protected and that any use of or other dealing with this information is subject to consent, where this is required by law. This is in line with the general privacy practices of the Company.
This Policy sets out how the Company collects, uses, discloses, and safeguards the Personal Information it processes in the course of its business.

3. DEFINITIONS

In this Policy, in addition to the other terms that have been defined in the body of the Policy, the Company makes use of the following terms:
- “Personal Information” means all information which may be considered to be personal in nature or information about an identifiable natural and / or existing juristic person (where applicable) in terms of the Protection of Personal Information Act 4 of 2013 (“POPIA”); and
- “User, you, your or yourself” refers to any person who makes use of the Website for any purposes whatsoever, whether or not such use is free of charge or paid for.
In addition, unless the contrary is specified, terms that are used in the Policy that are specifically defined in POPIA, are given the meanings ascribed to them in POPIA.

4. WHAT PERSONAL INFORMATION DOES THE COMPANY COLLECT AND WHY?

The Company may collect Personal Information in conducting its ordinary business operations, including through the use of its Website. In processing such Personal Information, the Company at all times ensures that (i) it complies with the provisions of POPIA, and (ii) such Personal Information is used for legitimate business purposes.

5. OBTAINING CONSENT

The Company does not, except where otherwise permitted by law, collect, use or disclose your Personal Information without your consent.

6. USE AND DISCLOSURE OF PERSONAL INFORMATION

The Company operates its Website, and conducts its business in general, in accordance with South African legislation. The Company considers it imperative to protect the privacy interests of data subjects.
In the event that the Company sends Personal Information outside of South Africa (including if such information is hosted offshore), the Company will ensure that it takes all reasonable steps to ensure that it complies with all applicable laws in this regard, including POPIA.

7. RETENTION OF PERSONAL INFORMATION

All Personal Information retained on the Company’s database, including such information obtained through the use of the Website, is in accordance with the retention provisions set out in the applicable laws and regulations of South Africa, including those set out in POPIA

8. YOUR RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION

It is important to note that you have rights in relation to your Personal Information.
You have the right to contact the Company at any time to ask the Company to:
- confirm that it holds your Personal Information (at no charge);
- provide you access to any records containing your Personal Information or a description of the Personal Information that the Company hold about you (subject to payment of a prescribed fee); and / or
- confirm the identity or categories of third parties who have had, or currently have, access to your Personal Information (also subject to payment of a prescribed fee).
The Company’s contact information is as set out in item 1.1 of the Schedule.
When you make a request regarding your Personal Information, the Company will take reasonable steps to confirm your identity.
There may be times when the Company cannot grant access to your Personal Information, including where granting you access would (i) interfere with the privacy of others, or (ii) result in a breach of confidentiality. The Company will always provide you with reasons if this is the case.
If you are of the view that any Personal Information that the Company holds about you is incorrect in any way, including that it is inaccurate, irrelevant, outdated, incomplete or misleading, you are allowed to ask the Company to correct it. If you believe that any Personal Information that the Company holds about you is excessive or has been unlawfully obtained, you can ask the Company to destroy or delete it. You may do the same if you think that the Company has retained if for longer than necessary, given the purpose. The Company will do so unless there are good grounds not to (such as that the Company is required to hold it for a period prescribed by any applicable legislation).
It is important, however, to understand that if you withdraw your consent for the Company to use some of your Personal Information, it may affect the quality and level of service that the Company can provide to you.

9. SECURITY

The Company has adopted a security model to protect your Personal Information that complies with generally accepted information security practices and procedures. As part of the Company’s security systems, the Company has implemented fire-wall technology, password controls, encryption processes and antivirus software. This is in addition to the physical security measures adopted by the Company to ensure that it takes all appropriate, reasonable technical and organisational measures to prevent (i) loss of, damage to, or unauthorised destruction of Personal Information, and (ii) unlawful access to or processing of Personal Information. The Company has a stringent security policy in place that every officer, employer and supplier of the Company must adhere to.
The Company confirms that it takes all reasonable measures to:
- identify all reasonably foreseeable internal and external risks to any Personal Information in its possession or under its control;
- establish and maintain appropriate safeguards against any risks that are identified by the Company;
- regularly verify that these safeguards are effectively implemented by or on behalf of the Company; and
- ensure that such safeguards are continually updated in response to new risks or deficiencies in previously implemented safeguards.

10. THIRD-PARTY WEBSITES

The Website may contain links to third party websites. In the event that you follow a link to any of these websites, it is important to note that these websites have their own terms of use and privacy policies and that the Company does not accept any responsibility or liability for them. If you (i) are a client of the Company, or (ii) are a user of the Website, and you have purchased products or services from the Company, the Company may use your contact details to send you details of any new similar products or services which the Company thinks you would be interested in. In doing so, the Company will at all times comply with any applicable direct marketing laws.
Any communications that you do receive from the Company pursuant to clause 11.1 will set out how to opt out of receiving future communications from the Company, free of charge, if you no longer wish to receive material for any reason whatsoever. The Company will only send you marketing messages when you tick the relevant boxes at certain times when engaging with the Company.
As the Company is not responsible for any representations, information, warranties and / or content on any website of any third party (including websites linked to this Website), the Company does not exercise control over third parties’ privacy policies and the onus is on the User to refer to the privacy policy of any such third party before providing them with any of your Personal Information.

11. UPDATING OF PRIVACY POLICY

The Company, in its sole discretion, reserves the right to update, modify or amend this Policy from time to time with or without notice. You therefore agree and undertake to review the Policy whenever you visit the Website. Save as expressly provided to the contrary in this Policy, any amended version of the Policy shall supersede and replace all previous versions thereof.

12. CONTACT INFORMATION

Questions, concerns or complaints related to this Policy or the Company’s treatment of Personal Information should be directed to the email address set out in item 1.5 of the Schedule.