A. WHO WE ARE
The purpose of this Privacy Policy is to set out how, why and when serviceSpot (Pty) Ltd (“serviceSpot”) uses your Personal Information so as to comply with the Protection of Personal Information Act 4 of 2013 (“POPI”).

We respect your privacy and take the protection of Personal Information very seriously. We strive to deliver excellent service every time and to do this, we need to use some of your Personal Information.

This Privacy Policy describes how we handle the Personal Information we collect about you and/or receive from you. By using our Platforms, you agree to the processing of your Personal Information as set out in this Privacy Policy.

It is important that you read this Privacy Policy together with our other terms and conditions, privacy notices or policies that serviceSpot may provide from time to time when collecting or using your Personal Information.

Further, please pay special attention to the clauses in this Privacy Policy that appear in similar text and style (i.e. bold) which:

● may limit the risk or liability of serviceSpot or a third-party.
● may create risk or liability for you.
● may compel you as a user to indemnify serviceSpot or a third-party.
● serves as an acknowledgement, by you of a fact.

This Privacy Policy applies to all users.

In this Privacy Policy, the terms:

● “Personal Information”, and “process/processing” bear the same meanings as set out in POPI.
● “we”, “us” or “our” refers to serviceSpot.
● “you” and “your” refers to every person that accesses or uses our Platforms also referred to as a user.
● “user(s)” refers to anyone registered on our Platforms and has provided us with a unique email address and password as well as other Personal Information in order to book or provide services on our Platforms or anyone that has accessed our Platforms.
● “Platforms” mean serviceSpot’s websites and mobile applications.


B. WHAT PERSONAL INFORMATION WE COLLECT AND RECEIVE
serviceSpot processes Personal Information in a manner that is reasonable, adequate, relevant, non-excessive and purpose-specific. We may also gather Personal Information about you from your devices, other persons and organisations.

We collect Personal Information about you when you use our Platforms or services, or when you interact with us, and do so in particular when you:

● contact us, including via our Platforms as a user.
● engage with us on social media.
● have already made your Personal Information available in public sources (such as public posts on social media etc.)
● engage with third-parties that we interact with for the purpose of conducting our business (such as partners, regulators and government departments or service providers).

We may collect the following Personal Information from or about you as a user:

● name and surname.
● email address.
● physical address.
● gender.
● mobile phone number.
● online identifiers.
● date of birth.
● identification number.
● banking details (where applicable).
● social media profiles.
● location data.

You warrant that the information you have provided is accurate, current, true and correct and that it does not impersonate or misrepresent any person or entity or falsely state or otherwise misrepresent your affiliation with anyone or anything.

Should your Personal Information change or you wish to object to the processing of, amend and/or correct your Personal Information, you can do this as set out in part K below.

Information from using the Platforms
When you access our Platforms, we process some of your Personal Information. Depending on how you access and use the Platforms, we may receive:

● log information, including information on how, when and for how long you use our Platforms, services and other features, the content you view and search queries you submit.
● information about the equipment you use to access or use our Platforms, including the type of device you are using, how you access our Platforms, your browser or operating system and your Internet Protocol address.
● the geographic location from which you accessed our Platforms, including your device’s global positioning system signal and information about nearby Wi-Fi networks and cell towers. We get this information when you use location-enabled services.
● information relating to support you may require from us such as information about your query and your contact details. When you interact with our Platforms via email or phone we may collect and use information about you in order to provide support. Your communications with us may be recorded.



C. WHY DO WE NEED TO PROCESS YOUR PERSONAL INFORMATION?
We primarily use the Personal Information we collect from you to enable you access to our Platforms and services. We also use your Personal Information for other reasons, including to ensure that we comply with all laws, to better understand you and your needs, and to inform you about other services you might be interested in.

