Supplier and Customer Privacy Policy

It's our promise to suppliers and Customers that we respect the trust you place in us and the privacy of the information you share. Part of providing superior supplier and Customer service includes making sure that we're building a relationship of trust with our suppliers and Customers. Our way of doing that is to let you know in a clear, prominent, and easily accessible way how we collect, use, share, and above all protect your personal information. We will only collect personal information that is necessary for the purposes described in this policy and will only process personal information in compliance with
applicable laws, including the protection of Personal Information Act (POPIA) and in ways that are for, or compatible with, the business purposes for which the personal information was collected or that are subsequently authorised by you. Any reference to an individual may include a juristic person.
This Policy outlines:
• How and why we collect your personal information;
• How your personal information is used and protected;
• When and with whom we share your personal information; and
• What choices you can make about how we collect, use, and share your personal information.

Panners Investments takes steps to ensure that we manage your personal information properly to maintain your trust.
We may collect the following categories of personal information. Not all categories may be collected about every individual and this will depend on the purpose for which we need the personal information:
• Personal identifiers, such as name and address;
• Device and online identifiers and related information, such as telephone number and email address;
• Internet, application, and network activity, such as cookie IDs and browser visits;
• Government identifiers, such as CIPC registration numbers, national identification numbers and driver’s license numbers;
• Demographic information, such as age and date of birth;
• Financial information, such as annual financial statements, bank statements, credit and debit card numbers and claims information;
• Purchase history information, such as products you have bought, rented, and returned;
• Location information, such as geo-location information;
• Audio, visual, and other sensory information, such as audio and video recordings;
• Employment information, such as occupation, title, licenses and professional memberships; or
• Background and criminal information, such as background checks and criminal convictions.

Collection of Personal Information

We collect information from you in a variety of ways. It may be:
• Provided directly by you (supplier / customer);
• Through Facility Technology;
• Collected from another company within our family of companies; or
• Collected from an external third-party source.

Information Provided Directly by You (supplier / customer)
You share information with us in various ways, such as when you engage with our associates in the Accounts department or that manage your business relationship, complete the supplier / customer onboarding process, or use our supplier-facing websites or mobile applications.

Information We Collect Through Facility Technology
We may collect your personal information from technology we use in our facilities, such as our facility cameras. We operate cameras in warehouses for security and operational purposes.

Information We Collect From External Third-Party Sources
As part of our standard supplier / customer onboarding process, we may receive information from third party sources, such as business credit report and score to help us assess supplier fitness, reduce fraud and ensure an effective partnership with you our supplier / customer.

All personal information that is supplied to the Company must be accurate, up-to-date, not misleading and complete in all respects. You undertake to immediately advise the Company of any changes to your personal information should any of these details change.

Our goal is to limit the information we collect to the information needed to support our business.

Purpose for Collection of Personal Information

The information collected and processed by Panners Investments may be used for the following purposes:
• To create and maintain your account;
• To conduct auditing and monitoring of transactions and engagement;
• To update our operational and technical functionality;
• To conduct business analysis, such as analytics, projections and identifying areas for operational improvement;
• To conduct research and development; or
• To fulfill our legal functions or obligations.

All Personal Information which you provide to the Company will be used and/or retained only for the purposes for which it is collected, whereafter it will be permanently destroyed. We will only retain personal information for longer than the purpose for which it was collected if it is required by law or where you have given consent for us to retain such information for an extended period.

Sharing of Personal Information

All of the categories of personal information that we collect may be shared with other companies, including those within our corporate family, for a business purpose. We may share your personal information in limited circumstances, such as:
• To conduct our business;
• To maintain a business relationship;
• When legally required to do so; or
• With Customers or third parties that help with our business activities.

We may share your personal information in other special circumstances, which include situations when sharing is required by law, or we believe sharing will help to protect the safety, property, or rights of Panners Investments, our customers, our associates, or other persons.

Where we need to transfer your personal information outside the borders of South Africa, we will ensure that we only transfer the personal information to countries that have similar privacy laws to those applicable in South Africa or to a party who is contractually bound to comply with data protections obligations which impose no lesser legal requirements than those imposed by POPIA.

Before transferring personal information to a third-party contractor, the Company will obtain assurances from the third party that it will process personal information in a manner consistent with this policy. Where we learn that a third party contractor is using or disclosing personal information in a manner contrary to this policy, we will take reasonable steps to prevent such use or disclosure.

Websites and Mobile Applications

By using our websites, mobile applications, Wi-Fi and/ or by providing your information to us you expressly consent to our collection and use of the information you disclose to us in accordance with this policy, including but not limited to your consent for us to share your information as set out in this privacy policy. If you disclose any personal information relating to other people to us, you warrant that you have the authority to do so and to permit us to use the information in accordance with this policy.

By using our websites, mobile applications, Wi-Fi and/ or by providing your information to us, you agree to the practices described in this policy and you agree to Panners Investments, its directors, officers, employees, servants, agents and/or contractors and/or other third parties to process (which will include collecting, using and disclosing) your personal information for the purposes stated in this policy.

If you do not agree to this policy, please do not use our websites, mobile applications, Wi-Fi and/ or provide your information to us. Any use by you of our websites, mobile applications, Wi-Fi and/ or any provision by you of your information will be deemed to constitute your acceptance of the terms in this policy.

Security

The security and confidentiality of your personal information is important to us. We have implemented technical, administrative, and physical security measures to protect your personal information from unauthorised access or disclosure and improper use.

Access to your personal information is restricted to only to those employees who need the personal information to perform a specific job / task. All employees with access to Personal Information are kept up-to-date on our security and privacy practices. After a new policy is added, these employees are notified and/or reminded about the importance we place on privacy, and what they can do to enhance protection for our supplier and Customer’s personal information.

We are committed to ensuring that our security measures which protect your personal information are continuously reviewed and updated where necessary.

It is important for you to protect yourself against unauthorised access to your account password. Be sure to log out of your account or to close your browser after you have completed your visit to the website or mobile application.

Whilst we will do all things reasonably necessary to protect your personal information, we cannot guarantee nor do we accept any liability of whatsoever nature for any unauthorised or unlawful disclosure and/or use of your personal information, either by employees and/or made by any third parties (including third party Customers) who are not subject to our control, unless such disclosure and/or use is as a result of our gross negligence.

Your rights

Upon reasonable request and in accordance with POPIA, we will grant suppliers and Customers reasonable access to their personal information and will permit them to correct, amend or delete personal information that is incomplete or inaccurate.

Should you so request, we will provide you with the record or a description of the personal information which we have about you, including information about the identity of all third parties who have, or have had, access to the personal information: (i) within a reasonable time; (ii) at a prescribed fee, if any; (iii) in a reasonable manner and format; and (iv) in a form that is generally understandable.

We will take reasonable steps to ensure that all personal information is kept as accurate, complete and up-to-date as reasonably possible but may not always expressly request you to verify and update your personal information, unless this process is specifically necessary. We expect that you will notify us from time to time in writing of any updates required in respect of your personal information.

In addition, you may cancel or modify the email communications you have chosen to receive from us by following the instructions contained on our website. If you have any questions concerning your personal information or how to exercise these rights, please Contact Us at admin@rolux.co.za

You also have the right to lodge a complaint with the Information Regulator. You can email the Information Regulator with your complaint/query at inforeg@justice.gov.za or call them on
012 406 4818. Visit their website for more details: http://www.justice.gov.za/inforeg/contact.html.

The Company reserves the right to amend this policy at any time. All amendments to this policy will be posted on the website.

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