1.1 Introduction and scope
1.1.1 Future Indefinite Investments 180 (Pty) Ltd and its subsidiaries (“Future Indefinite” or “we” or “us” or “our”) are part of the Wonderland Property Group, a South African-based group of companies focused on developments and investments in the commercial, industrial, retail, and residential sectors.Our head office is located in the Greater Johannesburg area at 147 North Reef Road, Bedfordview, Germiston.
1.1.2 Future Indefinite is committed to protecting and respecting your privacy. We strive to ensure that our use of your Personal Information is lawful, reasonable, and relevant to our business activities, with the ultimate goal of improving our services and your experience.
1.2.1 “Personal Information” means the information relating to an identifiable, living, natural person, and where applicable, an identifiable, existing juristic person, including inter alia, race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, wellbeing, disability, religion, conscience, belief, culture, language and birth of the person, as well as the name of the person, his or her ID number, letters from or about that person, letters from or about that person that contain confidential information and biometric information as defined in the Protection of Personal Information Act 4 of 2013 (“POPI Act”);
1.2.2 “Responsible Party” means a public or private body or any other person which, alone or in conjunction with others, determines the purpose of and means for processing Personal Information;
1.2.3 “Special Personal Information” means Personal Information regarding a data subject’s religious or philosophical beliefs, race or ethnic origin, trade union membership, political persuasion, health or sex life or biometric information of a data subject, or the criminal behaviour of a data subject.
1.3 Your consent to the Processing of your Personal Information
1.3.1 Future Indefinite is a Responsible Party in respect of your Personal Information and Special
Personal Information (and “process” has a corresponding meaning).
1.3.3 Consent must be given by you in order for Future Indefinite to process your Personal Information or Special Personal Information. Any consent given will remain in place for any current agreements or subsequent agreements entered into between the parties.
2.2.1 If you are browsing a third party website that contains a link to a Future Indefinite advertisement or a link to the Future Indefinite Website, Future Indefinite is not responsible for any processing of your Personal Information done by that third party; and
2.2.2 If you are browsing the Future Indefinite Website and you click a link relating to a third party advertisement or third party website, the Future Indefinite is not responsible for any processing of your Personal Information done by that third party.
3.2.1 A cookie is a small text file, placed on your device (PC, tablet or mobile phone) when you visit an online service. Cookies send information back to the originating online service or another online service that recognises that cookie.
3.2.2 Cookies can be either permanent (persistent cookies) and remain on your device until you delete or clear them, or temporary (session cookies) where they stay until you close your browser.
3.2.3 Cookies can also be either first party cookies which are set by the online service you are visiting, or third party cookies which are set by an online service other than the online service you are visiting.
3.2.4 Cookies help us to do things such as identifying your device when you use our online services, which browser you use, which specific pages you view and the time and date you visited us online, to remember you when you return, to provide you with a faster, better, and safer browsing experience, to keep track of your preferences, to provide you with a more personalised experience and measure and analyse traffic patterns and user behaviour on our online services.
3.3 Different types of cookies are used for different purposes, including the following:
3.3.1 Your Preferences and Settings: to help us remember your preferences including your preferred language, browser settings and communication and opt-out preferences, so that they do not have
to be reset each time you return to us online.
3.3.2 Performance: to assess the our online performance, and to improve the features, functions,
content and design thereof.
3.3.3 Sign-in and Authentication: to verify your account, remember you when you sign-in so that you
don’t need to keep signing in, and keep you logged in so that you can navigate easily between our
3.3.4 Security: to enable and support our security features, to keep your account safe and to help us
combat fraud and any activity on our online services which violates our policies or applicable law.
3.3.5 Analytics and Research: to collect usage and performance data in relation to our online services, e.g., to count the number of unique visitors to pages on our Sites; what content was viewed and what links were clicked on, to log users’ IP addresses in order to analyse trends and to compile
other statistics about use of our Online Services and user behaviour.
3.4. If you don’t want to receive cookies, or want to adjust your cookies preferences, most browsers allow you to change your browser settings to block or delete cookies. Your browser’s “help” function will tell you how to do this. You should be aware that if you block or delete cookies, our online services may not work properly and you may not be able to access certain areas.
