Leopard Creek Website Privacy Policy
Leopard Creek (“we” “us” or “our”) is a golf estate and own and operate this website.
This website privacy policy describes how we process information we collect and/or receive from you.
1. What Is Personal information?
Personal information is defined by the Protection of Personal Information Act (“POPIA”), as ‘any information relating to an identifiable living natural or existing juristic person’.
Personal information is, in simpler terms, any information about you that enables you to be identified. Personal information covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
We process personal information by both automated (electronically) and non-automated means (paper based as part of a filing system).
2. What Are My Rights?
Under POPIA, you have the right to have your personal information processed according to 8 processing conditions that are summarised as follows:
Condition 1 – Accountability.
We must ensure that the conditions set out in Chapter 3 of the Act and all the associated measures are complied with.
Condition 2 – Personal information must be collected and processed lawfully in a reasonable manner that does not infringe on your rights. Personal information may only be processed if it is adequate, relevant, and not excessive.
Personal information may only be processed if you consent thereto, alternatively where it is necessary to do so for the conclusion or performance of a contract, an obligation in terms of law, to protect your legitimate interest/s, or to pursue our legitimate interest/s.
Personal information must as far as possible be collected directly from you.
Condition 3 requires that personal information must be collected for a specific explicitly defined and lawful purpose related to a function or activity of ours. Such personal information may not be retained any longer than necessary for achieving the purposes for which the information was collected and/or subsequently processed.
Condition 4 prohibits the further processing of your personal information unless such processing is compatible with the initial purpose of collecting the information.
Condition 5 requires us to take reasonable, practicable steps to ensure that your personal information is complete, accurate, and not misleading. Such personal information must also be kept up to date, taking into consideration the purpose of the personal information.
The nature and purpose of your personal information will dictate as to how often such information must be updated.
Condition 6 requires that we must, as far as it is practicable, inform you before your personal information is collected and the purpose of collecting and from where your personal information will be collected.
You are entitled to our details and must be made aware of the consequences of not disclosing personal information to us where it is required for a specific purpose.
You must also be made aware if your personal information is collected and processed as requirement established in law.
As per Section 72 of the Act, you will be advised if your personal information will be transferred across the borders of South Africa.
Condition 7 requires that we must secure the integrity and confidentiality of your personal information by taking appropriate reasonable, technical, and organisational measures, to prevent the loss thereof or unlawful access thereto.
Condition 8 – You have the right to establish whether your personal information is held by us and to have it corrected or destroyed if it is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or have been obtained unlawfully.
1. Information We Collect & Receive
We collect and receive information about you in the following ways:
1.1. Information you give us
This includes any information that you provide to us directly:
1.1.1. when you utilise our services;
1.1.2. by filling in forms on our websites, or those provided to you;
1.1.3. when you contact us or we contact you and you provide information directly to us.
1.2. What personal information we collect
1.2.1. When you use our services, you will be required to provide us with the following information, your
1.2.1.1. name and surname;
1.2.1.2. contact number and email address;
1.2.1.3. physical address;
1.2.1.4. identity or passport number; and
1.2.1.5. date of birth.
1.3. Information we collect or receive when you use our website platforms
We collect information when you use websites by using cookies, web beacons and other technologies. Depending on how you access and use websites, we may receive:
1.3.1. Log information;
1.3.2. Information we infer about you based on your interaction with products and services;
1.3.3. Device information (for example the type of device you’re using, how you access platforms, your browser or operating system and your Internet Protocol (“IP”) address);
1.3.4. Location information.
1.4. Information from third-party sources
We may receive additional information about you that is publicly or commercially available and combine that with the information we have collected or received about you in in other ways.
2. How We Use the Information We Collect & Receive
We use the information we collect and receive for the following general purposes:
2.1. to provide you with information, products or services you request from us;
2.2. in order to refer you to an appropriate third-party service provider;
2.3. to communicate with you; and
2.4. to provide you with support.
