Privacy Policy

SYRENE WEBSITE PRIVACY NOTICE

  1. APPLICATION OF THE PRIVACY NOTICE

The SYRENE Group Limited (collectively referred to as “we”, “us”, “SYRENE” or “the Company”) Privacy Notice applies to the Personal Information of visitors and investors who visit our Corporate SYRENE Website and who engage with us in any manner (“you”).

Use of the Corporate SYRENE Website is also subject to our disclaimer as set out on the Website.

  1. WHAT PERSONAL INFORMATION DO WE COLLECT AND PROCESS?

We respect your privacy and we will comply with all applicable laws when handling your Personal Information. In this Privacy Notice, Personal Information is used as defined in the Protection of Personal Information Act 4 of 2013 (POPIA). Personal Information is largely any information that is used to identify a juristic person or a natural person.

When you use our Website we may collect, without detracting from the generality thereof, the following Personal Information which belongs to you:

– Your input data such as your name, email address; including password or identifiers, which may have been allocated to you as part of the registration for alerts on the Vault alert services on the Website; when making enquiries or interacting with us about our services via any electronic platform such as email.

– Metrics and information collected by Google analytics which may include device identification; network and connection information (including Internet Service Provider (ISP) and Internet Protocol (IP) addresses), device and browser identifiers and information, cookie identifiers and information, and similar data as applicable; usage information and browsing history, such as usage metrics, content interactions (including searches, views, downloads) and user journey history and approximate geographical location.

  1. THE PURPOSE FOR THE COLLECTION AND USE OF YOUR INFORMATION

3.1 The Personal Information which you provide to us is used for the following purposes:

  • to register for alerts and Securities Exchange News Service (Sens) announcements on the Vault platform; to provide any information to you that you have requested; to enable access to the corporate intranet; to provide you with any Company information, goods or services that you have enquired about and/or requested; to provide, maintain, protect and improve our Website; to manage our relationship with you (for example, customer services and support activities); to deliver services with third parties with whom you have a separate relationship; to monitor, measure, improve and protect our content, Website offerings and provide an enhanced user experience;
  • to monitor and carry out statistical analysis as offered by Google analytics, provided that in such circumstances it is on an aggregated basis which will not be linked back to you or any living individual.

3.2 Our Website may contain technology, including only necessary cookies and those used by Google analytics that enable us to collect information about how you use the functions or the features of our Website.

3.3 Where you are not in agreement with the types of processing, you can opt out of this type of processing by not providing us with any of your information and or managing your privacy settings within your browser or on our Website (where applicable).

SYRENE PRIVACY NOTICE

  1. SHARING YOUR INFORMATION

4.1 We may share your information with:

  • any Company employee, manager, subsidiary or related company which we may merge or divest from wholly or in part;
  • our service providers and agents (including their sub-contractors) or third parties which process information on our behalf (e.g. affiliates, internet service and platform providers and those service providers or organisations who we engage to help us provide you with the Company services or to send communications to you);
  • SYRENE partners, including system implementers, independent software vendors and developers that may help us to provide you with the Website, products, services and information you have requested;
  • any law enforcement or regulatory bodies;
  • our own professional advisors, including attorneys and auditors, consultants;
  • another organisation to whom we may transfer our agreement with you.

4.2 We may share non-personal identifiable information about the use of our Website, products or services publicly or with third parties but this will not include information that can be used to identify you.

4.3 Where we share or disclose your Personal Information as described above, such sharing and or disclosure will always be subject to an agreement which will be concluded as between ourselves and the party to whom we are disclosing your Personal Information to, which contractually obliges the recipient of your Personal Information to comply with strict confidentiality and data security conditions.

4.4 Where your Personal Information is transferred to a recipient in a country which is situated outside South Africa, your Personal Information will only be transferred to those recipients who are stated in countries which have similar data privacy laws in place or, where the recipient of the Personal Information concludes an agreement which contractually obliges the recipient to comply with strict confidentiality and data security conditions and which in particular will be to a no lesser set of standards than those imposed by POPIA.