We may lawfully process the Personal Information we collect and receive from you to:

● identify you.
● verify your identity if the law requires or permits it.
● to protect or pursue your, our or a third party’s legitimate interest.
● if you have consented to us processing your Personal Information.
● enter into and conclude a contract or perform under a contract entered into with you.
● provide you with access to and use of our Platforms in order to provide you with our services in order to fulfill our contractual obligations to you.
● enable us to process payments.
● communicate with you regarding our Platforms.
● notify you about changes to our Platforms, services and terms and conditions, privacy policies or notices, and any other changes that impact our Platforms or services.
● get feedback from you which we need to develop our services and grow our business.
● comply with any legal or regulatory obligations such as tax or financial laws.
● undertake research for statistical purposes. The research and statistics we get from this process do not include your Personal Information and cannot be linked to you, nor can you be identified from these statistics.

The law may permit us to process your Personal Information when we need to:

● comply with legislative, regulatory risk and compliance requirements.
● to fulfil reporting requirements and lawful information requests.
● to meet record-keeping obligations.
● to minimise risks, detect, prevent, investigate and report theft, fraud, corruption and other illegal activities or crimes.
● to develop fraud models and fraud tools.

We may process your Personal Information if it is required to protect or pursue ours or a third party’s legitimate interest which may include:

● the daily management of our business and operations to protect our customers, employees, service providers and assets.
● to provide you with the most appropriate services and to develop and improve our services and our business.
● to develop, implement, monitor and improve our business processes, policies and systems.
● to manage business continuity and emergencies.
● to protect and enforce our rights and remedies in the law.
● to develop, test and improve solutions which may include connecting your Personal Information with other Personal Information obtained from third-parties or public records to better understand your needs and develop solutions that meet your needs.
● tailoring services which would include consideration of your use of third-party services.
● to provide information about the services we offer directly or through partners.
● send you information about competitions, promotions or services that may interest you (unless you have opted out of receiving such information). Please note that you may also receive newsletters based on your interests, bookings and browsing behaviour. To unsubscribe from newsletters sent to you based on your recent activity, visit the Newsletter Subscriptions page under “My Account” or unsubscribe when receiving such a newsletter.
● get feedback from you which we need to develop our services and grow our business.
● to respond to complaints including analytics of complaints to understand trends and prevent future complaints and provide compensation where appropriate.
● to detect, prevent and report theft, fraud, corruption and other crimes. This may include the processing of Special Personal Information, such as alleged criminal behaviour or the supply of false, misleading or dishonest information when registering an account with us.
● for statistical purposes, such as market segmentation or customer segments.

At the time that we collect Personal Information from you, we will have a lawful reason or purpose to collect that Personal Information. We may use that same Personal Information for other purposes. We will only do this where the law allows us to, and where the purpose of further processing is compatible with the original purpose(s) when we collected your Personal Information.



D. DIRECT MARKETING
We may collect and use your Personal Information to tell you about services or promotions we think you might be interested in. To do this, we may contact you via:

● Email
● Phone
● SMS
● WhatsApp
● Social media
● Advertising on our Platforms or third-party platforms

If you are not our customer, or in cases where the law requires, we will only market to you electronically with your consent. You may opt out of marketing at any time.

E. USER TRACKING AND COOKIES
When you access and use our Platforms we may use various technological tools to improve your experience on our Platforms through the use of cookies and/or user tracking.

Cookies are small text files placed on the device that you use to access our Platforms. These files do not contain your Personal Information but allow us to associate you with a particular device.

Many websites use cookies and we use cookies to:

● make our Platforms more user friendly.
● personalise your interactions with our Platforms, tailor our services and Platforms to your interests and needs, and ensure they work on your device.
● analyse Personal Information that will enable us to send you the types of promotional offers that may be particularly relevant to you.
● develop and improve our business.
● analyse your activity on our Platforms so that we can administer, support, improve and develop our business and for statistical and analytical purposes and to help us to prevent fraud.
● provide advertising that is relevant to you, limit the number of times you see the same advertisement and measure the effectiveness of the advertisements on our Platforms and other websites, based on your online activities such as the websites and apps you use or content you view, and information we have about you.

