1. Introduction
We are committed to and respect your privacy. We are Coleese (Pty) Ltd Publishing (Pty) Ltd (Registration number: 2022/236389/07), also known as Coleese (Pty) Ltd. This policy describes how we collect, use, disclose, store, and protect your personal information. We may amend this policy at any time by posting the amended version here and on our other sites, and applications.

2. Application
This policy applies to you when you visit and use any Coleese (Pty) Ltd website, application, service, instant messaging services, administrative tools, or order our goods or services as a customer either as a natural person or a business (collectively “Services”), regardless of how you access or use them.
If you use any of our Portals or Services, you are regarded as a customer and thus agrees to any subsequent messages from the Portal or Services that are required for it to function and provide you with the services and functionality it renders. As a customer, you are naturally opted in for these messages on an opt-out basis.
You are contracting with Coleese (Pty) Ltd (the data controller) and its service providers (the data processors – available on request) who are responsible for the collection, use, disclosure, retention, and protection of your personal information in accordance with the Protection of Personal Information Act 4 of 2013 (POPIA), as well as any applicable acts. Coleese (Pty) Ltd may transfer data to other members of the Coleese (Pty) Ltd corporate family and we may process and retain your personal information on our servers and elsewhere in the world where our data centres or service providers are located.

3. Personal information
3.1 Scope
Your personal information is information relating to an identified or identifiable natural person or business that we collect through our Portals and Services in relation to the provision of products or services. An identifiable natural person or business is one who can be identified, directly or indirectly, by reference to an identifier which includes but is not limited to:
– a first name and last name
– identification number
– marital status
– national origin
– language
– birthplace
– relevant financial history
– medical history
– personal views, preference and opinions
– email address
– contact number
– device ID
– race
– age
– personal information of competent person for those under 18 years of age
– sex
– unique identifier
– device type
– unique device token
– location data
– an online identifier
– company name
– company registration number
– computer
– connection information such as statistics on your page views, traffic to and from the Portals, referral URL, ad data, your IP address, your browsing history, web log information, the links you click, and other actions you take while using our Services
– or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person or business.
Personal Information includes special personal information which is identified by the following identifiers:
– Race (like where a company submits reports to the Department of Labour where the statistical information must be recorded)
– Ethnic origin
– Trade union membership
– Health (like where you apply for an insurance policy)
– Biometric information (to verify your identity); and / or your criminal behaviour and alleged commission of an offense.
3.2 FICA requirements for our Services
The Financial Intelligence Centre Act, 38 of 2001 (as amended) is an anti-money laundering act. The aim of the act is to combat money laundering and imposes certain duties on certain organisations in order to prevent and combat money laundering. As part of compliance with the aim this legislation seeks to achieve, the Service provider will require the following FICA Documentation from Landlords prior to properties being listed to be rented out on the coleese.com, and from Tenants when they register to rent the listed properties:
Natural Person – Landlord/Tenant
– SA ID document (Foreigners must provide Passport)
– Proof of residential address, not older than 3 months (e.g. utility bill)
– Landlord/Tenant to provide affidavit and marriage certificate if proof of residence is in spouse’s or another person’s name
Company
– CIPC Business Registration Papers
– Proof of business address of company e.g Utility bill not older than 3 months
– ID documents of company Directors
– Confirmation of residential address and contact details of company Directors
– Resolution to specify who is authorised to act on behalf of the company
– ID document(s) of person(s) authorised to act on behalf of the company
– Confirmation of residential address and contact details of person(s) acting on behalf of the company
– Confirmation of Company’s Shareholding / Share Certificate
– Business Registration Number Certificate (BRNC)
Close Corporation (CC)
– CIPC Business Registration Papers
– Proof of business address of Close Corporation e.g. utility bill not older than 3 months
– ID document(s) of Member(s)
– Proof of residential address, not older than 3 months (e.g. Utility bill), and contact details of member(s)
– Resolution to specify who is authorized to act on behalf of Close Corporation
– ID document(s) of person(s) acting on behalf of Close Corporation
– Confirmation of residential address and contact details of person(s) acting on behalf of Close Corporation
– Business Registration Number Certificate (BRNC)
Trust(s)
– Letters of authority signed by the Master of the High Court
– Trust Deed or other Founding documents
– Resolution to specify who is authorized to act on behalf of Trust
– ID document(s) of the person(s) acting on behalf of Trust
– Confirmation of residential address and contact details of the person(s) acting on behalf of Trust
– ID documents of all trustees and beneficiaries
– Proof of residential address and contact details of all trustees and beneficiaries
– ID document of the Founder of the Trust
– Proof of residential address and contact details of the Founder of the Trust
– Business Registration Number Certificate (BRNC)
3.3 Personal Information
This personal information can be collected by various means and sources:
– automatically when you visit and use our Portals and Services
– on registration or submission
– submitted information on a web form
– responses to marketing via email, SMS, and social media platforms
– feed/import adverts to our Portals
– calling a call tracking number
– respond to an advert via WhatsApp
– update or add information to your account
– cookies, web beacons, unique identifiers, and similar technologies
– participation in community discussions, chats, and surveys
– dispute resolution or when you otherwise correspond with us
– through an order
– provided voluntarily
– excludes anonymous, de-identified, statistical, and public information.
3.4 Processing of Personal Information
We will only process this personal information for lawful purposes relating to our business if the following applies:
– If you have consented thereto
– If a person legally authorized by you, the law, or a court, has consented thereto
– If it is necessary to conclude or perform under a contract, we have with you
– If the law requires or permits it
– If it is required to protect or pursue your, our or a third party’s legitimate interest
We may process your special personal information in the following circumstances:
– If you have consented to the processing
– If the processing is needed to create, use or protect a right or obligation in law
– If the processing is for statistical or research purposes and all legal conditions are met
– If the special personal information was made public by you
– If the processing is required by law
Your obligations – You may only send us your own personal information or someone else’s personal information if you have their permission to do so.
In order to enter into our Usage Policy, some of your personal information is necessary while other personal information is voluntary, but all may all be necessary in order to use our Services, such as posting an ad, responding to an ad, and registering.
4. Acceptance and changes
4.1. Acceptance. You may not make use of any of our Portals or Services if you do not accept our Usage Policy or Privacy Policy.
4.2. Changes. We may change this policy at any time and will notify you of the changes on our Portals, through our Services, or by email. The changed policy applies to you if you continue using our Portals or our Services following the notification.

