Policies & Guidelines

Privacy Policy:

Warshay Investments (Pty) Ltd (“KWV”)  and its affiliates provide this internet web site (“Web Site”). Your use of this Web Site is subject to the following terms and conditions that KWV may revise from time to time. By using this site, you signify your assent to these terms of use. If you do not agree to these terms of use, you may not use the Web Site.

Use of Proprietary Information on this Web Site
KWV maintains this Web Site for your personal information and education. You may download or print the Proprietary Information on this Web Site for your own non-commercial, educational, private or domestic use only, provided you do not delete or change any copyright, trademark, or other proprietary notices, or distort, mutilate or otherwise modify the Proprietary Information in a manner that may be prejudicial to KWV. You should assume that everything you see or read on the Web Site (such as images, brand presentations, photographs, illustrations, icons, texts, video clips, written and other Proprietary Information) is copyrighted and protected under treaty provisions and world-wide copyright laws, unless otherwise noted, and is KWV’s property (“KWV’s Proprietary Information”). You may not sell, reproduce, distribute, modify, display, publicly perform, prepare derivative works based on, report or otherwise use any KWV Proprietary Information in any way for any public or commercial purpose. Furthermore, you may not use or display KWV’s Proprietary Information on any other web site or in a networked computer environment for any purpose.
If you violate any of these terms, your permission to use KWV’s Proprietary Information will automatically terminate and you must immediately destroy any copies you have made of KWV’s Proprietary Information. Any unauthorised use of KWV’s Proprietary Information by you may violate copyright laws, trademark laws, the laws of privacy and publicity, and communications regulations and statutes.

Your Submissions or Communications
Any communication or material you transmit to the Web Site by electronic mail or otherwise, including, but not limited to, any data, questions or answers, comments, suggestions, or the like, will be treated as non-confidential and non-proprietary by KWV. By posting communications to the Web Site, you automatically grant KWV a royalty-free, perpetual, irrevocable non-exclusive licence to use, reproduce, modify, publish, edit, translate, distribute, perform, and display such communication(s) alone, or as a part of other works in any form, media, or technology whether now known of hereafter developed and to sublicense such rights to anyone. Anything you transmit or post may be used by KWV or licensed to others by KWV for any purpose, including but not limited to reproduction, disclosure, transmission, publication, broadcast and posting, or developing, manufacturing and marketing products using such information.

Privacy
KWV analyses aggregate and non-personally identifiable data relating to usage of this site. A geographical analysis of visitors and browsers to this site is made known to KWV. We may use your E-mail address submitted in connection with your messages or communications and other contact information which was submitted by you in order to communicate with you.

Disclaimer
The information on this site is intended for general information purposes only and is not intended to serve as financial or other advice. Whilst KWV tries to ensure that the information on this site is accurate and complete, KWV shall not be held responsible for any eventualities arising from the use of this information. Your use of the Web Site is at your own risk. KWV does not warrant or represent that KWV’s Proprietary Information is accurate, error-free, truthful or reliable or that your use of KWV’s Proprietary Information will not infringe rights of third parties. KWV does not warrant that the functional aspects of the Web Site will be error free or that this Web Site or the server that makes it available is free of viruses or other harmful components. If your use of this Web Site or KWV’s Proprietary Information results in the need for servicing or replacing property, material, equipment or data, KWV is not responsible for those costs. Without limiting the foregoing, everything on the Web Site is provided to you “AS IS” and “AS AVAILABLE”, WITHOUT WARRANTY OF ANY KIND, EITHER EXPRESSED OR IMPLIED, INCLUDING BUT NOT LIMITED TO IMPLIED WARRANTIES OF REASONABLE CARE AND SKILL, OR NON-INFRINGEMENT. KWV makes no warranties about the accuracy, reliability, completeness, or timeliness of the KWV Proprietary Information, software text, graphics, and links, or about results to be obtained from using the Web Site.

