Privacy Policy

Introduction

This privacy notice explains how Vukile collects and uses personal data, and describes the rights you have with respect to your personal data.

In this notice, “Vukile,” “our”, “we” or “us” refers to Vukile Property Fund Limited, The controllers of your personal data are Vukile Property Fund Limited or one of the Vukile group.

Vukile have appointed a representative to act on their behalf in certain instances.

Vukile processes personal data for a variety of purposes which are set out hereunder and in accordance with the Protection of Personal Information Act 4 of 2013 (POPIA). Alternatively, we process your personal data in the context of providing professional services. We obtain your personal data via publicly available sources, such as LinkedIn, social media, fill in forms and other sources in terms which personal information is given.

If you have any questions regarding the processing of your personal data or wish to contact the information officer of Vukile, please refer to Contact Us on the Vukile website.

What data is covered

In this privacy notice, “personal data” means any information relating to an individual who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data or an online identifier. Subject to Vukile’s rights to process special and personal information, personal data refers to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of an individual.

It also includes special categories of personal data (special category data) from which we can determine or infer an individual’s

• Racial or ethnic origin
• Political opinions
• Religious or philosophical beliefs
• Membership of a trade union
• Genetic data
• Biometric data
• Physical or mental health or condition
• Sex life or sexual orientation

As well as personal data relating to criminal convictions and offences.

Your rights in relation to personal data

You have the following rights in relation to your personal data:

• To access the personal data held by Vukile about you
• To have your personal data corrected, for example, if it is incomplete or incorrect
• To opt out of receiving marketing communications at any time
• To restrict or object to the processing of personal data or request erasing personal data (in certain circumstances and subject to applicable law)
• To receive a copy of the personal data which you have provided to Vukile, in a structured, commonly used and machine-readable format (known as “data portability”) (in certain circumstances and subject to applicable law)
• Where you have provided personal data voluntarily, or otherwise consented to its use, the right to withdraw your consent
• The right to complain to a data protection authority (see section “Complaints ”)

If you have a query or wish to exercise your rights, please speak to the Vukile Information Officer contactable via Contact Us on the Vukile website

Complaints

If you are concerned about an alleged breach of privacy law or any other regulation by Vukile, you can contact the Vukile Information Officer who will investigate your complaint and give you information about how it will be handled.

You also have the right to complain to the regulator, or refer the matter to a court of competent jurisdiction or as specified in any applicable engagement agreement with Vukile.

Visitors to Vukile website

When you visit our site, we collect certain personal data automatically from your device. Specifically, the data we collect automatically include information, such as your IP address, pixel ID, device type, unique device identification number, browser type, operating system, broad geographic location (e.g., country or city-level location) and other technical information. We also collect information about how your device has interacted with our site, including the pages accessed, current URL, time you visited the site and links clicked. Collecting this information enables us to better understand the visitors who come to our site, where they come from and what content on our site is of interest to them. We use this information for our internal analytics purposes with Vukile protecting your personal information in terms of POPIA at all times, and to improve the quality and relevance of our site to our visitors. Information will be collected using cookies and similar tracking technologies.

Our site uses Adobe Analytics (“Adobe”) in order to provide reporting, visualisations and analysis of data. Adobe processes the following types of personal data: your IP address Your personal data will be processed by Adobe for the following purposes: (i) to capture web metrics about the journey of users within our site (e.g. pages viewed and links clicked); (ii) to analyze and understand overall site traffic information; (iii) to allow us to make informed decisions about our site; and (iv) to authenticate users and permit them to access our site. Vukile is the data controller for the purposes of this processing and license.

Our site also uses various social media plugins.

Purposes for which we process your personal data as a visitor to our site are:

• To administer and manage our site, including to confirm and authenticate your identity, and prevent unauthorized access to restricted areas of our site
• To personalize and enrich your browsing experience by displaying content (including targeted advertising) that is more likely to be relevant and of interest to you
• To analyze the data of visitors to our site and site traffic information
• To capture webmetrics about the journey of users within our site
• To determine the company, organization, institution or agency that you work for or with which you are otherwise associated
• To develop our business and services
• To provide you with marketing communications,
• To conduct benchmarking and data analysis (for example, regarding usage of our site and demographic analyses of visitors of our site)
• To understand how visitors use the features and functions of our site
• To monitor and enforce compliance with applicable terms of use
• To conduct quality and risk management reviews
• To allow for content download and lead capturing
• To allow services and information to be delivered effectively to you

Legal grounds for processing personal data of visitors of our site are:

• Any other ground as permitted in terms of POPIA.
• Our legitimate interest in the effective delivery of information and services to you, and the effective and lawful operation of our businesses
• Our legitimate interest in developing and improving our site, and your user experience
• Explicit consent of the visitor

Individual data obtained in providing services to clients
We seek confirmation from our clients that they have the authority to provide personal data to us in connection with the performance of the services and that any personal data they provide to us has been processed in accordance with applicable law.

We process many categories of personal data such as:

• Personal details (such as name, age, data of birth, gender, marital status and country)
• Contact details (such as phone numbers, email address and postal address)
• Financial details (such as salary, payroll, income, investments, benefits and tax status)
• Employment details (such as role, rank, experience, performance data and employment numbers)

Social Media Platforms

Vukile uses various social media platforms, for example, for recruitment or marketing purposes. We use social media to provide you with easy access to relevant information regarding job opportunities at Vukile and events we organize, and to promote our services and brand.

