Eagle Canyon Golf & Lifestyle Estate

privacy

FORM 2 REQUEST FOR ACCESS TO RECORD PAIA FORM 2

Eagle Canyon Golf Estate Privacy Policy

Introduction

This Privacy Policy outlines Eagle Canyon Golf Estate (" we ", " our " or " the Company ") practices with respect to information collected from users who access our website at www.eaglecanyongolfestate.co.za (" Site "), or otherwise share personal information with us (collectively: " Users ").

We respect the privacy of everyone who visits this website. As a result we would like to inform you regarding the way we would use your Personal Information. We recommend you to read this Customer Privacy Notice and Consent so that you understand our approach towards the use of your Personal Information. By submitting your Personal Information to us, you will be treated as having given your permission – where necessary and appropriate – for disclosures referred to in this policy. By using this web site, you acknowledge that you have reviewed the terms of this Customer Privacy Notice and Consent to Use of Personal Information (the “Customer Privacy Notice and Consent”) and agree that we may collect, use and transfer your Personal Information in accordance therewith.

If you do not agree with these terms, you may choose not to use our site, and please do not provide any Personal Information through this site. This Customer Privacy Notice and Consent forms part of our Site Terms and Conditions of Use and such shall be governed by and construed in accordance with the laws of South Africa. This Notice explains how we obtain, use and disclose your personal information, as is required by the Protection of Personal Information Act, 2013 (POPI Act). At Eagle Canyon Golf and Lifestyle Estate we are committed to protecting your privacy and to ensure that your Personal Information is collected and used properly, lawfully and openly.

About Eagle Canyon Golf and Lifestyle Estate

Eagle Canyon is a luxurious, secure Golf and Residential Lifestyle Estate which has evolved into over 800 freestanding homes and 500 sectional title units, a unique Colorado Links 18-hole golf course, clubhouse, gym, restaurant and bar, children’s play areas, parks and more – An all-inclusive lifestyle sanctuary.

Grounds for data collection

Processing of your personal information (meaning, any information which may potentially allow your identification with reasonable means; hereinafter " Personal Information " is necessary for the performance of our contractual obligations towards you and providing you with our services, to protect our legitimate interests and for compliance with legal and financial regulatory obligations to which we are subject.

When you use the Site, you consent to the collection, storage, use, disclosure and other uses of your Personal Information as described in this Privacy Policy.

We encourage our Users to carefully read the Privacy Policy and use it to make informed decisions.

What information we collect?

We collect and process your Personal Information mainly to provide you with access to our services and products, to help us improve our offerings to you and for certain other purposes explained below. The type of information we collect will depend on the purpose for which it is collected and used. We will only collect information that we need for that purpose.

We collect information directly from you where you provide us with your personal details, for example when you purchase a product or services from us or when you submit enquiries to us or contact us. Where possible, we will inform you what information you are required to provide to us and what information is optional.

Examples of information we collect from you are:

• Your name

• Your address

• Your email address

• Your telephone/cell number

• Any user-generated content, posts and other content you submit to our website

• Device Information: We collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Site.

We also collect information about you from other sources as explained below.

With your consent, we may also supplement the information that you provide to us with information we receive from other companies in the office products industry in order to offer you a more dedicated product.

How do we receive information about you?

We receive your Personal Information from various sources:

When you voluntarily provide us your personal details in order to register on our Site;
When you use or access our Site in connection with your use of our services;
From third party providers, services and public registers (for example, traffic analytics vendors).

We may automatically collect non-Personal Information about you such as the type of internet browsers you use or the website from which you linked to our website. We may also aggregate details which you have submitted to the site (for example, the products or services you are interested in). You cannot be identified from this information and it is only used to assist us in providing an effective service on this web site. We may from time to time supply third parties with this non-personal or aggregated data for uses in connection with this website.

What information we collect?

We do not rent, sell, or share Users’ information with third parties except as described in this Privacy Policy.

We will use your Personal and Non-Personal Information only for the purposes for which it was collected or agreed with you, for example:

• To confirm and verify your identity or to verify that you are an authorised customer for security purposes

• To carry out our obligations arising from any contracts entered into between you and us

• To notify you about changes to our service

• For market research purposes

• To assist with business development

• For the detection and prevention of fraud, crime, or other malpractice

• To conduct market or customer satisfaction research or for statistical analysis

• For audit and record keeping purposes

• In connection with legal proceedings

• We will also use your Personal Information to comply with legal and regulatory requirements or industry codes to which we subscribe or which apply to us, or when it is otherwise allowed by law.

