TWIN CITY GROUP PRIVACY NOTICE
Who are we?
The Twin City Group is a collective of private companies which specialise in property investment and management South Africa and abroad. We are a Responsible Party in terms of the Protection of Personal Information Act, 4 of 2013 (POPIA) with respect to your Personal Information and as such we want to take certain steps to make sure that you are fully aware of exactly who we are, the types of Personal Information we process, how we process it, who we may need to share it with, as well as what your rights are in relation to our processing of your personal information in terms of POPIA.
As will become clear to you in this notice, we process all personal information in order to enable us to do business with you and to provide products and services to you as requested. In this notice, “you” means you as an individual or an entity with whom we are dealing and whose Personal Information we may need to collect and process in order to provide the requested services and for any of the purposes described below.
What Personal Information do we collect and process?
Please note that in accordance with Section 18 of POPIA you are hereby expressly informed of the fact that when you engage with us, or we engage with you, you may need to provide us with the following Personal Information, including but not limited to:
You should know that we collect and record all internet communications (including IP addresses), all correspondence we have with you irrespective of the medium of communication, details of your dealings with us and any visits to our website(s). In addition, we collect and generate information in relation to your profile as a client of ours.
Unless we are specifically required to do so, in which case we will inform you and obtain your consent, we do not collect any special personal information as defined in section 26 of POPIA, including your religious or philosophical beliefs, race or ethnic origin, trade union membership, political persuasion health or sexual orientation or biometric information.
What do we do with your Personal Information and why do we collect it?
We take the privacy of our data subjects (clients, employees, suppliers etc.) very seriously and we only collect and process Personal Information for specific purposes which are connected to our legitimate business purposes, which we generally need in order to comply with our obligations towards you and also to comply with obligations which are imposed upon us in terms of applicable laws regulating us.
The Personal Information you provide to the Twin City Group in your dealings with us, is primarily processed for the purposes of enabling us to comply with our contractual and lawful obligations. However, we do want to highlight a few specific instances which are also connected to our legitimate business purposes:
In supplementation of the above purposes, we are legally required to collect and process certain personal information for very specific purposes, such as to comply with our obligations as a managing agent.
Who do we share your Personal Information with?
For us to maintain the high standards of product and service delivery you have come to appreciate, we are required to share your personal information with some of our suppliers, service providers and business partners (“approved third parties”). We use service providers and suppliers who we trust, who we have agreements with and they are required to keep your personal information secure and confidential, and to only use it for purposes which we have agreed to and if we are comfortable that they are securing your personal information. If you are interested in who these approved third parties are, you can ask us and direct your enquiry to email@example.com
Where do we store your Personal Information and how long do we store it for?
First, you should know that we only store your Personal Information for as long as what we need to in order to fulfil a purpose for why we initially collected it, which may include either complying with our obligations towards you as a customer, or to comply with applicable laws that require us to do so. All your personal information is stored securely by the Twin City Group through the use of cloud-based storage facilities. In storing your Personal Information, we may transmit or transfer Personal Information outside South Africa to a foreign country, as such, personal information may be stored on servers located outside of South Africa in foreign countries that have different data protection laws in place. We are comfortable that these foreign countries protect Personal Information to an extent that compares to the way in which we do, which is acceptable to us.
What are your Rights?
It is important that you know that you have certain rights in terms of POPIA and we want you to know exactly what they are and how they relate to us. As a data subject in relation to the Twin City Group, you have the following rights:
The contact details of the Information Regulator are:
The Information Regulator (South Africa)
JD House 27 Stiemens Street Braamfontein Johannesburg, 2001
PO Box 31533
Braamfontein, Johannesburg, 2107
With that said, we have (and continue to) implement reasonable security measures and protocols to protect the personal information we hold. These measures are to protect any personal information we hold form being disclosed without authorisation, from loss, damage, destruction or unauthorised access. As you will appreciate nothing is 100% secure in this day and age and therefore, we ask that if you suspect that either you, or we, have had an information security breach, please notify us immediately so that we can take action.
Should you have any queries or even questions regarding this privacy notice and the Twin City Group’s POPIA compliance efforts, please direct your queries and questions to firstname.lastname@example.org
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