SA DIGITAL VILLAGES (PTY) LTD PRIVACY POLICY

1     DEFINITIONS                                           3

2     PURPOSE OF THIS POLICY                 4

3     PROCESS OF COLLECTING PERSONAL INFORMATION                        4

4     LAWFUL PROCESSING OF PERSONAL INFORMATION                        5

5     SPECIAL PERSONAL INFORMATION AND PERSONAL INFORMATION OF CHILDREN                                                  5

6     PURPOSE FOR PROCESSING PERSONAL INFORMATION                      6

7     PERSONAL INFORMATION OF SADV EMPLOYEES                                         7

8     KEEPING PERSONAL INFORMATION ACCURATE                       7

9     STORAGE AND PROCESSING OF PERSONAL INFORMATION BY SADV AND THIRD PARTY SERVICE PROVIDERS                                                      8

10     PERSONAL INFORMATION FOR DIRECT MARKETING PURPOSES             8

11     RETENTION OF PERSONAL INFORMATION                                                9

12     FAILURE TO PROVIDE PERSONAL INFORMATION                                             10

13     SAFE-KEEPING OF PERSONAL INFORMATION                                             10

14     BREACHES OF PERSONAL INFORMATION                                             10

15     PROVISION OF PERSONAL INFORMATION TO THIRD PARTY SERVICE PROVIDERS                              11

16     USE OF WEBSITE COOKIES           12

17     ACCESS TO PERSONAL INFORMATION                                            12

18    TIME PERIODS                                                                                                         14

19     COSTS TO ACCESS TO PERSONAL INFORMATION                                                                                             14

20     CHANGES TO THIS POLICY                                                                                                                                          14

21     CONTACT US                                                                                                                                                                      14

1     DEFINITIONS                                                                                                                                                                           3

2     PURPOSE OF THIS POLICY                                                                                                                                                4

3     PROCESS OF COLLECTING PERSONAL INFORMATION                                                                                        4

4     LAWFUL PROCESSING OF PERSONAL INFORMATION                                                                                          5

5     SPECIAL PERSONAL INFORMATION AND PERSONAL INFORMATION OF CHILDREN                          5

6     PURPOSE FOR PROCESSING PERSONAL INFORMATION                                                                                      6

7     PERSONAL INFORMATION OF SADV EMPLOYEES                                                                                                   7

8     KEEPING PERSONAL INFORMATION ACCURATE                                                                                                    7

9     STORAGE AND PROCESSING OF PERSONAL INFORMATION BY SADV AND THIRD PARTY SERVICE PROVIDERS                                                                                                                                                                                      8

10     PERSONAL INFORMATION FOR DIRECT MARKETING PURPOSES                                                                  8

11     RETENTION OF PERSONAL INFORMATION                                                                                                             9

12     FAILURE TO PROVIDE PERSONAL INFORMATION                                                                                              10

13     SAFE-KEEPING OF PERSONAL INFORMATION                                                                                                     10

14     BREACHES OF PERSONAL INFORMATION                                                                                                             10

15     PROVISION OF PERSONAL INFORMATION TO THIRD PARTY SERVICE PROVIDERS                          11

16     USE OF WEBSITE COOKIES                                                                                                                                          12

17     ACCESS TO PERSONAL INFORMATION                                                                                                                   12

18    TIME PERIODS                                                                                                                                                                     14

19     COSTS TO ACCESS TO PERSONAL INFORMATION                                                                                             14

20     CHANGES TO THIS POLICY                                                                                                                                          14

21     CONTACT US                                                                                                                                                                      14

1. DEFINITIONS

In this Policy (as defined below), unless the context requires otherwise, the following words and expressions bear the meanings assigned to them and cognate expressions bear corresponding meanings –

1.1 Child” means any natural person under the age of 18 (eighteen) years;

1.2 Data Breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Information under the control of or in the possession of SADV;

