Privacy Policy

We are committed to protecting your personal information and to processing it responsibly. In practice, that means:

• we collect only the personal information we reasonably need, for clear and lawful purposes;
• we process your personal information lawfully, fairly and transparently;
• we do not sell or rent your personal information;
• we share your personal information only where it is necessary and lawful, and only with parties who are required to protect it;
• we keep your personal information secure, using appropriate technical and organisational measures;
• we keep your personal information only for as long as we need it or the law requires; and
• we respect your rights and give you clear ways to exercise them.

We process personal information in line with South African law, principally the Protection of Personal Information Act 4 of 2013 (POPIA). Depending on the situation, we also have regard to:

• the Promotion of Access to Information Act 2 of 2000 (PAIA), which sets out how you can request access to information we hold;
• the Electronic Communications and Transactions Act 25 of 2002 (ECTA), which governs electronic communications and transactions;
• the Consumer Protection Act 68 of 2008 (CPA), where it applies; and
• the European Union General Data Protection Regulation (GDPR) and the UK GDPR, where you are located in those regions and those laws apply to you.

Depending on how you use the Website and whether you apply to join us, we may collect the following categories of personal information:

• Identity and contact details, such as your name, email address, telephone number, and location.
• Application and professional information, such as your experience as a property practitioner, your current agency arrangements, your PPRA registration and Fidelity Fund status where relevant, and other details you provide when you apply to join us.
• Assessment information, such as your answers to our qualification quiz and application questions, and the outcome of any assessment.
• Commission and financial inputs that you enter into tools on the Website, such as a commission calculator. These inputs are used to produce an illustrative estimate for you and are treated as personal information.
• Communications, such as the content of enquiries, emails, messages and calls between you and us, and our notes about them.
• Marketing preferences, such as whether you have chosen to receive marketing from us.
• Technical and usage information, such as your IP address, device and browser type, operating system, the pages you view, how you reach and move through the Website, and information collected through cookies and similar technologies.

We do not seek to collect special categories of personal information through the Website. Please do not send us sensitive information that we have not asked for.

We collect personal information:

• Directly from you, when you complete a form, apply to join us, answer our quiz, use a tool on the Website, subscribe to our communications, or contact us.
• Automatically, when you use the Website, through cookies, pixels, server logs and analytics tools, as described in the Cookies section below.
• From third parties, in limited cases, such as where someone refers you to us, or where a service provider or public source helps us verify information you have given us.

You can browse most of the Website without giving us personal information. It is generally only when you apply, enquire, subscribe, or use a tool that we ask you to provide it.

We process your personal information for the following purposes, relying on the lawful bases shown:

• to receive and assess your application to join Real Estate Services, and to communicate with you about it (to take steps towards a possible agreement with you, and our legitimate interest in recruiting suitable agents);
• to respond to your enquiries and provide the information, tools and services you ask for (to perform what you have requested, and our legitimate interest in running the Website);
• to operate, maintain, secure and improve the Website (our legitimate interest, and legal obligations relating to security);
• to send you marketing and updates about Real Estate Services, where you have consented or where the law otherwise allows it (your consent, or our legitimate interest, subject to your right to opt out);
• to prevent, detect and investigate fraud, misuse and security incidents (our legitimate interest and legal obligations); and
• to comply with the law and with regulatory requirements, and to establish, exercise or defend legal claims (compliance with our legal obligations, and our legitimate interest).

Where we rely on your consent, you may withdraw it at any time. Withdrawing consent does not affect processing that took place before you withdrew it.

Like most websites, we use cookies and similar technologies, such as pixels, tags and server logs, to make the Website work, to keep it secure, to understand how it is used, and to measure and improve our marketing.

A cookie is a small text file placed on your device. Some cookies are necessary for the Website to function. Others help us with analytics and advertising, and we use these in line with your choices.

We use, among others, Google Analytics to understand how visitors use the Website, and advertising and measurement tools from platforms such as Meta (Facebook and Instagram) and Google to measure and improve our campaigns. These providers may set their own cookies and may combine information about your visit with information they already hold. We use Kartra to power the Website, our forms and our communications.

You can control cookies through your browser settings and, where we show a cookie banner, through the choices you make there. Blocking some cookies may affect how the Website works. You can also opt out of certain advertising tracking through the settings of the relevant platform, or through industry opt-out tools.

As a rule, we do not sell, rent or trade your personal information. We share it only where it is necessary and lawful, and only the minimum needed. We may share your personal information with:

• Our service providers (operators), who process personal information on our behalf and under our instructions, such as our website and email platform (Kartra), analytics providers (such as Google), advertising and measurement platforms (such as Meta and Google), scheduling tools (such as Calendly), hosting and IT providers, and other tools we use to run our business.
• Our partners, such as our bond origination partner, where you choose to use a service that involves them, and only to the extent needed to provide that service.
• Our professional advisers, such as lawyers, auditors and accountants, where reasonably needed.
• Authorities and regulators, where we are required or permitted by law to share information, or to protect our rights.
• A successor, in the event of a merger, restructuring, sale or transfer of our business or assets, subject to appropriate protections.

