Kinesis Property Group Privacy Policy

We value our clients and respect their privacy. We are committed to procuring and managing information responsibly, as per the Protection of Personal Information Act.

Our policy makes provision for procedures whereby we collect personal information, how we process and use the information, and under which circumstances we share your information and with whom, as well as the destruction of information procedures.

Clients retain the right to update, remove or destroy the information we retain for purposes other than those mandated, but not limited to, in the following acts:

- Financial Intelligence Centre Act, 38 of 2001 (FICA),
- The Prevention of Organised Crime Act, 112 of 1998,
- The Protection of Constitutional Democracy Against Terrorist and Related Activities Act, 2004
(POCDATARA)

In our course of business, we collect information for the purpose of marketing and for the purposes of concluding formal real estate transactions.

We do not share information with any third parties unless we have the written instruction from clients to do so.

Types of information collected:

1. Personal Information
2. Usage Data

We do not record any telephone conversations without all parties consenting to such recordings.

THIRD PARTIES TO OUR PRIVACY POLICY AND THE PROCESSING, STORING AND MANAGEMENT OF INFORMATION ON SUCH PLATFORMS

Our website is built and managed by a third party, PropData. We rely on PropData to ensure that all data/ personal information submitted via our website on to the PropData platform by any Data Subject, is handled in accordance with the Protection of Personal Information Act, and that should there be a breach on the part of the third party, all breaches will be disclosed to the Information Regulator and affected parties/persons will be notified of the breach by PropData.

Please refer to pages 14 - 17 for the website usage privacy policy as drafted by PropData.

We also list properties on the Property 24 website, where consumers can view or respond to listed properties.
Consumers making use of the Property 24 website and application are subject to the use agreement which can be found on their website and application.

Find the Property 24 privacy policy on their website: https://www.property24.com/terms-and-conditions

We also list property on the following websites/ portals from time to time:

https://property.mg.co.za/property-for-sale-by-kinesis-property-ag26847
https://www.privateproperty.co.za/estate-agency/kinesis-property/3719

All ad hoc property listings on third party platforms are subject to the terms of use and privacy policy of that particular website, platform or application. Kinesis Property will always endeavour to keep all Data Subject information private.

PERSONAL DATA - USE

The Company may use Personal Data for the following purposes:

- Real Estate Contracts (Sale Agreements/ Offer to Purchase/ Mandates/ Leases)
- Contacting clients via electronic communication (e.g e-mail, sms, app-based communication), telephonically, app notifications and postal services.
- Update clients/ subscribers with the latest news, important information and services.
- Survey and poll to track industry trends, service delivery and client satisfaction.

PERSONAL DATA - SHARING

In a real estate transaction, we are obligated to share certain information with third parties, such as conveyancers, other parties to a transaction in a contract, service providers for the purposes for delivering services, other agents, or in the case of an emergency.

For these purposes, we will not require your written consent at the commencement of the business relationship, as this forms part of the natural process of the transaction.

Should a Data Subject feel that any third party has abused their personal information by sharing it without authorisation, uses it for unsolicited direct marketing, unlawfully obtained or processed any personal information, the Data Subject must directly address the matter with the third party.

DATA STORAGE AND PROCESSING

We retain information/ data pertaining to real estate transactions for a period of 5 years after the completion of the transaction, as per the Financial Intelligence Centre Act. After the 5-year period, the documentation and digital copies are destroyed.

Data kept on our marketing database, consisting of names, surnames, addresses, telephone numbers, and e-mail addresses, are kept indefinitely. The information is stored securely on a digital platform and only two staff members have access. Clients always have the option to opt out of any marketing database. In the case of a client opting out, we remove that client immediately from all our platforms.

Personal Data is processed at the Kinesis Property office as well as any other places where the director (or staff) involved in the processing, are located.

This implies that information may be transferred to, maintained on, or destroyed from computers and devices located outside of the province, country, or other governmental jurisdiction with other data protection laws, which may differ from those where the client is located.

Kinesis Property will take all reasonable steps to ensure that all client data is treated in accordance with the Protection of Personal Information Act, and always with the utmost respect for the client's privacy and safety.

DISCLOSURE - ANTI-MONEY LAUNDERING

As an Accountable Institution, Kinesis Property is required by law to submit reports to the Financial Intelligence Centre, such as Cash Threshold Reports, Suspicious Persons or Suspicious Transaction reports.

