Gmaven Leasing App Privacy Policy

This is the privacy policy for the Gmaven commercial-property leasing app, which you access through a third-party AI assistant platform. It is specific to that app and is distinct from the site-wide Website Privacy Policy. Please read it with the Leasing App Terms of Service. You can see all our legal documents on the Legal page.

1. Who we are

This app is operated by Gmaven (Pty) Ltd ("Gmaven", "we", "us", "our"), a company incorporated in the Republic of South Africa, registration number 2013/104774/07:

• Physical address: Rockjumper House, 1 Doug Crowe Square, Garlington, Hilton, KwaZulu-Natal, South Africa
• Postal address: Rockjumper House, 1 Doug Crowe Square, Garlington, Hilton, KwaZulu-Natal, South Africa

We are the responsible party (the equivalent of a "data controller") for the personal information described in this policy.

For any privacy matter, contact our Information Officer at officer@gmaven.com or +27 (0) 10 142 1360.

We process personal information in accordance with the Protection of Personal Information Act, 2013 (POPIA).

2. What this policy covers

This policy explains how we handle personal information when you use the Gmaven leasing app to search for commercial property and, if you choose, to enquire about a property. The app is accessed through a third-party artificial-intelligence assistant platform. That platform has its own privacy policy that governs its own handling of your information, which is separate from this one.

A separate Gmaven app (a brochure-generation tool for property professionals) has its own, different privacy policy. This policy does not cover it.

3. What personal information we collect

We collect only what is needed to help you find commercial property and to connect you with the relevant property owner or broker.

• Search criteria you provide: for example area, size, rental range, and property type. On their own these are not personal information.
• At the enquiry step only, and only if you choose to proceed and give your consent:
  • your name;
  • your contact details, for example telephone number and email address; and
  • enquiry details, for example your intended move-in date, lease term, the business that will occupy the space, and basic suitability information such as the occupying entity and its general standing.

We do not ask for your identity number, your banking details, or any special personal information (such as information about your health, race, religion, or political views) through this app.

Information about others: if you give us personal information about another person, for example a colleague or the business that will occupy the space, you confirm that you are entitled to share it and that the person is aware of how it will be used.

4. How we collect it

We collect your search criteria as you describe your requirement to the AI assistant. We collect the personal information in section 3 only at the point where you ask to make an enquiry, and only after you have agreed to it being shared.

5. Why we collect it (purpose)

• To understand your space requirement and return relevant available properties.
• To pass your enquiry, with your consent, to the relevant property owner, fund, their nominated leasing contact, or a commercial property broker so they can respond to you.
• To improve the quality and accuracy of the service.

We will not use your personal information for any unrelated purpose without your consent. This reflects the POPIA principle of purpose limitation.

6. Our lawful basis for processing

We process your personal information on the basis of:

• your consent, given at the enquiry step; and
• the necessity of taking steps at your request before, and with a view to, a possible leasing enquiry being progressed.

You may withdraw your consent at any time (see section 11). If you do, we may no longer be able to facilitate your enquiry.

7. Who receives your information (recipients)

• The property owner, fund, their nominated leasing contact, or a commercial property broker for the property you enquire about, so that they can contact you. Once they receive your enquiry, that party becomes a separate responsible party for its own handling of your information, and its own privacy practices apply.
• Our service providers (operators) who host and operate the app and the platform behind it. These include the AI assistant platform through which you access the app, and our hosting and customer-relationship-management providers. They process your information on our behalf, under agreements that require them to keep it confidential and secure.

We may also disclose your personal information where the law requires it, or to protect our rights or the safety of others. If our business is sold or transferred, your information may transfer to the new owner, who will remain bound by protections consistent with this policy.

We do not sell your personal information.

8. Cross-border processing

Because the app runs through an international AI assistant platform and cloud hosting, your personal information may be processed outside South Africa. Where this happens, we take steps to ensure your information receives a level of protection that is consistent with POPIA, relying on one or more of the grounds permitted by section 72 of POPIA, namely that:

• the recipient is subject to binding agreements or rules that provide an adequate level of protection broadly similar to POPIA;
• you have consented to the transfer; and/or
• the transfer is necessary to take steps at your request before progressing your enquiry.

9. How long we keep it (retention)

• Search criteria (non-personal): retained, in aggregate and de-identified form, for service improvement. This is no longer personal information about you.
• Enquiry personal information: retained only as long as necessary to facilitate your enquiry and to deal with any follow-up, and in any event no longer than 12 months from your last contact with us about that enquiry, after which it is deleted or de-identified, unless a law requires us to keep it longer.

10. How we protect it (security)

We apply reasonable technical and organisational measures to protect your information, including access controls, encryption of information while it is in transit, and activity logging. No system is perfectly secure, but we take our obligations seriously and review our measures.

11. Your rights and choices

Under POPIA you have the right to:

• ask what personal information we hold about you;
• ask us to correct or delete it;
• object to our processing of it; and
• withdraw your consent at any time (which may mean we can no longer facilitate your enquiry).

To exercise any of these rights, contact our Information Officer (section 1).

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

• Physical address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
• Postal address: P.O. Box 31533, Braamfontein, Johannesburg, 2017
• Telephone: +27 (0) 10 023 5200
• General enquiries: enquiries@inforegulator.org.za
• Complaints: POPIAComplaints@inforegulator.org.za

We ask that you raise any concern with us first, so that we have the chance to resolve it.

12. Direct marketing

We do not use your personal information to send you our own direct marketing without your consent. Passing your enquiry to a property owner or broker so that they can respond to you is part of the service you asked for, not direct marketing by us.

13. Automated processing

The app uses an AI assistant to interpret your search and return relevant available properties. This is to help you find suitable space. It is informational. We do not make automated decisions that produce legal or similarly significant effects for you. The property owner or broker, not the app, decides how to respond to your enquiry.

14. Cookies and analytics

The app surface itself, as accessed through the AI assistant platform, does not set marketing cookies on your device. The Gmaven website on which this policy is published, and the AI assistant platform, may use their own cookies or similar technologies, governed by their own notices. See the Gmaven website Cookie Policy for the website's use of cookies.

15. Children

The app is suitable for a general audience and is not directed at children. It does not target children under 13, and we do not knowingly collect personal information from children. If you believe a child has provided us with personal information, contact our Information Officer and we will delete it.

16. Changes to this policy

We may update this policy. The current version and its date appear at the top. Where changes are material, we will notify you appropriately.

17. How to contact us

For any question about this policy or your personal information, contact our Information Officer at officer@gmaven.com or +27 (0) 10 142 1360.