Legal

Spur Corporation Limited and its subsidiary companies ('Spur') provides its websites for informational purposes only. By using the site, you agree to follow the terms and conditions outlined in this document; should you disagree, please cease usage of the Spur site.

Site content disclaimer

While we strive to display reliable and complete content, certain errors and inaccuracies may occur within the site materials. Spur is not responsible for any such erroneous or insufficient content, nor are we responsible for any damage that the website may cause due to occurrences such as misstatements, omissions or viruses, amongst others. Similarly, we are not responsible for the content of or damages that may be caused by any sites that Spur websites may link to.

Trademarks

Spur websites contain many trademarks protected under law. These trademarks are the property of Spur and may not be reproduced or copied without our express written permission. This also applies to the content and design of the sites.

Information submissions

Any information submitted through the websites to Spur will become and remain the property of Spur without any compensation to the submitter or creator. We assume no liability for the legality or copyright of the information submitted

Privacy Policy

1. INTRODUCTION
This website privacy policy describes how we process information we collect and/or receive from you.
2. INFORMATION WE COLLECT AND RECEIVE
We collect and receive information about you in the following ways:
2.1. Information provided by you. We may collect personal information (that is information about you
that is personally identifiable like your name, address, gender, e-mail address, physical
address, phone number(s) and other unique information such as product and service
preferences and contact preferences that are not otherwise publicly available) to the extent
that you provide us with same; and
2.2. Information that is collected automatically. We receive and store information which is transmitted
automatically and this information includes information from cookies, your Internet Protocol
(“IP”) address, browser type, web beacons (which are electronic files that allow a web site to
count users who have visited that page or to access certain cookies), embedded web links,
and other commonly used information- gathering tools.
2.3. Information you give us
This includes any information that you provide to us directly:
2.3.1. when you sign-up to utilise our services;
2.3.2. by filling in forms on our websites, or those provided to you;
2.3.3. when you enter a competition, promotion or complete a survey;
2.3.4. by posting comments or content on our social media pages; or
2.3.5. when you contact us or we contact you and you provide information directly to
us.
2.4. What personal information we collect
2.4.1. When you register to use our services, you may be required to provide us with the
following information, your:
2.4.1.1. name and surname;
2.4.1.2. contact number and email address;
2.4.1.3. physical address;
2.4.1.4. identity or passport number; and 2.4.1.5.
date of birth.
2.5. Information we collect or receive when you use our website or social media platforms
We collect information when you use websites or social media platforms by using cookies,
web beacons and other technologies. Depending on how you access and use websites, we
may receive:
2.5.1. log information;
2.5.2. information we infer about you based on your interaction with products and
services;
2.5.3. device information (for example the type of device you're using, how you access
platforms, your browser or operating system and your Internet Protocol ("IP")
address);
2.5.4. location information.
2.6. Information from third-party sources
We may receive additional information about you that is publicly or commercially available and
combine that with the information we have collected or received about you in in other ways.
3. HOW WE USE THE INFORMATION WE COLLECT AND RECEIVE
We use the information we collect and receive for the following general purposes:
3.1. to provide you with information, products or services you request from us;
3.2. in order to refer you to an appropriate third-party service provider;
3.3. to communicate with you;
3.4. to provide you with support; and
3.5. to provide effective advertising (for example to be provide you with news, special offers and
general information about other goods, services and events which we offer, that are similar to
those that you have already hired or enquired about).
4. HOW WE SHARE THE INFORMATION WE COLLECT AND RECEIVE
4.1. We don’t sell your personal information to third parties for their marketing purposes.
4.2. We may share information with:
4.2.1. our affiliates, in other words, other companies in our group;
4.2.2. we may disclose your personal information to a limited number of our employees and
