BRETT NEVILLE GOSLING TRUST PRIVACY POLICY

 

  1. COMPANY INFORMATION

Company: Brett Neville Gosling Trust

Information officer: Anke Cecillia Gosling

E-mail address: anke@vintageview.co.za

 

  1. DEFINITIONS

2.1. “Policy” shall mean the Website Privacy Notice and Policy.

2.2. “Information Officer” shall mean the person registered as the information officer by the company as stipulated under Company Information on page 1 (one) of this Policy.

2.3. “POPIA” shall mean the Protection of Personal Information Act 4 of 2013.

2.4. "Personal Information" shall mean all information which may be considered to be personal in nature or information about an identifiable natural and / or existing juristic person (where applicable) in terms of the Electronic Communications and Transactions Act 25 of 2002 ("ECTA"), the Consumer Protection Act 68 of 2008 ("CPA") and the Protection of Personal Information Act 4 of 2013 (“POPIA”).

2.5. “User, you, your or yourself” shall refer to any person who makes use of the Website for any purposes whatsoever, whether or not such use is free of charge or paid for.

 

  1. COMMITMENT TO YOUR PRIVACY

 3.1. Welcome to the Website, owned and operated by Brett Neville Gosling Trust.

3.2. Brett Neville Gosling Trust is committed to protecting the privacy of the user of the Website.

3.3. Brett Neville Gosling Trust values the trust of its subscribers and all others who work with it, and we recognize that maintaining your trust requires transparency and accountability in how the Company handles your Personal Information.

3.4. In performing Brett Neville Gosling Trust’s services in the ordinary course of business, we may collect, use, store and disclose Personal Information.

3.5. Anyone from whom Brett Neville Gosling Trust collects such information can expect that it will be appropriately and lawfully protected and that any use of or other dealing with this information is subject to consent, where this is required by law. This is in line with the general privacy practices of Brett Neville Gosling Trust.

3.6. This Policy sets out how Brett Neville Gosling Trust collects, stores, uses, discloses, and safeguards the Personal Information it processes in the course of its business.

 

  1. WHAT PERSONAL INFORMATION DOES THE COMPANY COLLECT AND WHY?

 4.1. Brett Neville Gosling Trust may collect Personal Information in conducting its ordinary business operations, including through the use of its website.

4.2. Brett Neville Gosling Trust will collect and store personal information and continue to communicate with data subjects under the following circumstances:

4.2.1. When users contact us with queries or requests pertaining to our products or services.

4.2.2. When employing staff members and to maintain their employment status.

4.2.3. When contracting with customers and processing invoices or financial information.

4.2.4. In the event of applications for employment by submitting resumes to the company.

4.2.5. When sending out communications pertaining to general information, notices, and service offerings.

4.3. In processing such Personal Information, Brett Neville Gosling Trust shall at all times ensure that we comply with the provisions of POPIA, and such Personal Information is used for legitimate business purposes.

 

  1. OBTAINING CONSENT

Brett Neville Gosling Trust does not, except where otherwise permitted by law, collect, store, use or disclose your Personal Information without your consent.

 

  1. USE AND DISCLOSURE OF PERSONAL INFOMRATION

 6.1. Brett Neville Gosling Trust operates its website, and conducts its business in general, in accordance with South African legislation. Brett Neville Gosling Trust considers it imperative to protect the privacy interests of data subjects.

6.2. If Brett Neville Gosling Trust sends Personal Information outside of South Africa (including if such information is hosted offshore), we will ensure that all reasonable steps are taken to ensure that we comply with all applicable laws in this regard, including POPIA.

 

  1. RETENTION OF PERSONAL INFORMATION

 All Personal Information retained on HR & Labour Consulting’s database, including such information obtained through the use of the Website, is in accordance with the retention provisions set out in the applicable laws and regulations of South Africa, including those set out in POPIA.

 

  1. YOUR RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION

 8.1. It is important to note that you have rights in relation to your Personal Information.

8.2. You have the right to contact Brett Neville Gosling Trust at any time to ask us to:

8.2.1. confirm that it holds your Personal Information (at no charge);

8.2.2. provide you access to any records containing your Personal Information or a description of the Personal Information that the Company hold about you (subject to payment of a prescribed fee); and / or

8.2.3. confirm the identity or categories of third parties who have had, or currently have, access to your Personal Information (also subject to payment of a prescribed fee).

8.3. Brett Neville Gosling Trust’s contact information is as set out under Company Information on page 1 (one) of this Policy.

8.4. When you make a request regarding your Personal Information, Brett Neville Gosling Trust will take reasonable steps to confirm your identity.

8.5. There may be times when Brett Neville Gosling Trust cannot grant access to your Personal Information, including where granting you access would interfere with the privacy of others, or result in a breach of confidentiality. Brett Neville Gosling Trust will always provide you with reasons if this is the case.

