This is the Privacy Statement of Quoin Technologies (we or us)at www.quointechnologies.co.za, www.brokerzone.co.za and www.ownerzone.co.za and all our clients and potential clients who engage with us in any manner (collectively, you)

Use of the Website is also subject to our terms and conditions available on our website. Relationship with us as a client is subject to any separate terms between us

We may need to change or update this Privacy Statement from time to time. Any updated versions will be posted on the Website and will be effective from the date of posting. Where practical, we may notify you of the changes. 

What personal information do we collect? 

We respect your privacy rights and comply with all applicable laws in handling personal information. When used in this Privacy Statement, the term “personal information” has the meaning given to it in the Protection of Personal Information Act, 2013 (POPIA), applicable in the Republic of South Africa. 

Generally speaking, personal information is any information that can be used to personally identify a natural or juristic person. If any information that we collect personally identifies you, or you are reasonably identifiable from it, we will treat it as personal information. Quoin Technologies requests for your Financial Intelligence Centre Act (FICA) information upon submission of an offer. Such information may include but is not limited to the following: Company CK registration / Individual ID, Proxy/ User certified ID documents, Certified Utility Bill, Company Resolution Mandate, Ultimate Beneficial Ownership Structure, Source of Funds, Trust Deed/Will, Letter of Authority, VAT certificate and the company BRNC document. 

All registrations are conducted via the brokerzone and ownerzone websites. When registering as a new client, the website will prompt you for certain mandatory personal information, whereafter you will be given access to our transactional website. If purchasing or leasing property in a Company or Trust, you will be prompted to enter your company registration information and will be asked to upload. Should there be a case whereby insufficient documentation had been provided, you will receive communication via telephone and email requesting for the outstanding documentation, once this is provided to us, you will be deemed FICA compliant, bidding access to our auction website will be provided. 

Quoin Technologies currently conducts verification checks on your personal Information using third- party verification systems such as TPN and Transunion. 

How do we use cookies? 

The Quoin Technologies Website uses “cookies” to help you personalise your online experience. A cookie is a text file that is placed on your hard disk by a Web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you. 

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you register with Quoin Technologies, a cookie helps Quoin Technologies to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same Quoin Technologies website, the information you previously provided can be retrieved, so you can easily use the brokerzone and ownerzone features that you customised. 

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Quoin Technologies services or websites you visit. 

If you provide us with personal information of third parties, please make sure that you are authorised to do so. 

Why do we collect personal info? 

The purpose for why the Company is processing your Personal Information shall always be for a specific, lawful and clear purpose and the Company shall as far as reasonably possible ensure you are aware of such purpose. 

The most general use of Personal Information is for purposes required by the Company to operate and manage its normal business operations, this is inclusive of (but not limited to) the following: 

• The Company requires this Personal Information in order to ensure that we can provide our services to you sufficiently and successfully. 

• The Company has a legal requirement in terms of FICA to conduct the necessary KYC (Know Your Client) and Due Diligence procedures with regards to our Users and Potential Users. 

• To respond to general enquiries submitted through our “contact us” page; 

• To conduct verification checks; 

• To communicate with you via automated emails and provide you with access to our information; 

• To gain insight into how our visitors use the website and to improve our website service;
  We may handle anonymised information for research or analytics purposes or include it in our publications which we share with third parties. You will not be identifiable from this information. 

How do we process personal information? 

Process of Collecting Personal Information:  

• The Company will always collect Personal Information in a fair, lawful and reasonable manner to ensure that your privacy is protected and based on legitimate grounds for collection.  

• The Company shall as far as reasonably possible collect Personal Information from you directly, but there may be instances where it can be collected from third parties. Collection from such third-parties may include: 

• Credit reference agencies; 

• Other companies providing services to us;  

• Publicly available sources. 

General Procedure for Collecting Personal Information:  

• The Company shall be required to collect certain Personal Information in order to conduct its respective business services to its customers. The type of Personal Information to be collected may be different depending on the service and/or the respective Website you are utilising. 

• The Company may from time to time, collect information to conduct the necessary customer due diligence processes as may be required for regulatory purposes and to ensure compliance with FICA.  

• The Company shall conduct the necessary due diligence and verification checks on the information and documentation duly provided.  

• In the case where insufficient or incorrect documentation were provided, we shall notify you via telephone and/or email requesting the outstanding documents.  

• Access to our Websites or finalisation of transactions (as applicable) may be temporarily placed on hold until such time that all outstanding documentation has been received and the necessary due diligence procedure has been completed upon satisfaction of the Company. 