1.3 Data Subject” has the meaning ascribed thereto under POPIA;

1.4 Direct Marketing” means to approach a person, by electronic communication, for the purpose of promoting or offering to supply, in the ordinary course of business, any goods or services to the Data Subject;

1.5 Employees” means any employee of the SADV;

1.6 Operator” means a person or entity who Processes Personal Information for a Responsible Party in terms of a contract or mandate, without coming under the direct authority of that Responsible Party;

1.7 Personal Information” has the meaning ascribed thereto under POPIA and specifically includes any form of information that can be used to identify a Data Subject;

1.8 Policy” means this Privacy Policy;

1.9 POPIA” means the Protection of Personal Information Act No. 4 of 2013;

1.10 Processing” has the meaning ascribed thereto under POPIA. “Process” has a corresponding meaning;

1.11 Regulator” means the Information Regulator established in terms of the Act;

1.12 Responsible Party” means a public or private body or any other person which alone or in conjunction with others, determines the purpose of and means for Processing Personal Information;

1.13 “SADV” means SA Digital Villages (Pty) Ltd, a wholesale open-access last-mile-connectivity provider incorporated in the Republic of South Africa with registration number 2007/008930/07. “Us”, “we” and “our” has the corresponding meaning;

1.14 Special Personal Information” means Personal Information concerning a Data Subject’s religious or philosophical beliefs, race or ethnic origin, trade union membership, political opinions, health, sexual life, biometric information or criminal behaviour; and

1.15 Third Party” means any independent contractor, agent, consultant, sub-contractor or other representative of SADV.

2.PURPOSE OF THIS POLICY

2.1 The purpose of this Policy is to inform Data Subjects about how SADV Processes their Personal Information.

2.2 SADV, in its capacity as Responsible Party, shall strive to observe, and comply with its obligations under POPIA as well as accepted information protection principles, practices and guidelines when it Processes Personal Information from or in respect of a Data Subject

2.3 This Policy applies to Personal Information collected by SADV in connection with the goods and services which SADV provides and offers. This includes information collected directly from you as a Data Subject, as well as information we collect indirectly though our service providers who collect your information on our behalf.

2.4 This Privacy Policy does not apply to the information practices of Third Party companies who we may engage with in relation to our business operations (including, without limitation, their websites, platforms and/or applications) which we do not own or control; or individuals that SADV does not manage or employ. These Third Party sites may have their own privacy policies and terms and conditions and we encourage you to read them before using them.

3. PROCESS OF COLLECTING PERSONAL INFORMATION

3.1 SADV collects Personal Information directly from Data Subjects, unless an exception is applicable (such as, for example, where the Data Subject has made the Personal Information public or the Personal Information is contained in or derived from a public record).

3.2 SADV will always collect Personal Information in a fair, lawful and reasonable manner to ensure that it protects the Data Subject’s privacy and will Process the Personal Information based on legitimate grounds in a manner that does not adversely affect the Data Subject in question.

3.3 SADV often collects Personal Information directly from the Data Subject and/or in some cases, from Third Parties. Where SADV obtains Personal Information from Third Parties, SADV will ensure that it obtains the consent of the Data Subject to do so or will only Process the Personal Information without the Data Subject’s consent where SADV is permitted to do so in terms of clause 3.1 above.

3.4 Examples of such Third Parties include: (i) our customers when SADV handles Personal Information on their behalf; (ii) recruitment agencies; (iii) other companies providing

services to SADV; and (iv) where SADV makes use of publicly available sources of information.

4. LAWFUL PROCESSING OF PERSONAL INFORMATION

4.1

Where SADV is the Responsible Party, it will only Process a Data Subject’s Personal

 

Information (other than for Special Personal Information) where –

4.1.1

consent of the Data Subject (or a competent person, where the Data Subject is a Child)

 

is obtained;

4.1.2

Processing is necessary to carry out the actions for conclusion of a contract to which a

 

Data Subject is party;

4.1.3

Processing complies with an obligation imposed by law on SADV;

4.1.4

Processing protects a legitimate interest of the Data Subject; and/or

4.1.5

Processing is necessary for pursuing the legitimate interests of SADV or of a third party

 

to whom the information is supplied.