Trademark Notice
The trademarks, brands, logos and service marks that you see on this site are the property of KWV or its affiliates or are licensed to the KWV group of companies by third parties. Nothing contained on the Web Site should be construed as granting, by implication, estoppel, or otherwise, any licence or right to use any trademark displayed on this Web Site without the written permission of KWV or third party who owns the trademark. Your misuse of any trademark displayed on the Web Site, or any other content on the Web Site, except as provided herein, is strictly prohibited.

Copyright Notice
All contents of this Web Site are subject to copyright protection and reproduction of the content, or any part thereof, is prohibited without prior written consent from KWV. To apply for such consent, you may contact: prince@kwv.co.za.

Links
On this site you may be offered links to other sites operated by parties other than KWV. The inclusion of any link to such sites does not imply endorsement by KWV of the sites or the services or products offered on such sites. KWV has not reviewed all of the sites linked to this Web Site and is not responsible for the content or accuracy of any off-site pages or any other sites linked to this Web Site. Your linking to any other off-site pages or other sites is at your own risk.

You may not establish a link to this Web Site from a third party site, without prior written consent from KWV. To apply for such consent, you may contact: prince@kwv.co.za

Limitation of Liability
Under no circumstances whatsoever shall KWV be liable for any loss arising out of or in connection with the use of information available from this Web Site whether direct or indirect including, without limitation, any liability relating to any loss of use, interruption of business, lost profits or lost data, or incidental, special or consequential damages of any kind regardless of the form of action, whether in contract, tort (including negligence) or otherwise.

Enforceability
If any of the foregoing is not fully enforceable for any reason, the remainder shall nonetheless continue to apply.

Jurisdiction
These terms and conditions shall be governed by and construed in accordance with the laws of the Republic of South Africa without giving effect to any principles of conflict of law. You hereby consent to the exclusive jurisdiction of the High Court of South Africa in respect of any disputes arising in connection with your use of this Web Site, or these terms and conditions or any matter related to or in connection therewith.

General Provisions
Unless otherwise specified, the information and Proprietary Information in this site are presented solely for informational purposes. KWV makes no representation that KWV’s Proprietary Information is appropriate or available for use in every country of the world. You use this Web Site at your own risk and are responsible for compliance with applicable local laws, keeping in mind that access to KWV’s Proprietary Information may not be legal by certain persons or in certain countries. Any cause of action you may have with respect to this Web Site must be commenced within three years after the claim or cause of action arises or such claim or cause of action is barred. The waiver by KWV of a breach of any provision of this Agreement will not be interpreted as a waiver of any other or subsequent breach.
KWV does not enter into contracts via e-mail, nor verbally and personnel are not authorized to do so. KWV contracts must be paper-based versions signed in person by someone duely authorised by KWV Ltd’s Board to do so.

PAIA

1. PURPOSE
Section 51 of the Promotion of Access to Information Act No.2 of 2000, (“the Act”), as amended by the Protection of Personal Information Act no. 4 of 2013 (“POPIA”) requires that Warshay Investments (Pty) Ltd t/a KWV and its subsidiaries, hereafter referred to “KWV”, as a private body must compile a manual giving information to the public regarding the procedure to be followed in requesting information from KWV for the purpose of exercising or protecting rights in accordance with data protection constraints.

2. SCOPE

2.1 KWV specialises in the manufacturing and trading of alcohol products.
2.2 This manual documents the categories of information held by KWV and aims to assist potential requestors in requesting access to information from KWV as contemplated under the Act.
2.3 The following words or expressions bear the following meanings in this manual:
2.3.1 “the Act” means the Promotion of Access to Information Act No.2 of 2000, together with the regulations and rules published in terms of this Act;
2.3.2 “Manual” means this manual together with its annexures, as amended from time to time, made available at the offices of KWV;
2.3.3 “SAHRC” means the South African Human Rights Commission.