In the case where you would like to object to the Processing of your Personal Information, you are advised to complete and submit Form POPI/OPPI provided for in Appendix 6 within our PAIA Manual, to the contact details provided for of the Information Officer of the Company below. However, take note that certain Personal Information is required for Website access and transactional purposes and that by submitting this objection for any required Personal Information can lead to the inability to gain access or concluding transactions 

What if you don’t provide the personal info we need? 

• We may not be able to supply the products and/or services you require from us;  

• We may not be able to respond to your enquiry as submitted to us through the “contact us” page; 

• You will not be able to provide an account. 

Do we disclose personal info to 3rd parties? 

• We may disclose your Personal Information to third-parties as required by law, where it is necessary to give effect to a contract or transaction with you, or where we have a legitimate interest in doing so. We may disclose your Personal Information to: 

• • third-party internal and external auditors, our employees, contractors or third party service providers in connection with the Website, and our business operators; 
  • our insurers, underwriters and professional advisors, including our accountants, lawyers, business advisors and consultants; 

• • employees and/or the managers of any entities through which they operate if we merge, combine or divest a part of our business; 

• • law enforcement or regulatory bodies as required by law; and

• • any other juristic or natural person for any authorised purpose with your express consent. 

• The Company shall ensure that in the case where your Personal Information is shared with third-party service providers, that they shall process the Personal Information in accordance with this Privacy Statement, all other applicable internal policies and POPIA. 

• Third-party service providers shall not use or have access to Personal Information other than the purpose specified by us with at least the same or better level of security to protect your Personal Information. 

• The Company will never sell your Personal Information 

Will we cross-border share? 

• The Company shall only transfer your Personal Information outside of South Africa where consent of such transfer has been provided or where its required and as necessary for storage or security purposes or in order to fulfil the purpose of its collection. 

• In the case where the Company does transfer your Personal Information outside of South Africa, the Company shall ensure that the Personal Information is only used for the specified purpose and that the requirements as set out in this Privacy Statement, other applicable policies and requirements set out in POPIA are being complied with. 

How do we manage personal info? 

All Personal Information Processed by the Company shall be retained in a safe and secured manner at all times. The Company shall at minimum ensure that these procedures in the management of your Personal Information are followed:  

• Storage, Retention & Deletion of Data:

• • All Personal Information collected or received by the Company shall be stored in a safe and secured environment. 

• • The Company shall as far as reasonably possible attempt to store all Personal Information in an electronic format. 

• • In the case where copies of physical records of Personal Information are received, then the Company shall take all reasonable efforts to make a copy thereof in electronic form and ensure that the physical record is destroyed. 

• • The Company shall take all reasonable measures to ensure that records of Personal Information in our possession is only retained for the period as necessary for achieving the purpose of its collection. Records of Personal Information shall only be retained for a longer period if:  

• • • the retention is required and authorised by applicable law;  

• • • the retention is required for the performance and/or the conclusion of a contract of which the Data Subject is a party to;  

• • • the Data Subject has provided consent for the longer period; d) the retention is required for any other lawful purpose.  

• • We shall ensure that all Personal Information no longer required to be retained for the purposes set out in the above shall as soon as possible be either destroyed, deleted or de-identified.  

• • You may submit a formal request to us to delete your Personal Information in our possession, with due regard and subject to the above, by completing the applicable part and submitting Form RCDPI/DDRPI provided for in Appendix 7 of our PAIA Manual to the contact details provided for of the Information Officer of the Company below.  

• Update / Correction of Data:

• • We shall take all reasonable steps to ensure that your Personal Information are up to date. 

• • Where there are any changes to your Personal Information provided to us, you must notify us as soon as possible of such change and provide us with the respective supporting documentation.  

• • In the case where we notice any discrepancies with regards to the Personal Information provided, we shall notify you directly via telephone and/or email.  

• • If you notice that any Personal Information has been incorrectly captured by us, its best advised to notify us as soon as possible to correct the mistake.  

• • You may submit a formal request to us to update or correct your Personal Information in our possession, by completing the applicable part and submitting Form RCDPI/DDRPI provided for in Appendix 7 of our PAIA Manual to the contact details provided for of the Information Officer of the Company below. 

• Safety and Security of Personal Information:

• • As the Website is accessible via the internet, and the internet is inherently insecure, we cannot guarantee the security of information you send to us online (including that it will not be intercepted). You send information to us online at your own risk.  

• • The Company shall take all reasonable measures to ensure a safe and secure environment of your Personal Information.  

• • The Company shall take all appropriate, reasonable technical and organisational measures to prevent loss, unlawful access and unauthorised destruction of Personal Information in its possession or under its control.  

• • The Company shall conduct regular testing to asses and evaluate the effectiveness of its technical organisational measures to ensure its security and safeguard measures are up to standard. 

