By providing The Residence Portfolio with your personal information, you agree to the terms of this  Privacy Policy and authorise us to process such information in the manner set out herein. 

This Privacy Policy and Disclaimer applies to all external parties with whom we interact, including but  not limited to guests, agents, visitors to our properties, and other users of our hospitality services (“you”). 

The Residence Portfolio respects the privacy of your personal information and has implemented  reasonable measures to ensure that processing of your personal information is aligned to the  requirements of the Protection of Personal Information Act 4 of 2013 (‘POPIA’). 

In this Privacy Policy we explain how and when we collect, use, disclose, transfer, store and process  personal information. If you have questions arising from the processing of information that are not  specifically listed herein, you may visit our website at www.theresidenceportfolio.co.za, or contact us  on info@theresidenceportfolio.co.za for assistance. The Residence Portfolio may review and update  this Privacy Policy from time to time. 

Please read the following information carefully. If you book on behalf of others, you are responsible for  ensuring that the others are aware of the content of this Privacy Policy and are in agreement with you  supplying their personal date to use to make a booking or enquiry. By making a booking or an enquiry,  you agree to the transfer, storage and processing of it as necessary. We will take all reasonable steps  necessary to ensure your data is treated securely and in accordance with this Privacy Policy but if you  do not agree with this policy we cannot accept your booking and you should not use this website. 

Terms defined in the Terms and Conditions shall have the same meaning herein, unless expressly  stated otherwise. 

Definitions 

In this document the following words shall have the meanings ascribed to them: “Personal information” shall have the meaning ascribed to that term in the POPIA; 

“POPI” or “POPIA” means the Protection of Personal Information Act, No. 4 of 2013, as amended  from time to time and available for viewing at www.gov.za/documents/acts; 

“Privacy Policy” means the privacy policy of The Residence Portfolio set out in this document, as  amended from time to time; 

“process” means anything that is done with any personal information, whether or not by automated  means, such as collection, recording, organisation, structuring, storage, adaptation or alteration,  retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making  available, alignment or combination, restriction or destruction, and “processing” and “processed”  shall be construed accordingly; and 

“Terms and Conditions” means the Website terms and conditions and policies set out in the  document titled “Terms and Conditions” accessible on the Website, as may be amended from time  to time. 

Introduction 

This Privacy Policy ensures that The Residence Portfolio: 

∙ complies with the provisions of the POPIA; 

∙ is open and transparent about how we use your personal data; and 

∙ makes you aware, as far as reasonably possible, of your rights under the POPIA.

The Residence Portfolio hereby undertakes and/or warrants that: 

∙ all relevant staff members are aware, or shall be made aware of, the importance of the privacy  and protection of your personal information and the correct processes to follow in relation to  privacy and the handling of personal information; 

∙ your data will be used lawfully, fairly and in a transparent manner; 

∙ we will only collect your personal information for valid purposes that we have clearly explained  to you and not use your personal information in any way that is incompatible with these relevant  purposes and limited only to those purposes; 

∙ will only keep your personal information for as long as necessary for the purposes for we require  it or as required by law; and 

∙ we will take all reasonable steps and measures to ensure that your personal information is kept  securely and protected against unauthorized or unlawful processing and against loss or  destruction using appropriate technical and organizational measures. 

What personal information we collect 

∙ The Residence Portfolio will only collect personal information from you which we need to fulfil the  requirements of our services to you, as our guest. 

∙ We collect and record only the minimum personal information that is required for us to deliver our  services to you. 

∙ The categories of your personal information which we may collect and hold may include but are not  limited to: such as name, address, email address, telephone number, date of birth, and personal  travel arrangements. In addition, we may also be required to obtain your passport details to pass  to authorities which require Advanced Passenger Information. 

∙ We will need to collect this information to arrange the travel and other services you are requesting.  In some cases, we may also need to collect more sensitive personal data such as information  concerning medical conditions, disabilities and special requirements such as dietary requests which  may disclose your religious beliefs, so as to be able to consider your particular needs in relation to  a booking. 

How we use this personal information 

We use your personal information to: 

∙ fulfil our contract with you and/or deal with your booking or intended booking, including  processing your booking, sending you your itinerary or other details relating to your booking; ∙ update you on changes to your stay or travel itinerary (for example, if there is a change to your  booking pre-travel or if a flight is delayed or cancelled); 

∙ manage your wider travel or services requirements (for example, liaising with and transferring  your data to airlines, service providers and/or travel facilitators so that they can facilitate your  booking and/or your travel arrangements so any disruption can be minimised), this includes  when you book a package, hotel, car or other service which may be provided by us or third  parties with us; 

∙ process payments for your booking, fulfil requests for refunds and for accounting or audit  purposes; 

∙ personalise the service and offers you receive (for example, by being aware of previous travel  experiences, transactions or preferences, and tailoring the way we provide our products or  services to you based on your preferences and profile); 

∙ communicate and interact with you at different times throughout your journey; ∙ communicate with airlines, accommodation providers and other parties that are part of your  journey regarding your experience, preferences, compliments or complaints; 

∙ improve the products and services we offer or help us to create new ones; ∙ conduct guest satisfaction surveys so that we can obtain a better understanding of how we can  continue to improve the products and services we offer or help us to create new ones. During  these surveys we may collect personal information from you relating to your  thoughts/comments about your experience with us; and 

∙ market our products and services to you. 