4. Processing of Personal Information
4.1 We hereby notify you that during your interactions with the Future Indefinite, we will collect
certain Personal Information about you. We may process various types of Personal Information
about you, as follows:
4.1.1 Identity Information, which includes information concerning your name, user name, marital
status, title, occupation, interests, date of birth, gender, race and legal status, as well as copies of your identity documents, photographs, identity number, registration number and your qualifications;
4.1.2 Contact Information, which includes your billing addresses, delivery addresses, e-mail addresses and telephone numbers;
4.1.3 Financial Information, which includes bank account details, insurance information, financial statements, tax clearance certificates and VAT registration numbers;
4.1.4 Transaction Information, which includes details about payments made to or received from you and company information, which may consist of financial activity, including invoices and statements;
4.1.5 Technical Information, which includes your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Website or to use our products and services or engage with us;
4.1.6 Usage Information, which includes information as to your access and use of the Website, our services, such as what links you went to, what content you accessed, the amount of content viewed and the order of that content, as well as the amount of time spent on the specific content and what services you access and use when engaging with Future Indefinite.
4.1.7 Location Information, which includes geographical information from your Access Device (which is usually based on the GPS or IP location); and
4.1.8 Marketing and Communications Information, which includes your preferences in respect of receiving marketing information from us and our third parties, and your communication preferences.
5. Special Personal Information
5.1 We hereby notify you that, in certain circumstances, by engaging with Future Indefinite, we may
collect certain Special Personal Information about you.
5.2 The processing of Special Personal Information requires higher levels of protection. We need to have further justifications for processing Special Personal Information. Future Indefinite has implemented appropriate policies and safeguards, which we are required by law to maintain o process Special Personal Information.
5.3 When will we process your Special Personal Information?
5.4 We will generally not process particularly Special Personal Information about you unless it is
necessary for establishing, exercising or defending a right or obligation in law, or where we have obtained your consent to do so. On rare occasions, there may be other reasons for processing your Special Personal Information, such as where the information has been deliberately made public by you. The situations in which we may process your Special Personal Information include the following:
5.4.1 Racial and ethnic information may be processed by Future Indefinite for recruitment purposes and through CCTV cameras installed at Future Indefinite premises for safety and security reasons;
5.4.2 As part of the recruitment and hiring process, we may process information relating to your criminal behavior;
5.4.3 We may process information pertaining to your political persuasion as part of the know your client (KYC) processes and customer due diligence (CDD) checks;
5.4.4 We may process information relating to your health as part of our screening processes when accessing our premises, in order to comply with health and safety regulations and protocols; and
5.4.5 We may process information which indicates your religious beliefs (for example, when you attend events organized by Future Indefinite, we may ask you for your dietary requirements, and this may indicate your religious beliefs).
6. How we collect your Personal Information
6.1 We collect your Personal Information in the following ways:
6.1.1 through direct or active interactions with you;
6.1.2 through automated or passive interactions with you;
6.1.3 from third parties and public sources; and
6.2 Direct or active collection from you
6.2.1 We may require that you submit certain information:
220.127.116.11 to enable you to access portions of the Website;
18.104.22.168 to subscribe to our publications;
22.214.171.124 to request marketing or information about our events to be sent to you;
126.96.36.199 to make contact with our partners and employees;
188.8.131.52 to grant you access to our premises;
184.108.40.206 to enable you to facilitate the conclusion of an agreement with us; and
220.127.116.11 that is necessary for our fulfilment of our statutory or regulatory obligations.
6.2.2 We also collect Personal Information directly from you when you communicate directly with us, for example when you complete certain application forms (including our credit application), via e- mail, telephone calls, feedback forms, giving us your business card, site visits.
6.2.3 If you contact us, we reserve the right to retain a record of that correspondence in accordance with our Record Retention Policy and applicable data protection legislation, which may include Personal Information.