Where a service provider processes personal information on our behalf, we require it to keep the information secure and to process it only as we instruct.

Some of our service providers are located outside South Africa, or store information outside South Africa. This means your personal information may be transferred to, and processed in, other countries.

Where we transfer personal information outside South Africa, we do so in line with POPIA, and we take reasonable steps to ensure that it continues to be protected to a comparable standard, for example through the recipient being subject to laws or binding agreements that provide adequate protection.

We use appropriate technical and organisational measures to protect your personal information against loss, unauthorised access, and unlawful processing. These include secure transmission using encryption (such as SSL) where appropriate, access controls, and working with reputable service providers.

Please note that email is not a fully secure medium. We ask that you do not send us sensitive information by email. Where you enter payment or banking details in the course of any transaction, these are handled by the relevant secure payment or banking provider, and we do not store your full card details.

No method of transmission or storage is completely secure. While we work hard to protect your information, we cannot guarantee absolute security, and you share information with us at your own risk to that extent.

We keep your personal information only for as long as we need it for the purposes set out in this Privacy Policy, or for as long as the law requires or permits.

In practice, this means we keep application and contact information for as long as needed to assess and act on your application and to maintain our relationship with you, and for a reasonable period afterwards. We may keep some information for longer where we need it to comply with legal, tax, audit or regulatory obligations, to resolve disputes, or to enforce our agreements. When we no longer need your personal information, we securely delete or anonymise it.

Subject to the conditions and exceptions in the law, you have the right to:

• ask what personal information we hold about you, and request access to it;
• ask us to correct or update personal information that is inaccurate, out of date, or incomplete;
• ask us to delete or destroy personal information where we no longer have a lawful basis to keep it;
• object, on reasonable grounds, to our processing of your personal information;
• object at any time to your personal information being used for direct marketing;
• withdraw consent that you have given, where our processing relies on consent; and
• lodge a complaint with the Information Regulator.

Where the GDPR or UK GDPR applies to you, you may also have the right to restrict processing, and the right to data portability.

To exercise any of your rights, please contact us at info@realestateservices.co.za. We may need to verify your identity before we act on your request, and we will respond within the time the law allows.

Formal requests for access to information may be made under the Promotion of Access to Information Act 2 of 2000 (PAIA). Our PAIA manual, where required, sets out how to make such a request and is available on request from our Information Officer.

We may send you marketing communications about Real Estate Services where you have consented, or where the law otherwise permits it. Every marketing message we send includes a simple way to unsubscribe.

You can opt out of marketing at any time by using the unsubscribe link in any marketing email, by adjusting your preferences, or by emailing us at info@realestateservices.co.za. Even if you opt out of marketing, we may still send you communications that relate to your application or to a service you have asked for.

The Website is intended for adults, and in particular for property practitioners and prospective property practitioners. It is not directed at children, and we do not knowingly collect personal information from anyone under 18.

If you believe that we hold personal information about a child, please contact us at info@realestateservices.co.za and we will take appropriate steps to delete it.

If you have a concern about how we handle your personal information, please contact us first at info@realestateservices.co.za, so that we can try to resolve it.

You also have the right to lodge a complaint with the Information Regulator (South Africa):

• Website: https://inforegulator.org.za
• Email for POPIA complaints: POPIAComplaints@inforegulator.org.za
• General enquiries: enquiries@inforegulator.org.za

The Website may contain links to, or make use of, third-party websites and services. This Privacy Policy applies only to information we collect through our own Website.

We are not responsible for the privacy practices or the content of any third-party website or service. We encourage you to read the privacy policy of any website or service you visit or use through a link from ours.

You play an important role in protecting your own information. Please keep any username and password confidential, make sure the information you give us is accurate and up to date, and take reasonable care with the device and connection you use to access the Website.

We may update this Privacy Policy from time to time to reflect changes to our practices, our services, or the law. The current version is always the one published on this page, and the date it was last updated is shown on the page.

Where changes are significant, we may also bring them to your attention by email or through a notice on the Website. Please check this page from time to time.

If you have any questions about this Privacy Policy, or you wish to exercise any of your rights, please contact our Information Officer:

• Information Officer: Giovanni Gaggia
• Real Estate Services (RES SA Holdings (Pty) Ltd)
• Email: info@realestateservices.co.za

This Privacy Policy should be read together with our other policies:

• Terms of Service
• Privacy Policy
• Disclaimer
• Estate Agent Terms of Service