2.4 Company Details

Warshay Investments (Pty) Ltd t/a KWV and its subsidiaries
Registration Number: 2021/018 792/07
Registered Address: 57 Main Road, Southern Paarl, Paarl, 7646
Street Address: 57 Main Road, Southern Paarl, Paarl, 7646
Postal Address: 57 Main Road, Southern Paarl, Paarl, 7646
Tel: 021 807 3911
Information Officer: Daniël Smit
Email: popiainfo@kwv.co.za
Website: https://www.kwv.co.za

3. REFERENCES
None

4. ABBREVIATIONS AND DEFINITIONS
None

5. RESPONSIBILITY

Roles and responsibilities

All personal Information must have an owner including what information should be collected, and how it should be used, managed and secured.
The information owner must ensure that the information is secured according to its sensitivity and that access rights and provisions are in place for the information

6. STEPS

6.1 A guide on how to use the Act has been compiled by the SAHRC in terms of section 10 of the Act and can be viewed on the SAHRC website and the website of the Information Regulator. (The transfer of functions of the Act from the South African Human Rights Commission to the Information Regulator effective from 30 June 2021.)
6.2 Any queries should be directed to:
6.2.1 The South African Human Rights Commission:
6.2.2 PAIA Unit
6.2.3 The Research and Documentation Department
6.2.4 Physical address: Braampark Forum 3, 33 Hoofd Street, Braamfontein, South Africa
6.2.5 Postal Address: Private Bag X2700, Houghton, 2041, Johannesburg, South Africa Telephone: +27 (0)11 877 3600
6.2.6 Fax: +27 (0)11 403 0668
6.2.7 Website: https://www.sahrc.org.za/index.php/understanding-paia
6.2.8 Email: info@sahrc.org.za

6.3 The Information Regulator (South Africa)

JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
P.O Box 31533, Braamfontein, Johannesburg, 2017
Website: https://www.justice.gov.za/inforeg/index.html
Email: inforeg@justic.gov.za

6.4 Availability of Manuals

6.4.1 This manual is available for inspection by the general public upon request, during office hours and free of charge, at the offices of KWV.
6.4.2 Copies of the manual may be made, subject to the prescribed fees, and
  6.4.2.1 May be requested from the South African Human Rights Commission (“SAHRC”);
  6.4.2.2 May be made available to the Information Regulator upon request.
6.4.3 The manual is also posted on KWV’s website at https://www.kwv.co.za/

6.5 The Processing of Personal Information

6.5.1 KWV collects information from our business or our website which information may be personal information and which information is protected under the Protection of Personal Information Act (POPIA).
6.5.2 KWV collects personal information where it has obtained the consent of the person to whom the information belongs and where:
  6.5.2.1 Processing complies with an obligation imposed by law on KWV;
  6.5.2.2 KWV has a legitimate requirement to use or process such information; or
  6.5.2.3 KWV meets its responsibilities to customers, employees and other natural or juristic persons.

6.6 KWV may disclose personal information lawfully to:
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6.6.1 Any regulatory authority and the regulators they appoint;
6.6.2 Comply with any regulation passed under the relevant legislation, or any legal process;
6.6.3 Protect and defend KWV’s rights and property (including its intellectual property);
6.6.4 Protect public interest;
6.6.5 Legal advisors or similar service providers with the appropriate undertakings to protect the information; or
6.6.6 Group companies and subsidiaries.

6.7 KWV may supply employee personal information to:

6.7.1 Pension/provident fund and/or their trustees;
6.7.2 Medical Aid funds/medical Insurances;
6.7.3 Recruitment companies; or
6.7.4 Credit Bureaus.
6.7.5 Government institutions
6.7.6 Training Institutions
6.7.7 Relevant third parties

6.8 Where KWV uses the services of third parties to process personal information, KWV will ensure that the necessary contractual measures are in place to protect against loss or disclosure of such personal information.

