Privacy Policy

1. About this policy

GAIS37 respects your privacy and is committed to handling personal information responsibly in accordance with the Protection of Personal Information Act 4 of 2013 ("POPIA") and other applicable laws.

This policy explains how GAIS37 (Pty) Ltd (registration number 2020/102683/07), trading as GAIS37 ("we", "us" or "our"), collects, uses, stores and shares personal information when you visit www.gais37.com, contact us or engage with our business.

Where we process information on behalf of a client, we follow the applicable service agreement and the client's lawful instructions. The client's privacy notice may also apply.

2. What is personal information?

Personal information is information relating to an identifiable living person or, where applicable, an identifiable existing organisation. It may include contact details, identifiers, correspondence and information about professional or business activities.

3. Information we collect

Depending on your interaction with us, we may collect:

• Your name, email address, telephone number and business address.
• Your organisation, job title and professional contact details.
• Information you provide in enquiries, meetings, forms, surveys or correspondence.
• Event registrations and communication preferences.
• Contract, billing and transaction information where relevant to an engagement.
• Application details and supporting documents if you apply to work with us.
• Technical information such as IP address, browser type, device information and website usage, where collected through our website systems.

We collect information relevant to a specific purpose. Please do not submit passwords, access credentials or sensitive documents through general website enquiry forms.

Special personal information and children's information require additional protection. Where such processing is necessary, we will identify an appropriate legal authorisation and safeguards.

4. How we collect information

We generally collect information directly from you when you:

• Submit an enquiry or request a meeting, proposal or demonstration.
• Communicate with us by email, telephone, online or in person.
• Subscribe to communications or register for an event.
• Complete a survey or provide feedback.
• Enter into a business relationship with us.
• Apply for a position or contractor opportunity.

Where lawful and relevant, we may also receive information from your organisation, authorised representatives, recruitment providers, business referrals or publicly available professional sources.

Public availability does not remove our obligation to process information lawfully.

5. Why we use information

We use personal information, as appropriate, to:

• Respond to enquiries and provide requested information.
• Assess requirements, prepare proposals and manage engagements.
• Deliver and support agreed services.
• Administer contracts, billing and business records.
• Organise meetings and events.
• Manage recruitment and supplier relationships.
• Maintain website functionality, security and performance.
• Improve our services and understand feedback.
• Send permitted marketing communications.
• Meet legal obligations and establish, exercise or defend legal rights.

We process information on an appropriate lawful basis, which may include consent, contractual necessity, a legal obligation or the protection of legitimate interests, depending on the circumstances.

Providing information is generally voluntary. If information is necessary to respond to a request or deliver a service, withholding it may prevent us from doing so. We will identify mandatory requirements where relevant.

6. Sharing information

We may share relevant information with:

• Hosting, cloud, communications and other technology providers supporting our operations.
• Delivery partners where their involvement is necessary for an agreed engagement.
• Event or communications providers supporting activities you have requested or lawfully agreed to receive.
• Professional advisers, including legal, accounting and audit advisers.
• Authorities where disclosure is legally required or permitted.

We limit disclosures to the relevant purpose. Providers processing information on our behalf must be subject to appropriate contractual confidentiality and security obligations.

We do not sell personal information.

7. Transfers outside South Africa

Some services may involve storing or processing information outside South Africa.

Any cross-border transfer must meet POPIA's requirements, including adequate protection through applicable law, binding corporate rules or a binding agreement, or another lawful ground such as consent or contractual necessity.

Where relevant, we will provide further information about the destination and applicable protection when collecting your information or arranging the service.

8. Cookies and website analytics

Our website may use cookies or similar technologies to support functionality, remember preferences and understand usage.

Technical identifiers and analytics information may constitute personal information. We do not assume that all analytics data is anonymous.

Where non-essential analytics or advertising technologies are used, we will explain their purposes and providers and obtain consent where required. You may manage available preferences through the website's cookie controls or your browser settings. Blocking essential cookies may affect functionality.

This policy does not, by itself, authorise advertising tracking or retargeting.

9. Direct marketing

We send electronic direct marketing only where permitted by law, including with your consent or under the applicable existing-customer provisions for our own similar products or services.

Where we rely on the existing-customer provisions, you will have an opportunity to object when your details are collected and in each marketing communication.

Marketing messages will identify GAIS37 and provide a straightforward way to unsubscribe. You may also contact us to stop marketing communications.

Visiting the website, submitting an enquiry or accepting our Terms of Use does not automatically constitute marketing consent. Necessary service communications may continue after you unsubscribe from marketing.

10. Security and retention

We take reasonable technical and organisational measures appropriate to the information and risks involved. These include restricting access, protecting systems and requiring appropriate safeguards from service providers.

No system is completely secure. Where a security compromise requires notification, we will notify the Information Regulator and affected persons as required by law.

We retain information only for as long as necessary for its purpose, applicable legal requirements or another lawful retention ground. When retention is no longer justified, we securely delete, destroy or de-identify the information.

We may retain limited suppression records to honour marketing opt-outs.

11. Your rights

Subject to applicable requirements and exceptions, you may:

• Ask whether we hold personal information about you and request access.
• Request correction of inaccurate or misleading information.
• Request deletion or destruction where legally justified.
• Object to processing where the law permits.
• Withdraw consent where processing relies on consent.
• Object to direct marketing.
• Lodge a complaint with the Information Regulator.

Withdrawal of consent does not invalidate lawful processing that occurred before withdrawal.

Contact our Information Officer using the details below. We may need proportionate proof of identity to protect your information. We will explain applicable procedures, lawful fees or reasons why a request cannot be fulfilled and respond within the applicable legal timeframes.

12. Third-party websites

Our website may contain links to external websites. Their operators are responsible for their own privacy practices. Please review their privacy notices before providing information.

13. Questions and complaints

Contact our Information Officer if you have a privacy question, request or complaint.

You may also complain directly to the Information Regulator (South Africa) without first completing an internal complaint process:

• Website: inforegulator.org.za
• Complaints: inforegulator.org.za/complaints
• General enquiries: enquiries@inforegulator.org.za
• Telephone: 010 023 5200

14. Changes to this policy

We may update this policy as our practices or legal requirements change. The current version will appear on our website with its revision date.

Where necessary, we will provide additional notice or obtain fresh consent. Publication of an updated policy does not itself authorise a new use of personal information.

15. Contact GAIS37

Responsible party: GAIS37 (Pty) Ltd (registration number 2020/102683/07), trading as GAIS37
Physical address: Sandton, Gauteng, South Africa
Information Officer: The Information Officer, GAIS37
Privacy email: info@gais37.com
Telephone: +27 84 658 2521
Website: www.gais37.com