8.6. If you are of the view that any Personal Information that Brett Neville Gosling Trust holds about you is incorrect in any way, including that it is inaccurate, irrelevant, outdated, incomplete or misleading, you are allowed to ask us to correct it.

8.7. If you believe that any Personal Information that Brett Neville Gosling Trust holds about you is excessive or has been unlawfully obtained, you can ask us to destroy or delete it.

8.8. You may do the same if you think that Brett Neville Gosling Trust has retained if for longer than necessary, given the purpose. Brett Neville Gosling Trust will do so unless there are good grounds not to (such as that Brett Neville Gosling Trust is required to hold it for a period prescribed by any applicable legislation).

8.9. It is important, however, to understand that if you withdraw your consent for Brett Neville Gosling Trust to use some of your Personal Information, it may affect the quality and level of service that we can provide to you.

 

  1. SECURITY

 9.1. Brett Neville Gosling Trust has adopted a security model to protect your Personal Information that complies with generally accepted information security practices and procedures.

9.2. As part of Brett Neville Gosling Trust’s security systems, we have implemented password control, PMH Guardian for all workstations and the server (this ensures the computer is running optimal and security patches are installed), antivirus software (Sentinel One) and PMH Guardian Backup (this is an offsite cloud backup with encryption). This is in addition to the physical security measures (Hikvision Security Camera systems and Loskop Alarm system with locked Offices) adopted by Brett Neville Gosling Trust to ensure that it takes all appropriate, reasonable technical and all measures to prevent loss of, damage to, or unauthorized destruction of Personal Information, and unlawful access to or processing of Personal Information.

9.3. Brett Neville Gosling Trust has a stringent security policy in place that every employee, consultant, contractor, and supplier of Brett Neville Gosling Trust must adhere to.

9.4. Brett Neville Gosling Trust confirms that it takes all reasonable measures to:

9.4.1. identify all reasonably foreseeable internal and external risks to any Personal Information in its possession or under its control;

9.4.2. establish and maintain appropriate safeguards against any risks that are identified by Brett Neville Gosling Trust;

9.4.3. regularly verify that these safeguards are effectively implemented by or on behalf of Brett Neville Gosling Trust; and

9.4.4. ensure that such safeguards are continually updated in response to new risks or deficiencies in previously implemented safeguards.

 

  1. COOKIES

 10.1. The website uses cookies in a limited way.

10.2. Cookies are small files containing information that a website uses to track a visit by a user. 10.3. Brett Neville Gosling Trust uses session cookies to better understand how the website is used by users to improve the performance of the website for users, particularly the way search pages are delivered.

10.4. Brett Neville Gosling Trust has installed settings on the website to ensure that session cookies do not remain on your computer at the end of your visit to the website and cannot be used to obtain any personally identifiable details.

 

  1. THIRD-PARTY WEBSITES

 11.1. The website may contain links to third party websites.

11.2. In the event that you follow a link to any of these websites, it is important to note that these websites have their own terms of use and privacy policies, and that Brett Neville Gosling Trust does not accept any responsibility or liability for them.

11.3. If you are a customer of Brett Neville Gosling Trust, or are a user of the website, and you have purchased products or services from Brett Neville Gosling Trust, we may use your contact details to send you details of any new similar products or services which we think you would be interested in. In doing so, Brett Neville Gosling Trust will at all times comply with any applicable direct marketing laws.

11.4. Any communications that you do receive from Brett Neville Gosling Trust will set out how to opt out of receiving future communications from us, free of charge, if you no longer wish to receive material for any reason whatsoever.

11.5. Brett Neville Gosling Trust will only send you marketing messages when you tick the relevant boxes at certain times when engaging with us.

11.6. As Brett Neville Gosling Trust is not responsible for any representations, information, warranties and / or content on any website of any third party (including websites linked to this website), we do not exercise control over third parties' privacy policies and the responsibility is on the User to refer to the privacy policy of any such third party before providing them with any of your Personal Information.

 

  1. EMAILS DOMAIN VINTAGEVIEW

 12.1. Disclaimer added to email domain for all Vintage View email users at the bottom of each email send, forwarded or replied to.

 

  1. UPDATING OF PRIVACY POLICY

 13.1. Brett Neville Gosling Trust, in its sole discretion, reserves the right to update, modify or amend this Policy from time to time with or without notice.

13.2. You therefore agree and undertake to review the Policy whenever you visit the website. 13.3. Save as expressly provided to the contrary in this Policy, any amended version of the Policy shall supersede and replace all previous versions thereof.

 

  1. CONTACT INFORMATION

Questions, concerns, or complaints related to this Policy or the Company’s treatment of Personal Information should be directed to the email address set out under Company Information on page 1 (one) of this Policy. Users may also contact the information regulator with complaints and concerns: inforeg@justice.gov.za