Spotters Fee Privacy Policy

Physical Address:

No 5 Parkland,

229 Bronkhorst Street,

Pretoria,

South Africa

Information Officer:Ludwig Traut,

Contact:admin@spottersfee.co.za

1.Introduction

Welcome to our privacy policy.We respect your privacy and take the protection of personal information very seriously.We understand that your trust is our most important asset.

To provide you with our full range of products and services we need to collect and process certain information about you.

The purpose of this policy is to describe the way that we collect, store, use, and protect information that can be associated with you or another specific natural or juristic person and can be used to identify you or that person personal information.

This privacy policy must be read in conjunction with ourTerms and Conditions.

2.Audience

This policy applies to you if you are:

•a visitor to our website,mobile site,or

•a customer who has ordered a product or requested a service that we provide or

•anyone contacting us by phone, SMS, email, in letters and other correspondence, and in person.

3.Personal information

Personal information includes:

•certain information that we collect automatically when you visit our website

•certain information collected on registration (see below)

•certain information collected on submission and

•optional information that you provide to us voluntarily (see below)

but excludes:

•information that has been made anonymous so that it does not identify a specific person

•permanently de-identified information that does not relate or cannot be traced back to you specifically

•non-personal statistical information collected and compiled by us and

•information that you have provided voluntarily in an open, public environment or forum including any blog, chat room, community, classifieds, or discussion board because the information has been disclosed in a public forum, it is no longer confidential and does not constitute personal information subject to protection under this policy.

Common examples of the types of personal information which we may collect and process include:

•Identifying information – such as your first name and last name

•Contact information– such as your phone number and email address

4.Acceptance

You acknowledge and accept all the terms of this policy when accessing the website to order a product or request our services.

If you do not agree with anything in this policy, then you may not access the website and order a product or request our services.

You may not access our website or order a product or request our services if you are younger than 18 years old or do not have legal capacity to conclude legally binding contracts.

By accepting this policy, you are deemed to have read, understood, accepted, and agreed to be bound by all of its terms.

You may only send us your own personal information or the information of another data subject where you have their permission to do so.

5.Changes

We reserve the right to change the terms of this policy at any time. All changes to this policy will be posted on the website. Unless otherwise stated, the current version shall supersede and replace all previous versions of this policy. If you do not agree with the changes, then you must stop using the website and our products or services. If you continue to use the website or ourproductsor services following notification of a change to the terms, the changed terms will apply to you and you will be deemed to have accepted those updated terms.

6.Collection

6.1 Purposes for collection

We may use or process any product or services information, or optional information that you provide to us for the purposes indicated in this privacy policy. Processing includes gathering your personal information, disclosing it, and combining it with other personal information. We generally collect and process your personal information for various purposes, including

• • products or services purposes – such as collecting orders or requests for and providing our products or services
• • marketing purposes – such as pursuing lawful related marketing activities
• • business purposes – such as business intelligence and analytics, product improvement, internal audit, accounting, business planning, and joint ventures, disposals of business, or other proposed and actual transactions and
• • legal purposes – such as handling claims, complying with regulations, or pursuing good governance.

6.2 On registration

Once you register on our website to create an account, you will no longer be anonymous to us. You will need to provide certain personal information when you register on our website.

This personal information will include:

your firstname and surname

your email address

your telephone number

your password.

We will use this personal information to fulfil your account, provide additional services and information to you as we reasonably think appropriate, and for any other purposes set out in this policy. This includes newsletters and email alerts. If you wish to opt out you can do so by clicking on the unsubscribe link at the bottom of the emails.

6.3 On product order or service request

When you order a product or request a service from us, you will be asked to provide us with additional personal information on a voluntary basis.

6.4 Communication

6.5 Messages and updates

6.6 From browser

6.7 Cookies

6.8 Optional details

6.9 Recording calls

6.10 Consent to collection

Email alerts

Newsletters

Valuations

Where you have given consent to process your personal information you may withdraw consent at any time by clicking the unsubscribe link in an email alert or newsletter.

7.Disclosure

7.1 Sharing

We may share your personal information with:

Our products or services providers under contract who help provide certain products or services or help with parts of our business operations, including fraud prevention, bill collection, payment services, credit checks,marketing, technology services. Our contracts dictate that these product or services providers only use your information in connection with theproductsor services they supply orservices they perform for us and not for their own benefit

7.2 Regulators

We may disclose your personal information as required by law or governmental audit.This will include public authorities, insurance companies, finance companies, automotive advertising companies and/or other agencies. Information shared in this way will not be used for marketing purpose

7.3 Law enforcement

For the purposes of the prevention or detection of offences, and/or the apprehension or prosecution of offenders, we may share any information obtained or collected by us with the Police, other public or private sector agencies or representative bodies in accordance with the relevant legislation. We may disclose personal information if required:

by a subpoena or court order

to comply with any law

to protect the safety of any individual or the general public and

to prevent violation of our customer relationship terms.

7.4 Marketing purposes

We may disclose aggregate statistics (information about the customer population in general terms) about the personal information to advertisers or business partners.

7.5 Employees

We may need to disclose personal information to our employees that require the personal information to do their jobs. These include our responsible management, human resources, accounting, audit, compliance, information technology, or other personnel.

7.6 Change of ownership

If we undergo a change in ownership, or a merger with, acquisition by, or sale of assets to another entity, we may assign our rights to the personal information we process to a successor, purchaser, or separate entity. We will disclose the transfer on the website. If you are concerned about your personal information migrating to a new owner, you may request us to delete your personal information.

8.Security

All the information we receive about you is stored on secure servers and we have implemented technical and organisational measures that are suitable and necessary to protect your personal data. We continually evaluate the security of our network and adequacy of our internal information security program which is designed to help secure your data against accidental or unlawful loss, access or disclosure, identify reasonably foreseeable risks to the security of our network, and minimize security risks, including through risk assessment and regular testing.

Please note, despite the measures we have implemented to protect your data, the transfer of data through the Internet or other open networks is never completely secure and there is a risk that your personal data may be accessed by unauthorised third parties..

9.Accurate and up to date

We will try to keep the personal information we collect as accurate, complete and up to date as is necessary for the purposes defined in this policy. From time to time we may request you to update your personal information on the website. You are able to review or update any personal information that we hold on you by accessing your account online, emailing us, or phoning us. Please note that in order to better protect you and safeguard your personal information, we take steps to verify your identity before granting you access to your account or making any corrections to your personal information.

10.Retention

We will only retain your personal information for as long as it is necessary to fulfil the purposes explicitly set out in this policy, unless:

retention of the record is required or authorised by law or

you have consented to the retention of the record.

During the period of retention, we will continue to abide by our non-disclosure obligations and will not share or sell your personal information.

We may retain your personal information in physical or electronic records at our discretion.

11.Transfer to another country

We may transmit or transfer personal information outside of the country in which it was collected to a foreign country and process it in that country. Personal information may be stored on servers located outside the country in which it was collected in a foreign country whose laws protecting personal information may not be as stringent as the laws in the country in which it was collected. You consent to us processing your personal information in a foreign country whose laws regarding processing of personal information may be less stringent.

12.Removing

You may choose to remove the personal information you have submitted to us, by clicking the profile menu under your user account on our website or contacting us.

We will request proof of identity before removing your information.

13.Limitation

We are not responsible for, give no warranties, nor make any representations in respect of the privacy policies or practices of linked or any third party websites.