3. How We Share & Collect The Information We Receive
3.1. We don’t sell your personal information to third parties for their marketing purposes.
3.2. We may share information with:
3.2.1. our affiliates, in other words, other companies in our group;
3.2.2. we may disclose your personal information to a limited number of our employees and third-party service providers (other than those who we refer you to), who we assist you to interact with;
3.2.3. our business partners. We may share non-personally identifiable information with select business partners;
3.2.4. other parties in response to legal process or when necessary to conduct or protect our legal rights;
3.2.5. companies that provide services to us. Companies that provide services to us or act on our behalf may have access to information about you. These companies are limited in their ability to use information they receive in the course of providing services to us or you; and
3.2.6. third-parties where you provide consent.
4. Your Rights
4.1. Our websites use cookies. If you wish to reject our cookies, you can configure your browser to do so.
4.2. We want to make sure that any data we hold about you is up to date. So, if you think your personal information is inaccurate, you can ask us to correct or remove it.
4.3. Your further have the following rights, which we will always work to uphold:
• The right to be informed about our or collection and use of your personal information. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions.
• The right to access the personal information we hold about you.
• The right to have your personal information rectified if any of your personal information held by us is inaccurate or incomplete.
• The right to delete your information, in example the right to ask us to delete or otherwise dispose of any of your personal information that we hold.
4.4. The right to restrict (i.e. prevent) the processing of your personal information.
4.5. The right to object to us using your personal information for a particular purpose or purposes.
4.6. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal information, you are free to withdraw that consent at any time.
4.7. The right to not have your personal information processed for the purposes of direct marketing by means of electronic communication without your consent.
4.8. It is important that your personal information is kept accurate and up to date. If any of the personal information we hold about you changes, please keep us informed as long as we have that information.
4.9. Further information about your rights can also be obtained from the Information Regulator’s Office at https://www.justice.gov.za/inforeg.
4.10. If you have any cause for complaint about our use of your personal information, you have the right to lodge a complaint with the Information Regulator’s Office. We would welcome the opportunity to resolve your concerns ourselves.
5. Retention of Data
We will retain your personal information only for as long as is necessary for the purposes set out in this privacy policy or to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.
We will not keep your personal information for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal information will therefore be kept for:
• as long as it serves the purpose it was collected and intended for,
• such periods as prescribed in any legislation applicable to our business,
• any period agreed to in a contract,
• the purposes of fulfilment of a contract, or
• any period you may have agreed to.
6. Our Commitment to Security
The security of your data is important to us. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. However, we do employ a number of safeguards intended to mitigate the risk of unauthorised access or disclosure of your information. We will do our best to protect your personal information and we will use up to date technology that will help us to do this. We will at all times comply with our obligation under applicable law.
7. Transfer of Data
7.1. We are based in and operate from South Africa. Your information, including personal information, may be transferred to and maintained on servers located outside of your country of residence, where the data privacy laws, regulations and standards, may not be equivalent to the laws in your country of residence.
7.2. We might transfer your personal information to places outside of South Africa and store it there, where our suppliers might process it. If that happens, your personal information will only be transferred to and stored in country that has equivalent, or better, data protection legislation than South Africa or with a service provider which is subject to an agreement requiring it to comply with data protection requirements equivalent or better than those applicable in South Africa.
7.3. Your use of our website, followed by your submission of information to us, represents your consent to such transfer.
7.4. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
8. Links To Other Websites
Our website or may contain links to and from websites, mobile applications or services of third parties, advertisers or affiliates. Please note that we are not responsible for the privacy practices of such other parties and advise you to read the privacy statements of each website you visit which collects personal information.
9. Changes To This Privacy Policy
We may update this privacy policy from time to time. Any changes that we may make to our privacy policy will be posted on our website and will be effective from the date of posting.
10. Access to Your Personal Information
10.1. You may at any time request:
10.1.1. confirmation that we hold your personal information;
10.1.2. access to your personal information;
10.1.3. the identities or categories of third parties to whom we have disclosed your personal information; or
10.1.4. that we correct or delete any personal information that is incomplete, misleading, inaccurate, excessive or out of date.
11. How Do I Contact You?
To contact us about anything to do with your personal information and the protection of your personal information, including to make a data subject access request, please use the following details (for the attention of The Information Officer):
Email address: privacy@leopardcreek.co.za
Telephone number: 013-791 2000.
Postal Address: PO BOX 385, Malelane, 1320.
Requests may be made in writing to privacy@leopardcreek.co.za
12. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal information protection. Any changes will be made available on our company website.