4.2

SADV will only Process Personal Information where one of the legal bases referred to in

 

paragraph 4.1 above are present.

4.3

Where required (i.e., where we are not relying on a legal ground listed in paragraph 4.1

 

above), SADV will obtain the Data Subject’s consent prior to collecting, and in any case

 

prior to using or disclosing, the Personal Information for any purpose.

4.4

SADV will make the manner and reason for which the Personal Information will be

 

Processed clear to the Data Subject.

4.5

Where SADV is relying on a Data Subject’s consent as the legal basis for Processing

 

Personal Information, the Data Subject may withdraw his/her/its consent or may object to

 

SADV’s Processing of the Personal Information at any time. However, this will not affect

 

the lawfulness of any Processing carried out prior to the withdrawal of consent or any

 

Processing justified by any other legal ground provided under POPIA.

4.6

If the consent is withdrawn or if there is otherwise a justified objection against the use or

 

the  Processing  of  such  Personal  Information,  SADV  will  ensure  that  the  Personal

 

Information is no longer Processed.

5. SPECIAL PERSONAL INFORMATION AND PERSONAL INFORMATION OF CHILDREN

5.1 Special Personal Information is sensitive Personal Information of a Data Subject and SADV acknowledges that it will generally not Process Special Personal Information unless –

5.1.1 Processing is carried out in accordance with the Data Subject’s consent;

5.1.2 Processing is necessary for the establishment, exercise or defence of a right or obligation in law;

5.1.3 Processing is for historical, statistical or research purposes, subject to stipulated safeguards;

5.1.4 information has deliberately been made public by the Data Subject; or

5.1.5 specific authorisation applies in terms of POPIA.

5.2 SADV acknowledges that it may not Process any Personal Information concerning a Child and will only do so where it has obtained the consent of the parent or guardian of that Child or where it is permitted to do so in accordance with applicable laws.

6. PURPOSE FOR PROCESSING PERSONAL INFORMATION

6.1 SADV understands its obligation to make Data Subjects aware of the fact that it is Processing their Personal Information and inform them of the purpose for which SADV Processes such Personal Information.

6.2 SADV will only Process a Data Subject’s Personal Information for a specific, lawful and clear purpose (or for specific, lawful and clear purposes) and will ensure that there is a legal basis for the Processing of any Personal Information. Further, SADV will ensure that Processing will relate only to the purpose for and of which the Data Subject has been made aware (and where relevant, consented to) and will not Process any Personal Information for any other purpose(s).

6.3 SADV will generally use Personal Information for purposes required to operate and manage its normal business operations and these purposes include one or more of the following non-exhaustive purposes –

6.3.1 for the purposes of providing its business and home products or services to customers and where relevant, for purposes of doing appropriate customer onboarding and credit vetting;

6.3.2 for purposes of onboarding suppliers as approved suppliers of SADV. For this purpose, SADV will also Process a supplier’s Personal Information for purposes of performing credit checks, and this may include engaging third party credit vetting agencies;

6.3.3 for purposes of monitoring the use of SADV’s electronic systems and online platforms by consumers. SADV will, from time to time, engage third party service providers (who will Process the Data Subject’s Personal Information on behalf of SADV) to facilitate this;