• For monitoring and auditing site usage

• Evaluate the use of the site, products and services

• Analyse the effectiveness of our advertisements, competitions and promotions

• Personalise your website experience, as well as to evaluate (anonymously and in the aggregate) statistics on website activity, such as what time you visited it, whether you’ve visited it before and what site referred you to it

• Make the site easier to use and to better tailor the site and our products to your interests and needs

• Help speed up your future activities and experience on the site. For example, a site can recognise that you have provided your Personal Information and will not request the same information a second time.

• Collect information about the device you are using to view the site, such as your IP address or the type of Internet browser or operating system you are using, and link this to your Personal Information so as to ensure that the site presents the best web experience for you

• To contact you regarding products and services which may be of interest to you, provided you have given us consent to do so or you have previously requested a product or service from us and the communication is relevant or related to that prior request and made within any timeframes established by applicable laws.

• Suggest products or services (including those of relevant third parties) which we think may be of interest to you

• Offer you the opportunity to take part in competitions or promotions

• You can opt out of receiving communications from us at any time. Any direct marketing communications that we send to you will provide you with the information and means necessary to opt out.

• To respond to your queries or comments

• Where we collect Personal Information for a specific purpose, we will not keep it for longer than is necessary to fulfil that purpose, unless we have to keep it for legitimate business or legal reasons. In order to protect information from accidental or malicious destruction, when we delete information from our services we may not immediately delete residual copies from our servers or remove information from our backup systems.

In addition to the different uses listed above, we may transfer or disclose Personal Information to our subsidiaries, affiliated companies and subcontractors.

In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our trusted third party providers, who may be located in different jurisdictions across the world, for any of the following purposes:

Hosting and operating our Site;
Providing you with our services, including providing a personalised display of our Site;
Storing and processing such information on our behalf;
Serving you with advertisements and assist us in evaluating the success of our advertising campaigns and help us retarget any of our users;
Providing you with marketing offers and promotional materials related to our Site and services;
Performing research, technical diagnostics or analytics;

Disclosure of Personal Information

We may disclose your Personal Information to our service providers who are involved in the delivery of products or services to you. We have agreements in place to ensure that they comply with these privacy terms.

We may share your Personal Information with, and obtain information about you from:

• Third parties for the purposes listed above;

• Other companies in the office products industry when we believe it will enhance the services and products we can offer to you, but only where you have not objected to such sharing;

• Other third parties from whom you have chosen to receive marketing information.

We may also disclose your information:

• Where we have a duty or a right to disclose in terms of law or industry codes;

• Where we believe it is necessary to protect our rights.

We may also disclose information if we have good faith to believe that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our Agreement), including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.

Personal Information Security

We are legally obliged to provide adequate protection for the Personal Information we hold and to stop unauthorised access and use of personal information. We will, on an on-going basis, continue to review our security controls and related processes to ensure that your Personal Information is secure.

Our security policies and procedures cover:

• Physical security;

• Computer and network security;

• Access to personal information;

• Secure communications;

• Security in contracting out activities or functions;

• Retention and disposal of personal information; cceptable usage of personal information;

• Governance and regulatory issues;

• Investigating and reacting to security incidents.

When we contract with third parties, we impose appropriate security, privacy and confidentiality obligations on them to ensure that Personal Information that we remain responsible for, is kept secure.

We will ensure that anyone to whom we pass your Personal Information agrees to treat your information with the same level of protection as we are obliged to.

Cookies

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services.

We use the term “cookies” to refer to cookies and other similar technologies covered by the POPI Act on privacy in electronic communications.

• What is a cookie?

Cookies are small data files that your browser places on your computer or device. Cookies help your browser navigate a website and the cookies themselves cannot collect any information stored on your computer or your files. When a server uses a web browser to read cookies they can help a

website deliver a more user-friendly service. To protect your privacy, your browser only gives a website access to the cookies it has already sent to you.

• Why do we use cookies?

