BELLVILLE CONNECT PRIVACY POLICY

(“Privacy Policy”)

THE GREATER TYGERBERG PARTNERSHIP (PTY) LTD (Trading as Bellville Connect) (REGISTRATION NUMBER: 2012/181308/08)

(“BELLVILLE CONNECT”, “Us”, “We” “Our”)

IMPORTANT – PLEASE READ THESE TERMS CAREFULLY WHEN USING OR ACCESSING OUR WEBSITE AND/OR THE MOBILE APPLICATION (“BELLVILLE CONNECT”).

1. INTRODUCTION

1. 1. We respect your privacy and take the protection of personal information very seriously. The purpose of this policy is to describe the way we collect, store, use, and protect information that can be associated with a specific natural or juristic person and can be used to identify that person.

   2. Please read this policy carefully before accessing the Website, Mobile Application or the Bellville Connect Services.

2. EFFECTIVE DATE

   1. You agree that this policy will apply and be effective when you access or use our Website, Mobile Application or the Bellville Connect Services found at www.bellvilleconnect.co.za.

3. BROWSER TERMS AND COMMERCIAL TERMS

   1. There are other terms that are applicable to your use of our Website, Mobile Application or the Bellville Connect Services. Browser Terms can be found at https://www.bellvilleconnect.co.za/terms-and-conditions/ or on our Website. Commercial Terms become applicable when you purchase and access products and services through our Website found at www.bellvilleconnect.co.za.

4. ACCEPTANCE AND CONSENT

   1. You accept all the terms in this policy when you use our Website, Mobile Application or the Bellville Connect Services. You hereby consent to us collecting the personal information as referred to in this policy.

5. AMENDMENTS TO THIS POLICY

   1. We may amend and/or amplify the terms of this policy from time to time in line with any changes that the law or our internal business operations require, without prior notice. It is your responsibility as the user or member to consider the policy each time you use our Website, Mobile Application or access any the Bellville Connect Services. If you do not agree with any terms of this policy, you must stop using our Website, Mobile Application and the Bellville Connect Services immediately.

6. PRIVACY LAWS AND PROTECTING YOUR PERSONAL INFORMATION

   1. We will take the necessary steps to protect your privacy when you use our Website or Mobile Application, including compliance with the Protection of Personal Information Act, 4 of 2013 (“POPI”), General Data Protection Regulations (GDPR) and all reasonable steps to be in compliance with the privacy laws of users outside of the EU and South Africa.

   2. We have listed your rights that you have under data protection laws.

      1. the right to access – you can ask for copies of your personal data;

      2. the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

      3. the right to erasure – you can ask us to erase your personal data;

      4. the right to restrict processing – you can ask use to restrict the processing of your personal data;

      5. the right to object to processing – you can object to the processing of your personal data;

      6. the right to data portability – you can ask that we transfer your personal data to another organisation or to you;

      7. the right to complain to a supervisory authority – you can complain about our processing of your personal data; and

      8. the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

   3. These rights are subject to certain limitations and exceptions.

   4. General Data Protection Regulation (GDPR) – You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

7. WHAT IS PERSONAL INFORMATION?

   1. If we refer to “personal information” or “information” in this policy, we mean personal information as defined in POPI. It includes, for example, your full name, surname, email address, identity number, contact details, and location.

8. INFORMATION COLLECTION

   1. We collect information about you when you use our Website or Mobile Application or access and use Bellville Connect Services and communicate with us. We may also collect information about you from third parties (if necessary).

   2. Our service is not directed to children under sixteen and does not knowingly collect personally identifiable information from children under the age of sixteen. If you are under the age of sixteen, you must ask your parent or guardian for permission to use this website. If we learn that we have collected personal information of a child under sixteen, we will take the appropriate steps to delete such information from our files as soon as possible. If you learn that a child has provided us with personal information in violation of this policy, you can alert us at +27 21 823 6713.

9. USE OF COOKIES

   1. We sometimes use “cookies”. “Cookies” are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive.

   2. They enable us to improve interactivity with the Website and Mobile Application. The purpose of “cookies” is to enhance your future visits to our Website or Mobile Application. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use all the functions that Bellville Connect offers on the Website and Mobile Application.

   3. Cookies enable us to improve our service to you, estimate our audience size and usage patterns, store information about your preferences and recognise when you return to our Website and Mobile Application. In some instances, we collect and store information about your location. We convert your IP address or mobile GPS data into a rough geo-location.

   4. Please note that third parties who advertise on our website may also use cookies, but we do not have access to, or control over them, and therefore cannot take responsibility for them.