6.3 Collection from third parties and public sources
6.3.1 Future Indefinite receives Personal Information and Special Personal Information about you from
various third parties including recruitment agencies, suppliers of background checks services and publicly available sources.
6.4 CCTV/Access Control Systems
6.4.1 Future Indefinite collects Personal Information and Special Personal Information about you
through CCTV cameras installed at Future Indefinite premises as well as utilizing our access control systems where we collect your Personal Information when visiting our premises for safety and security reasons.
7. How we use your Personal Information
7.1 We use your Personal Information for the following purposes:
7.1.1 to provide services to our customers and all activities ancillary thereto;
7.1.2 to open and maintain accounts for billing purposes;
7.1.3 to comply with our statutory and regulatory reporting obligations;
7.1.4 to comply with our health and safety requirements when accessing our premises;
7.1.5 to conduct the recruitment and hiring processes, which includes conducting criminal record and
credit checks (where appropriate), the capturing of a job applicant’s details and providing status
updates to job applicants;
7.1.6 in relation to supplier information, to create supplier profiles on our systems, pay suppliers, and
for general supplier administration;
7.1.7 to maintain and improve the Website and to improve the experience of our Website users,
including by requesting feedback from our Website users on our products and services and to
facilitate the procurement of our products and services.
7.1.8 to maintain and update our customer, or potential customer, databases;
7.1.9 to maintain and update our supplier, or potential supplier, databases;
7.1.10 to detect, prevent or manage actual or alleged fraud, security breaches or the abuse, misuse or
and/or any terms and conditions and/or any agreements;
that are relevant to you;
7.1.12 to compile and use statistical information (including non-personal information) about you and
other users and their access to the Website and to analyze and compare how you and other users make use of the Website, including (without limitation) their browsing habits, click-patterns, preferences, frequency and times of use, trends and demographic information including recommendations to users and tailoring information and content for users;
7.1.13 to conduct market research surveys;
7.1.14 to offer you information and content which is more appropriately tailored for you as far as
7.1.15 to provide you with the latest information about our products and services or events provided that
you have agreed to receive such information;
7.1.16 for security, administrative and legal purposes;
7.1.17 pitching, opportunity tracking and reporting;
7.1.18 campaign tracking and reporting;
7.1.19 to communicate with you and retain a record of our communications with you and your
communications with us;
7.1.20 to fulfil any contractual obligations that we may have to you or any third party;
7.1.21 to invite you to webinars, functions or events that we may host;
7.1.22 for other activities and/or purposes which are lawful, reasonable and adequate, relevant and not
excessive in relation to the provision of our services and/or the use of the Website, our business activities or such other purpose for which it was collected.
8. Sharing of your Personal Information
8.1 We will not intentionally disclose your Personal Information, whether for commercial gain or
8.2 You agree and give permission for us to share your Personal Information under the following circumstances:
8.2.1 with our employees, suppliers, consultants, subcontractors and agents if and to the extent that they require such Personal Information in order to process it for us and/or in the provision of services for or to us, which include know-how and research, reporting purposes (e.g. the South African Revenue Service); hosting, development and administration, technical support and other support services relating to the Website or the operation of our business. We will authorize any Personal Information processing done by a third party on our behalf, amongst other things by entering into written agreements with those third parties governing our relationship with them and containing confidentiality; non-disclosure and data protection provisions. Such persons may be disciplined, their contracts terminated or other appropriate action taken if they fail to meet their obligations;
8.2.2 to enable us to enforce or apply our terms and conditions and/or any agreements you have with us;
8.2.3 to enable us to monitor web traffic: web servers serving the website automatically collect information about pages you visit. This information is used for internal review, to tailor information to individual visitors and for traffic audits;
8.2.4 for statistics purposes: we may perform statistical analyses in order to measure interest in the various areas of the Website or social media marketing (for product development purposes);
8.2.5 to protect our rights, property or safety or that of our customers, employees, contractors, suppliers, agents and any other third party;
8.2.6 with governmental agencies and other regulatory or self-regulatory bodies, if required to do so by law or when we reasonably believe that such action is necessary to:
18.104.22.168 comply with the law or with any legal process;
22.214.171.124 protect and defend the rights, property or safety of Future Indefinite, or our clients, employees, contractors, suppliers, agents or any third party;
126.96.36.199 protect the rights, property or safety of members of the public (if you provide false or deceptive information or misrepresent yourself, we may proactively disclose such information to the appropriate regulatory bodies and/or commercial entities).
