1.1. Information you give us

This includes any information that you provide to us directly:

1.1.1. when you sign-up to utilise our Platforms;
1.1.2. by filling in forms on our Platforms, at any of our establishments, or otherwise provided by you;
1.1.3. when you enter a competition, promotion or complete a survey;
1.1.4. when you utilise any of our services;
1.1.5. by posting comments or content on our social media pages;
1.1.6. when you contact us or we contact you and you provide information directly to us;
1.1.7. when you make a reservation over the phone, communicate with us by email, fax, or via online chat services or contact customer service. These communications may also be recorded for purposes of quality assurance and training; or
1.1.8. when you do business with us;
1.1.9. when you provide information to us, you agree that the information is true, accurate and complete, and that you have authorization to provide it to us.

1.2. What personal information we collect

1.2.1. When you register to use our Platforms, you may be required to provide us with the following information, your –
1.2.1.1. title;
1.2.1.2. name and surname;
1.2.1.3. contact number and email address;
1.2.1.4. physical address;
1.2.1.5. postal address;
1.2.1.6. identification number or other acceptable formal identification;
1.2.1.7. date of birth;
1.2.1.8. other information required for the defined and lawful purpose related to the function or activity, and
1.2.1.9. copies of relevant supporting documents, where required.

1.2.2. When you make use of our platforms, use our services or visit our establishments you may be required to provide us with the following information in addition to the above –
1.2.2.1. the source of your funds (for the purposes of compliance with the Financial Intelligence Centre Act, 2001 (“FICA”) or similar anti-money laundering legislation);
1.2.2.2. declaring if you are a foreign or domestic politically exposed person or a prominent influential person, alternatively, a family member or know associate of such persons (for the purposes of compliance with the Financial Intelligence Centre Act, 2001 (“FICA”) or similar anti-money laundering legislation);
1.2.2.3. country of origin (for the purposes of compliance with the Financial Intelligence Centre Act, 2001 (“FICA”) or similar anti-money laundering legislation); and
1.2.2.4. your banking details (for the purposes of processing transactions that require the information concerned).

1.3. Information we collect or receive when you use our Platforms
We collect information when you use Platforms by using cookies, web beacons and other technologies. Depending on how you access and use our Platforms, we may receive:
1.3.1. log information;
1.3.2. information we infer about you based on your interaction with products and services;
1.3.3. device information (for example the type of device you’re using, how you access platforms, your browser or operating system and your Internet Protocol (“IP”) address);
1.3.4. location information; and
1.3.5. information otherwise provided directly by you.

1.4. Information in the Tsogo Sun Group

1.4.1. The companies in the Tsogo Sun Group receive information about you from each other for the general purposes described in 2 below.
1.4.2. BY SUBMITTING YOUR PERSONAL INFORMATION TO US, YOU CONSENT THAT WE MAY PROCESS YOUR PERSONAL INFORMATION WITHIN THE TSOGO SUN GROUP.

1.5. Information from third-party sources

We may receive information from a third party where processing is necessary to secure reservations, the personal information of which would be subject to confirmation when the reservation is enacted.
We may receive additional information about you that is publicly or commercially available and combine that with the information we have collected or received about you in other ways.

2.1. We use the information we collect and receive for the following general purposes:
2.1.1. to provide you with information, products or services you request from us;
2.1.2. in order to refer you to an appropriate third-party service provider;
2.1.3. to communicate with you;
2.1.4. to allocate special offers to you, which may include awarded points in respect of your Tsogo Rewards Programme membership;
2.1.5. your geolocation data may be used to provide you with information about your closest Tsogo Sun gambling establishment or otherwise to enhance our services;
2.1.6. to provide you with support and/or services related to the purpose for which the information was collected;
2.1.7. to provide effective advertising, which may include linking your information with that of a third party (for example, to provide you with news, special offers and general information about other goods, services and events which we offer, that are similar to those that you have already used or enquired about). Also refer to “How We Share The Information We Collect And Receive” section below.