   5. We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our Website and Mobile Application.

10. USE OF YOUR INFORMATION

    1. We will not sell personal information, unless such information has been appropriately anonymised ensuring all identifying fields have been securely masked and encrypted. No personalised individual data will be disclosed to anyone except as provided in this privacy policy.

11. INFORMATION THAT WE STORE AND USE

    1. We generally store and use the following information:

       1. your first name(s);

       2. surname;

       3. address;

       4. phone numbers;

       5. email address;

       6. IP address;

       7. cookie information;

       8. location information;

       9. demographic information;

       10. including your age and gender; and

       11. and any other information which we reasonably need to perform our obligations in terms of the agreement with you when you purchase or use our Bellville Connect Services.

12. PURPOSES FOR PROCESSING INFORMATION

    1. We will only process adequate and relevant information to:

       1. Perform in terms of our agreement;

       2. Operate and manage your account;

       3. Monitor and analyse our business;

       4. Carry out market research, business and statistical analysis; and

       5. Comply with our regulatory or other obligations.

13. SHARING OF PERSONAL INFORMATION

    1. We will keep your personal information confidential and only share it with others in terms of this policy, if you consent to it, or if the law requires from us to share it.

    2. We have trusted relationships with carefully selected third parties who perform services for us. All these service providers have a contract with us in terms whereof they have a legal obligation to secure your personal information and to use it only in a way that we permit. In general, we may share your information with our affiliates, third party service providers, payment gateways, regulatory and governmental authorities or tax authorities (if they request us to do so), and any other third party if the law requires from us to share it.

    3. Our Website and Mobile Application may connect to various social media sites or apps, including Facebook, Twitter, LinkedIn, Instagram and Google+. If you want to use our Website and Mobile Application for social media integration, including to create user profiles and login functionality, we will share your information with the relevant social media sites or apps.

    4. We may transmit or transfer personal information outside South Africa to a foreign country.

    5. Across the EU, we will endeavour to ensure compliance with the General Data Protection Regulation (GDPR) and should you believe we are in contravention of the GDPR, you may contact our privacy officer at +27 21 823 6713 and we will ensure we revert within 48 hours of your correspondence.

14. RETENTION OF INFORMATION

    1. We will aim to keep the personal information we collect as accurate, complete and up to date as is necessary for the purposes in this policy. From time to time we will request you to update your personal information on the Website and Mobile Application.

    2. We will only retain your personal information for as long as it is necessary to fulfil the purposes explicitly set out in this policy, unless retention of the record is required or authorised by law; or you have consented to the retention of the record.

15. CONCERNS AND SECURITY BREACH

    1. We will report any security breach to the Information Regulator in South Africa, and the GDPR regulatory body (if applicable) and to the individuals or companies involved. If you want to report any concerns about our privacy practices or if you suspect any breach regarding your information, kindly notify us by sending an email to [email protected]

ANNEXURE B: BROWSER TERMS

BELLVILLE CONNECT PRIVACY POLICY

(“Browser Terms”)

THE GREATER TYGERBERG PARTNERSHIP (PTY) LTD (Trading as Bellville Connect) (REGISTRATION NUMBER: 2012/181308/08)

(“BELLVILLE CONNECT”, “Us”, “We” “Our”)

IMPORTANT – PLEASE READ THESE TERMS CAREFULLY WHEN USING OR ACCESSING OUR WEBSITE AND/OR THE MOBILE APPLICATION (“BELLVILLE CONNECT”).

1. BROWSER TERMS

What are these Browser Terms?

1. 1. These are the Terms that regulate your use of our Website, Mobile Application or the Bellville Connect Services, and our relationship with you (“You”). They create a legally binding contract between us, as soon as they apply.

   2. This is not an exhaustive list, but these Browser Terms apply when you browse, use, ‘surf’, share, post and or comment on our Website, Mobile Application and the Bellville Connect Services.

2. THE GOAL OF THESE BROWSER TERMS

   1. We will have no obligations to you whatsoever and we will not be liable at all for any liability, damage or loss resulting from your use or inability to use our Website, Mobile Application and the Bellville Connect Services. You should not act in a way that relies on any information on our Website and Mobile Application and the Bellville Connect Services. You use our Website, Mobile Application and the Bellville Connect Services at your own risk.

3. OUR WEBSITE

   1. Our Website is found at www.bellvilleconnect.co.za

4. EFFECTIVE DATE

   1. These Browser Terms will apply and become effective if you access or use our Website, Mobile Application and the Bellville Connect Services. Don’t use our Website, Mobile Application or Bellville Connect Services if you don’t absolutely agree to these Browser Terms, as you can only use our Website, Mobile Application or the Bellville Connect Services on these Browser Terms.