LEGAL OBLIGATIONS

When requested we will disclose personal information if we need to:

- Lodge a defense in a legal case.
- Protect us against liability.
- Prevent an illegal transaction or activity.
- Prevent any money laundering or terrorist funding.
- Assist the South African Police Service, or any crime intelligence service of South Africa, or the National Prosecuting Authority, when a court order instructs us to do so.

SECURITY OF YOUR PERSONAL DATA

We endeavour to always treat your personal data as our own and never purposefully place your information at risk. That said, please note that we use commercial software and electronic storage applications and are in that respect dependent on the built-in protection of those applications and services.

E-MAIL COMMUNICATION

The content our e-mails, and any attachments, are strictly confidential and solely for the use of the intended recipient(s).

If you have received an email in error, please notify our office by forwarding the mail on to
cesar@kinesisproperty.co.za, and delete email from your system.

Any views or opinions presented in any email are solely those of the author and do not necessarily represent those of Kinesis Property.

Kinesis Property accepts no liability for the content of any emails, or for the consequences of any actions taken based on the information provided, unless that information is subsequently confirmed in writing.

To change your communication preferences with Kinesis Property, including unsubscribing from further marketing or commercial communications, please e-mail our Information Officer directly with your instruction.

Information Officer - Cesar Alexandre - cesar@kinesisproperty.co.za

WEBSITE | PROPDATA PRIVACY POLICY - KINESIS PROPERTY GROUP

Find the website privacy policy on https://www.kinesisproperty.co.za/privacy-policy/ which was drafted by PropData without the input or approval from the Kinesis Property Group. This privacy policy only pertains to the Kinesis PropData website platform and does not constitute the Kinesis Property Group privacy policy/ manual.

PROPDATE WEBSITE PLATFORM

Persons accessing the Kinesis Property website subject themselves to and agree to Kinesis Property CC T/A Kinesis Property Group terms conditions and privacy policy, as set out below.

INTRODUCTION

We respect your privacy and take it very seriously. We are Kinesis Property CC T/A Kinesis Property Group, and this is our plan of action for the protection of your personal information. It describes how we collect, use, disclose, and store your personal information.

APPLICATION

This policy applies to you when you visit our website, use our application, or order our products or services as a customer. [via our website]

PERSONAL INFORMATION

Scope. Your personal information includes information we collect:

- automatically when you visit our website or use our application;
- accept on registration or submission;
- get through an order; or
- you provide voluntarily.

It excludes anonymous, de-identified, statistical, and public information. Your obligations. You may only send us your own personal information or someone else's personal information if you have their permission to do so.

ACCEPTANCE AND CHANGES

Acceptance. You may not order any of our products or services if you do not accept this policy or any changes to it. Changes. We may change this policy at any time and will notify you of the changes on our website, through our application, or by email. The changed policy applies to you if you continue using our website, our application, or our products or services following the notification.

COLLECTION

Automatically through website. When you visit our website, we automatically collect your Internet usage information (including your IP address, browser details, and usage information) through your browser, which we may use to display our website correctly, track your activities on it, or for other necessary purposes. Automatically through application. When you use our application, we automatically collect your application usage information (including your operating system version and other relevant system information) through analytics software and other technologies, which we may use to optimise our offering to you. On registration or submission. We may ask you to provide us with certain identifying information (including
your first name, surname, and email address) when you register on or otherwise submit information through our website or application for the first time.
Through an order. We ask you to provide us certain products or services information when you order our products or services.
Voluntarily. We may ask you to provide us certain optional information on a voluntary basis. Consent to collection. We will get your consent to collect your personal information in accordance with applicable law when you provide us with it.
Purpose for collection. We may process your information that you provide to us for the purposes that you indicated when you agreed to provide it to us. Processing includes gathering your personal information, disclosing it, and combining it with other personal information. [Data submitted by individuals/Data Subjects feeds through to our marketing database. The information on the database will only be used/ processed for its intended purpose. Information submitted for transactional purposes such as the sale and lease of immovable property are dealt with in accordance with our company privacy policy].

USE

Processing. We may process your personal information to fulfil our obligations to you. Cookies. We may place small text files on your device when you visit our website that allow us to provide you with a personalised experience by associating your personal information with your device. They let us remember your preferences, allow third parties to provide services to you, and otherwise serve useful purposes for you. Your internet browser generally accepts them automatically, but you can often change this setting or delete them manually. However, we won't be able to provide you with access to certain aspects of our website where cookies are necessary if you do so. We have no access to or control over any cookies that our business partners use on our website and they have their own privacy policies that govern them.

