1. INTRODUCTION

1.1 Jura Espresso SA (Pty) Ltd ("JURA, we, us, our") is sensitive to the personal nature of the information you provide to us.

1.2 This privacy policy ("this Policy") explains how we protect and use your Personal Information.

1.3 By providing us with your Personal Information, you –

1.3.1 Agree to this Policy and authorise us to process such information as set out herein; and

1.3.2 Authorise us, our Service Providers and other third parties to Process your Personal Information for the purposes stated in this Policy.

1.4 We will not use your Personal Information for any other purpose than that set out in this Policy and will endeavour to protect your Personal Information that is in our possession from unauthorised alteration, loss, disclosure or access.

1.5 Please note that we may review and update this Policy from time to time. The latest version of this Policy is available on request, alternatively may be downloaded from our Website.

1.6 This Policy applies to all external parties with whom we interact, including but not limited to individual clients / tenants, representatives of client organizations, visitors to our offices, and other users of our services ("you"). Defined terms used in this Policy are explained in Annexure A.

2. COLLECTION OF PERSONAL INFORMATION

2.1 We may collect or obtain Personal Information about you –

2.1.1 Directly from you;

2.1.2 In the course of our relationship with you;

2.1.3 When you make your personal information public;

2.1.4 When you visit and/or interact with our website or our social media platforms;

2.1.5 When you register to receive newsletters and updates from us or our Service Providers;

2.1.6 When you interact with any third-party content or advertising on our website; 

2.1.7 When you visit our offices;

2.1.8 In the course of rendering services to our clients as an Operator.

2.2 In addition to the above, we may create Personal Information about you such as records of your communications and interactions with us, including, but not limited to, your attendance at shareholders meetings, rallies, events, or at interviews in the course of applying for a job with us, subscription to our newsletters and other mailings and interactions with you during the course of our digital marketing campaigns etc.

3. CATEGORIES OF PERSONAL INFORMATION WE MAY PROCESS

We may process the following categories of Personal Information about you -

4. SENSITIVE PERSONAL INFORMATION

4.1 Where we need to Process your Sensitive Personal Information, we will do so in the ordinary course of our business, for a legitimate purpose, and in accordance with applicable law.

5. PURPOSES OF PROCESSING AND BASES FOR PROCESSING

5.1 We will Process your Personal Information in the ordinary course of the business of leasing out commercial and retail space to tenants. We will primarily use your Personal Information only for the purpose for which it was originally or primarily collected. We will use your Personal Information for a secondary purpose only if such purpose constitutes a legitimate interest and is closely related to the original or primary purpose for which the Personal Information was collected. We may subject your Personal Information to Processing during the course of various activities, including, without limitation, the following -

5.1.1 Operating and conducting our business;

5.1.2 Rendering services to our clients;

5.1.3 Analysis, evaluation, review and collation of information in order to determine potential issues and / or disputes, prepare memoranda, correspondence, reports, other documents and records (whether in electronic or any other medium whatsoever);

5.1.4 Compliance with applicable law and fraud prevention;

5.1.5 Transfer of information to our service providers and other third parties; and

5.1.6 Recruitment.

5.2 We may process your Personal Information for relationship management and marketing purposes in relation to our services (including, but not limited to, Processing that is necessary for the development and improvement of our products and services, for accounts management, and for marketing activities in order to establish, maintain and/or improve our relationship with you and with our Service Providers. We may also analyse your Personal Information for statistical purposes.

5.3 We may process your Personal Information for internal management and management reporting purposes, including but not limited to conducting internal audits, conducting internal investigations, implementing internal business controls, providing central processing facilities, for insurance purposes and for management reporting analysis.

5.4 We may Process your Personal Information for safety and security purposes.

6. DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES

6.1 We may disclose your Personal Information to our Associates and Service Providers, for legitimate business purposes, in accordance with applicable law and subject to applicable professional and regulatory requirements regarding confidentiality. In addition, we may disclose your Personal Information -

6.1.1 If required by law;

6.1.2 Legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;

6.1.3 Third party operators (including, but not limited to, data processors such as providers of data hosting services and document review technology and services), located anywhere in the world, subject to Clause 6.2;

6.1.4 To any relevant party for the purposes of the prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including, but not limited to, safeguarding against, and the prevention of threats to, public security; and 

6.1.5 To any relevant third-party acquirer(s), in the event that we sell or transfer all or any portion of our business or assets (including, but not limited to, in the event of a reorganization, dissolution or liquidation)

6.2 To any relevant third-party provider, where our website uses third party advertising, plugins or content. If we engage a third-party operator to process any of your personal information, we recognise that any Operator who is in a foreign country must be subject to a law, binding corporate rules or binding agreements which provide an adequate level of protection similar to POPIA. We will review our relationships with Operators we engage and, to the extent required by any applicable law if force, we will require such operators to be bound by contractual obligations to -

6.2.1 Only process such personal information in accordance with our prior written instructions; and

6.2.2 Use appropriate measures to protect the confidentiality and security of such personal information.

7. INTERNATIONAL TRANSFER OF PERSONAL INFORMATION

7.1 We may transfer your Personal Information to recipients outside of the Republic of South Africa.

7.2 Subject to Clause 6.2 above, Personal Information may be transferred outside of the Republic of South Africa provided that the country to which the data is transferred has adopted a law that provides for an adequate level of protection substantially similar to POPIA, the Operator/third party undertakes to protect the Personal Information in line with applicable data protection legislation and the transfer is necessary in order to provide the products and services that are required by our clients.