6.3.4  for purposes of preventing, discovering and investigating non-compliance with this Policy and other SADV policies, and investigating fraud, or other related matters;6.3.5in connection with the execution of payment processing functions, including payment of
SADV suppliers’ invoices;6.3.6to provide a service to SADV customers in terms of relevant services agreements;6.3.7for  employment-related  purposes  such  as  recruitment,  administering  payroll  and
carrying out background checks;6.3.8in connection with internal audit purposes (i.e. ensuring that the appropriate internal
controls are in place in order to mitigate the relevant risks, as well as to carry out any
investigations where this is required);6.3.9in connection with external audit purposes. For this purpose, SADV engages external
service providers and, in so doing, shares Personal Information of the Data Subjects
with Third Parties;6.3.10to respond to any correspondence that SADV commercial customers may send to
SADV, including via email or by telephone;6.3.11to contact the Data Subject for direct marketing purposes subject to the provisions of
section 10 below;6.3.12in order to address customer complaints in respect of SADV’s products and services;6.3.13for such other purposes to which the Data Subject may consent from time to time; and6.3.14for such other purposes as authorised in terms of applicable law.

7. PERSONAL INFORMATION OF SADV EMPLOYEES

7.1 SADV Processes the Personal Information of its Employees for employment-related purposes in accordance with the requirements of POPIA and in terms of the SADV’s internal policies and procedures.

8. KEEPING PERSONAL INFORMATION ACCURATE

8.1 SADV will take reasonable steps to ensure that all Personal Information is kept as accurate, complete and up to date as reasonably possible depending on the purpose for which Personal Information is collected or further processed.

8.2 SADV may not always expressly request the Data Subject to verify and update his/her/its Personal Information unless this process is specifically necessary.

8.3 SADV, however, expects that the Data Subject will notify SADV from time to time in writing of any updates required in respect of his/her/its Personal Information.

9. STORAGE AND PROCESSING OF PERSONAL INFORMATION BY SADV AND THIRD PARTY SERVICE PROVIDERS

9.1 SADV may store your Personal Information in hardcopy format and/or in electronic format using SADV’s own secure on-site servers or other internally hosted technology. Your Personal Information may also be stored by Third Parties or other SADV affiliate companies, via cloud services or other technology, with whom SADV has contracted with, to support SADV’s business operations.

9.2 SADV’s Third Party service providers, including data storage and processing providers, may from time to time also have access to a Data Subject’s Personal Information in connection with purposes for which the Personal Information was initially collected to be Processed.

9.3 SADV will ensure that such Third Party service providers will process the Personal Information in accordance with the provisions of this Policy, all other relevant internal policies and procedures and POPIA.

9.4 These Third Parties do not use or have access to your Personal Information other than for purposes specified by us, and SADV requires such parties to employ at least the same level of security that SADV uses to protect your personal data.

9.5 Your Personal Information may be Processed in South Africa or another country where SADV, its affiliates and their Third Party service providers maintain servers and facilities and SADV will take steps, including by way of contracts, to ensure that it continues to be protected, regardless of its location, in a manner consistent with the standards of protection required under applicable law.

10. PERSONAL INFORMATION FOR DIRECT MARKETING PURPOSES

10.1 To the extent that SADV carries out Direct Marketing, it shall strive to observe, and comply with its obligations under POPIA when implementing principles and practices in relation to Direct Marketing.

10.2 SADV acknowledges that it may only use Personal Information to contact the Data Subject for purposes of Direct Marketing from time to time where it is permissible to do so.

10.3 It may use Personal Information to contact any Data Subject and/or market SADV’s services directly to the Data Subject(s) if the Data Subject is one of SADV’s existing clients, the Data Subject has requested to receive marketing material from SADV or SADV has the Data Subject’s consent to market its services directly to the Data Subject.

10.4 If the Data Subject is an existing client, SADV will only use his/her/its Personal Information if it has obtained the Personal Information through the provision of a service to the Data Subject and only in relation to similar services to the ones SADV previously provided to the Data Subject.

10.5 SADV will ensure that a reasonable opportunity is given to the Data Subject to object to the use of their Personal Information for SADV’s marketing purposes when collecting the Personal Information and on the occasion of each communication to the Data Subject for purposes of Direct Marketing.

