DATE OF LAST REVISION: JUNE 29, 2021
REDSANDS GOLF (PTY) LTD
PRIVACY NOTICE AND INFORMED CONSENT NOTICE
CONSENT TO PROCESS PERSONAL INFORMATION IN TERMS OF THE PROTECTION OF INFORMATION ACT, 4 OF 2013 (POPIA) & THE EUROPEAN COMMUNITY GENERAL DATA PROTECTION REGULATIONS (GDPR)
(EMAIL, WEBSITE AND SOCIAL MEDIA PRIVACY NOTICE)
The Protection of Personal Information Act, 4 of 2013 (POPIA) gives effect to the constitutional right to data privacy in terms of Section 14 of the Bill of Rights of the Constitution.
The responsible use of the REDSANDS GOLF (PTY) LTD website and related resources in respect of data privacy is important to us.
Whilst REDSANDS GOLF (PTY) LTD is committed to protecting all person’s rights to privacy and who in consequence will ensure that all person’s Personal Information is used appropriately, transparently, and according to applicable law, REDSANDS GOLF (PTY) LTD has to ensure that these rights to privacy are balanced with other rights such as the right to use and have access to the REDSANDS GOLF (PTY) LTD Information and Services including its online and social media platforms and applications.
This Policy sets out the responsibilities and obligations of all persons who make use of, or access or receive REDSANDS GOLF (PTY) LTD Information and Communications via its electronic communication facilities and resources including its website, email and social media platforms and how all users of these facilities and resources are to ensure that when using these resources that they respect and process another’s Personal Information lawfully and in accordance with the provisions of POPIA & GDPR.
- Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to REDSANDS GOLF (PTY) LTD, PO BOX 7296, WELGEMOED, 7538.
- Cookies are small files that are placed on Your computer, mobile device, or any other device by a website, containing the details of Your browsing history on that website among its many uses.
- Country refers to: South Africa
- Device means any device that can access the Service such as a computer, a cell phone or a digital tablet.
- Personal Data is any information that relates to an identified or identifiable individual.
- Service refers to the Website.
- Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals utilised by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analysing how the Service is used.
- Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
- Usage Data refers to data collected automatically, either generated using the Service or from the Service infrastructure itself (for example, the duration of a page visit).
- Website refers to Redsands Golf Travel, accessible from https://www.redsandsgolf.co.za/
- The Client/You meaning the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
1.1 REDSANDS GOLF (PTY) LTD carries out its aims and objectives as an agency, marketer, and sales of holiday accommodation and leisure activities, does, and will, on an ongoing basis receive, provide and process Personal Information.
1.2 In terms of a law known as the Protection of Personal Information Act, 4 of 2013 (POPIA) & The European community general data protection regulations (GDPR) everyone has the right to privacy, including the right to the lawful collection, retention, dissemination and use of one’s Personal Information.
1.3 In order to give effect to this right, REDSANDS GOLF (PTY) LTD is under a duty to provide any person whose Personal Information is processed by it, (known as “The Client”) with several details pertaining to the use of and subsequent processing of The Client’s Personal Information, before such Personal Information may be used or processed by us.
Categories of Information We Collect:
- Information You Provide Us
- Content or Information You Provide in the Services
- Content You Provide Through Our Site
- Support Channels or Communities
- Marketing Information
- Payment Processing Information
- Technical, Device, and Connection Information
- Cookies and Other Tracking Technology
- Other Information Sources
1.4 In accordance with this requirement, REDSANDS GOLF (PTY) LTD sets out below the reasons why it will have to process The Client’s Personal Information, the conditions under which it will receive and use The Client’s Personal Information, how REDSANDS GOLF (PTY) LTD will use and handle this Personal Information, as well as the conditions under which it will provide its own Personal Information.
2.1.1 all REDSANDS GOLF (PTY) LTD electronic platforms and facilities, including social media, websites and / or email, whether owned by, established by, used by, hosted by and / or accessed by REDSANDS GOLF (PTY) LTD, and
2.1.2 all and any Clients, who may access and make use of the aforementioned REDSANDS GOLF (PTY) LTD electronic platforms and facilities, including, without detracting from the generality thereof, REDSANDS GOLF (PTY) LTD employees and staff, consumers and customers, vendors, contractors, service providers and / or other third parties.
2.1.3 all the Personal Information which is owned by REDSANDS GOLF (PTY) LTD, and which is provided to any responsible parties and / or operators because of such person accessing or making use of the REDSANDS GOLF (PTY) LTD social media and electronic platforms.