3.1. We don’t sell your personal information to third parties for their marketing purposes.
3.2. We may share information:
3.2.1. within the Tsogo Sun Group;
3.2.2. with a limited number of our employees and third party service providers (other than those who we refer you to), who we assist you to interact with;
3.2.3. with our business partners (we may share non-personally identifiable information with select business partners);
3.2.4. with other parties in response to legal process or when necessary to conduct or protect our legal rights;
3.2.5. with companies that provide services to us. Companies that provide services to us or act on our behalf may have access to information about you. These companies are limited in their ability to use information they receive in the course of providing services to us or you;
3.2.6. with other parties that provide advertising services to us. These third parties may include i) advertising service providers which help us provide advertisements that are tailored to your’ interests, ii) audience-measurement companies which help us measure the overall usage of our Platforms and compare that usage with other online services, and iii) social networking services such (as Facebook, Twitter, LinkedIn and Instagram). We do not control the privacy practices of these or any other third-party services and recommend you read the privacy policies of these services before connecting to them. These third parties may collect or receive information about you and this information may be collected over time and combined with their own information or other information collected on various websites and online services.

4.1. We may ask you on various Platforms (or through other methods) whether you would like to receive certain marketing communications from us. By choosing to receive certain electronic communications from us you provide your consent to such direct marketing.
4.2. You have the right to ask us not to contact you for marketing purposes. You can exercise this right at any time by using any of the various “opt-out” options that we will always provide to you when we communicate with you.
4.3. You are also able to change your communication preferences on our Platforms. You are able to unsubscribe from receiving direct marketing communications from us. Please note that each entity in the Tsogo Sun Group operates independently and manages their own “opt-out” data base. Therefore, when you opt out from receiving direct marketing from one of the Tsogo Sun Group entities, you will still receive direct marketing from other entities in the Tsogo Sun Group.
4.4. We won’t send you marketing messages if you tell us not to, but we will still need to send you service-related messages. As such, if you choose not to opt-in or later opt-out of receiving marketing communications from us, you will still receive transaction-related communications from us.

We may monitor and record our communications with you, including e-mails. Information which we collect may then be used for training purposes, quality assurance, to record details about the products and services you use or ask us about, and in order to meet our legal and regulatory obligations generally.

6.1. Our websites use cookies. If you wish to reject our cookies, you can configure your browser to do so.
6.2. Our apps use push notifications. If you wish to reject our push notifications, you can change your settings on your phone or device.
6.3. We want to make sure that any data we hold about you is up to date. So, if you think your personal information is inaccurate, you can ask us to correct or remove it.

We will retain your personal information only for as long as is necessary for the purposes set out in this privacy policy or to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

The security of your data is important to us.  We strive to use commercially acceptable means to protect your personal information, and will at all times endeavour to guarantee its absolute security.  We do employ safeguards intended to mitigate the risk of unauthorised access or disclosure of your information.  We will do our best to protect your personal information and we will use up-to-date technology that will help us to do this.  We will at all times comply with our obligations under applicable law.

9.1. We might transfer your personal information to places outside of South Africa and store it there, where our suppliers might process it. If that happens, your personal information will only be transferred to and stored in country that has equivalent, or better, data protection legislation than South Africa or with a service provider which is subject to an agreement requiring it to comply with data protection requirements equivalent or better than those applicable in South Africa.
9.2. YOUR USE OF OUR PLATFORMS AND/OR YOUR SUBMISSION OF INFORMATION TO US, REPRESENTS YOUR CONSENT TO SUCH TRANSFER.
9.3. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

10.1. What are cookies and why do we use them?

We might use cookies and other techniques such as web beacons when you visit our website. “Cookies” are small text files used by us to recognise repeat users, facilitate your on-going access to and use of our website and allow us to track your usage behaviour and compile aggregate data that will allow us to improve the functionality of our website and content. “Web beacons” are small, clear picture files used to follow your movements on our website. For example, storing your preferred settings for the next time you visit.

10.2. The information we collect from cookies enables us to:

10.2.1. tailor our websites to your personal needs;
10.2.2. remember the notifications that you have been shown, so that you are not shown them again;
10.2.3. make improvements and updates to our websites based on the way you want to use them; and
10.2.4. we generally do not use cookies to identify you personally.