third party service providers (other than those who we refer you to), who we assist
you to interact with;
4.2.3. our business partners. We may share non-personally identifiable information with select
business partners;
4.2.4. other parties in response to legal process or when necessary to conduct or protect our
legal rights;
4.2.5. companies that provide services to us. Companies that provide services to us or act on
our behalf may have access to information about you. These companies are
limited in their ability to use information they receive in the course of providing
services to us or you; and
4.2.6. third-parties where you provide consent. In some cases, third-parties (often advertisers)
may wish to attain information about you in order to promote their products to
you, or for whatever other reason. We may share information with third-parties
where you provide consent in the form of an explicit opt-in. Before we ask you to
opt-in, we will endeavour to provide you with a clear description of what data
would be shared with the third-party. Remember that once you have opted in to
allow us to send your information to the third-party, we cannot control what they
do with your data; therefore, be sure to investigate their privacy policies before
providing permission for us to share your information.
5. YOUR RIGHTS
5.1. You have the right to ask us not to contact you for marketing purposes. You can exercise this
right at any time by using any of the various "opt-out" options that we will always provide to
you when we communicate with you. We won’t send you marketing messages if you tell us
not to but we will still need to send you service-related messages.
5.2. Our websites use cookies. If you wish to reject our cookies, you can configure your browser to do
so.
5.3. We want to make sure that any data we hold about you is up to date. So, if you think your personal
information is inaccurate, you can ask us to correct or remove it.
6. RETENTION OF DATA
We will retain your personal information only for as long as is necessary for the purposes set out in
this privacy policy or to comply with our legal obligations, resolve disputes, and enforce our legal
agreements and policies.
7. OUR COMMITMENT TO SECURITY
The security of your data is important to us. While we strive to use commercially acceptable means to
protect your personal information, we cannot guarantee its absolute security. However, we do employ
a number of safeguards intended to mitigate the risk of unauthorized access or disclosure of your
information. We will do our best to protect your personal information and we will use up to date
technology that will help us to do this. We will at all times comply with our obligation under applicable
law.
8. TRANSFER OF DATA
8.1. We are based in and operate from South Africa. Your information, including personal information,
may be transferred to and maintained on servers located outside of your country of residence,
where the data privacy laws, regulations and standards, may not be equivalent to the laws in
your country of residence.
8.2. We might transfer your personal information to places outside of South Africa and store it there,
where our suppliers might process it. If that happens, your personal information will only be
transferred to and stored in country that has equivalent, or better, data protection legislation
than South Africa or with a service provider which is subject to an agreement requiring it to
comply with data protection requirements equivalent or better than those applicable in South
Africa.
8.3. Your use of our website, followed by your submission of information to us, represents your consent
to such transfer.
8.4. We will take all steps reasonably necessary to ensure that your data is treated securely and in
accordance with this privacy policy.
9. LINKS TO OTHER WEBSITES
Our website or social media platforms may contain links to and from websites, mobile applications or
services of third parties, advertisers or affiliates. Please note that we are not responsible for the privacy
practices of such other parties and advise you to read the privacy statements of each website you visit
which collects personal information.
10. CHANGES TO THIS PRIVACY POLICY
We may update this privacy policy from time to time. Any changes that we may make to our privacy
policy will be posted on our website and will be effective from the date of posting.
11. ACCESS TO YOUR PERSONAL INFORMATION
11.1. You may at any time request:
11.1.1. confirmation that we hold your personal information;
11.1.2. access to your personal information;
11.1.3. the identities or categories of third parties to whom we have disclosed your personal
information; or
11.1.4. that we correct or delete any personal information that is incomplete, misleading,
inaccurate, excessive or out of date.
11.2. Requests may be made in writing to [email protected]