6.9 Categories of Data Subjects and Personal Information Processed by the Company.

Categories of data subjects and personal information processed by the Company include the following:

Categories of Data Subject Personal Information Processed
Clients / Prospective Clients: Natural Persons Names; contact details; physical and postal addresses; dates of birth; identification numbers; financial information; nationality; confidential correspondence.
Clients / Prospective Clients: Juristic Persons Names of contact persons; name of legal entity; physical / postal addresses and contact details; financial information; registration number; founding documents and related information; authorised signatories; information of connected parties
Contracted Service Providers / Vendors Names of contact persons; name of legal entity; physical and postal address and contact details; financial information; registration number; founding documents; authorised signatories; BEE Certificates.
Employees / Potential Employees / Contracted staff members Gender; marital status; race; age; language; identity number; physical and postal addresses and contact details; financial information; Doc. no. 2025466 vs 00 Page 4 of 13 Printed on: 2021-08-05 pregnancy status; educational information, employment history, medical history, criminal history, opinions
KWV Group Companies: Juristic Persons Name of legal entity; physical / postal addresses and contact details; statutory information; financial information.



6.10 Categories of Information Insofar as the Act is concerned

The list of subjects and categories of information held by the Company includes the following:
6.10.1 Statutory Company Information

6.10.1.1 Memorandum and Articles of Association/Memorandum of Incorporation
6.10.1.2 Certificates issued by the Registrar of Companies
6.10.1.3 Company resolutions
6.10.1.4 Proxy forms
6.10.1.5 Company forms lodged with the Registrar in terms of the Companies Act, Minute books
6.10.1.6 Share registers
6.10.1.7 Director’s attendance registers
6.10.1.8 Shareholder agreements

6.10.2 Accounting Records

6.10.2.1 Annual financial statements
6.10.2.2 Books of account
6.10.2.3 Fixed Asset Registers
6.10.2.4 Client Invoices
6.10.2.5 Supplier Invoices and Auditor’s reports
6.10.2.6 Income Tax returns
6.10.2.7 Value Added Tax returns

6.10.3 Banking Details

6.10.3.1 Bank facilities and account details
6.10.3.2 Overdraft facilities
6.10.3.3 Bank statements
6.10.3.4 Bank signatory forms
6.10.3.5 Other banking records and agreements

6.10.4 Human Resources / Employment Records

6.10.4.1 Pay as You Earn (PAYE) records
6.10.4.2 Contracts of employment
6.10.4.3 Personnel files
6.10.4.4 Disciplinary records
6.10.4.5 Schedule of shares
6.10.4.6 Employee benefit records
6.10.4.7 Salary and wage register
6.10.4.8 Provident fund agreement, rules and actuarial valuation reports
6.10.4.9 Minutes of meetings of trustees and members of provident fund
6.10.4.10 Provident fund contribution reports
6.10.4.11 Attendance and leave registers
6.10.4.12 Expense accounts
6.10.4.13 Group life
6.10.4.14 Human resource policies and codes of conduct
6.10.4.15 Training manual
6.10.4.16 Medical Aid Administration

6.10.5 Client Information

6.10.5.1 Documentation and other information received from clients.
6.10.5.2 Documentation and other information received from third parties.
6.10.5.3 Correspondence with clients.
6.10.5.4 Correspondence with third parties.
6.10.5.5 Information prepared by employees for clients, including opinions, memoranda and reports.
6.10.5.6 Other information relating to, or held on behalf of, clients

6.10.6 Insurance Records

6.10.6.1 Insurance policies taken out for the benefit of KWV and its employees.

6.10.7 Immovable And Movable Property

6.10.7.1 Agreements of lease of immovable property occupied by KWV.
6.10.7.2 Credit sale agreements and/or hire purchase agreements.
6.10.7.3 Other agreements for the purchase, ordinary sale, conditional sale or hire of assets.

6.10.8 Information Technology

6.10.8.1 Computer software, support and maintenance agreements.
6.10.8.2 Other documentation pertaining to computer systems and computer programmes held by KWV.