Where we need to process your special personal information (or those you are booking for), we will  do so in the ordinary course of our business, for a legitimate purpose, and in accordance with  applicable law. We also share this information with third parties (who help manage our business  and deliver services such as those parties who provide wheelchairs at airports) and other  companies (who help manage your booking or journey), and we transfer it globally. Where you (or 

any passenger travelling) provides us with special personal information you agree that you have  voluntarily provided such information, and you consent (and the passenger travelling consents) for  us to use that information for the purposes for which it was collected. 

If you have any queries about any of our products or services, compliments or complaints, we will  need to collect information from you, including your contact details, in order for us to respond to  your query or provide you with assistance. We will collect this information when you, send us an  email, call our customer service centre, visit a local office or contact us via another form of  communication such as through social media or an online chat tool. 

We may disclose your personal information to our associates, operators and service providers, for  legitimate business purposes, in accordance with applicable law and subject to applicable  professional and regulatory requirements regarding confidentiality. In addition, we may disclose  your personal information: 

∙ if required by law; 

∙ legal and regulatory authorities, upon request, or for the purposes of reporting any actual or  suspected breach of applicable law or regulation; 

∙ third party operators (including, but not limited to, data processors such as providers of data  hosting services and document review technology and services), located anywhere in the world,  subject to 4.5; 

∙ where it is necessary for the purposes of, or in connection with, actual or threatened legal  proceedings or establishment, exercise or defence of legal rights; 

∙ to any relevant party for the purposes of the prevention, investigation, detection or prosecution  of criminal offences or the execution of criminal penalties, including, but not limited to,  safeguarding against, and the prevention of threats to, public security; 

∙ to any relevant third party acquirer(s), in the event that we sell or transfer all or any portion of  our business or assets (including, but not limited to, in the event of a reorganization, dissolution  or liquidation); and 

∙ to any relevant third party provider, where our Website uses third party advertising, plugins or  content. 

If we engage a third party operator to process any of your personal information, we recognise that  any operator who is in a foreign country must be subject to a law, binding corporate rules or binding  agreements which provide an adequate level of protection similar to POPIA. We will review our  relationships with operators we engage and, to the extent required by any applicable law if force,  we will require such operators to be bound by contractual obligations to: 

∙ only Process such Personal Information in accordance with our prior written instructions; and ∙ use appropriate measures to protect the confidentiality and security of such Personal  Information. 

Direct Marketing 

∙ We may process your personal information for the purposes of providing you with information  regarding services that may be of interest to you. You may unsubscribe for free at any time. ∙ If you currently receive marketing information from us which you would prefer not to receive in the  future please email us at info@theresidenceportfolio.co.za 

International transfer of Personal Information 

∙ We may transfer your personal information to recipients outside of the Republic of South Africa. ∙ Subject to 4.5, Personal Information may be transferred outside of the Republic of South Africa  provided that the country to which the data is transferred has adopted a law that provides for an  adequate level of protection substantially similar to POPIA, the operator/third party undertakes to  protect the Personal Information in line with applicable data protection legislation and the transfer  is necessary in order to provide the hospitality and other related services that are required by our  clients. 

Storage of your personal information 

∙ We keep your personal information for as long as is reasonably necessary for the purposes for  which it was collected. For example, to manage bookings and provide you with any relevant 

products or services, as explained in this Privacy Policy. We will ensure that it is disposed of in a  secure manner. 

∙ In some circumstances we may store your personal information for longer periods of time, for  example, where we are required to do so in accordance with legal, regulatory, tax, or accounting  requirements. In specific circumstances we may store your personal information for longer periods  of time so that we have an accurate record of your dealings with us in the event of any complaints  or if we reasonably believe there is a prospect of litigation relating to your personal information or  dealings. 

Your rights in terms of the POPIA 

Where applicable, your rights in terms of the POPIA include, among others, to: 

∙ be informed of the personal information being held by The Residence Portfolio, why it is being held,  and how, if at all, it was used and shared or otherwise dealt with by us; 

∙ have access at any time to your personal information being held by us; 

∙ at any time be able to rectify errors in relation to your personal information in our possession; ∙ request that your personal information held by us is deleted or no longer used by us, save for if we  are required by law to retain the personal information (in which case it cannot be deleted). 

Accuracy of personal information 

Should your personal information change at any time, the onus is on you to inform and notify The  Residence Portfolio of such change. You acknowledge that the personal information provided to The  Residence Portfolio should be accurate, complete and up-to-date. 

Security breach and Disclaimer 

∙ Whilst we have implemented and taken all reasonable measures to protect your personal  information in our possession and to ensure that our information systems are not breached,  because the internet is an open system, the transmission of information via the internet is not  completely secure and The Residence Portfolio cannot guarantee the security of any information  transmitted using the internet and we cannot be held liable for any loss of privacy occurring during  the course of such transmission. 

∙ Should a breach occur, The Residence Portfolio undertakes to ascertain how and where the breach  occurred and make sure that the exposed area is repaired immediately. 

∙ We will ascertain which data has become vulnerable as a result and notify you if the breach may  affect you and assist you to minimize any potential damages that you may suffer as a result. 

Contacting The Residence Portfolio 

If you have any questions, complaints, objections, requests to restrict processing of your personal  information, or otherwise in respect of this Privacy Policy, you may contact us  on info@theresidenceportfolio.co.za. 

Updates to our Privacy Policy 

The Residence Portfolio reserves the right to review, revise, amend or replace the contents of this  Privacy Policy from time to time.