1 INTRODUCTION

1.1 ID-Scan collects, uses and, in some circumstances, shares the personal information of Users in the provision of services to you.

1.2 ID-Scan respects the rights of Users whose personal information is collected,used and stored by ID-Scan, including their right to protection against the unlawful collection, retention, sharing and use of such personal information.

1.3 The purpose of this Privacy Policy is to provide Users with information about the information processing activities of ID-Scan and the manner in which their rights are protected.

1.4 This Privacy Policy shall serve as a blanket notification to Users about ID-Scan’s processing activities which will remain valid for as long you either utilises the services of ID-Scan or ID-Scan renders any services to you.

1.5 Users will not be notified separately on each occasion that ID-Scan processes the same personal information in the same way over the period.

1.6 ID-Scan may amend the provisions of this Privacy Policy to comply with any changes in the law, and/or pursuant to any changes to its information processing activities or privacy practices.

1.7 This privacy policy, and the interpretation and enforcement thereof, will be governed by the laws of the Republic of South Africa.

1.8 The provisions of this Privacy Policy will be included as an annexure into all agreements between ID-Scan and the Users.

2 DEFINITIONS AND INTERPRETATION

2.1 In this Privacy Policy, the following words bear the following meanings:

2.1.1 ‘’consent’’ means any voluntary, specific and informed expression of will in terms of which permission is given by or on behalf of a User for the processing of their personal information;

2.1.2 ‘‘direct marketing’’ means to approach a data subject, either in person or by mail or electronic communication, for the direct or indirect purpose of promoting or offering to supply any goods or services to the data subject; ID SCAN (PROPRIETARY) LIMITED – PRIVACY POLICY 7 September 2022.docx

2.1.3 ‘’information officer’’ means the person on site responsible for the Information technology;

2.1.4 ‘‘operator’’ means an outside third party who processes personal information for or on behalf of ID-Scan terms of a contract or mandate; 2.1.5 ‘’personal information’’ means any information linked to a User or information that can identify a User, including but not limited to: 2.1.5.1 information relating to a User’s gender, nationality, ethnic or social origin age, language; 2.1.5.2 a User’s e-mail address, physical address, telephone number, location information or online identifier;

2.1.5.3 a User’s financial information including banking details and invoice information;

2.1.5.4 a User’s personal opinions, views or preferences;

2.1.5.5 correspondence sent by a User which is of a private or confidential nature; and

2.1.5.6 the User’s name if it appears with other personal information relating to that User, or if the disclosure of their name on its own would reveal further personal information about that User;

2.1.6 ‘’POPI’’ means the Protection of Personal Information Act of 2013, including any regulations or codes of conduct promulgated under it;

2.1.7 ‘’PAIA’’ means the Promotion of Access to Information Act 2 of 2000;

2.1.8 ‘’process or processing’’ means, in relation to personal information, any operation or activity or any set of operations, whether or not by automatic means, including:

2.1.8.1 the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use of that information; 2.1.8.2 dissemination by means of transmission, distribution or making available in any other form; or

2.1.8.3 merging, linking, as well as restriction, degradation, erasure or destruction of ID SCAN (PROPRIETARY) LIMITED – PRIVACY POLICY 7 September 2022.docx that information; and

2.1.9 ‘’User’’ means any customer, client, service provider of ID-Scan.

2.1.10 Any reference in this Privacy Policy to: 2.1.10.1 the singular includes the plural and vice versa;

2.1.10.2 any one gender includes the other genders, as the case may be;

2.1.10.3 an act, regulation or other law is to the version of that law in force at the effective date of this Policy and includes any amendment or re-enactment made to that law after the effective date of this Policy.

2.2 When calculating any number of days for the purposes of this Policy, the first day must be excluded and the last day of the relevant interval included, unless the last day is not a business day, then the last day will be the next succeeding business day.

2.3 The word “include” means “include without limitation”. Use of the word ‘’include’’ or “in particular” is for illustration or emphasis only and where followed by specific examples must not be interpreted as limiting the meaning of the general wording preceding it.

2.4 A requirement that any Policy, request, demand or other communication made in terms of this Privacy Policy must be in writing will be met if it is in the form of a data message as defined in the Electronic Communications and Transactions Act, No. 25 of 2002, and is accessible in a manner usable for subsequent reference, provided that this policy may not be amended as such

3 RESPONSIBLE PARTY

3.1 ID-Scan will be the party who will be collecting and processing a User’s personal information and as such is designated as the ‘’responsible party’’ for the purposes of this Policy.