Cookie Policy

1 WHAT ARE COOKIES AND WHY DO WE USE THEM?
1.1. We might use cookies and other techniques such as web beacons when you visit our website.
“Cookies” are small text files used by us to recognise repeat users, facilitate your on-going
access to and use of our website and allow us to track your usage behaviour and compile
aggregate data that will allow us to improve the functionality of our website and content. “Web
beacons” are small, clear picture files used to follow your movements on our website. For
example, storing your preferred settings for the next time you visit.
1.2. The information we collect from cookies enables us to:
1.2.1. tailor our websites to your personal needs;
1.2.2. remember the notifications that you have been shown, so that you are not shown
them again;
1.2.3. help us find information once you have logged in;
1.2.4. help us link your browsing information to you and your personal information, for
example, when you choose to register for a service;
1.2.5. make improvements and updates to our websites based on the way you want to
use them; and
1.2.6. we generally do not use cookies to identify you personally.
1.3. The type of information collected by cookies is not used to personally identify you.
2. WHAT KIND OF COOKIES DO WE USE?
We use the following categories of cookies:
2.1. Category 1: necessary cookies
Necessary cookies enable you to use our websites and all its features, such as enabling
access to secure areas of the website. Without these cookies you may not be able to use all
the features of our websites.
2.2. Category 2: performance cookies
Performance cookies collect information about how you use our websites so we can improve
them for you in future. For example, they collect information on which pages you visit most
often and any error messages you may get. The information collected by these cookies is
anonymous. They do not collect any information that can identify you personally.
2.3. Category 3: functionality cookies
Functionality cookies enable us to provide you with a more personalized experience. They
help us to remember data, such as your username and language preference, to save you
having to enter them again the next time you visit. The information these cookies collect is
anonymous. They cannot track your browsing activity on other websites.
2.4. Category 4: targeting/advertising cookies
We and our service providers may use advertising cookies to deliver ads that we believe are
relevant to you and your interests. For example, we may use targeting or advertising cookies
to customize the advertising and content you receive on our websites, to limit the number of
times you see the same ad on our websites and to help measure the effectiveness of our
advertising campaigns.
2.5. Category 5: social media cookies
Our websites use third-party cookies from social media sites such as Facebook, Twitter and
LinkedIn to enable in-depth campaign reporting and to track social network users when they
visit our websites, by using a tagging mechanism provided by those social networks. These
cookies can also be used for event tracking and remarketing purposes. Any data collected
with these tags will be used in accordance with our privacy policy and with the social network's
privacy policies. Our websites will not collect or store any personally identifiable information
from the user.
3. HOW CAN YOU MANAGE YOUR COOKIE SETTINGS?
3.1. To ensure you get the best possible experience when visiting our websites, we recommend
that you accept cookies. However, you can opt-out of each cookie category (except strictly
necessary cookies) by clicking on the “cookie settings” button or disable cookies in your web
browser.
3.2. Cookies may, however, be necessary to provide you with certain features available on our
website. If you disable cookies you may not be able to use these features, and your access
to our website will be limited.

External Privacy Statement

1. INTRODUCTION

1.1. For purposes of this Statement:

1.1.1. “Applicable Laws” means all laws, regulations that Spur is required to comply with;

1.1.2. “Client” or “you” means any prospective, new or existing client of Spur and its subsidiaries; and

1.1.3. “Spur” or “we” or “us” means the Spur Group Proprietary Limited its direct and indirect subsidiaries. To obtain more information on these subsidiaries please refer to www.spurcorporation.com

1.2. This Statement sets out how your personal information will be used by Spur and applies to any information, including personal and special personal information, you give to Spur or which Spur may collect from third parties.

1.3. It is important that you read this Statement carefully before submitting any personal information to Spur.

1.4. By submitting any personal information to Spur you provide consent to the processing of your personal information as set out in this Statement]

1.5. The provisions of this Statement are subject to mandatory, unalterable provisions of Applicable Laws;

1.6. Please do not submit any personal information to Spur if you do not agree to any of the provisions of this Statement. If you do not consent to the provisions of this Statement, or parts of the Statement, Spur may not be able to provide its products and services to you.