9. Storage and transfer of your Personal Information
9.1 We store your Personal Information on:
9.1.1 our premises, in the form of hard copies;
9.1.2 the premises of third party service providers such as subcontractors and document storage service
9.1.3 our servers; or
9.1.4 on the servers of our third party service providers, such as IT systems or hosting service providers.
9.2 From time to time, Future Indefinite and its service providers may need to transfer to and/or store your Personal Information on servers in a jurisdiction other than where it was collected (i.e. outside of South Africa) and we hereby notify you that such jurisdiction may not have comparable data protection legislation.
9.3 If the location to which Personal Information is transferred and/or is stored does not have substantially similar laws to those of South Africa, which provide for the protection of Personal Information, we will take reasonably practicable steps, including the imposition of appropriate contractual terms to ensure that your Personal Information is adequately protected in that jurisdiction.
9.4 Please contact us if you require further information as to the specific mechanisms used by us when transferring your Personal Information outside of South Africa or to a jurisdiction that is different to the one in which we collected your Personal Information.
10.1 We take reasonable technical and organizational measures to secure the integrity of your Personal
Information and using accepted technological standards to prevent unauthorized access to or disclosure of your Personal Information, and protect your Personal Information from misuse, loss, alteration and destruction.
10.2 We review our information collection, storage and processing practices, including physical security measures periodically, to ensure that we keep abreast of good practice.
10.3 We also create a back-up of your information for operational, business continuity and safety purposes and we have a back-up disaster recovery program.
10.4 Despite the above measures being taken when processing Personal Information and Special Personal Information, as far as the law allows, we will not be liable for any loss, claim and/or damage arising from any unauthorized access, disclosure, misuse, loss, alteration or destruction of your Personal Information and/or Special Personal Information.
10.5 Future Indefinite has implemented policies and procedures to address actual and suspected data breaches and undertakes to notify you and the relevant regulatory authorities of breaches in instances in which Future Indefinite is legally required to do so and within the period in which such notification is necessary.
11. Retention of your Personal Information
11.1 We may keep your Personal Information for as long as you continue to engage with us, provide
services or products to us, access the Website and content and/or use our services or for as long as reasonably necessary or until you contact us and ask us to destroy it.
11.2.1 we are required or permitted by law, a code of conduct or a contract with you to do so;
11.2.2 we reasonably need it for lawful purposes related to the performance of our functions and activities;
11.2.3 we reasonably require it for evidentiary purposes;
11.2.4 you agree to us retaining it for a specified further period; or
11.2.5 it is impossible or impractical for us to remove such Personal Information from physical archive storage.
11.3 To determine the appropriate retention period for Personal Information, Future Indefinite will consider, among other things, the nature and sensitivity of the Personal Information, the potential risks or harm that may result from its unauthorized use or disclosure, the purposes for which we process it and whether those purposes may be achieved through other means. Future Indefinite will always comply with applicable legal, regulatory, tax, accounting or other requirements as they pertain to the retention of Personal Information.
12. Maintenance of your Personal Information
12.1 Where required by law, Future Indefinite will take all reasonable steps to ensure that your Personal Information is accurate, complete, not misleading and up to date.
12.2 We also acknowledge that you may have rights of access to, and the right to rectify, your Personal Information, and rights to object to the processing of your Personal Information in certain circumstances.
12.3 You must let us know if any of the Personal Information that we have about you is incorrect, incomplete, misleading or out of date, by notifying us at the contact details set out in clause 1.1.3 above or where applicable, by notifying your Future Indefinite contact.
12.4 Where required by law, we will take reasonable steps to correct or update your Personal Information accordingly, having regard to the purpose for which such Personal Information was collected or used.