3.2 ID-Scan‘s contact details are as follows:

Contact Person Albert Loubser

Mobile Number +27 82 562 2188

Email Address albert@idscan.co.za

Physical Address 3rd Floor, Misa Park Building, 15 Catherine Avenue, Northcliff, Randburg, 2194

3.3 ID SCAN (PROPRIETARY) LIMITED – PRIVACY POLICY 7 September 2022.docx 3.3 ID-Scan may either itself or instruct third party operators from time to time to undertake certain processing activities relating to the User’s personal information.

4 WHAT PERSONAL INFORMATION IS COLLECTED

4.1 ID-Scan may collect the following personal information from a User:

4.1.1 In the event of a juristic entity, registered name and registration number (if applicable);

4.1.2 In the event of an individual – initials, first name, surname, date of birth, identity number or passport number;

4.1.3 Preferred language;

4.1.4 Nationality;

4.1.5 Billing information;

4.1.6 Address;

4.1.7 Home and office telephone numbers;

4.1.8 Mobile numbers;

4.1.9 Email addresses.

4.2 The supply of personal information by the User to ID-Scan is voluntary and not mandatory. However, if the User refuses to supply any personal information, certain consequences may naturally flow from such a refusal, such as preventing ID-Scan from concluding or performing any contract with the User, or preventing ID-Scan from complying with one or more of its obligations in law.

4.3 There is no applicable law which directly requires or authorises ID-Scan to collect a User’s personal information.

5 PURPOSE FOR COLLECTION AND PROCESSING OF PERSONAL INFORMATION

5.1 ID-Scan shall only collect a User’s personal information for a specific, explicitly defined and lawful purpose relating to a function or activity of ID-Scan’s business.

5.2 Such purposes may include the following: ID SCAN (PROPRIETARY) LIMITED – PRIVACY POLICY 7 September 2022.docx

5.2.1 to enter into a contract with a User;

5.2.2 to perform any obligations under a contract with a User;

5.2.3 to comply with a legal obligation;

5.2.4 to protect a legitimate interest of a User (unless the User has specifically objected in writing to all or some of the processing activities on reasonable grounds);

5.2.5 to pursue its own legitimate interests or the legitimate interests of a third party who it is sharing the information with (unless the User has specifically objected in writing to all or some of the processing activities on reasonable grounds);

5.2.6 to process personal information for direct marketing purposes (only if the User has opted in to receiving any direct marketing material);

5.2.7 to present content to the User in the most effective way for them and their viewing device and browser;

5.2.8 to customise and display content including, but not limited to products, articles, listings and advertisement to the User in a way that ID-Scan feels may interest the User or be most beneficial to them;

5.2.9 to send content including, but not limited to products, articles, listings and advertisement content to the User via email or other electronic media, where the User has consented to be contacted by ID-Scan with such content;

5.2.10 to enable the User to voluntarily participate in interactive features of ID-Scan; and

5.2.11 to notify the User about changes to its service offerings.

5.3 If ID-Scan intends to process a User’s personal information for any other purpose not listed in clause 5.2 or which is otherwise not automatically permitted by law, it shall ensure that it obtains the User’s written consent to do so.

5.4 ID-Scan will not sell a User’s personal information to any third party.

6 COLLECTION DIRECTLY FROM USER

6.1 ID-Scan shall, as far as possible, always collect personal information about a User directly from the User, except in the following circumstances: ID SCAN (PROPRIETARY) LIMITED – PRIVACY POLICY 7 September 2022.docx

6.1.1 Where personal information is collected from a public record, or from another source if the information has already been made public by the User;

6.1.2 where the User has given their written consent to ID-Scan to collect their information from another source;

6.1.3 where the collection of a User’s personal information from another source will not prejudice any of the User’s legitimate interests;

6.1.4 where the collection of personal information from another source is necessary to maintain ID-Scan’s legitimate interests or those of any third party it intends sharing the information with;

6.1.5 where the collection of personal information directly from the User would prejudice the purpose for the collection; 6.1.6 where the collection of personal information directly from the User is not reasonably practicable in the circumstances.

6.2 If ID-Scan collects personal information from a source other than the User, it shall record in writing the details of that source, including the full names and contact details of that source where applicable.

6.3 The User hereby consents to ID-Scan requesting and obtaining credit information pertaining to the User from any reputable credit reporting agency or institution for the purpose of concluding any transaction for the sale of goods or services to the User.