10.3. What kind of cookies do we use?

We use the following categories of cookies:
10.3.1. Category 1: necessary cookies

Necessary cookies enable you to use our websites and all its features. Without these cookies you may not be able to use all the features of our websites.

10.3.2. Category 2: performance cookies

Performance cookies collect information about how you use our websites so we can improve them for you in future. For example, they collect information on which pages you visit most often and any error messages you may get. The information collected by these cookies is anonymous. They do not collect any information that can identify you personally.

10.3.3. Category 3: functionality cookies

Functionality cookies enable us to provide you with a more personalized experience. The information these cookies collect is anonymous. They cannot track your browsing activity on other websites.

10.3.4. Category 4: targeting/advertising cookies

We and our service providers may use advertising cookies to deliver ads that we believe are relevant to you and your interests. For example, we may use targeting or advertising cookies to customize the advertising and content you receive on our websites, to limit the number of times you see the same ad on our websites and to help measure the effectiveness of our advertising campaigns.

10.3.5. Category 5: social media cookies

Our websites use third-party cookies from social media sites such as Facebook, Twitter and LinkedIn to enable in-depth campaign reporting and to track social network users when they visit our websites, by using a tagging mechanism provided by those social networks. These cookies can also be used for event tracking and remarketing purposes. Any data collected with these tags will be used in accordance with our privacy policy and with the social network’s privacy policies. Our websites will not collect or store any personally identifiable information from the user. However, our website may be used as a channel to update your contact details.
10.4. How can you manage your cookie settings?

10.4.1. To ensure you get the best possible experience when visiting our websites, we recommend that you accept cookies. However, you can opt-out of each cookie category (except strictly necessary cookies) by clicking on the “cookie settings” button or disable cookies in your web browser.

10.4.2. Cookies may, however, be necessary to provide you with certain features available on our website. If you disable cookies you may not be able to use these features, and your access to our website will be limited.

Our Platforms may contain links to and from websites, mobile applications or services of third parties or affiliates. Please note that we are not responsible for the privacy practices of such other parties and advise you to read the privacy statements of each website you visit which collects personal information.

We may update this privacy policy from time to time. Any changes that we may make to our privacy policy will be posted on our website and will be effective from the date of posting. Tsogo Sun encourages you to periodically review this Privacy statement to be informed of how Tsogo Sun is protecting your information.

13.1. You may request details of personal information which we hold about you under the Promotion of Access to Information Act, 2000 (“PAIA”). Fees to obtain a copy or a description of personal information held about you are prescribed in terms of PAIA. Our PAIA Manual can be located at https://www.tsogosun.com/paia/
13.2. Confirmation of whether or not we hold personal information about you may be requested free of charge. If you would like to obtain a copy of your personal information held by us, please review our PAIA Manual.
13.3. You may request the correction of personal information that we hold about you. You also have a right in certain circumstances to request the destruction or deletion. If you wish to exercise this right, please review our PAIA Manual.
13.4. You have a right to object on reasonable grounds to the processing of your personal information where the processing is carried out in order to protect our legitimate interests or your legitimate interests, unless the law provides for such processing. If you wish to exercise this right, please review our PAIA Manual.

We have appointed the National Compliance Manager as the Information Officer to oversee compliance with this Privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Information Officer. The National Compliance Manager has been authorised to act as the Head of the Tsogo Sun Group for the purposes of the compilation of the PAIA Manual and to address requests for access to information from the Tsogo Sun Group made in terms of the Act.

Group Information Officer

The Head:                           The National Compliance Manager

Street Address:                Palazzo Towers East, Montecasino Boulevard, Fourways

Postal Address:                Private X190, Bryanston, 2021

Telephone:                          (011) 510 7700

E-mail:                                 corporate.compliance@tsogosun.com

Website:                             www.tsogosun.com

 You have the right to make a complaint at any time to the Information Regulator of South Africa.

 Information Regulator of South Africa

Tel: 010 023 5200
Email: POPIAComplaints@inforegulator.org.za