10.6 SADV will not use your Personal Information to send you marketing materials if you have requested not to receive them. If you request that we stop Processing your Personal Information for marketing purposes, SADV shall do so. We encourage that such requests to opt-out of marketing be made via forms and links provided for that purpose in the marketing materials sent to you.

11. RETENTION OF PERSONAL INFORMATION

11.1 SADV may keep records of the Personal Information it has collected, correspondence, or comments in an electronic or hardcopy file format.

11.2 In terms of POPIA, SADV may not retain Personal Information for a period longer than is necessary to achieve the purpose for which it was collected or processed and is required to delete, destroy (in such a way that it cannot be reconstructed) or de-identify the information as soon as is reasonably practicable once the purpose has been achieved. This prohibition will not apply in the following circumstances –

11.2.1 where the retention of the record is required or authorised by law;

11.2.2 SADV requires the record to fulfil its lawful functions or activities;

11.2.3 retention of the record is required by a contract between the parties thereto;

11.2.4 the data subject (or competent person, where the data subject is a child) has consented to such longer retention; or

11.2.5 the record is retained for historical, research or statistical purposes provided safeguards are put in place to prevent use for any other purpose.

Accordingly, SADV will, subject to the exceptions noted in this Policy, retain Personal Information for as long as necessary to fulfil the purposes for which that Personal Information was collected and/or as permitted or required by applicable law.

11.3      Where SADV retains Personal Information for longer periods for statistical, historical or research purposes, SADV will ensure that appropriate safeguards have been put in place

to ensure that all recorded Personal Information will continue to be Processed in accordance with this Policy and applicable laws.

11.4 Once the purpose for which the Personal Information was initially collected and Processed no longer applies or becomes obsolete, SADV will ensure that the Personal Information is deleted, destroyed or de-identified sufficiently so that a person cannot re-identify such Personal Information. In instances where we de-identify your Personal Information, SADV may use such de-identified information indefinitely.

12. FAILURE TO PROVIDE PERSONAL INFORMATION

12.1 Should SADV need to collect Personal Information by law or under the terms of a contract that SADV may have with you and you fail to provide the personal data when requested, we may be unable to perform the contract we have or are attempting to enter into with you.

12.2 In such a case, SADV may have to decline to provide or receive the relevant services, and you will be notified where this is the case.

13. SAFE-KEEPING OF PERSONAL INFORMATION

13.1 SADV shall preserve the security of Personal Information and strive to take steps to prevent its alteration, loss and damage, or access by non-authorised third parties.

13.2 SADV will ensure the security and integrity of Personal Information in its possession or under its control with appropriate, reasonable technical and organisational measures to prevent loss, unlawful access and unauthorised destruction of Personal Information.

13.3 SADV has implemented physical, organisational, contractual and technological security measures (having regard to generally accepted information security practices or industry specific requirements or professional rules) to keep all Personal Information secure, including measures protecting any Personal Information from loss or theft, and unauthorised access, disclosure, copying, use or modification. Further, SADV maintains and regularly verifies that the security measures are effective and regularly updates same in response to new risks.

14. BREACHES OF PERSONAL INFORMATION

14.1 A Data Breach refers to any incident in terms of which reasonable grounds exist to believe that the Personal Information of a Data Subject has been accessed or acquired by any unauthorised person.

14.2 A Data Breach can happen for many reasons, which include: (a) loss or theft of data or equipment on which Personal Information is stored; (b) inappropriate access controls allowing unauthorised use; (c) equipment failure; (d) human error; (e) unforeseen circumstances, such as a fire or flood; (f) deliberate attacks on systems, such as hacking,

viruses or phishing scams; and/or (g) alteration of Personal Information without permission and loss of availability of Personal Information.

14.3 SADV will address any Data Breach in accordance with the terms of POPIA.

14.4 SADV will notify the Regulator and the affected Data Subject (unless the applicable law requires that we delay notification to the Data Subject) in writing in the event of a Data Breach (or a reasonable belief of a Data Breach) in respect of that Data Subject’s Personal Information.