6.4 Personal information may be collected from or supplied by the User in any of the following ways:

6.4.1 requesting services or information from ID-Scan; or

6.4.2 when contacting ID-Scan for any other reason.

7 GENERAL CONDITIONS FOR PROCESSING PERSONAL INFORMATION

7.1 ID-Scan shall comply with all laws, contracts or regulations when it processes a User’s personal information.

7.2 ID-Scan shall not act unreasonably when processing a User’s personal information. This means that it will collect and process a User’s personal information in a way that the User can reasonably expect and in a way that is fair. ID SCAN (PROPRIETARY) LIMITED – PRIVACY POLICY 7 September 2022.docx

7.3 ID-Scan shall respect the User’s right to privacy at all times. If there is another way in which it can achieve the same goal without posing any risk of harm to the privacy rights of the User, then it will choose that option.

7.4 Similarly, if ID-Scan needs to process personal information but there are less privacy-invasive methods of collecting, using and sharing that information, then it will use those methods.

7.5 ID-Scan shall ensure that the personal information that is collected and processed as is and remains relevant to the identified purpose/s for such processing, and that such information is and remains adequate, but not excessive, for achieving the identified purpose/s.

7.6 If there are any alternative ways to achieve the identified purpose/s without processing personal information, ID-Scan shall not process that personal information.

7.7 ID-Scan shall ensure that the processing activities it chooses to apply are proportionate to achieving the identified purpose/s and that no less privacy invasive measures are available to achieve the same purpose/s.

7.8 ID-Scan shall ensure that, regardless of the stated purpose/s for processing personal information, the rights and interests of Users will not be unnecessarily prejudiced or infringed, unless it cannot be avoided, and then in such cases, it shall ensure that its own rights and/or interests justify such prejudice or infringement taking place.

7.9 Once ID-Scan has achieved the purpose for the collection of the User’s personal information, it will destroy or delete such information, unless the User has directed otherwise in writing, or ID-Scan is required by law to retain the information for a longer period of time.

7.10 If ID-Scan no longer needs to process personal information to achieve the purpose originally specified, it will stop using that information.

8 DISCLOSURE AND SHARING OF PERSONAL INFORMATION

8.1 ID-Scan may, for the purposes of concluding or performing any sale or other transaction with a User, share certain personal information with third party operators who perform certain processing activities on behalf of ID-Scan and the User. ID SCAN (PROPRIETARY) LIMITED – PRIVACY POLICY 7 September 2022.docx

8.2 Other than as stated in clause

8.1 ID-Scan shall not share a User’s personal information with any third parties unless it has the User’s express consent to do so

9 USER’S RIGHTS IN RELATION TO THE PROCESSING OF THEIR PERSONAL INFORMATION

9.1 Users shall have the following rights in relation to the processing of their personal information:

9.1.1 to access and correct any personal information held by ID-Scan about them;

9.1.2 to object to the processing of their information; and

9.1.3 to lodge a complaint with the Information Regulator.

9.2 Users may make a request in terms of clause

9.1.1 by following the process for making such a request as set out in ID-Scan’s PAIA manual. 10 FURTHER PROCESSING

10.1 ID-Scan shall not process a User’s personal information for any purpose not previously specified except in the following circumstances:

10.1.1 where the User has consented to such further processing;

10.1.2 where the further processing is necessary for the exercise of any contractual rights or the fulfilment of any obligations between ID-Scan and the User;

10.1.3 where the further processing activities are linked to or compatible with the original purpose;

10.1.4 where the further processing is necessary for the prevention, detection, investigation, prosecution and punishment of an offence;

10.1.5 where the further processing is necessary to enforce any law;

10.1.6 where the further processing is necessary for the conduct of legal proceedings in any court or tribunal that have commenced or are reasonably contemplated;

10.1.7 where the further processing is necessary to prevent or mitigate a serious and imminent threat to the life or health of the User or another individual;

10.1.8 where the further processing is necessary for historical, statistical or research purposes. ID SCAN (PROPRIETARY) LIMITED – PRIVACY POLICY 7 September 2022.docx

10.2 ID-Scan shall ensure that if it intends processing personal information for other purposes not previously specified, it shall notify the User of such further purposes and the possible consequences of the intended further processing for the User.

11 ACCURACY, CORRECTNESS AND COMPLETENESS OF PERSONAL INFORMATION

11.1 ID-Scan shall take reasonably practicable steps to ensure that the personal information kept by it about Users is complete, accurate, not misleading and is updated when necessary.