5. Collection
5.1. Automatically. We collect your Internet usage information automatically when you visit our website, including your IP address, browser details, and usage information, which we may use to display our Portals or Services correctly, track your activities on it, or for other necessary purposes.
5.2. On registration or submission. We may ask you to provide us with certain identifying information when you register on or otherwise submit information through our Portals or Services for the first time.
5.3. Submitted information on a web form. You will need to provide information while completing and submitting any form on our Platforms or Services.
5.4. Respond to marketing on email, SMS, and social media platforms. We may collect and process your data when you interact with marketing activities like responding to an email, filling in a lead form on Facebook, responding to an SMS.
5.5. Feed/import adverts to our Portals. We may collect and process certain information from feeds, APIs or other imports to enable a more automated way of advertising and managing adverts to the benefit of the advertiser.
5.6. Call a call tracking number. We will collect, process, and record calls made to call tracking numbers displayed on our Portals or through our Services for quality, training, marketing, and security purposes.
5.7. Respond to an advert via WhatsApp. We will collect and process your mobile number associated with WhatsApp when you respond to an advert that has WhatsApp enabled as a means of contact. We will also collect your contact number when you save our WhatsApp number on your phone and send us a message through this channel.
5.8. Update or add information to your account. We will collect and process the newly submitted information related to your profile and account to keep our records up to date.
5.9. Cookies, web beacons, unique identifiers, and similar technologies. We may collect and process information about the pages you view, the links you click, and other actions you take while using our Portals or Services.
5.10. Participate in community discussions, chats, and surveys. We may collect information when you discuss, chat or complete surveys about or through our Portals and Services.
5.11. Dispute resolution or when you otherwise correspond with us. We may collect information when you contact us on any of our Portals or through our Services and from any form or source of device or application.
5.12. Through an order. We ask you to provide us personal information when you order free or premium usage of our Portals or Services.
5.13. Provided voluntarily. We may ask you to provide us with certain optional information on a voluntary basis.
5.14. Consent to collection. We will get your consent to collect your personal information in accordance with the POPI act and other applicable laws when you provide us with it.
5.15. Purpose for collection. We may process information that you provide to us to be able to provide you with effective and relevant services and marketing and for the purposes that you indicated. Processing includes gathering your personal information, disclosing it, and combining it with other personal information.
5.16. If the law requires us to do so, we will ask for your consent before collecting personal information about you from third parties.
The third parties from whom we may collect your personal information include, but are not limited to, the following:
– Partners of our company for any of the purposes identified in this Privacy Policy.
– your spouse, dependents, partners, employer, and other similar sources.
– people you have authorized to share your personal information, like a person that makes a travel booking on your behalf or a medical practitioner for insurance purposes.
– attorneys, tracing agents, debt collectors and other persons that assist with the enforcement of agreements.
– payment processing services providers, merchants, banks, and other persons that assist with the processing of your payment instructions, like EFT transaction partners.
– insurers, brokers, other financial institutions, or other organizations that assist with insurance and assurance underwriting, the providing of insurance and assurance policies and products, the assessment of insurance and assurance claims and other related purposes.
– law enforcement and fraud prevention agencies and other persons tasked with the prevention and prosecution of crime;
– regulatory authorities, industry ombudsman, governmental departments, local and international tax authorities.
– trustees, Executors or Curators appointed by a court of law.
– our service providers, agents and sub-contractors like couriers and other persons we use to offer and provide products and services to you.
– courts of law or tribunals.
– participating partners, whether retail or online, in our customer loyalty reward programs.
– our joint venture partners; and/or