5. PRIVACY POLICY AND COMMERCIAL TERMS

   1. There are other terms that are applicable to your use of our Website, Mobile Application and the Bellville Connect Services. A privacy policy can be found at https://www.bellvilleconnect.co.za/terms-and-conditions/ or on our Website. Commercial terms become applicable when you purchase services and products through our Website found at https://bellvilleconnect.co.za

   2. If there is a conflict between these Terms and the Commercial Terms, the Commercial Terms will apply.

6. CHANGES TO OUR WEBSITE AND/OR THESE TERMS

   1. We have the sole and unfettered right (as far as the law allows) to suspend, change or add to our Website, Mobile Application and the Bellville Connect Services, and to change or add to any of these Browser Terms and such changes will apply as soon as they are made.

7. USE OF OUR WEBSITE

   1. You may not:

      1. distribute any content from our Website, Mobile Application and the Bellville Connect Services without our prior consent;

      2. use any technology, including but not limited to crawlers and spiders, to search our Website, Mobile Application and Bellville Connect Services or obtain information from the same;

      3. copy our Website, Mobile Application and the Bellville Connect Services or any source code or pages;

      4. post any defamatory or illegal content;

      5. link to our Website and Bellville Connect Services in a manner other than through the homepage or mobile interface; or

      6. deep-link to any other pages in a way that would suggest that you own the intellectual property that belongs to us.

8. INTELLECTUAL PROPERTY

   1. You acknowledge and agree that all right, title and interest in, and to, any of our intellectual property (including but not limited to any copyright, trademark, design, logo, process, practice, source code, or methodology which forms part of, or is displayed or used on the Website, Mobile Application and the Bellville Connect Services or any products sold by us, including, without limitation, any graphics, logos, designs text, button icons, images, audio clips, digital downloads, data compilations, mobile applications, page headers and software) is proprietary to us and will remain ours at all times.

   2. You agree that you will not acquire any rights of any nature in respect of our intellectual property by using our Website, Mobile Application and or Bellville Connect Services.

9. LIMITED LIABILITY

For purposes of clarity:

1. 1. we will not be liable to you for any loss caused using our Website, Mobile Application and the Bellville Connect Services or your liability to any third party arising from those subjects. This includes:

      1. any interruption, malfunction, downtime, off-line situation or other failure of the Website, Mobile Application and the Bellville Connect Services, system, databases or any of its components;

      2. any loss or damage regarding your data or other data directly or indirectly caused by malfunction of the Website, Mobile Application and the Bellville Connect Services; and

      3. any third-party systems whatsoever, power failures, unlawful access to or theft of data, computer viruses or destructive code on the Website and Bellville Connect Services and/or third-party systems or programming defects;

2. INDEMNITY

You shall indemnify, defend and hold us (including our shareholders, directors and employees, in whose favour this constitutes a stipulation capable of acceptance in writing at any time), our affiliates and their employees and suppliers harmless from any and all third party claims, any, actions, suits, proceedings, penalties, judgments, disbursements, fines, costs, expenses, damages (including, without limitation, indirect, extrinsic, special, penal, punitive, exemplary or consequential loss or damage of any kind) and liabilities, including reasonable attorneys’ fees, whether directly or indirectly arising out of, relating to, or resulting from the negligence, breach of these Browser Terms or violation of applicable law, rule, regulation by a party or its affiliates, or their respective owners, officers, directors, employees, or representatives.

11. GOVERNING LAW AND DISPUTE RESOLUTION

    1. The content of these Browser Terms is governed by South African law, including the Website and Bellville Connect Services and any interaction you may have with the Website and Bellville Connect Services regardless of what country you are based in, or the country where you access the Website and Mobile Application or the country where you receive or use our services.

    2. If we ever have a dispute, then you agree that the High Court of South Africa (Cape Town) will have sole jurisdiction to consider our dispute, applying these Terms and South African law.

12. CONTACT INFORMATION

    1. Please email us at [email protected] for any enquiries about our Website, Mobile Application and the Bellville Connect Services.

13. DISCLOSURE IN TERMS OF SECTION 43 OF ELECTRONIC COMMUNICATIONS AND TRANSACTIONS ACT, 25 OF 2002

    1. Site owner: The Greater Tygerberg Partnership (Pty) Ltd (trading as “Bellville Connect”), registration number: 2012/181308/08

    2. Legal status: Bellville Connect is a South African private limited liability company.

    3. Email address:

    4. Website address: www.bellvilleconnect.co.za

Registered address: Unit 3A, Bell Park Building, c/o Durban Road & De Lange Street, Bellville, 7135