3.3 Accordingly, the relevant data privacy principles relating to the processing of Personal Information, whether that belonging to REDSANDS GOLF (PTY) LTD or that belonging to The Client (including, but not limited to, the collection, handling, transfer, sharing, correction, storage, archiving and deletion) will apply without exception, save where POPIA & GDPR provides for such an exception, to all and any Personal Information provided by REDSANDS GOLF (PTY) LTD to another or received by REDSANDS GOLF (PTY) LTD as a result of the use of the REDSANDS GOLF (PTY) LTD electronic platforms and facilities.
4. AGREEMENT TO BE BOUND AND CONSENT TO PROCESS
4.1 By accessing or using the REDSANDS GOLF (PTY) LTD electronic platforms and facilities including all website and URL’s, any sites housed under its domain names and / or social media platforms, and / or when sending or receiving emails using the REDSANDS GOLF (PTY) LTD email, The Client:
5. RECEIPT, USE AND SHARING OF PERSONAL INFORMATION BY REDSANDS GOLF (PTY) LTD
5.1 REDSANDS GOLF (PTY) LTD will receive Personal Information pertaining to a Client when The Client submits a query or request via the REDSANDS GOLF (PTY) LTD electronic platforms or facilities, including via its website, or by way of email, telephone or via social media.
5.2 On receipt of the request or query, REDSANDS GOLF (PTY) LTD will thereafter use and process the Data Client’s Personal Information for the purpose of the query and for a variety of related purposes, which will all depend on the query or request, and which without detracting from the generality thereof may include:
- for the purposes of identifying and / or verifying The Client’s details;
- for the purposes of providing information, products and / or services or details in connection therewith or pertaining thereto, that The Client, may have requested;
- for employment application purposes;
- for the purpose of concluding an employment relationship with an applicant;
- for the purposes of managing any information pertaining to The Client;
- for further processing or general administration purposes;
- for legal or contractual purposes;
- to help REDSANDS GOLF (PTY) LTD improve the quality of our products and services;
- to help REDSANDS GOLF (PTY) LTD detect and prevent fraud and money laundering;
- for the purposes of research, analytical and statistical purposes;
- for the purpose of carrying out analysis and consumer / customer profiling;
- for the purposes of identify other products and services which might be of interest to The Client;
- for the purpose of approaching The Client with business opportunities, promotional events, special offers and sales by direct marketing or otherwise;
- for the purposes of informing The Client about REDSANDS GOLF (PTY) LTD products and services.
The parties agree that:
- Consent may be withdrawn, deleted, qualified or amended upon written request from The Client;
- The Client may pre-emptively block any communication;
- The Client may request any direct marketing to be stopped;
- Any communication must only relate to goods or services similar to what The Client bought or has enquired about from the Company.
5.3 In order to correctly handle any request or query, and to perform the purposes described above, REDSANDS GOLF (PTY) LTD may from time to time share The Client’s Personal Information with the following parties:
- REDSANDS GOLF (PTY) LTD employees, which will only be done on a need-to-know basis;
- REDSANDS GOLF (PTY) LTD suppliers, which will only be done on a need-to-know basis;
- REDSANDS GOLF (PTY) LTD operators such as service providers and agents who perform services on behalf of the REDSANDS GOLF (PTY) LTD which will only be done on a need-to-know basis and in terms of a REDSANDS GOLF (PTY) LTD operator agreement.
5.4 REDSANDS GOLF (PTY) LTD do not share The Client’s Personal Information with any third parties who have not been described above, unless:
- REDSANDS GOLF (PTY) LTD is legally obliged to provide such information to another for legal or regulatory purposes;
- REDSANDS GOLF (PTY) LTD is required to do so for purposes of existing or future legal proceedings;
- the onward transmission or sharing of Personal Information is necessary for the pursuance or protection of REDSANDS GOLF (PTY) LTD legitimate interests or that of The Client or a third party;
and under all of the abovementioned circumstances, REDSANDS GOLF (PTY) LTD will take reasonable measures to ensure that such Personal Information is only provided to the recipient, if such recipient undertakes to keep the Personal Information confidential and secure.
5.5 Where REDSANDS GOLF (PTY) LTD must transfer The Client’s Personal Information across the South African borders, it will before it does so, ensure that the recipient thereof agrees to be bound by POPIA & GDPR under and in terms of a set of binding corporate rules or binding agreements that provide an adequate level of protection and uphold the principles for the reasonable and lawful processing of such Personal Information.