6. Use
6.1. Scope. We respect your privacy and have implemented the POPI Act to the best of our understanding and knowledge. We will never share your personal and/or contact information with anyone without your consent or if ordered by law. Your personal information is used to provide and improve our Portals and Services, provide you with a personalised experience, provide you customer service and help, provide you with personalised advertising and marketing, contact you about your account and our Services, and detect, prevent, mitigate, and investigate fraudulent or illegal activities.
6.2. Processing. We may process your personal information to fulfil our obligations to you and our customers. Your information will be used to personalize recommendations and information we send you regarding news, events, promotions, special offers, marketing, and third-party content. We also process the personal information we collect from you for a range of different business purposes that includes improving our Portals and Services, compiling statistics and reports, and enforcing our Usage Policy, this Privacy Policy, and other policies or any agreement or contract we have with you.
6.3. Cookies. We may place small text files on your device when you visit our Portals or use our Services that allow us to provide you with a personalized experience by associating your personal information with your device. They let us remember your preferences, allow third parties to provide services to you, and otherwise serve useful purposes for you. Your internet browser generally accepts them automatically, but you can often change this setting or delete them manually. However, we will not be able to provide you with access to certain aspects of our Portals and Services where cookies are necessary if you do so. We have no access to or control over any cookies that our business partners use on our Portals and they have their own privacy policies that govern them.
6.4. Messages. We aim to only contact you or send you messages and marketing when we determine them to be of interest to you. We may use your identifying information to send you administrative information and messages about our Portals, Services, updates, and your interests. We may also, from time to time, send you promotional messages or marketing from third parties, but you may choose to opt out of them, or we will first send you one message asking you to opt-in and will not continue to send you promotional messages or marketing unless you have done so. We don’t sell or share your personal information with third-party services for marketing purposes. We may contact you via email, telephone, SMS/text messages, postal mail, social media platforms, instant messaging systems, and via push notifications (collectively “Marketing Channels”).
6.5. Targeted content. We may use your personal information to provide you with targeted content on our Portals and through our Services and Marketing Channels in a completely automated process. We aim to deliver targeted marketing, service updates, and promotional offers about third-party services based on your communication subscription/preferences.
6.6. Manage subscription/preferences. You have the right to withdraw your consent at any time. Visit our POPIA information page for a quick-and-easy guide on how to request this or click here to read our PAIA manual.
6.7. Perform Credit Check. You hereby consent that, and authorises Coleese (Pty) Ltd (“the Company”) and its representative(s)
a) To contact, request and obtain credit information (for the avoidance of doubt this includes any and all information held on my profile by Experian South Africa (Pty) Ltd (“Experian”) including payment profile information) from Experian (a registered credit bureau) to verify my identity, perform an assessment of my behaviour, profile, payment patterns, indebtedness, whereabouts, and creditworthiness or another related purposes in any format (including in pdf, xml or raw data string) available from Experian and to continuously access my information from Experian for as long as I may have a relationship with the Company,
b) make any reasonable enquiries to verify and research any details provided by me to the Company;
c) to do an account verification check to verify that banking details provided, are correct;
d) to access the information in any format, including online, batch and raw xml string and I consent that the enquiry should not be displayed on my credit profile if the enquiry was not performed for credit application purposes;
e) to submit my information, including payment profile and default information and any other relevant information, to Experian and to allow Experian to release the information for lawful purposes to third parties.

7. Disclosure
7.1. Sharing. We do not sell, rent, or otherwise disclose your personal information to third parties for their marketing and advertising purposes without your consent. We may share your personal information with third parties for the purposes of fulfilling our obligations to you, including with:
– other companies or divisions within our group
– our contractors who help provide part of our goods or services, or
– third parties as required by applicable law.
7.2. Honour this policy. We will require anyone that we share your personal information to honor this policy whenever possible in terms of applicable law.
7.3. Mandatory disclosure. We may disclose personal information to third parties if required for legal reasons, such as to regulators as required by law or governmental audit, law enforcement as required by a subpoena or court order, or third parties as required by applicable law.
7.4. Marketing purposes. We may disclose aggregate statistical information that we have derived from your and other people’s personal information to our advertisers or business partners.
7.5. Personnel. We may need to disclose personal information to our personnel to do their jobs, but will not do so unnecessarily.
7.6. Change of ownership. We may assign our rights to the personal information we process to our new owners if our ownership changes for any reason.
7.7. Disclosure. We attempt to minimize the amount of personal information we disclose to what is directly relevant and necessary to accomplish the specified purpose.