6.10.9 Sales And Marketing

6.10.9.1 Brochures, Newsletters and Advertising Materials.
6.10.9.2 Marketing agreements.

6.10.10 Miscellaneous Agreements

6.10.10.1 Loans from third parties (including banks).
6.10.10.2 Loans to third parties.
6.10.10.3 Suretyship agreements.
6.10.10.4 Security agreements, guarantees and indemnities.
6.10.10.5 Agency, management and distribution agreements.
6.10.10.6 Agreements with suppliers.
6.10.10.7 Confidentiality and/or non-disclosure agreements.
6.10.10.8 Any other relevant agreements.

6.11 Records Available in terms of Other Legislation
Records are kept in accordance with such other legislation as is applicable to KWV which includes, but is not limited to, the following:

6.11.1 Income Tax Act 58 of 1962
6.11.2 Financial Advisory and Intermediary Services Act 37 of 2002
6.11.3 Financial Intelligence Centre Act, 38 of 2001
6.11.4 Value Added Tax Act 89 of 1991
6.11.5 Occupational Health and Safety Act 85 of 1993
6.11.6 Labour Relations Act 66 of 1995
6.11.7 Basic Conditions of Employment Act 75 of 1997
6.11.8 Employment Equity Act 55 of 1998
6.11.9 Prevention of Organised Crime Act 121 of 1998
6.11.10 Protection of Constitutional Democracy against Terrorism and Related Activities Act No. 33 of 2004
6.11.11 Protection of Personal Information Act no. 4 of 2013
6.11.12 Medical Schemes Act 131 of 1998
6.11.13 Skills Development Levies Act 9 of 1999
6.11.14 Unemployment Insurance Act 63 of 2001
6.11.15 Unemployment Insurance Contributions Act 4 of 2002
6.11.16 Companies Act 71 of 2008

6.12 Information Automatically Available

6.12.1 The following categories of records are automatically available for inspection, or photocopying without having to be requested in terms of the Act:
6.12.1.1 Newsletters
6.12.1.2 Booklets
6.12.1.3 Pamphlets / Brochures
6.12.1.4 Reports of a public nature
6.12.1.5 Other information intended for public viewing.
6.12.2 The only fee payable for access to the records listed in this clause 6.12 is a prescribed fee for reproduction.
6.13 Information Security Measures to Protect Personal Information
6.13.1 KWV is committed to developing appropriate safeguards to make sure that personal data is kept secure and confidential, and is protected against reasonably anticipated threats to its security or integrity, and against unauthorised access or use that might result in substantial harm or inconvenience to data subjects.
6.13.2 Reasonable technical and organisational measures are implemented for the protection of personal information processed by the Company.
6.13.3 The Company continuously implements and monitors technical and organisational security measures to protect personal information against unauthorised access as well as accident or wilful manipulation, loss or destruction.

6.14 Request Procedures

Any and all records shall only be made available subject to the provisions of the Act.
6.14.1 Form Of Request
6.14.1.1 When making a request to access a record, the requester must use the prescribed form (refer to Annexure B), addressed to the head of the body.
6.14.1.2 The requester must provide sufficient detail on the request form to allow for the identification of the record and the requester. The requester should also indicate which form of access is required and specify a postal address or fax number in the Republic.
6.14.1.3 The requester must identify the right that is sought to be exercised or protected and provide an explanation of why the requested record is required for the exercise or protection of that right.
6.14.1.4 If a request is being made on behalf of another person, the requester must submit proof of the capacity in which the requester is making the request.

6.15 Fees

6.15.1 A requester who seeks access to a record containing personal information about the requester is not required to pay the request fee.
6.15.2 Where fees are payable these are detailed in the request form.
6.15.3 If the request is granted, a further fee will be payable for the search, preparation and reproduction of the record.
6.15.4 The requester may lodge an application to the court against the tender or payment of the request fee or may lodge a complaint with the Information Regulator.

6.15 Decision

6.16.1 The Company will, within 30 days of receipt of a request, decide whether to grant or decline a request, providing reasons to that effect.
6.16.2 The 30-day period within which the Company has to decide whether to grant or refuse a request may be extended for a further period of not more than 30 days if reasonably required under the circumstances.
6.16.3 If the request for access is refused, the requester may lodge an application to court or alternatively, lodge a complaint with the Information Regulator.