By accessing and using our Platforms you consent to our use of cookies and/or user tracking technologies.

F. WHO WE SHARE YOUR PERSONAL INFORMATION WITH
We do not sell your Personal Information to third parties for their marketing or any other purposes. However, where we share your Personal Information, it will be done in line with POPI and if:

● you consented to us sharing your Personal Information.
● it is necessary for us to conclude or perform in terms of a contract we have with you.
● we have to comply with a legal obligation.
● it is necessary to protect or pursue your, our, or a third party’s legitimate interests.

We will only share your Personal Information with third parties after making sure that these third parties have adequate data privacy policies in place and that they have an obligation to keep your Personal Information secure and confidential.

We may provide or make your Personal Information available to:

● our employees and third-party service providers who assist us to interact with you.
● our associates, cessionaries, delegates, assignees, affiliates or successors in title for any of the purposes identified in this policy.
● payment processing service providers, card schemes, banks and other persons that enable or assist with the processing of transactions routing, reconciliation, authorisation and settlement requests and the enablement of transaction processing.
● internet and cloud service providers.
● law enforcement, government officials, fraud detection agencies or other third parties when the disclosure of Personal Information is necessary or appropriate in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose us to legal liability or to prevent physical harm or financial loss, to report or support the investigation into suspected illegal activity.
● people you have authorised to obtain your Personal Information, such as your bank.
● enable our service providers (under contract with us) who help with parts of our business operations (fraud prevention, marketing, technology services etc). However, our contracts with such third parties dictate that these service providers may only use your Personal Information in connection with the services they perform for us and not for their own benefit and must treat such Personal Information as confidential information.

Our Platform may also contain links to other third-party websites that may collect and process your Personal Information. Other third-party websites and/or platforms may also contain links to our Platform where they collect and process your Personal Information.

We are not responsible for the privacy practices or the content of those linked third-party websites and/or platforms including how and when they collect and process your Personal Information.

G. RETENTION AND RESTRICTION OF RECORDS
We keep your Personal Information for as long as:

● we need it to provide our Platforms or services to you.
● it is required or allowed by law and is in line with our internal retention policies.
● it is necessary to uphold the contract between you and us.
● you have agreed to us keeping your Personal Information subject to your request for us to stop processing your Personal Information.

We will retain your Personal Information for as long as is necessary to achieve the purpose for which this information was collected or subsequently processed. If your Personal Information is used for more than one purpose, we will retain it until the purpose with the latest period expires, but we will stop using it for the purpose with a shorter period once that period expires.

By accessing and using the Platform, you consent to us retaining records of your Personal Information for no longer than may be necessary to achieve the purpose for which the information was initially collected or subsequently processed.

H. SENDING YOUR PERSONAL INFORMATION OUTSIDE SOUTH AFRICA
We may transfer certain Personal Information outside the geographic borders of South Africa to service providers for purposes set out above (see part C above), including for data storage and back-up purposes to ensure the integrity of our systems.

When we transfer your Personal Information outside of the geographic borders of South Africa, we will ensure that we do so in accordance with the requirements for lawful transfer outside of South Africa as set out in POPI.

By accessing and using our Platforms, you consent to us transferring your Personal Information outside of South Africa as set out in POPI.



I. SECURING YOUR PERSONAL INFORMATION
We secure the integrity and confidentiality of your Personal Information in our possession or under our control by taking appropriate, reasonable technical and organisational measures to prevent loss of, damage to or unauthorised destruction of Personal Information; and unlawful access to or processing of Personal Information.

In order to implement and maintain such measures, we have in place policies, controls and related processes, which are reviewed and updated on a regular basis. Our policies, controls and procedures cover for example:

● physical, technical and network security.
● access controls and monitoring of access.
● secure storage, destruction and encryption of records of Personal Information.
● Personal Information breach reporting and remediation.
● by way of written agreements, imposition of security and confidentiality obligations on third parties (based within or outside the borders of South Africa) who process Personal Information as part of rendering services to us.