8. Storage
8.1. Accuracy. We will do our best to keep your personal information that we collect accurate, complete, and up to date. It is also your responsibility to keep us informed of any changes to your information, including contact information or advertised items or positions.
8.2. Participation. We may ask you to update your personal information from time to time or give you a way to review it, but will take steps to verify your identity to prevent unauthorized access when doing so.
8.3. Retention. We will only keep your personal information for as long as is necessary to fulfill our obligations to you unless you have given us permission to keep it longer or we are otherwise legally allowed to do so. We retain your personal information for as long as necessary to provide the Services you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our policies. Our specific retention times can vary significantly based on the context of the Services we provide and on our legal obligations. After it is no longer necessary for us to retain your personal information, we will dispose of it in a secure manner.
9. Transfer across the border
We may transfer your personal information outside of the country in which it was collected to a foreign country. You consent to us processing your personal information in a foreign country with less stringent data protection laws than the country in which it was collected.
Under what circumstances will we transfer your information to other countries?
We will only transfer your personal information to third parties in another country in any one or more of the following circumstances:
– Where your personal information will be adequately protected under the other country’s laws or an agreement with the third-party recipient
– Where the transfer is necessary to enter into or perform under a contract with you, or a contract with a third party that is in your interest.
– Where you have consented to the transfer; and/or
– Where it is not reasonably practical to obtain your consent, the transfer is in your interest.
This transfer will happen within the requirements and safeguards of the law. Where possible, the party processing your personal information in the other country will agree to apply the same level of protection as available by law in your country or if the other country’s laws provide better protection the other country’s laws would be agreed to and applied.
An example of us transferring your personal information to another country is where foreign payments take place if you purchase goods or services in a foreign country.

10. Your duties and rights regarding the personal information we have about you
You must provide proof of identity when enforcing the rights below.
You must inform us when your personal information changes.
Please refer to our Promotion of Access to Information Act 2 of 2000 Manual (PAIA Manual) for further information on how you can give effect to the rights listed below.
You have the right to request access to the personal information we have about you by contacting us. This includes requesting:
– Confirmation that we hold your personal information.
– A copy or description of the record containing your personal information; and
– The identity or categories of third parties who have had access to your personal information.
We will attend to requests for access to personal information within a reasonable time. You may be required to pay a reasonable fee to receive copies or descriptions of records, or information about third parties. We will inform you of the fee before attending to your request.
Please note that the law may limit your right to access information.
You have the right to request us to correct or delete the personal information we have about you if it is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, obtained unlawfully or we are no longer authorised to keep it. You must inform us of your request in writing. Please refer to our PAIA Manual for further information in this regard, like the process you should follow to give effect to this right.
It may take up to 15 business days for the change to reflect on our systems. We may request documents from you to verify the change in personal information.
A specific agreement that you have entered with us may determine how you must change your personal information provided at the time when you entered into the specific agreement. Please adhere to these requirements. If the law requires us to keep personal information, it will not be deleted upon your request. The deletion of certain personal information may lead to the termination of your relationship with us.
You may object on reasonable grounds to the processing of your personal information.
We will not be able to give effect to your objection if the processing of your personal information was and is permitted by law; you have provided consent to the processing and our processing done according to your consent or the processing is necessary to conclude or perform under a contract with you.
You must inform us of any objection in writing. Please refer to our PAIA Manual for further information in this regard, like the process you should follow to give effect to this right.
Where you have provided your consent for the processing of your personal information, you may withdraw your consent. If you withdraw your consent, we will explain the consequences to you. We may proceed to process your personal information even if you have withdrawn your consent if the law permits or requires it. It may take up to 15 business days for the change to reflect on our systems, during this time we may still process your personal information.
You have a right to file a complaint with us or any Regulator with jurisdiction about an alleged contravention of the protection of your personal information by us. We will address your complaint as far as possible.

11. General
Limitation – We are not responsible for anyone else’s privacy policies or practices.
Enquiries – Please contact us if you have any questions about this privacy policy or how we handle your personal information.

12. Complaints Procedure
12.1. Procedure. We have set out some guidelines to ensure that we can effectively respond to complaints. It explains what we would require from you in order to provide feedback and take appropriate action. View the complaints procedure here.
12.2. Contact us. If you feel that any law related to your personal information has been incorrectly interpreted and implemented by us, please contact us immediately.
12.3. Your right to file a complaint with the Information Regulator remains unaffected.