6.17 Grounds for Refusal

6.17.1.1 KWV has the right to refuse a request for information based on any of the following grounds:
6.17.1.2 Mandatory protection of the privacy of a third party who is a natural person, which would involve the unreasonable disclosure of personal information of that natural person;
6.17.1.3 Mandatory protection of the commercial information of a third party, if the record contains:
6.17.1.3.1 Trade secrets of that third party;
6.17.1.3.2 Financial, commercial, scientific or technical information which disclosure could likely cause harm to the financial or commercial interests of that third party; and
6.17.1.3.3 Information disclosed in confidence by a third party, if the disclosure could put that third party at a disadvantage in negotiations or commercial competition.
6.17.1.4 Mandatory protection of confidential information of third parties if it is protected in terms of any agreement or legislation;
6.17.1.5 Mandatory protection of the safety of individuals and the protection of property;
6.17.1.6 Mandatory protection of records which would be regarded as privileged in legal proceedings;
6.17.1.7 The information relates to the commercial activities of KWV, which may include:
6.17.1.7.1 Trade secrets of KWV;
6.17.1.7.2 Financial, commercial, scientific or technical information which disclosure could likely cause harm to the financial or commercial interests of KWV;
6.17.1.7.3 Information which, if disclosed, could put KWV at a disadvantage in negotiations or commercial competition;
6.17.1.7.4 A computer program which is owned by KWV and which is protected by copyright.
6.17.1.8 The research information of KWV or a third party, if its disclosure would disclose the identity of the institution, the researcher or the subject matter of the research and would place the research at a serious disadvantage;
6.17.2 A request for information that is clearly frivolous or vexatious, or which would involve an unreasonable diversion of resources will be refused.

6.18 Prescribed Fees and Forms in respect of Private Bodies

The prescribed fees and form for requests to private bodies are attached to this manual, marked “Annexure A” and “Annexure B” respectively and are available on the websites of the Information Regulator, https://www.justice.gov.za/inforeg/docs.htmland the SAHRC, www.sahrc.org.za.

7. RECORDS
None

8. ATTACHMENTS
8.1 Annexure A
8.2 Annexure B

 

Website Privacy Policy:

1. PURPOSE
Privacy laws around the world dictate that if you collect personal information from your website visitors, then you need to have a Privacy Policy posted to your site and available with your mobile app (if applicable).

A Privacy Policy is a legal agreement that explains what kinds of personal information the Business gather from website visitors, how KWV use this information, and how we keep it safe.

Personal information refer to information that identifies or relates specifically to you, for example, your race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth. Information relating to your education or the medical, financial, criminal or employment history, any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier or other particular assignment, together with biometric information, personal opinions, views or preferences also falls within the very broad definition. In addition, correspondence is also included.

The Privacy Policy generally covers:

  • The types of information collected by the website or app
  • The purpose for collecting the data
  • Data storage, security and access
  • Details of data transfers
  • Affiliated websites or organisations (third parties included)
  • Use of cookies

2. SCOPE
This privacy notice applies to Warshay investments (Pty) Ltd and its subsidiaries (hereafter referred to as “KWV”) and all prospective, present and past KWV Stakeholders (Stakeholders), including but not limited to the following:

  • Employees, affiliates, consultants and contractors
  • Customers (including persons that are involved in the course of service delivery)
  • Visitors to our website
  • Third Party Service Providers / partners / operators / resellers
  • Any party who contracts with us or otherwise uses our products and/or services

3. REFERENCES
None

4. ABBREVIATIONS AND DEFINITIONS
The term 'KWV' and abbreviation 'KWV' refer to any company within the Warshay Investment Group of Companies, irrespective of its location and name, both nationally and internationally.

5. RESPONSIBILITY
The Information Officer/Deputy Information Officer is the custodian of all protection of personal information related policies and has to ensure the policy is updated and maintained. Privacy champions to ensure implementation and adherence to this policy at all times.