14.5 SADV will provide such notification as soon as reasonably possible after it has become aware of any Data Breach in respect of such Data Subject’s Personal Information.

15. PROVISION OF PERSONAL INFORMATION TO THIRD PARTY SERVICE PROVIDERS

15.1 SADV may disclose Personal Information to Third Parties and will enter into written agreements with such Third Parties to ensure that they Process any Personal Information in accordance with the provisions of this Policy, and POPIA.

15.2 SADV notes that such Third Parties may assist SADV with the purposes listed in paragraph

6.3 above – for example, service providers may be used, inter alia,

15.2.1 for data storage;

15.2.2 to provide internet, voice, and other value-added solutions to customers;

15.2.3 to assist SADV with auditing processes (external auditors); and/or

15.2.4 to notify the Data Subjects of any pertinent information concerning SADV.

15.3 SADV will disclose Personal Information with the consent of the Data Subject or if SADV is permitted to do so without such consent in accordance with applicable laws.

15.4 Further, SADV may also send Personal Information to a foreign jurisdiction outside of the Republic of South Africa, including for Processing and storage by Third Parties or other SADV group companies.

15.5 When Personal Information is transferred to a jurisdiction outside of the Republic of South Africa, SADV will obtain the necessary consent to transfer the Personal Information to such foreign jurisdiction or may transfer the Personal Information where SADV is permitted to do so in accordance with the provisions applicable to cross-border flows of Personal Information under POPIA.

15.6 The Data Subject should also take note that the Processing of Personal Information in a foreign jurisdiction may be subject to the laws of the country in which the Personal Information is held, and may be subject to disclosure to the governments, courts of law,

enforcement or regulatory agencies of such other country, pursuant to the laws of such country.

16. USE OF WEBSITE COOKIES

16.1 Our website uses cookies, which are small text files sent by a web server to store on a web browser. They are used to ensure websites function properly, store user preferences when needed and collect anonymous statistics on website usage.

16.2 You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to the website. If you accept a “cookie” or fail to deny the use of “cookies”, you agree that we may use your personal information collected using “cookies” (subject to the provisions of this Policy). Where you either reject or decline cookies, you are informed that you may not be able to fully experience the interactive features of our website.

17. ACCESS TO PERSONAL INFORMATION

17.1 POPIA read with the relevant provisions of the Promotion of Access to Information Act, No. 2 of 2000 (“PAIA“) confers certain access rights on Data Subjects. The SADV PAIA Manual can be found https://www.sadv.co.za/wp-content/uploads/2021/06/SADV-PAIA-

Manual-29062021.pdf (“PAIA Manual“). These rights include –

17.1.1 a right of access: a Data Subject having provided adequate proof of identity has the right to: (i) request a Responsible Party to confirm whether any Personal Information is held about the Data Subject; and/or (ii) request from a Responsible Party a description of the Personal Information held by the Responsible Party including information about Third Parties who have or have had access to the Personal Information. A Data Subject may request:

17.1.1.1 SADV to confirm, free of charge, whether it holds any Personal Information about him/her/it; and

17.1.1.2 to obtain from SADV the record or description of Personal Information concerning him/her/it and any information regarding the recipients or categories of recipients who have or had access to the Personal Information. Such record or description is to be provided: (a) within a reasonable time; and (b) in a reasonable manner and format and in a form that is generally understandable.

17.1.2 a right to request correction or deletion: a Data Subject may also request the SADV to –

 

13

17.1.2.1

correct or delete Personal Information about the Data Subject in its possession or

 

under its control that is inaccurate, irrelevant, excessive, out of date, incomplete,

 

misleading or obtained unlawfully; or

17.1.2.2

destroy or delete a record of Personal Information about the Data Subject that the

 

SADV is no longer authorised to retain records in terms of POPIA’s retention and

 

restriction of records provisions.