Messages. We may use your identifying information to send you administrative and update messages about our website or application.

[This pertains strictly to PropData. Kinesis Property only sends out messages to those on our database for marketing purposes to those who opted in to receiving communication from us.]

Promotional messages. We will not send you promotional messages unless you have chosen to opt into them. But, we may send you one message asking you to opt into promotional messages without you having opted into promotional messages.
Targeted content. We may use your personal information to provide you with targeted content through our
website or application in a completely automated process.
Recording calls. We may monitor and record any telephone calls that you make to us, unless you
specifically request us not to.

[We at Kinesis do not record calls. This clause pertains to individuals who contact PropData directly.]

DISCLOSURE

Sharing. We may share your personal information with third parties for the purposes of fulfilling our obligations to you, including with:

- other companies or divisions within our group;
- our contractors who help us meet our obligations to you, including those that help us understand your personal information; or
- get through an order; or
- third parties as required by applicable law.

[This clause is applicable to PropData. Kinesis Property does not share personal information with any third parties unless we have your explicit instruction to do so.]

Honour this policy. We will require anyone that we share your personal information with to honour this policy whenever possible in terms of applicable law.
Mandatory disclosure. We may disclose personal information to third parties if required for legal reasons, such as if required by the relevant authorities or a court order.
Marketing purposes. We may disclose aggregate statistical information that we derive from your and other people's personal information to our advertisers or business partners.
Personnel. We may need to disclose personal information to our personnel to do their jobs, but will not do so unnecessarily.
Change of ownership. We may assign our rights to the personal information we process to our new owners if our ownership changes for any reason.

SECURITY

We take the security of personal information very seriously and always do our best to comply with applicable data protection laws. Our hosting company will host our website in a secure server environment that uses a firewall and other advanced security measures to prevent interference or access from outside intruders. We implement disaster recovery procedures where appropriate.

STORAGE

Access. You may ask us to provide you with a description of the personal information that we hold on you, correct or update it or delete it (provided that we do not need it to fulfil our obligations to you or applicable law does not require us to keep it). We will take all reasonable steps to verify your identity before doing so. We may charge a fee to recoup our costs associated with this request if there is a cost to us associated with it and provided that applicable law allows us to do so. Please contact us with your name and any other information needed to identify you correctly if you want access to information or want us to correct, update or delete it.
Accuracy. We will do our best to keep your personal information that we collect accurate, complete, and up to date.
Participation. We may ask you to update your personal information from time to time, but will take steps to verify your identity to prevent unauthorised access when doing so.
Retention. We will only keep your personal information for as long as is necessary to fulfil our obligations to you, unless you have given us permission to keep it longer or we are otherwise legally allowed to do so.
Transfer. We may transfer your personal information outside of the country in which it was collected to a foreign country. You consent to us processing your personal information in a foreign country with less stringent data protection laws than the country in which it was collected.

GENERAL

Updating or removing. You may update or remove your personal information:

- through our website or application; or
- by contacting us.

Limitation. We are not responsible for anyone else's privacy policies or practices.
Enquiries. Please contact us by email if you have any questions about this privacy policy or how we handle your personal information.

Prop Data Pty Ltd
(Company Registration No 2016/330940/07)
(PAPIA) MANUAL PREPARED IN ACCORDANCE WITH SEC 51 OF PROMOTION OF ACCESS TO INFORMATION ACT NO 2 OF 2000)
NATURE OF BUSINESS: The entity is a private body in terms of Section 51 of the Public Access to Information Act. The private body is a Private Company formed in terms of the Companies Act (No 61 of 1973).

CONTACT DETAILS [Sec 51(1)(a)]
Name of Body: Prop Data Pty Ltd
Head of Body: Managing Director
Postal Address: P 0 Box 1108, Westville, 3630
Street Address: Unit 1, Level 1, 13 The Boulevard, Westway Office Park, Westville
Telephone Number: 031 2660035
Facsimile Number: 0866731610
E-Mail Address: info@propdata.net
To view the PropData PAPIA policy - please click on the link below:
https://www.propdata.net/paia-act

Opt-in for communication from Kinesis Property Group:

Consent/Request to Submit Information Form - Natural Person

Consent/Request to Submit Information Form - Juristic Person