11.2 However, if a User is aware of any personal information in ID-Scan’s custody that is incorrect, inaccurate or which needs to be updated, the User must make a written request to ID-Scan’s information officer at info@idscan.co.za.

11.3 If a User has contested the accuracy of any personal information being used by ID-Scan, it shall immediately stop using that information until its accuracy has been verified.

11.4 ID-Scan reserves its right to only adhere to a request from a User in terms of clause 11.2 if the correction or updating of that information will result in the personal information being correct and accurate.

11.5 Where personal information that has been shared by ID-Scan with a third party is subsequently updated or corrected, ID-Scan shall ensure that all third parties, with whom that information was shared, receives the updated and/or corrected version of the information as soon as it has been updated and/or corrected.

12 SECURITY SAFEGUARDS

12.1 ID-Scan is committed to protecting the personal information in its custody against any loss of, damage to or unauthorised destruction of that information, and to prevent any unauthorised parties from accessing that information.

12.2 ID-Scan takes steps to continually identify and document any risks to the personal information it has in its possession or under its control and that appropriate security safeguards are in place against those risks.

12.3 ID-Scan shall ensure that in any contracts entered into with third party operators who process personal information on ID-Scan’s behalf, include the following obligations: ID SCAN (PROPRIETARY) LIMITED – PRIVACY POLICY 7 September 2022.docx

12.3.1 the operator shall not process any personal information without ID-Scan’s knowledge and authority;

12.3.2 the operator shall treat all personal information given to it as confidential and shall not disclose it to any unauthorised third parties;

12.3.3 the operator shall establish and maintain adequate security measures which are the same or offer similar protection over the personal information as that employed by ID-Scan;

12.3.4 the operator shall notify ID-Scan immediately where there are reasonable grounds to believe that any personal information has been leaked to or accessed by any unauthorised person;

12.3.5 if the operator is situated in another country, it must comply with the data protection laws in that country and be able to provide verification that it is so compliant;

12.3.6 if an operator is legally obliged to disclose any personal information processed by them on ID-Scan’s behalf to other parties, it must notify ID-Scan beforehand to enable ID-Scan and individual Users to protect their rights if necessary.

12.4 ID-Scan shall ensure that all personal information on its systems is properly backed-up and that back-up copies are stored separately from the live files. 13 NOTIFICATION OF BREACH OF SECURITY

13.1 If personal information about a User is inadvertently leaked or ID-Scan’s security has been unlawfully breached by any unauthorised party, ID-Scan shall immediately identify the relevant Users who may be affected by the security breach, and shall contact them at their last known email address or contact details or by the quickest means possible.

13.2 ID-Scan shall provide sufficient information to the User to allow him or her to take the necessary protective measures against the potential consequences of the compromise or shall advise Users of the steps to be taken by them and the possible consequences that may ensue from the breach for them.

14 DECISIONS BASED ON PERSONAL INFORMATION PROCESSED

14.1 ID-Scan is required to make a decision about a User using any personal information that has been obtained, it shall ensure that a record of such information ID SCAN (PROPRIETARY) LIMITED – PRIVACY POLICY 7 September 2022.docx and the decision made is kept for a reasonable period of time to give the User an opportunity to request access to that record.

14.2 ID-Scan shall allow a User a reasonable opportunity to make representations before any decision is made solely on the basis of the personal information processed, if that decision will affect the legal position of the User or will otherwise adversely affect them in some manner or form.

14.3 ID-Scan shall always ensure that the underlying logic behind any decision made pursuant to the automated processing of personal information is sound and that this underlying logic can be communicated to the User to enable them to make representations.

14.4 If ID-Scan has made a decision based on incorrect personal information, it shall immediately revisit that decision as soon as it receive notice or becomes aware of the error or inaccuracy of that information.

15 DIRECT MARKETING

15.1 The User hereby consents to the processing of their personal information for the purpose of direct marketing by ID-Scan by means of electronic communications including automatic calling machines, SMS’s or electronic mail.

15.2 ID-Scan will only send electronic communications to the User for the purpose of marketing similar products or services offered by ID-Scan with the User’s consent.

15.3 The User may object, free of charge, and without unnecessary formality, to the use of their details either when the information was first collected from them or when each subsequent electronic communication is sent to them by ID-Scan.

