Privacy Policy

A. DEFINITIONS

"Data" means any data (including Personal Information) provided to Freight VI by a Data Subject;

"Data Subject" has the meaning given in POPIA and includes a natural person and juristic person (companies);

"Freight VI","us" or "we" means Freight VI , a private company limited and registered in South Africa with registration number 2021/732559/07 and its related companies, subsidiaries and/or parent companies, sponsors, affiliates and creators;

"Information Regulator" means the supervisory authority in South Africa, established in terms of POPIA;

"Operator" means a person who Processes Personal Information for a Responsible Party in terms of a contract or mandate, without coming under the direct authority of that party;

"Process","Processing" or "Processed" means any operation or activity or any set of operations, whether or not by automatic means, concerning Personal Information, including-

the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use;
dissemination by means of transmission, distribution or making available in any other form; or
merging, linking, as well as restriction, degradation, erasure or destruction of information;

"Personal Information" means information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person, including, but not limited to-

information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth of the person;
information relating to the education or the medical, financial, criminal or employment history of the person;
any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier or other particular assignment to the person;
the biometric information of the person;
the personal opinions, views or preferences of the person;
correspondence sent by the person that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence;
·the views or opinions of another individual about the person; and
the name of the person if it appears with other personal information relating to the person or if the disclosure of the name itself would reveal information about the person;

"POPIA" means the Protection of Personal Information Act, 2013, as amended, consolidated or replaced from time to time;

"Responsible Party" means a public or private body or any other person which, alone or in conjunction with others, determines the purpose of and means for Processing Personal Information;

"Special Personal information" means Personal information concerning-

the religious or philosophical beliefs, race or ethnic origin, trade union membership, political persuasion, health or sex life or biometric information of a Data Subject; and
the criminal behavior of a Data Subject to the extent that such information relates to-
the alleged commission by a Data Subject of any offence; or
any proceedings in respect of any offence allegedly committed by a Data Subject or the disposal of such proceedings; and

"User" means a person who uses and/or accesses computer software and/or material via the Freight VI website.

B. PURPOSE

The purpose of this Policy is, inter alia, to:

regulate the manner in which Personal Information is dealt with by all persons and entities which Process Personal Information for or on behalf of Freight VI;
prescribe rules for the Processing of Personal Information;
ensure that Freight VI, as the responsible party determining the purpose of and means for Processing Personal Information, must comply with the rules for lawful Processing of Personal Information as set out in this Policy;
enable Freight VI to monitor user activities for compliance with privacy legislation ensuring that Personal Information is processed in line with all applicable data privacy laws and regulations; and
to ensure that the Personal Information of the data subjects is Processed by Freight VI in accordance with POPIA.

C. SCOPE

This Policy applies to any person Processing Personal Information on behalf of Freight VI and includes inter alia:

Employees;
Contractors; and
representatives of Freight VI.

D. COLLECTION OF PERSONAL INFORMATION

a. Users

Freight VI processes Personal Information that a User provides to it directly or that it learns about a User from the User's use of Fortress systems and Fortress communications and through other dealings with Users.

If a User registers with Freight VI by completing a submission form, including but not limited to a newsletter registration form, an information enquiry form or a registration to gain access to a password protected zone, a User is not anonymous to Freight VI.

The types of Personal information that Freight VI collects and processes about Users may include the following:

User's name
date of birth
nationality
title
contact details
other information required for Know Your Customer (KYC), anti- money laundering and/or sanctions checking purposes
information collected from international sanctions lists, and
information that is publicly available on websites, databases and from other public data sources.

Freight VI may obtain a User's Personal Information when the User provides it to Freight VI or in circumstances where the User has made the information public, including via social media. Freight VI may collect or obtain a User's Personal Information when the User visits or uses Freight VI’s website or via social media.

Information collected by Freight VI is stored in a secure operating environment that is not available to the public.