8. DATA SECURITY

8.1 We implement appropriate technical and organisational security measures to protect your Personal Information that is in our possession against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, in accordance with applicable law.

8.2 Where there are reasonable grounds to believe that your Personal Information that is in our possession has been accessed or acquired by any unauthorised person, we will notify the relevant regulator and you, unless a public body responsible for detection, prevention or investigation of offences or the relevant regulator informs us that notifying you will impede a criminal investigation.

8.3 Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Information that is in our possession, we cannot guarantee the security of any information transmitted using the internet and we cannot be held liable for any loss of privacy occurring during the course of such transmission.

9. DATA ACCURACY

9.1 The Personal Information provided to us should be accurate, complete and up-to-date. Should Personal Information change, the onus is on the provider of such data to notify us of the change and provide us with the accurate data.

10. DATA MINIMISATION

10.1 We will restrict its processing of Personal Information to data which is sufficient for the fulfilment of the primary purpose and applicable legitimate purpose for which it was collected.

11. DATA RETENTION

11.1 We will only retain and store Personal Information for the period for which the data is required to serve its primary purpose or a legitimate interest or for the period required to comply with an applicable legal requirement, whichever is longer.

12. Newsletter

JURA would like to contact you from time to time in order to introduce you to products and services that may be of interest to you and to inform you about news. You therefore have the option of subscribing to our newsletter via our website. For this we need your e-mail address and your declaration that you agree to receive the newsletter. In order to provide you with targeted information and to be able to address you personally, we also collect and process voluntarily provided information such as first and last name.

The legal basis for the processing of your data is the existence of your consent. To subscribe to our newsletters, we use a double opt-in procedure. This means that after providing your e-mail address, we will send you a message to the specified e-mail address, in which we ask you to confirm that you wish to receive the newsletter. The confirmation is made by clicking on the activation link contained in the message.

In addition, the date and time of registration are collected during registration. We process this personal data on the basis of our legitimate interest. We need them to send you the newsletter.

Of course, you have the option of unsubscribing from the newsletter at any time. In this case, click on the link «Unsubscribe newsletter» in the newsletter you receive. Successful opt-out is confirmed by viewing a web page. Or please send your revocation to the following e-mail address: info-za@jura.com.

We use Evalanche to send out our newsletter. Evalanche will not pass on the data described here to third parties. Evalanche is an analysis service of SC-Networks GmbH, Würmstraße 4, 82319 Starnberg. Evalanche uses "cookies", which are text files placed on your computer, to help the newsletter analyse how users use the newsletter. The information generated by the cookie about your use of the newsletter (including your IP address) is read out and sent to a server in Germany. 

The newsletter contains so-called tracking pixels. This is a thumbnail that lets us know if a newsletter has been opened by you or not. As part of this retrieval, technical information such as information about the browser and your system, the device used and the mail client as well as your IP address and time of retrieval are first collected. This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined with the help of the IP address) or the access times.
The statistical surveys also include determining whether the newsletters are opened, when they are opened, which links are clicked and whether the delivery of the e-mails was successful. In addition, the reading time is recorded, whereby this is only done on a target group basis.

For technical reasons, this information can be assigned to the individual newsletter recipients, but it is neither our effort nor that of SC Networks/Evalanche to observe individual users. Rather, the evaluations serve us to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users. In order to be able to send you newsletters tailored to your needs, explicit tracking consent is required. 

If you have consented to this, you agree that a personal user profile will be created on the basis of your data in order to better adapt websites and newsletters on products, services and market trends to your needs. This allows SC-Networks GmbH to provide you with information that corresponds to your specific interests. Furthermore, you agree that your personal usage behaviour on websites and in dealing with all e-mails of SC-Networks GmbH is recorded through the use of cookies and tracking technology. You can revoke your consent to the creation of a personal user profile at any time. Furthermore, you have the option of revoking your consent to tracking by using the tracking unsubscribe link in each newsletter.

13. YOUR LEGAL RIGHTS

12.1 You may have rights under the South African and other laws to have access to your Personal Information and to ask us to rectify, erase and restrict use of your Personal Information. 

12.2 You may also have rights to object to your Personal Information being used, to ask for the transfer of Personal Information you have made available to us and to withdraw consent to the use of your Personal Information.

14. COOKIES AND SIMILAR TECHNOLOGIES

13.1 We may Process your Personal Information by our use of Cookies and similar technologies.

13.2 When you visit our Website, we may place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits.

15. DIRECT MARKETING

14.1 We may Process your Personal Information for the purposes of providing you with information regarding products which may be of interest to you. You may unsubscribe for free at any time.

14.2 If you currently receive marketing information from us which you would prefer not to receive in the future, please email us at dataprivacy@jura.com