 

On receipt of such a request, SADV is required to, as soon as is reasonably

 

practicable –

17.1.2.2.1

correct the information;

17.1.2.2.2

delete or destroy the information;

17.1.2.2.3

provide the Data Subject with evidence in support of the information; or

17.1.2.2.4

where the Data Subject and Responsible Party cannot reach agreement on the

 

request and if the Data Subject requests this, SADV will take reasonable steps to

 

attach to the information an indication that correction has been requested but has

 

not been made;

17.1.3

a right to withdraw consent and to object to processing: a Data Subject that has

   
 

previously consented to the Processing of his/her/its Personal Information has the right

 

to withdraw such consent and may do so by providing the SADV with notice to such

 

effect at the address set out in paragraph 21. Further, a Data Subject may object, on

 

reasonable grounds, to the Processing of Personal Information relating to him/her/it.

17.2 Accordingly, SADV may request the Data Subject to provide sufficient identification to permit access to, or provide information regarding the existence, use or disclosure of the Data Subject’s Personal Information. Any such identifying information shall only be used for the purpose of facilitating access to or information regarding the Personal Information.

17.3 The Data Subject can request in writing to review any Personal Information about the Data Subject that SADV holds including Personal Information that SADV has collected, utilised or disclosed.

17.4 SADV shall respond to these requests in accordance with POPIA and PAIA and provide the Data Subject with any such Personal Information to the extent required by law and any of SADV’s policies and procedures which apply in terms of the PAIA.

17.5 The Data Subject can challenge the accuracy or completeness of his/her/its Personal Information in SADV’s records at any time in accordance with the process set out in the PAIA Manual for accessing information.

17.6 If a Data Subject successfully demonstrates that their Personal Information in SADV’s records is inaccurate or incomplete, SADV will ensure that such Personal Information is amended or deleted as required (including by any Third Parties).

17.7 SADV will respond to each written request of a Data Subject not later than 30 days after receipt of such requests. Under certain circumstances, the SADV may, however, extend the original period of 30 days once for a further period of up to 30 days.

17.8 A Data Subject has the right to make a complaint to SADV in respect of this time limit by contacting SADV using the contact details provided in paragraph 21 below. The prescribed fees to be paid for copies of the Data Subject’s Personal Information are referenced in the PAIA Manual.

18. TIME PERIODS

18.1 SADV will respond to each written request of a Data Subject not later than 30 days after receipt of such requests. Under certain circumstances, SADV may, however, extend the original period of 30 days once for a further period of not more than 30 days.

18.2 A Data Subject has the right to make a complaint to SADV in respect of this time limit by contacting SADV using the contact details provided in paragraph 21 below.

19. COSTS TO ACCESS TO PERSONAL INFORMATION

The prescribed fees to be paid for copies of the Data Subject’s Personal Information are listed the PAIA Manual.

20. CHANGES TO THIS POLICY

20.1 SADV reserves the right to make amendments to this Policy from time to time and will use reasonable efforts to notify Data Subjects of such amendments.

20.2 The current version of this Policy will govern the respective rights and obligations between you and SADV each time that you access and use our site.

21. CONTACT US

21.1 All comments, questions, concerns or complaints regarding your Personal Information or

this Policy, should be forwarded to our Information Officer Robert Andre Lubbe –

Tel. 011 390 7700;

Address: 1st Floor, 23 Melrose Boulevard, Melrose Arch Precinct, Johannesburg;

Postal: 1st Floor, 23 Melrose Boulevard, Melrose Arch Precinct, Johannesburg;

Email: robert@sadv.co.za

21.2 If a Data Subject is unsatisfied with the manner in which SADV addresses any complaint with regard to the SADV’s Processing of Personal Information, the Data Subject can contact the office of the Regulator, the details of which are set out below –

Website: http://justice.gov.za/inforeg/

Tel: 012 406 4818

Fax: 086 500 3351

Email: inforeg@justice.gov.za