Users provide the information requested by Freight VI voluntarily, therefore if a User does not wish to submit any personal identifying information, the User should not submit any information within ‘submission form’ fields on the Freight VI website. However, should a User fail to provide the information Freight VI reasonably requires, Freight VI may be unable to offer its services to the User and/or Freight VI may terminate the supply of any of its services provided with immediate effect.

Freight VI does not have any motive or intention to gather contact Data of visitors to its website or physical premises who are under the age of 18 and would prefer that the consent of a parent or another competent person be supplied on behalf of a child under the age of 18.

It is the nature of the Internet, websites and social media that Freight VI, by default, records User information on Freight VI's server traffic reports from the browser which the User is using to view Freight VI, including an IP address and which web pages were visited.

Freight VI uses cookie technology. Cookie technology consists of trace elements of data that is stored on the User's computer's hard drive, and which contains information about the User, so that next time the User visits the Freight VI website, the cookie recognises the User's prior visit.

b.Employees

The types of Personal information that Freight VI collects and processes about employees may include the following:

employee names;
identity numbers;
date of birth;
contact details including telephone numbers, physical addresses, email addresses;
employee records;
photographs and/ or video images of employees;
race/ ethnic origin;
bank account details;
employee share scheme details; and
data disclosing health, medical information and/ or disabilities in respect of employees.

c. Directors, shareholders, sureties, tenants, brokers, contractors and service providers and other Data Subjects

The types of Personal information that Freight VI collects and processes about directors, shareholders, sureties, tenants, brokers, contractors and service providers and other Data Subjects may include the following:

Names and surnames;
Identification numbers;
Date of birth;
Company names;
Registration numbers;
Contact details including telephone numbers, physical addresses and email addresses;
Domicilia;
VAT registration details;
Criminal records;
CVs, educational history and qualifications;
Credit information;
Information relating to the shareholder register;
Race
Gender; and
Bank account details.

Save for Personal Information that Freight VI is required or permitted by law to collect, Personal Information is generally collected from the Data Subjects and the Data Subjects provide the information requested by Freight VI voluntarily. However, should a Data Subject fail to provide the information Freight VI reasonably requires or withdraw consent previously given, Freight VI may not be able to effectively manage its relationship with the Data Subject.

USE OF PERSONAL INFORMATION

Freight VI processes Personal Information on the basis of lawful justification, for example, the Personal Information being publicly available, on the basis of the consent of the Data Subject, in pursuit of its, or its Data Subject’s legitimate interests, for the purposes of concluding or performing a contract, or on the basis of a legal obligation or public law duty.

Freight VI processes Personal Information of Users for purposes including:

to manage, administer and improve our business and customer and service provider engagements and relationships, for corporate marketing, business development and analysis purposes and to operate control and management information systems;
to monitor and analyze the use of our services and for system administration, operation, testing and support purposes;
to manage our information technology and to ensure the security of our systems;
to establish, exercise and/or defend legal claims or rights and to protect, exercise and enforce our rights, to protect property or safety, or to assist our clients or others to do this;
to investigate, respond to and deal with complaints or incidents relating to us or our business, to maintain service quality and to train employees;
to cooperate with, respond to requests from, and to report transactions and/or other activity to, government, tax or regulatory bodies, or other intermediaries or counterparties, courts or other third parties;
to monitor and analyze the use of our products and services for risk assessment and control purposes (including detection, prevention and investigation of fraud);
to conduct compliance activities such as audit and reporting, assessing and managing risk, maintenance of accounting and tax records, fraud and anti-money

Users of Freight VI’s website understand and agree that in order to offer certain services or functions, Freight VI must collect and use personal information about users.

Freight VI may send to a User messages by email and/or SMS and/or WhatsApp regarding their account.

It is an optional condition of a User submitting Data to Freight VI that Users agree to receive future promotional messages from Freight VI by email and/or SMS and/or WhatsApp or to opt-out from future communications. A User can choose to opt-out of promotional messages at any time by contacting Freight VI or following the unsubscribe link or instructions on the future communication.

