Privacy Policy

Harcourts Platinum Privacy Notice

Our Organisation
Harcourts Platinum
302 Highlevel Terraces
22 Albany Road
Sea Point
Cape Town
South Africa
8005

What we do with your personal information

We use your personal information only for the purpose for which it is collected. Among others, this purpose could be to provide a hospitality service, assist us with administration, recruit prospective employees or even to comply with a legal obligation. 

As a prospective client, we will use your personal information only for marketing and communication purposes if we have your consent or another lawful justification for doing so.

We collect, use and retain personal information for the following purposes and periods, with the applicable lawful basis:

Category of Person Processing Purpose Lawful Basis Retention Period
Prospective Clients Managing an opt-out list for marketing purposes S14 – In the public interest Until no longer needed for purpose of proof
Marketing communication  S11 – We have the data subject’s consent Until consent is withdrawn
Clients Provide hospitality services  S11 – To conclude or perform a contract to which the data subject is party Until no longer needed for purpose of proof
Managing an opt-out list for marketing purposes S14 – In the public interest Until no longer needed for purpose of proof
Service Providers Management and provision of business services S11 – To conclude or perform a contract to which the data subject is party Until tax or other legal retention periods expire
Managing an opt-out list for marketing purposes S14 – In the public interest Until no longer needed for purpose of proof
Prospective Employees Recruitment management S11 – We have the data subject’s consent Until consent is withdrawn

What personal information do we collect?

We only collect the minimum amount of information that is relevant to the purpose.  If you use our services, personal information is required to fulfil the requirements of such service. 

We collect the following general personal information from our prospective clients:

  • First name
  • Last name
  • Initials
  • Email
  • Gender
  • Telephone number
  • Identification document
  • Name with other information that reveals information from person

We collect the following general personal information from our clients:

  • First Name
  • Last Name
  • Initials
  • Gender
  • Date of birth
  • Age
  • Physical address
  • Email
  • Telephone number
  • Passport and/or Identification documents
  • Name, together with other identifying information
  • Confidential Correspondence
  • Company Name 
  • Company registration number
  • Financial & banking details
  • Personal opinions, views or preferences

Special personal information may be required to provide you with the hospitality services and could include information about your health (disability) and biometric information, where applicable, to allow security access to our villas. We collect special personal information, under the appropriate lawful basis and keep it until no longer required for the burden of proof:

  • Medical and Health and Biometric Information
    • S27 – we have the data subject consent

From prospective employees we will collect the following information for recruitment purposes:

  • First Name
  • Last Name
  • Initials
  • Gender
  • Date of birth
  • Age
  • Physical address
  • Email address
  • Telephone number
  • Name, together with other identifying information
  • Confidential Correspondence
  • Personal opinions, views or preferences
  • Education history
  • Employment history

We collect the following special personal information from prospective employees which is required for the recruitment process, under the appropriate lawful basis and retain it only for the period until no longer required for the purpose it was collected: 

Criminal history  

  • S27 – we have the data subject consent 

Race or ethnic origin

  • S27 – For the establishment, exercise or defence of a right or obligation in law

Who might we share your personal information with?

To maintain and provide you with our services, we may need to share or disclose your personal information with other Responsible Parties where applicable to provide security access to our villas. We have the relevant agreements in place with such Responsible Parties for your further protection.   

Where we use Service Providers who are considered Operators, we enter into Operator’s Agreements to further protect your personal information. We review these agreements annually. 

We will not share your personal information with third parties for secondary or unrelated purposes unless otherwise disclosed on collection.

We use cloud services (Dropbox and WhatsApp) with servers outside of South Africa, in the USA. 

How do we look after personal information?

We limit the amount of personal information collected to only what is fit for the purposes as described above. We restrict, secure and control all of our information assets against unauthorised access, damage, loss or destruction; whether physical or electronic. We retain personal information only for as long as is described above, to respond to your requests, or longer if required by law. 

While in our possession, together with your assistance, we try to maintain the accuracy of your personal information. You have the right to request access to any of your personal information we may hold. If any of that information is incorrect, you may request that we correct it by informing us of any changes to your personal information. We require you to inform us of any changes in order for us to maintain the quality and accuracy of the data. You can submit your request by sending us an email to popia@seasky.co.za

If we are improperly using your information, you may request that we stop using it. Any requests are subject to applicable laws pertaining to our industry. 

Where it may have been necessary to get your consent to use your personal information, you have the right to withdraw that consent. If you withdraw your consent, we will cease using your personal information without affecting the lawfulness of processing based on consent before your withdrawal. Your request will be subject to applicable laws pertaining to our industry. 

Security

The security of your personal information is important to us, however no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

We have all reasonable industry standards of technology and operational security in place to protect all information provided by data subjects from loss, misuse, alteration or destruction. 

All reasonable steps will be taken to secure our data subjects’ data. Authorised Responsible Parties and Operators who are responsible for the processing of any data submitted, are required to maintain the confidentiality of such data.

It is expressly prohibited for any person, business or entity to gain or attempt to gain unauthorised access to our business and technology platforms, or to deliver or attempt to deliver any unauthorised, damaging or malicious code to it. If a person delivers or attempts to provide any unauthorised, harmful or malicious code to or attempts to gain unauthorised access to any platform, a criminal charge will be laid against that person, and, if we or any public body should suffer any damage or loss, civil damages will be claimed.

Our Information Officer:
Ms. Esta – Marita Opperman
Telephone: 066 232 8435
legal@seasky.co.za

You have the right to lodge a complaint with the SA Information Regulator if your query has not been resolved within the legal timeframe applicable by law. 

See the Information Regulator contact details below:
The Information Regulator (South Africa)
PO Box 31533
Braamfontein
27 Stiemens St
Braamfontein
2017
complaints.IR@justice.gov.za

inforeg@justice.gov.za