2. HOW TO CONTACT US

If you have any comments or questions about this Statement, please contact the Information Officer; Designated Information Officer: Duane Starkey

Email address: [email protected]

Postal address: PO Box 166, Century City 7446

Street address: 14 Edison Way, Century Gate Business Park, Century City 7441 Phone number: 021 555 5100

3. AMENDMENT OF THIS STATEMENT

3.1. We may amend this Statement from time to time for any of the following reasons:

3.1.1. to provide for the introduction of new systems, methods of operation, services, products or facilities;

3.1.2. to comply with changes to any legal or regulatory requirement;

3.1.3. to ensure that our Statement is clearer and more favourable to you;

3.1.4. to rectify any mistake that may be discovered from time to time; and/or

3.1.5. for any other reason which Spur, in its sole discretion, may deem reasonable or necessary.

3.2. Any such amendment will come into effect and become part of any agreement you have with Spur when notice is given to you of the change by publication on our website. It is your responsibility to check the website often.

4. PRIVACY AND INDEMNITY

4.1. Spur takes your privacy and the protection of your personal information very seriously, and we will only use your personal information in accordance with this Statement and applicable data protection legislation. It is important that you take all necessary and appropriate steps to protect your personal information yourself (for example, by ensuring that all passwords and access codes are kept secure).

4.2. We have implemented reasonable technical and operational measures to keep your personal information secure.

4.3. You hereby indemnify and hold Spur harmless from any loss, damages or injury that you may incur as a result of any unintentional disclosures of your personal information to unauthorised persons or the provision of incorrect or incomplete personal information to Spur.

5. INFORMATION WHICH WE MAY COLLECT ABOUT YOU

5.1. We may collect the following information about you:

5.1.1. this information may include your name, address, contact details, date of birth, place of birth, identity number, passport number, bank details, details about your employment, tax number and financial information;

5.1.2. records of correspondence or enquiries from you or anyone acting on your behalf;

5.1.3. details of transactions you carry out with us;

5.1.4. details of contracts, sales or leases you carry out with us;

5.1.5. sensitive or special categories of personal information, including biometric information, such as images, fingerprints and voiceprints.

5.2. Where you provide us with the personal information of third parties you should take steps to inform the third party that you need to disclose their details to us, identifying us. We will process their personal information in accordance with this Statement.

6. HOW WE COLLECT INFORMATION

6.1. You may provide personal information to us either directly or indirectly (through an agent acting on your behalf, or an introducer), by completing an application for our products and services or requesting further information about our products and services, whether in writing, through our website, over the telephone or any other means.

6.2. We may also collect your personal information from your appointed agent, any regulator, or other third party that may hold such information.

7. USE OF INFORMATION COLLECTED

7.1. We may use, transfer and disclose your personal information for the purposes of:

7.1.1. providing you with the services, products or offerings you have requested, and notifying you about important changes to these services, products or offerings;

7.1.2. managing your account or relationship and complying with your instructions or requests;

7.1.3. detecting and preventing fraud and money laundering and/or in the interest of security and crime prevention;

7.1.4. assessing and dealing with complaints and requests;

7.1.5. operational, marketing, auditing, legal and record keeping requirements; 7.1.6. verifying your identity or the identify of your beneficial owner;

7.1.7. transferring or processing your personal information outside of the Republic of South Africa to such countries that may not offer the same level of data protection as the Republic of South Africa, including for cloud storage purposes and the use of any of our websites;

7.1.8. complying with Applicable Laws, including lawful requests for information received from local or foreign law enforcement, government and tax collection agencies;

7.1.9. recording and/or monitoring your telephone calls and electronic communications to/with Spur in order to accurately carry out your instructions and requests, to use as evidence and in the interests of crime prevention;

7.1.10. conducting market research and providing you with information about our products or services from time to time via email, telephone or other means (for example, events);

7.1.11. where you have unsubscribed from certain direct marketing communications, ensuring that we do not send such direct marketing to you again;

7.1.12. disclosing your personal information to third parties for reasons set out in this Statement or where it is not unlawful to do so;

7.1.13. monitoring, keeping record of and having access to all forms of correspondence or communications received by or sent from Spur or any of its employees, agents or contractors, including monitoring, recording and using as evidence all telephone communications between you and Spur; and

7.1.14. improving or evaluating the effectiveness of our business or products, services or offerings.