Freight VI uses cookie technology and generates and saves User and session IDs to the User's Internet browser and computer to track and analyse website usage of the User. Freight VI does this to be able to identify any technical problems with the workings of Freight VI and to correct these to ensure a better online experience for the User.

Freight VI processes Personal Information of employees for purposes including:

to manage and administer the employment relationship with Freight VI's employees;
to execute monitoring and training;
for employment equity purposes;
to manage employee health and wellness;
to enable Freight VI to conduct SANS controls for security purposes including for theft prevention, for the prevention of security breaches, to prevent unauthorized access and to investigate suspicious activity;
to provide employee benefits and pension/provident fund administration; and
to comply with Freight VI's legal and regulatory obligations.

Freight VI processes Personal information of directors, shareholders, sureties, tenants, brokers, contractors and service providers for purposes including:

to comply with legislative requirements (for example broad-based black economic empowerment and employment equity);
to comply with the JSE listing requirements
reporting to relevant government departments for legislative purposes;
fraud prevention and detection;
credit vetting;
to carry out communication, service, billing and administration;
to market Freight VI's services by means of newsletters, know-how, promotional material and other marketing communications;
to contact third parties in relation to current, future and proposed engagements including to invite them to events (and arrange and administer those events);
to conduct analyses in respect of transactional viability;
for bank valuation purposes in respect of tenants;
for billing purposes and payment of invoices;
to obtain and update credit information with appropriate third parties, such as credit reporting agencies; and
to conduct processing necessary to fulfill other contractual obligations.

F. AUTHORISED ACCESS TO DATA

Freight VI may disclose information to any authorized official if required to do so by law or if it is required to protect the safety of other Freight VI Users or the public, or if Freight VI believes that such action is necessary to protect and defend Freight VI rights or properties, or for any other purpose recognized in law.

Freight VI will not sell, rent, share, or distribute Personal Information to any entity other than third parties which are vital in the administration of Freight VI and the supply of goods or services that have been requested by the User, including but not limited to: hosting service providers, web administrators and online purchase and delivery service providers.

Freight VI may need to share Data with employees and employees of third parties that require access to the Data to perform their day-to-day functions for Freight VI.

Freight VI may disclose anonymous demographic and biometric statistics about the Data within the database for business purposes.

In the event of Freight VI changing ownership to a new entity, Freight VI may transfer its rights to the Data to the new owner. Subject to applicable laws, the new owner of Freight VI is required to notify each Data Subject of the transfer and the Data Subject may choose to modify its Personal Information at that time or choose to remove it.

G. RECIPIENTS OF PERSONAL INFORMATION

From time to time Freight VI may need to share Data Subjects’ Personal Information with the following recipients:

suppliers and service providers;
the Johannesburg Stock Exchange;
third-party applications or platforms;
companies within the Fortress group of companies;
government departments;
the Competition Commission;
the BEE Commission;
the South African Revenue Service;
Financial institutions;
auditors;
industry bodies;
property managers;
attorneys, advocates and other legal advisors.

H. TRANSFER OF PERSONAL INFORMATION

From time to time Freight VI may need to share Data Subjects’ Personal Information with members of the Freight VI group that may be based outside South Africa. Freight VI may also allow its third party service providers, that may be located outside South Africa, to access Data Subjects' Personal Information. Freight VI may also make other disclosures of Data Subjects' Personal Information to countries outside South Africa, for example in the event of a legal or regulatory request from a foreign law enforcement body.

Freight VI will take steps to ensure that any international transfer of Personal Information is carefully managed to protect Data Subjects' rights and interests. In this regard, Freight VI will only transfer Personal Information to countries which are recognised as providing an adequate level of data protection similar to that of POPIA or where Freight VI is satisfied that there is a justification under POPIA for the transfer.

To the extent that Freight VI transfers any Special Personal Information or Personal Information relating to children to third parties in foreign countries that do not provide an adequate level of data protection, Freight VI shall obtain the requisite prior authorisation of the Information Regulator, in circumstances where required.

I. SECURE STORAGE OF DATA

Information collected by Freight VI is stored in a secure operating environment that is not available to the public.