Should you disclose your Personal Information to any third party other than serviceSpot, or if a third party unlawfully acquires your Personal Information elsewhere, serviceSpot shall not be liable for any loss or damage arising from or suffered by you as a result of the disclosure or unlawful acquisition elsewhere (as the case may be) of such Personal Information. This is because we do not regulate or control how that third party uses your Personal Information. You should always ensure that you read the privacy policy of any third party.

J. RESPONSIBLE AI USE STATEMENT
We recognise that achieving state of the art ethical and responsible AI is a process that never concludes. We strive to develop strong capabilities in this area. We follow these guiding principles to inform our ongoing use of AI:

● Force for good. We are committed to ensuring that our AI applications contribute to positive changes in our ecosystem, with ongoing human oversight and controls.
● Technical excellence and robustness. We strive to ensure that the scientific and technical standards informing research, design and application of our AI products and services are sound and robust.
● Fairness and inclusivity. We strive to avoid creating unfair biases and reinforcing or exacerbating existing biases.
● Accountability & transparency. We are committed to ensuring that our use of AI systems and their outputs are context-sensitive, transparent and explainable.
● Privacy & security. Data used to train and deploy AI systems will be proportionate, handled in conformity with POPI. Our development, use and deployment of AI tools are designed in a way that minimises known security threats, through appropriate technical and organisational measures.

K. KNOW YOUR RIGHTS
Having provided adequate proof of your identity, you have the right to:

● request a record or description of your Personal Information.
● request the identity or categories of third parties who have had access to your Personal Information.
● ask us to correct, delete or update any information we have for you if it is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, obtained unlawfully or if we are no longer authorised to retain the information. Please note that you can stop being a registered user by cancelling your account. In this instance, serviceSpot will only retain your Personal Information subject to any legislative requirement and/or our internal retention policy.
● withdraw your consent for the processing of your Personal Information. Please note that your right to object to the collection and processing of certain categories of your Personal Information may affect our ability to render you services when you are a registered user and may effectively lead to us deleting your Personal Information.
● query our decision to refuse you access or only let you access certain information.
● where you exercise your rights above, we will explain the consequences of this to you, which may include that we may not be able to provide certain services to you. We will inform you if this is the case. We may proceed to process your Personal Information, even if you have withdrawn your consent, if the law permits or requires it. It may take a reasonable time for the change to reflect on our systems. During this time, we may still process your Personal Information.
● expect us to comply with your requests upon receipt unless we have credible reason why we cannot comply.
● expect us to indicate where, if we cannot agree whether to correct or delete your Personal Information as requested, that a correction or deletion was requested but was not made.
● expect us to inform you, if reasonably practicable, should we change your Personal Information and this has an impact on decisions about you.
● be notified of the action taken by us because of your request.
● be notified of unauthorised access to your Personal Information.
● request reasonable evidence of our compliance with our obligations under this Privacy Policy on reasonable notice and request.
● submit a complaint to the Information Regulator.

serviceSpot may charge a fee in order to provide you with this record of your Personal Information. Where requests to access and amend your Personal Information are manifestly unfounded, excessive or repetitive, serviceSpot may charge an administrative fee or refuse the request.

Please note that the law may limit your right to access information. Please refer to our information manual prepared in accordance with Section 51 of the Promotion of Access to Information Act, No. 2 of 2000 (PAIA Manual) for further information on how you can give effect to this right.

As a registered user, you can exercise all your rights set out above in terms of POPI by going to the Data & Privacy section of our Help Centre.

L. HOW TO LODGE A COMPLAINT WITH THE INFORMATION REGULATOR
If you have any complaints about this Privacy Policy or our compliance with this Privacy Policy you can lodge a complaint with the Information Regulator.

The contact details of the Information Regulator are available on its website at: https://justice.gov.za/inforeg/

This version of the Privacy Policy replaces any preceding privacy policy provisions on our website. We may occasionally update this Privacy Policy. When you use our Platforms the version of the Privacy Policy posted on this page applies to you.