While Vukile will be responsible for the content it publishes using social media platforms, Vukile will not be responsible for managing the social media platforms (such as creating user statistics or placing cookies). When using these social media platforms, you are obliged to adhere to the legal and privacy terms imposed by the social media platform providers. Such providers collect personal data about you, including statistical and analytical data regarding your use of the social media platforms, such as an overview of pages you have accessed, “likes,” recent visits, posts you publish or find interesting. If you require access to such data or want to invoke one of your other rights (such as the right to object to the processing of your data), you should contact the social media platform provider. Some social media providers provide Vukile with aggregate data relevant for our pages, such as the amount of “likes” triggered by our content or the amount of posts, visitors to our sites, photos that are downloaded or links that are clicked.

Individuals who correspond with Vukile via phone and voicemail services
Vukile’s phone service is hosted internally at Vukile. When you call Vukile personnel, only your phone number will be stored on Vukile servers and will be delivered to the recipient of your call on their handset and via an email. No other personally identifiable information is collected but technical logs and reports may be stored for trouble shooting purposes.

Vukile’s voicemail service is provided by Microsoft. When you call Vukile personnel and leave a voicemail, this voicemail and any personal data contained within it will be stored on a Vukile server and will be delivered to the recipient of your call as an MP3 voice clip in an email.

Legal grounds for processing personal data of individuals who correspond with Vukile via phone and voicemail services:

• Any other ground as permitted in terms of POPIA.
• Our legitimate interest in maintaining communication networks

Visit to Vukile offices

When you visit a Vukile office, we process your personal data in order to provide you with certain facilities (such as access to our buildings and conference rooms or Wi-Fi), to control access to our buildings, and to protect our offices, personnel, goods and confidential information (for example, by using CCTV).

The personal data we collect is generally limited to your name, contact information, location, and the time you enter and leave our office.

Visitor records and access badges
We require visitors to our offices to sign in at reception and we keep that record of visitors for a short period of time. Visitors to our offices are provided with a temporary access badge to access our offices. Our visitor records will be used to verify that access badges are returned, to look into a security incident and for emergency purposes (for example, if an office needs to be evacuated).

Wi-Fi
We monitor and log traffic on our Wi-Fi networks. This allows us to see limited information about a user’s network behavior, but will also include being able to see at least the source and destination addresses the user is connecting from and to.

CCTV
Vukile uses CCTV monitoring where permitted by law. CCTV images are securely stored and only accessible on a need-to-know basis (for example, to look into an incident). We are allowed to disclose CCTV images to law enforcement bodies. We will also share CCTV images with our insurers for purposes of processing an insurance claim as a result of an incident. CCTV recordings are typically deleted or automatically overwritten after a short period of time unless an issue is identified that requires further investigation.

Legal grounds for processing personal data of visitors to Vukile offices are:

• Any other ground as permitted in terms of POPIA.
• Our legitimate interest in protecting our offices, personnel, goods and confidential information
• Our legitimate interest in preventing and detecting crime, and establishing, exercising and defending legal claims

Transfers of personal data

Vukile has subsidiary offices in Spain and Property Managers in Namibia, therefore, your personal data will be transferred outside the country in which you are located in certain instances.
We take appropriate security and legal precautions to safeguard the safety and integrity of personal data that is transferred within the Vukile Group.

Security

Vukile adequately protects the confidentiality and security of information it obtains in the course of its business. Access to such information is limited, and policies and procedures are in place that are designed to safeguard the information from loss, misuse and improper disclosure.

Keeping your data up to date

We maintain the accuracy and completeness of the personal data we hold. It is important that you inform us of any updates to your contact details or other personal data so that we have the most up-to-date information about you. Please contact the Vukile Reception in this regard.

Retention

Vukile will store data for a period of 7 years or if longer as required by law to achieve the purposes for which the data was collected or will subsequently process, unless:

• longer retention is required by law;
• Vukile requires the data for a lawful purpose relating to the function and activities conducted by Vukile;
• it is required by a contract between the parties;
• where your consent has been obtained for a longer period; or
• is used for historical, statistical and research purposes and has been deidentified with reasonable measures implemented to protect your privacy.

In order to meet our professional and legal requirements, to establish, exercise or defend our legal rights, and for archiving and historical purposes we need to retain information for significant periods of time.

Minors

Our Site is not intended for use by minors under the age of 18 (eighteen) years. Vukile does not knowingly collect, disclose, or sell the personal data of minors under 18 (eighteen) years of age.

Changes to this privacy notice

We will occasionally update this privacy notice to reflect changes in our practices and services. When we post changes to this privacy notice, we will revise the “last updated” date at the top of this privacy notice. If we make any material changes in the way we collect, use, and share personal data, we will notify you by prominently posting notice of the changes on the website. We recommend that you check this page from time to time to inform yourself of any changes in this privacy notice.

In general we also wish to bring under your attention:

• Replace “personal data” with the words “personal information”;
• When referring to legitimate interest for processing personal information, caution should be had as this term has not yet been defined and if defined, same might be narrowed in that although legitimate interest relating to service delivery and improving your site may not stand up against the nature of any disclosures or use of personal information.

POPIA

POPIA information request – send completed form to info@vukile.co.za

• Form 2: Request for Access to Record
• Form 3: Outcome of Request and of Fees Payable