15.4 The User can opt out of receiving further marketing communications by contacting ID-Scan at admin@idscan.co.za.

16 CHILDREN’S PERSONAL INFORMATION

16.1 ID-Scan processes personal information relating to persons under the age of 18 years. However, this is only done with the express consent from that person’s parent or legal guardian.

16.2 If a User being the parent or guardian of a child under the age of 18 years engage the services of ID-Scan and during this engagement discloses personal information pertaining to that child is being provided by the parent or guardian, then they ID SCAN (PROPRIETARY) LIMITED – PRIVACY POLICY 7 September 2022.docx hereby expressly consent to ID-Scan processing such information according to the further provisions of this Privacy Policy.

17 CROSS BORDER TRANSFERS OF PERSONAL INFORMATION

17.1 ID-Scan may transfer personal information to another country in the following circumstances:

17.1.1 the transfer is necessary for the performance of a contract that ID-Scan has with the User;

17.1.2 the transfer is necessary for the conclusion or performance of a contract with a third party which is for the benefit of or in the interest of the User;

17.1.3 the transfer is otherwise for the benefit of the User; or

17.1.4 the User has consented to the transfer of their information.

17.2 If ID-Scan is required to transfer personal information from South Africa to a third party in a foreign country, it shall ensure that the third party is subject to a law, binding code of conduct or contract which effectively upholds principles for the reasonable processing of personal information which are substantially similar to the data protection offered in the Republic of South Africa.

18 RETENTION OF INFORMATION

18.1 ID-Scan will keep a record of any personal information collected for no longer than is necessary to achieve the specific purpose for which it collected such information in the first place unless:

18.1.1 It is required by law to keep a record of such information for a longer period of time; or

18.1.2 It needs to keep a record of such information for another lawful purpose; or

18.1.3 It has a contractual obligation to keep record of such information; or

18.1.4 The User has consented to their information being kept for a longer period.

18.2 ID-Scan may, if it has de-identified personal information, kept such information for historical, statistical or research purposes.

18.3 ID-Scan shall ensure that appropriate safeguards are in place to prevent those records from being used for any other purposes, or against the information being ID SCAN (PROPRIETARY) LIMITED – PRIVACY POLICY 7 September 2022.docx re-identified.

19 RETURNING, DESTROYING OR DELETING PERSONAL INFORMATION

19.1 Where ID-Scan is no longer authorized to retain a record of any personal information, it shall either:

19.1.1 ensure that the information is permanently destroyed or deleted as soon as reasonably practicable; or

19.1.2 return the information to the User or transfer it to a third party, if requested by the User in writing to do so.

20 CONSENT

20.1 The User hereby consents to the processing of their personal information in terms of the provisions of this Privacy Policy.

20.2 The User acknowledges and agrees that such consent has been given voluntarily after the User has read and understood the provisions of this Privacy Policy, in particular, regarding the following:

20.2.1 the types of personal information to be processed;

20.2.2 the specific processing activities to be undertaken;

20.2.3 the specific purpose/s for such processing; and

20.2.4 the possible consequences for the User that may arise from such processing.

20.3 Should a User wish to withdraw any consent previously given by the User, they must notify ID-Scan’s information officer in writing.

21 LODGING AN OBJECTION

21.1 A User may, on reasonable grounds, object to the processing of their personal information at any time after that processing has started.

21.2 If a User wishes to object to the processing of their personal information, they must send written Policy of their objection to ID-Scan’s information officer, together with their reasons for doing so. ID SCAN (PROPRIETARY) LIMITED – PRIVACY POLICY 7 September 2022.docx

22 CHOICE OF LAW

22.1 This Privacy Policy shall be governed and interpreted in accordance with the laws of the Republic of South Africa.

23 AMENDMENT OF THIS PRIVACY POLICY

23.1 ID-Scan reserves the right to change, update, add, remove and/or amend any of the provisions of this Privacy Policy from time to time.

23.2 Such changes, updates, additions, removals or amendments will become effective from the date of their publication on this website.

23.3 It is the User’s obligation to periodically check the provisions of this Privacy Policy for any such changes, updates, additions, removals or amendments.

23.4 The User’s continued use of this website following any changes, updates, additions, removals or amendments to this Privacy Policy will be considered Policy of the User’s acceptance to abide by and be bound by this Privacy Policy, as amended.

24 CONTACT

24.1 For more information on your rights to privacy over your information, or the information processing activities of ID-Scan, please do not hesitate to contact us directly at admin@idscan.co.za. Last updated on 7 September 2022.