4.5 By using our Website, or by interacting with us in the ways described in this Privacy Notice, you consent to the transfer of your Personal Information to other parties in the circumstances set out in this Privacy Notice. If you do not want your information to be shared and/or transferred in such manner you should not use our Website.

  1. SOCIAL MEDIA, AND OTHER THIRD-PARTY PLATFORMS

5.1 When you link onto social media forums like Facebook, Twitter, Pinterest, lnstagram, Linkedln, YouTube, etc., which may house a reference to us, please note that these are not our platforms and that the use of these platforms will be subject to the relevant platform owners’ own privacy notices, and that we take no responsibility for your use of these platforms.

5.2 Where our Website may contain links to third-party Websites; if you follow these links, you will exit our Website and the use of these Websites will be subject to the relevant platform owners’ own privacy notices.

  1. HOW DO WE PROCESS CHILDREN’S PERSONAL INFORMATION?

Any person who accesses our Websites who is under the age of 18 may only do so with the consent of his or her parent/legal guardian. If we determine upon collection that any person accessing the Websites is under the age of 18, and has not provided a parent/guardian’s consent, we will not use or maintain his/her Personal Information.

  1. LAWFUL REASONS FOR PROCESSING

7.1 In terms of POPIA, consent to process your Personal Information is not required where there is a lawful reason for such processing.

SYRENE PRIVACY NOTICE

7.2 Where a lawful reason cannot be met or shown for any specific processing detailed under this Privacy Notice, then your consent to such processing is required. Where your consent is required for the processing of your Personal Information, the provision of the required Personal Information in such instances by you, to us, will be taken as your indication that we may process your Personal Information, which consent, you may at any time withdraw, in the prescribed manner and form, but which withdrawal may affect your ongoing ability to optimally use the Website.

  1. SECURITY AND STORAGE OF INFORMATION

8.1 We will use our best endeavours to keep your Personal Information secure by taking reasonable and appropriate measures to ensure that Personal Information is protected from misuse, loss, unauthorised access and disclosure.

8.2 Whilst we will use our best endeavours as indicated above to protect your Personal Information, please note that no method of transmission over the Internet or method of electronic storage is 100% secure and that in light of this we cannot guarantee the security of your Personal Information which is transmitted via the Website, or to other Websites, applications and services via an internet or similar connection.

8.3 Where we have given you, or you have chosen a password to access certain areas of our Website, please keep this password safe and do not share this password with anyone.

8.4 Once your Personal Information is no longer required or when we are no longer required by law to retain same, such Personal Information will be destroyed or de-identified.

  1. WHEN YOU PROVIDE US WITH INFORMATION ABOUT OTHERS

If you provide us with Personal Information about someone else, you warrant that you have consent to provide us with such 3rd party information and indemnify and hold us harmless against any losses or damages in the event that such consent is not in place.

  1. CHANGES TO THIS PRIVACY STATEMENT

As we change and evolve over time, this Privacy Notice is expected to change as well. We reserve the right to amend the Privacy Notice at any time, for any reason, and without notice to you other than the posting of the updated Privacy Notice on the Website and in this regard encourage you to visit our Website frequently in order to keep abreast with any changes.

  1. QUERIES / COMPLAINTS / CONTACT US

11.1 Any comments, questions or suggestions about this Privacy Notice or our handling of your Personal Information should be emailed to: book@thesyrene.co.za

For further contact details see: www.thesyrene.co.za

11.2 Should you wish to discuss a complaint, please feel free to contact us using the details provided above. All complaints will be treated in a confidential manner.

11.3 Should you feel unsatisfied with our handling of your Personal Information, or about any complaint that you have made to us, you are entitled to escalate your complaint to the South African, Information Regulator who can be contacted through https://www.justice.gov.za/inforeg/

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