All Data is available only to those authorized employees to whom Freight VI has granted permissions by issuing a username and keywords.

It is the responsibility of each employee to maintain the confidentiality and security of their password and to alert Freight VI or reset their password if compromise of security is suspected.

Freight VI may hold Personal Information in either electronic or hard copy form. In both cases Freight VI will take reasonable and appropriate steps to ensure that the Personal Information is protected from misuse and loss and from unauthorised access, modification or disclosure.

J. DATA SUBJECT RIGHTS

In terms of POPIA Data Subjects have the following rights:

to request access to, and information regarding the nature of Personal Information held and to whom it has been disclosed. Such request for access may be refused on the basis of the grounds of refusal in the Promotion of Access to Information Act, 2000, as amended (“PAIA”);
to request the restriction of Processing of Personal Information if:
its accuracy is contested by a Data Subject,
for a period enabling Fortress to verify the accuracy of the information;
if Freight VI no longer needs the Personal Information for achieving the purpose for which the information was collected or subsequently Processed, but it has to be maintained for purposes of proof;
if the Processing is unlawful and the Data Subject opposes its destruction or deletion and requests the restriction of its use instead; or
if the Data Subject requests to transmit the Personal Information into another automated processing system;
to not have Personal Information Processed for direct marketing purposes by means of unsolicited electronic communications, save for in certain circumstances;
to not to be subjected, under certain circumstances, to a decision which is based solely on the automated Processing of Personal Information intended to provide a profile of such person;
to request to rectify or correct Personal Information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully;
to request deletion of Personal Information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully or where Freight VI is no longer authorized to retain it. Freight VI will consider whether the information requires correction, deletion or destruction and if Freight VI does not agree that there are grounds for action, the Data Subject may request that Freight VI adds a note to the Personal Information stating that the Data Subject disagrees with it;
to object to Processing of Personal Information where the Processing is on the basis that it protects a Data Subject’s legitimate interests; where the Processing is on the basis that it is necessary for pursuing Freight VI’s legitimate interests or a third party to whom it is disclosed; or where the Processing is for the purposes of direct marketing other than by unsolicited electronic communications;
to lodge a complaint with the Information Regulator using the details below and request that the Information Regulator assess whether Freight VI has violated any provision of applicable data protection regulations;

The Information Regulator (South Africa)

JD House

27 Stiemens Street

Braamfontein

Johannesburg

2001

email: inforeg@justice.gov.za / complaints.IR@justice.gov.za

to institute civil proceedings regarding the alleged interference with the protection of the Data Subject's Personal Information.

A Data Subject has the right to request to update or remove the Personal Information they have submitted to Freight VI, by submitting a request on the electronic form provided. User updates or removal will reflect in Freight VI's active database, but Freight VI may retain Personal Information in backup files and archives to prevent a User from being accidentally re-added to the database after they have expressly unsubscribed. Freight VI will destroy Personal Information it no longer processes, in line with its Data Retention Policies.

To exercise these rights or if Data Subjects have questions about how Freight VI processes Data Subjects' Personal Information, please contact Freight VI using the following contact details:

Data Access Request Link and Form:

https://freightvi.co.za/contact

K. LIMITATION

Freight VI has no control over information or privacy policies of third party websites hyperlinked to and from Freight VI. These third party links are being provided for the convenience of the Users of Freight VI and Freight VI does not endorse and is not responsible or liable for the content, nature or reliability of any linked website or any link contained in a linked website. Freight VI takes no responsibility for monitoring, updating, supplementing or correcting any information on any linked website and makes no representation or warranties regarding such information. Please be aware that in linking to these outside websites, Users are leaving Freight VI and that Freight VI is not responsible for the content of any other site.

L. ENQUIRIES

Any questions or concerns related to this Privacy Policy should be directed to the Freight VI Information Officer and/or Deputy Information Officer:

1. Information Officer

Durban, Kwazulu - Natal, South Africa

+27 (87) 702 0475

info@freightvi.co.za