• • The Company shall further maintain and regularly verify that is security measures are effective and where applicable conduct regular updates to address newly identified risks (if any).
  • Personal Information may be kept in either electronic or hard copy form. In both cases, we take reasonable and appropriate steps to ensure that the Personal Information is protected from misuse, loss, unauthorised access, modification or disclosure. 

Can you access your personal info? 

• You have the right to contact us at any time requesting: 

• • confirmation that we have your Personal Information; 

• • access to the records containing your Personal Information or a description of the Personal Information that we have in possession of you; and 

• • the identity or categories of third-parties who have had, or currently have, access to your Personal Information. 

• Details and process on how to make a request are available within our PAIA Manual. When making a request, we will require adequate proof of your identity. We will try to provide you with suitable means of accessing information, where you are entitled to it, by for example, posting or emailing it to you. 

• There may be instances where we cannot grant access to your Personal Information. For example, if access would interfere with the privacy of others or would result in a breach of confidentiality, we may need to refuse access. If we refuse access, we will give written reasons for the refusal. 

• If you believe that any Personal Information that we hold about you is inaccurate, irrelevant, outdated, incomplete or misleading, you are encouraged to inform us to correct it. If you believe that any Personal Information that we hold about you is excessive or have been unlawfully obtained or that we are no longer authorised to retain it, you may ask us to destroy or delete it. If we do not agree that there are grounds for action, you may ask us to add a note to the Personal Information stating that you disagree with it. 

• We may charge a reasonable fee to cover our administrative and other costs in providing the requested information to you. We will not charge for simply making a request or for making any corrections to Personal Information. 

• For further detailed information with regards to our Access to Personal Information policy kindly refer to our PAIA Manual. 

How do we use your personal info for marketing? 

• We may, with your prior consent, use your contact details to send you details of new products or services which may interest you. These communications may be sent in various forms ( including by mobile phone and by email) in accordance with applicable marketing laws. If you indicate a preference for a method of communication, we will endeavour to use that method. 

• All of these communications will set out how to unsubscribe from (or opt out of) receiving future communications if you no longer wish to receive promotional material. 

What if there is a breach of personal info? 

• A Breach of Personal Information or a Data Breach refers to an incident where on reasonable grounds it is believed that Personal Information of a Data subject has been unlawfully accessed or acquired and/or accessed or acquired by unauthorised person. 

• The Company shall address any Data Breach in accordance with the terms and recommendations set out in POPIA and any other applicable law. 

• The Company shall notify the Regulator and the affected Data subject(s) (unless applicable law requires delay of notification) in writing. 

• The Company shall provide the notification as mentioned above as soon as reasonably possibly, no later than 72 (seventy-two) hours after becoming aware of the respective Data Breach. 

• In the case where the Company is regarded as the Operator (as defined in POPIA), then the Company shall notify the Responsible Party (as defined in POPIA) immediately after becoming aware of a potential Data Breach. 

What about 3rd party sites? 

This Privacy Statement does not apply to any third-party websites which may be accessible through links on the Website. We do not make any representations or warranties about the privacy practices of any third-party and do not accept any responsibility for them. Third-party website providers are responsible for informing users about their own privacy practices and we suggest that you review the privacy policies of any third-party providers whose sites you access. 

Enquiries & complaints 

• If you have any questions or would like to enquire about your Personal Information in our possession, kindly contact the Information Officer of the Company on the contact details provided in clause 15 below.  

• If you believe that your Personal Information has been unlawfully accessed or acquired, you are advised to contact us as soon as possible and provide details of the incident so that we can investigate it. 

• We will treat your complaints confidentially (unless otherwise required by law), investigate those complaints and aim to ensure that they are resolved within a reasonable time, in order to provide you with appropriate feedback. 

• It is advised that if you do have any enquiries or complaints regarding your Personal Information held by us, that you must first attempt to notify us as soon as possible to resolve the matter without undue delay. However, any person who wishes to contact the Information Regulator of South Africa (the “Regulator”) if they are not in agreement with the outcome of their request, may proceed with this route by notifying the Regulator. 

Contact information 

• All enquiries and complaints which must be completed and submitted on the Forms as indicated below, OR if you have a general enquiry or your request is not addressed in one of the Forms you can send such enquiry, request or Form to the duly appointed Information Officer of the Company at the following address details:  

• • Physical Address: 63 Protea Road, Claremont, Cape Town, 7708.  

• • Email Address: gary@quointechnologies.co.za  

• • Attention: Information Officer 

• Notification shall be sent to you as soon as your request above has been received. We shall address the respective request as soon as possible and provide feedback of the outcome of your request. 

• Contact details of the Regulator are as below:  

• • Physical Address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001. 

• • Postal Address: P.O Box 31533, Braamfontein, Johannesburg, 2017
     

More detailed contact information can be located on the website of the Regulator at the following address: https://www.inforegulator.org.za/contact.html