12.5 Should you provide us with Personal Information or Special Personal Information that you are not lawfully allowed to provide to us or should you not notify us or rectify any incorrect, misleading or out of date information, which causes any loss or damage to Future Indefinite, Future Indefinite reserves the right to institute legal proceedings against you, as applicable, and you hereby indemnify the Future Indefinite in respect of such damages and/or losses it may sustain in this regard and furthermore Future Indefinite shall not accept any liability with regards to the processing of any unlawfully provided, incorrect, misleading or outdated Personal Information or Special Information.
13. Your rights
13.1 Data protection legislation may confer certain rights on you in respect of your Personal
Information. We aim to be clear about what Personal Information we collect so that you can make meaningful choices about what Personal Information you make available to us. You may, for example:
13.1.1 request access to your Personal Information (commonly known as a “data subject access request”), which indicates what Personal Information we have about you.
13.1.2 request the correction of your Personal Information, in order to ensure that any incomplete or inaccurate Personal Information is corrected.
13.1.3 request erasure of your Personal Information, where there is no lawful basis for the retention or continued processing of it.
13.1.4 object to the processing of your Personal Information for a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
13.1.5 request restriction of processing of your Personal Information. This enables you to ask Future Indefinite to suspend the processing of your Personal Information in limited circumstances, which may differ by jurisdiction.
13.1.6 withdraw consent which you previously gave to the processing of your Personal Information at any time. You may withdraw your consent for us to process your Personal Information at any time. The withdrawal of your consent can only be made by you on condition that such withdrawal of your consent:
188.8.131.52 does not affect the processing of your Personal Information before the withdrawal of your consent; or
184.108.40.206 does not affect the processing of your Personal Information if the processing is in compliance with an obligation imposed by law on us; or
220.127.116.11 does not affect the processing of your Personal Information where such processing is necessary for the proper performance of a public law duty by a public body; or
18.104.22.168 does not affect the processing of your Personal Information as required to finalize the performance of a contract in which you are a party; or
22.214.171.124does not affect the processing of your Personal Information as required to protect your legitimate interests or our own legitimate interests or the legitimate interests of a third party to whom the information is supplied.
126.96.36.199Withdrawal of consent may limit our ability to provide certain services to you or the ability of a third party to provide certain services to you, but will not affect the continued processing of your Personal Information in instances in which your consent is not required.
13.2 As far as the law allows, we may charge a fee for attending to any of the above requests, and may also refuse to carry out any of your requests in whole or in part.
15.1 The Website and our services are not targeted at people under the age of 18.
15.2 We may in limited instances process Personal Information of children including in the course of providing services to you. In such cases, the processing of Personal Information of children is conducted with the consent of a competent person or to comply with an obligation in law.
15.3 We will not knowingly collect Personal Information of persons in this age group without express consent to do so or without a legal obligation to do so.
15.4 For any questions in respect of the processing of Personal Information of children, please contact the Information Officer or your Future Indefinite contact.
16. Direct Marketing
16.1 Future Indefinite processes Personal Information for the purpose of direct marketing by way of
electronic communication. We will only send you direct marketing materials if you have specifically opted-in to receive these materials, or if you are a client of Future Indefinite, at all times in accordance with applicable laws.
16.2 If you complete the subscription form on the Website, you agree to receive marketing communication from us.
16.3 You may refuse to accept, require us to discontinue, or pre-emptively block any approach or communication from us if that approach or communication is primarily for the purpose of direct marketing (“direct marketing communications”).
16.4 You may opt out of receiving direct marketing communication from us at any time by requesting us (in any manner, whether telephonically, electronically, in writing or in person) to stop providing any direct marketing communication to you. You may send your opt-out requests to firstname.lastname@example.org.
17. Third Party Sites
or services such websites advertise and which may be linked to our Website, or websites that link to or advertise on our Website.
18.6 Should you feel that your rights in respect of your Personal Information have been infringed, please address your concerns to the Information Officer email@example.com If you feel that the attempts by Future Indefinite to resolve the matter have been inadequate, you may lodge a complaint with the South African Information Regulator by accessing their website at www.justice.gov.za/inforeg.