PRIVACY NOTICE: FREE WI-FI SERVICE

INTRODUCTION

Vukile Property Fund Limited (“Vukile”) will obtain, use and store personal information of users of the free Wi-Fi service available at certain properties belonging to Vukile.

Information about users and their shopping preferences is imperative to Vukile in order to achieve the goal with provision of the free Wi-Fi service offered. If such service does not assist Vukile in its endeavours to ensure viable trading conditions for its tenants and improving customer satisfaction, the free Wi-Fi service will not benefit all parties involved and will not serve its intended purpose.

This Notice should be read with the Terms and Conditions: Free Wi-Fi Service and is subject to change from time to time in the discretion of Vukile and depending on any amendments to relevant legislation.

COMPLIANCE WITH APPLICABLE LEGISLATION

Vukile will comply in all respects with all applicable legislation in gathering, keeping, processing, protecting and utilising personal information.

By providing any personal information, the user authorises Vukile to use such personal information for all purposes legally permissible.

No personal information of any person under the age of 18 provided by such minor person to Vukile will be used by Vukile unless it has been authorised by the parent or legal guardian of such minor person.

SHARING OF PERSONAL INFORMATION

  1. Vukile will at all times aim not to divulge specific information regarding any particular user and will generally use the information gathered for analytical and statistical purposes. The determinations and findings of these investigations may be shared by Vukile with any relevant third parties in its discretion.
  2. Where Vukile however is of the opinion that disclosure of certain personal information relevant to a particular user or group of users is necessary for the benefit of the tenants and customers of the shopping centre as a whole and in achieving the purpose of the free Wi-Fi service offering, Vukile may divulge such personal information as provided by the user through the application in its sole discretion. This includes disclosure to tenants and third parties for marketing purposes. Any such disclosure will at times be done in accordance with the provisions of the applicable laws.
  3. Where personal information is shared with international entities not bound by South African laws pertaining to protection of personal information, an undertaking from such entities regarding the non-disclosure of personal information within the scope of the South African laws will be required.

ADDITIONAL INFORMATION GATHERED

  1. When using the free Wi-Fi service, Vukile also collects standard information about the users’ internet connection and internet usage. This information is collected on each and every user of the free Wi-Fi service and may also be used for statistical purposes as well as determining whether there is an abuse of the service or any unlawful use thereof as envisaged in the Terms and Conditions.
  2. The types of information collected may include, but will not necessarily be limited to, the URL the user came from, IP address, domain type, browser type, the country and telephone code where the relevant device is located, the webpages viewed during each free Wi-Fi session, the advertisements users clicked on, and any search terms entered by the users.
  3. Vukile uses cookies to optimize the service, but users can opt out of this option.

USERS’ RIGHTS AND PREFERENCES

Users have the right to know what personal information Vukile has about them and which will be accessible through the application, to correct or verify such information and to opt out of any marketing at any time.

Users may further request, at any time, that all personal details or information be deleted by Vukile, in which event the user will no longer be registered as a user of the free Wi-Fi service and will by implication no longer be eligible for any rewards or free Wi-Fi service usage.

Where Vukile is however legally obliged to retain any information, it will not delete same but undertakes not to utilize any information requested by the user to be deleted.

SECURITY

Reasonable security safeguards have been implemented and will remain in place to protect the personal information of users of this service.

Notwithstanding the aforegoing, Vukile gives no guarantees in this regard and the users accept that security threats and breaches may arise from time to time.

Vukile will inform users of material security breaches which may jeopardize any users.