6. STEPS

  1. We may update this Privacy Notice from time to time and encourage you to review it online periodically.
  2. We are committed to protecting the privacy rights of our Stakeholders. This privacy notice describes our information handling and associated privacy practices. This includes:
    • How we collect personal information about our Stakeholders
    • How we process and use such personal information
    • How we may share personal information
    • How we secure personal information
    • Stakeholder rights
  3. Our data practices are subject to applicable laws in the countries in which we operate. This means that we engage in the practices described in this notice in a particular country only if permitted under the laws of that country.
  4. We only collect, store and process your personal information in accordance with applicable laws and regulations.

6.2 TYPES OF PERSONAL INFORMATION COLLECTED
We may collect the following types or categories of personal information, including:

  • Contact details such as name, email address, telephone number and work location.
  • Company details required for third parties and customer administration.
  • Confidential information that relates to organisations, for example, information security risks and controls.
  • Government issued identification numbers for the purposes of employee application validation and employee administration and third party’s registration and administration.
  • Information related to candidate or employee race and disability status for BBBEE reporting purposes.
  • Other relevant personal information to enable the conduct of business.
  • Technical information including your Internet Protocol (IP address) which is used to connect your computer to the internet, operating system and browser type and platform for system administration; and
  • Information about your use of our Website including details of your visits such as pages viewed and the resources that you accessed. Such information includes traffic data, location data and other communication data.
  • We use Google Analytics to collect site traffic statistics. Analytics tracks and reports website traffic. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of Google Analytics by installing the Google Analytics opt-out browser add-on.

6.3 PERSONAL INFORMATION HANDLING PRACTICES
We endeavor to notify our Stakeholders about the manner in which, and the purposes for which, we collect and use their personal information. We collect and use personal information for the following purposes:

  • To establish and maintain a relationship with our customers, enabling ongoing service delivery.
  • To understand customer needs and preferences. For example, we maintain a record of services you have purchased or signed up for.
  • Where the collection and processing is required by Law, for example, mandatory tax reporting requirements.
  • For audit and record keeping requirements.
  • To conduct statistical or market related research.
  • For the administration of remuneration, employment benefits and accounts payable / receivable.
  • To evaluate candidates and applicants who submit personal information for employment opportunities.
  • To effectively respond to queries submitted through our online “contact us” feature or to individual team members.
  • To communicate relevant services and information to Stakeholders.
  • Competitions and promotions.
  • To follow up as part of our customer care procedures.

We may use your personal information collected including but not limited to your name, email, company and job title for purposes of contacting you, sending notifications, updates and invitations to events. If you would like to withdraw your consent for such processing, you may use the “contact us” feature on this website (update as per the process).
Unless required or permitted by law, we shall not use or disclose personal information or sensitive personal information for a new purpose that has not been identified and consented to by you.

6.4 RETENTION OF PERSONAL INFORMATION
We retain personal information for as long as may be reasonably necessary in accordance with applicable law.

6.5 DIRECT MARKETING ACTIVITIES
We would like to provide you with information about new products, promotions, special offers and other information, which we think you may find interesting. By you opting-in, you agree that we may send you marketing communications via (SMS, E-mail, Telephonic Calls).

You may opt out from receiving marketing communications by clicking on the opt-out link that will be contained in the relevant electronic communication.

6.6 COOKIES
Currently we only use cookie technology that is strictly necessary for administration and operation of our website. These are necessary to enable you to click through our website. Example of the type of information that is collected include:

  • The IP address from which you access the site.
  • The type of browser and operating system used to access the site.
  • The date and time of your access to the site.
  • The pages you visit.
  • The internet address of the website from which you accessed the site.

Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log onto the Website. If you accept a “cookie” or fail to deny the use of “cookies”, you agree that we may use your personal information collected using “cookies” (subject to the provisions of this Policy). Where you either reject or decline cookies, you are informed that you may not be able to fully experience the interactive features of the Website.

