Gmaven Website Privacy Policy

This is the site-wide policy for the Gmaven website (gmaven.com) and blog (blog.gmaven.com), and the enquiry and contact forms on them. It is not the policy for any Gmaven app (each of those has its own), and it does not replace the specific terms of the CRE software or Data services, which are governed by their own agreements. Please read it with our Website Terms of Use and Cookie Policy.

1. Who we are

This website 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 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 in connection with our website and blog, the enquiry and contact forms on them, and our products at a high level.

Some things are governed by their own documents, not this policy: our CRE software and Data services are provided under separate agreements with our customers; each of our Gmaven apps has its own privacy policy; and our blog runs on a third-party platform that sets its own cookies (see our Cookie Policy).

3. Information we collect

• When you visit the website or blog: technical and usage information collected automatically, such as your IP address, device and browser type, the pages you view, and the dates and times of your visits. This is collected through server logs and cookies or similar technologies (see our Cookie Policy).
• When you contact us or submit an enquiry form: your name, your business, your contact details (such as email address and telephone number), and the content of your message or enquiry.
• When you subscribe to a newsletter or updates, if offered: your email address.
• When you sign in to the CRE software: account and usage information, handled under the CRE software agreement; this policy covers only the marketing website and blog.

We do not seek special personal information through the website, and we ask that you do not send it to us through the website's forms.

Information about others: if you give us personal information about another person, you confirm that you are entitled to do so and that they are aware of how it will be used.

4. Why we collect it (purpose)

• To respond to your enquiry and to provide the information, products, or services you ask about.
• To operate, secure, maintain, and improve the website and blog.
• To send you updates or marketing that you have asked for or consented to.
• To meet our legal and regulatory obligations.

5. Our lawful basis

We process personal information on one or more of the bases POPIA allows: your consent; the performance of, or steps towards, a contract with you; our legitimate interests (such as responding to a business enquiry, securing the website, and marketing our services to businesses, balanced against your rights); and compliance with the law.

6. Personal information in our products and data services

Gmaven's business includes commercial-property data and software. In providing the Data services and the CRE software, we process information about properties, businesses, and the business contact details of decision-makers. Where that information identifies a person, we handle it as a responsible party or, where we process it on a customer's behalf, as an operator under POPIA, under the relevant customer agreement.

If you are a person whose business contact information we hold, you may contact our Information Officer to ask what we hold, to ask us to correct or delete it, or to object to its processing, and we will deal with your request in accordance with POPIA. The detailed terms for each engagement are set out in the relevant customer agreement.

7. Who we share it with

• Service providers (operators) who help us run the website and our business, such as hosting, website and blog platforms, analytics, email, and customer-relationship-management providers. They act on our instructions under agreements that require them to protect your information.
• Within the law: we may disclose personal information where the law requires it, or to protect our rights or the safety of others.
• Business transfer: 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

Some of our service providers may process your personal information outside South Africa. Where this happens, we take steps to ensure it receives a level of protection consistent with POPIA, relying on the grounds permitted by section 72 of POPIA (a recipient bound by adequate protection, your consent, or necessity for a contract or steps at your request).

9. How long we keep it

We keep personal information only as long as necessary for the purposes in this policy, and as any law requires. Enquiry and contact information is kept for as long as needed to deal with your enquiry and our relationship with you, and is then deleted or de-identified, unless a law requires us to keep it longer.

10. How we protect it

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

11. Your rights

Under POPIA you may ask what personal information we hold about you, ask us to correct or delete it, object to its processing, and withdraw any consent you have given. To exercise these rights, contact our Information Officer (section 1).

You may also complain to 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

Please raise any concern with us first, so we have a chance to resolve it.

12. Direct marketing

We send our own marketing only where the law allows, and where you have consented or not opted out, as applicable. Every marketing message will let you unsubscribe. Where our customers carry out their own outreach using their own data, that outreach is their responsibility as the responsible party for it.

13. Cookies

The website and blog use cookies and similar technologies. Please see our Cookie Policy for the detail and for how to control them.

14. Children

The website is intended for business audiences and is not directed at children. We do not knowingly collect children's personal information.

15. Changes

We may update this policy. The current version and its date appear at the top. Where changes are material, we will place a notice on the website.

16. Contact

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