6. RECEIPT, USE AND SHARING OF THE REDSANDS GOLF (PTY) LTD PERSONAL INFORMATION
REDSANDS GOLF (PTY) LTD on receipt and in response to a query or request received from The Client, referred to under section 5 above, may transmit via its website, or by way of email, telephone or via social media, its own Personal Information, which Personal Information on receipt by the requesting or receiving party, may only be used for the purpose relating to the initiating of the request or query and for no other purpose. Furthermore, the recipient undertakes that it will not use this Personal Information for any other purpose or share this information with any other party, save where it has been given express permission to do so by REDSANDS GOLF (PTY) LTD.
7. INFORMATION QUALITY/OPENNESS/CLIENTS PARTICIPATION
7.1 Whilst REDSANDS GOLF (PTY) LTD will make all effort to ensure the integrity and accuracy of The Client’s Personal Information, this may always not be possible. Following this, The Client accepts the responsibility for keeping his / her or its Personal Information up to date and undertakes to inform REDSANDS GOLF (PTY) LTD of any changes to his / her and its Personal Information.
7.2 The Client has a right of access to any Personal Information which REDSANDS GOLF (PTY) LTD may have and where applicable may ask REDSANDS GOLF (PTY) LTD to correct any inaccuracies in or to any such Personal Information. Any access request must be done by making a written submission at https://www.redsandsgolf.co.za/contact-us
8. SECURITY OF PERSONAL DATA
8.1 REDSANDS GOLF (PTY) LTD makes all reasonable effort to keep its social media and electronic platforms including its website secure, however REDSANDS GOLF (PTY) LTD advises that it cannot guarantee the security of any information provided to REDSANDS GOLF (PTY) LTD or by REDSANDS GOLF (PTY) LTD through the REDSANDS GOLF (PTY) LTD website, e-mail, internet, or social media sites. Following this REDSANDS GOLF (PTY) LTD cannot be held responsible for any loss or unauthorised use, or interception of information transmitted via these social media and electronic platforms or sites, including its Internet, which is beyond our reasonable control.
8.2 The REDSANDS GOLF (PTY) LTD website may contain links to other websites outside of our control. REDSANDS GOLF (PTY) LTD is not responsible for the content, privacy, or security of these other third party-controlled websites.
8.4 REDSANDS GOLF (PTY) LTD makes use of social plugins of social networks such as Facebook, YouTube, Instagram, LinkedIn, Google+ and Twitter. Please note that REDSANDS GOLF (PTY) LTD has no influence on or control over the extent of the data retrieved by the social networks’ interfaces and REDSANDS GOLF (PTY) LTD can accordingly not be held responsible or liable for any processing or use of Personal Information transmitted via these social plugins. For information on purpose and extent of the data retrieval by the social network concerned, and about the rights and settings which are available for you to access for the protection of your private information, please refer to the data protection information provided by the social network in question.
8.5 Subject to the provisions above, REDSANDS GOLF (PTY) LTD has implemented the appropriate technical and organisational security measures which are required to protect all Personal Information and related data which it holds from and / or against unauthorised access, accidental or wilful manipulation, loss, or destruction.
9. THIRD PARTY INFORMATION AND THAT BELONGING TO MINORS
9.1 If a Data Subject provides REDSANDS GOLF (PTY) LTD with Personal Information on behalf of another, REDSANDS GOLF (PTY) LTD will not be able to process the query or request unless such query or request is accompanied with the required permission and consent from the owner of that Personal Information.
9.2 If The Client is under the age of 18, such person’s Personal Information will only be processed if the minor’s parent or legal guardian gives the required consent or permission to the processing of the provided Personal Information.
10. INTELLECTUAL PROPERTY RIGHTS
All the content contained within the REDSANDS GOLF (PTY) LTD website, including pictures, text, designs, layout design, graphics such as maps and logo’s are the intellectual property of REDSANDS GOLF (PTY) LTD and it’s associated companies and are as such protected by South African and International Intellectual Property Law.
11. CONTACT DETAILS
12. REVISION OF POLICIES
REDSANDS GOLF (PTY) LTD reserve the right to and may from time to time update this Privacy Notice. Any such revision will be published as an amended version on the REDSANDS GOLF (PTY) LTD website.
Following this, any change to this Policy will be posted as an updated version and readers are advised to visit and re-read this policy on a regular basis.