6.7 CHOICE AND CONSENT
In most circumstances, we receive personal information directly from you, when you request services or products from us, we may require personal information for contact or billing purposes.

We will only require you to consent to the collection, use or disclosure of personal information as per the identified purposes in this notice. We will not unreasonably withhold products, services or information if you refuse or withdraw your consent.

You may withdraw or modify your consent at any time, subject to legal and contractual restrictions, provided that reasonable notice is given to us. If you would like to withdraw your consent for such processing, you may use the “contact us” feature on this website. Please allow at least 30 days for us to effect changes in communication preferences.

6.8 THIRD PARTIES
We may make use of third party services to support our service delivery to Stakeholders. Our third parties are vetted in terms of information protection risks and agree to required privacy practices and controls. Examples of third parties with whom we may share personal information, include (update examples) :

  • Member companies within KWV
  • Regulators
  • Selected and contracted service providers that support our service delivery
  • Persons acting on our behalf (incl. affiliate consultants and third parties)
  • Auditors
  • Courier services

We will not share personal information with third parties other than as disclosed in this notice or explicitly agreed with you. Further, we will only disclose your personal information if:

  • The law requires it.
  • We have a public duty to disclose the information.
  • If it is reasonably necessary to prevent illegal activity.
  • Our or your legitimate interests require disclosure.
  • You consented to such disclosure.

6.9 CROSS BORDER TRANSFER
We operate globally, and in certain instances, may process personal information in other countries to support ongoing business delivery. Some countries may not be subject to data protection laws or policies which are as stringent as the data protection laws applicable to the European Union and/or in South Africa. Where this is the case, we will ensure that the receiving party agrees in writing to implement adequate privacy principles before we share any personal information with such party.

6.10 HOW WE SECURE PERSONAL INFORMATION
We endeavour to protect the security, availability and confidentiality of personal information by implementing and maintaining reasonable technical and organisational controls. Our controls are aligned to leading practices and frameworks, and other generally accepted controls for information security

Our technical and organisational personal data security measures include:

  • the storage of your personal data under password-secured databases;
  • the restriction of access to your personal data to specific staff/personnel who are designated and mandated to manage your personal data;
  • the restriction of access to all our premises where your personal data is stored in physical or digital form; and
  • the binding of any third parties who handle your personal data to confidentiality obligations with respect to the same.

6.11 CHILDREN’S PRIVACY
Should KWV collect children’s Personal Information under the age of 16 years old, KWV will ensure that the relevant consent is obtained from the parent/legal guardian on behalf of the child.

6.12 YOUR PRIVACY RIGHTS
We take note of your rights under applicable data privacy and related legislation, specifically your right to object, upon reasonable grounds, to your personal information being processed. Further, you have the right to request access to the personal information we hold about you by contacting us or completing the PAIA Request Form available at http://www.justice.gov.za/forms/paia/J752_paia_Form%20C.pdf .

Alternatively, and in countries outside of South Africa you may write to us and send your request to popiainfo@kwv.co.za

You are encouraged to contact us in order to update your personal information as and when necessary.

6.13 QUERIES AND COMPLAINTS
If you have any queries or complaints about Privacy, please contact us via email at popiainfo@kwv.co.za

6.14 EXTERNAL LINKS
Our website may contain links to external websites and sources of information. This does not indicate endorsement by us and due care should be taken before following such links.

6.15 INFORMATION REGULATOR
Should you wish to contact the South African Information Regulator, we have provided their contact details:

Telephone: 012 406 4818
Fax: 086 500 3351
Email: inforeg@justice.gov.za

CONTACT US AT

Warshay Investments Pty Ltd t/a KWV
57 Main Street
Southern Paarl
7646
021 807 3911

7. RECORDS

Record name Kept by Location Period Disposal
None        

8. ATTACHMENTS
None

9. CHANGES

DATE CHANGES (insert paragraph numbers where changes were made) REASON FOR CHANGE (see 2000084 for examples)
23 June 2021 New Policy Protection of Personal Information Act implementation.