7.2. We may from time to time contact you about services, products and offerings available from Spur or specific subsidiaries which we believe may be of interest to you, by email, phone, text or other electronic means, unless you have unsubscribed from receiving such communications. You can unsubscribe from receiving such communications via our website, mobile application, or by contacting our Customer Care Centre .

8. DISCLOSURE OF YOUR INFORMATION.

8.1. Your personal information may be shared with our subsidiaries, our agents and sub contractors, and selected third parties who process the information on our behalf.

8.2. We may also disclose your personal information to third parties in the following circumstances: 8.2.1. to our subsidiaries who are contracted to provide products or services to you;

8.2.2. to assess and monitor any of your applications for our products or services;

8.2.3. to determine which products and services may be of interest to you and/or to send you information about such products and services, unless you object or choose not to receive such communications.

8.2.4. to have a better understanding of your circumstances and needs to provide and improve our products and services;

8.2.5. to any relevant person and/or entity for purposes of prevention, detection and reporting of fraud and criminal activities, the identification of the proceeds of unlawful activities and the combatting of crime;

8.2.6. to any regulator or supervisory authority, including those in foreign jurisdictions, if Spur is required to do so in terms of Applicable Laws;

8.2.7. to a prospective buyer or seller of any of our businesses or assets;

8.2.8. to any person if we are under a duty to disclose or share your personal information in order to comply with any Applicable Laws, or to protect the rights, property or safety of Spur, Clients or other third parties; and/or

8.2.9. to your agent or any other person acting on your behalf, an or an introducer.

8.3. We may transfer your information to another of the Spur entities, an agent, sub-contractor or third party who carries on business in another country, including one which may not have data privacy laws similar to those of South Africa. If this happens, we will ensure that anyone to whom we pass your information agrees to treat your information with the same level of protection as if we were dealing with it.

8.4. If you do not wish us to disclose this information to third parties, please contact us at the contact details set out above. We may, however, not be able to provide products or services to you if such disclosure is necessary.

9. RETENTION OF YOUR INFORMATION

We may retain your personal information indefinitely, unless you object, in which case we will only retain it if we are permitted or required to do so in terms of Applicable Laws. However, as a general rule, we will retain your information in accordance with retention periods set out in Applicable Laws, unless we need to retain it for longer for a lawful purpose. (For example, for the purposes of complaints handling, legal processes and proceedings.)

10. ACCESS TO, CORRECTION AND DELETION OF YOUR PERSONAL INFORMATION

10.1. You may request details of personal information which we hold about you under the Promotion of Access to Information Act, 2000 (“PAIA”). Fees to obtain a copy or a description of personal information held about you are prescribed in terms of PAIA. Confirmation of whether or not we hold personal information about you may be requested free of charge. If you would like to obtain a copy of your personal information held by Spur, please review our PAIA Manual available for inspection, free of charge, at the offices of Spur and at www.spurcorporation.com

class="pl-2"10.2. You may request the correction of personal information Spur holds about you. Please ensure that the information we hold about you is complete, accurate and up to date. If you fail to keep your information updated, or if your information is incorrect, Spur may limit the products and services offered to you or elect not to open the account.

10.3. You have a right in certain circumstances to request the destruction or deletion of and, where applicable, to obtain restriction on the processing of personal information held about you. If you wish to exercise this right, please contact the Spur Customer Care Centre at Customer [email protected]

10.4. You have a right to object on reasonable grounds to the processing of your personal information where the processing is carried out in order to protect our legitimate interests or your legitimate interests, unless the law provides for such processing.

11. COMPLAINTS

11.1. Should you believe that Spur has utilised your personal information contrary to Applicable Laws, you undertake to first attempt to resolve any concerns with us.

11.2. If you are not satisfied with such process, you may have the right to lodge a complaint with the Information Regulator, using the contact details listed below:

11.2.1. Tel: 012 406 4818

11.2.2. Fax: 086 500 3351

11.2.3. Email: complaints. [email protected]