We use cookies to learn more about the way you interact with our content and help us to improve your experience when visiting our website. Cookies remember the type of browser you use and which additional browser software you have installed. They also remember your preferences, such as language and region, which remain as your default settings when you revisit the website. Cookies also allow you to rate pages and fill in comment forms. Some of the cookies we use are session cookies and only last until you close your browser, others are persistent cookies which are stored on your computer for longer.

• How are third party cookies used?

For some of the functions within our websites we use third party suppliers, for example, when you visit a page with videos embedded from or links to YouTube. These videos or links (and any other content from third party suppliers) may contain third party cookies and you may wish to consult the policies of these third party websites for information regarding their use of cookies.

• How do I reject and delete cookies?

We will not use cookies to collect personally identifiable information about you. However, should you wish to do so, you can choose to reject or block the cookies set by Eagle Canyon Golf and Lifestyle Estate by changing your browser settings – see the Help function within your browser for further details. Please note that most browsers automatically accept cookies so if you do not wish cookies to be used you may need to actively delete or block the cookies.

You can also visit www.allaboutcookies.org for details on how to delete or reject cookies and for further information on cookies generally. For information on the use of cookies in mobile phone browsers and for details on how to reject or delete such cookies, please refer to your handset manual. Note, however, that if you reject the use of cookies you will still be able to visit our websites but some of the functions may not work correctly.

We also use a tool called “Google Analytics” to collect information about your use of the Site. Google Analytics collects information such as how often users access the Site, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Site and services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Access to your Personal Information

You have the right to request a copy of the Personal Information we hold about you. To do this, simply contact us at the numbers/addresses listed on our home page and specify what information you would like. We will take all reasonable steps to confirm your identity before providing details of your personal information.

Please note that any such access request may be subject to a payment of a legally allowable fee, as laid down in our POPI Act Policy.

Correction of your Personal Information

You have the right to ask us to update, correct or delete your personal information. We will take all reasonable steps to confirm your identity before making changes to Personal Information we may hold about you. We would appreciate it if you would take the necessary steps to keep your Personal Information accurate and up-to-date by notifying us of any changes we need to be aware of.

Definition of Personal Information

According to the POPI Act ‘‘Personal Information’’ means information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person. The POPI Act, which has more specific examples if you need them, can be found at the following link: www.gov.za/documents/download.php?f=204368

Right to object

In terms of the POPI Act (POPIA) section 18. (h) (iv) you have the right to object to the processing of personal information as referred to in section 11(3) of the POPIA.

Marketing

We may use your Personal Information, such as your name, email address, telephone number, etc. ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning our services, which we believe may interest you.

Out of respect to your right to privacy we provide you within such marketing materials with means to decline receiving further marketing offers from us. If you unsubscribe we will remove your email address or telephone number from our marketing distribution lists.

Please note that even if you have unsubscribed from receiving marketing emails from us, we may send you other types of important e-mail communications without offering you the opportunity to opt out of receiving them. These may include customer service announcements or administrative notices.

Corporate transaction

We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy.

Minors

We understand the importance of protecting children’s privacy, especially in an online environment. The Site is not designed for or directed at children. Under no circumstances shall we allow use of our services by minors without prior consent or authorisation by a parent or legal guardian. We do not knowingly collect Personal Information from minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at comms@echoa.co.za

Right to lodge a compliant

In terms of the POPI Act (POPIA) section 18. (h) (v) you have the right to lodge a complaint to the Information Regulator (South Africa) (IRSA). The IRSA contact details are:

https://www.justice.gov.za/inforeg/contact.html

Information Regulator South Africa

JD House,

27 Stiemens Street

Braamfontein

Johannesburg, 2001.

PO Box 31533

Braamfontein

Johannesburg, 2017

Tel: 010 023 5200

The Complaints Email address is: POPIAComplaints@inforegulator.org.za

Updates or amendments to this Privacy Policy

Please note that we may amend this notice from time to time. Please check our website periodically to inform yourself of any changes.

How to contact us

If you have any queries about this notice or believe we have not adhered to it, or need further information about our privacy practices or wish to give or withdraw consent, exercise preferences or access or correct your personal information, please contact us at comms@echoa.co.za or the numbers/addresses listed on our website https://www.eaglecanyongolfestate.co.za/contact in the Eagle Canyon Golf and Lifestyle Estate PAIA Manual

Last Modified April 2021

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