CHRISTOPHER GROUP PRIVACY POLICY

1. CHRISTOPHER GROUP

Christopher Group consists of:

1. Christopher Holdings (Pty) Ltd (Registration no: 2004/032158/07)
2. Christopher Commercial Properties (Pty) Ltd (Registration no: 2007/016575/07)
3. Christopher Litigation Fund (Pty) Ltd (2006/024112/07);
4. Christopher Consulting (Pty) Ltd (Registration no: 2009/011461/07);
5. Christopher Finance (Pty) Ltd (Registration no: 2015/260386/07);
6. WeDiscount (Pty) Ltd (Registration no: 2015/338241/07).

This Privacy Policy applies to each company within the Christopher Group.

2. PERSONAL INFORMATION – CONSENT:

3. The Christopher Group recognises the importance of protecting the privacy of Personal Information as defined in the Protection of Personal Information Act, No 4 of 2013 (“POPI”).
4. The Group is committed to protecting and preserving the Personal Information of any of its clients and any visitor to its website.
5. By using the Christopher Group website, you agree that the Christopher Group, its directors, consultants, employees, agents and subcontractors, affiliates and/or third parties may process (which will include collecting, using and disclosing) your Personal Information for the purposes stated in this Policy. If you do not agree with the Group processing activities described in this Policy, please do not use the Christopher Group
6. Personal Information will not be used for any purposes not mentioned in this Policy without your consent.

3. PERSONAL INFORMATION COLLECTED

1. 1. The Personal Information the Christopher Group collects and processes may include, but is not limited to, your contact information when you apply for any of our products or request to be contacted.
   2. Christopher Group strives to collect only Personal Information which is necessary for the intended purpose of collecting it.
   3. Personal Information which is collected automatically with each visit to the Christopher Group website, includes, but is not limited to:
      (i) 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
      (ii) information about your use of the Christopher Group website including details of your visits such as pages viewed and the resources that you accessed. Such information includes trace data, location data and other communication data.

4. USE OF PERSONAL INFORMATION

1. 1. Personal Information will only be collected, disclosed, or otherwise processed in accordance with this Policy.
   2. Personal Information will not be retained for longer than is necessary to achieve the purpose for which it was collected unless there is a lawful basis or legal requirement for it to be retained for a longer period.

5. SHARING OF PERSONAL INFORMATION

1. Christopher Group may disclose your Personal Information to our third-party service providers, only when
2. Christopher Group requires that our service providers take appropriate, reasonable, technical and organisational measures to keep your Personal Information secure.
3. The Christopher Group service providers may not use or disclose Personal Information for any purpose other than providing the services on our behalf.
4. Christopher Group may also disclose your Personal Information:
   (i) when such disclosure is necessary to protect the legitimate interests (safety, property or other rights) of Christopher Group, our directors, employees, consultants, or any other person, or where required or permitted by law; or
   (ii) if Christopher Group is under a duty to disclose or share your Personal Information in order to comply with any legal obligation.
5. There is a possibility that the Personal Information collected from you may have to be transferred to, and stored at, a destination outside of the Republic of South Africa (for example, by a third-party data hosting service provider).
6. Insofar as your information may be transferred outside of South Africa, Christopher Group will take reasonable organisational and/or contractual measures to ensure that your personal information is processed by such third-party service providers for the purposes for which it has been provided to Christopher Group and that the required levels of protection have been implemented by such third-party service providers to safeguard your Personal Information.
7. You agree that once your Personal Information has been de-identified (i.e. Christopher Group deletes any information that identifies you) such de-identified information may be shared in the following circumstances:
   (i) To Christopher Group’s agents, advisers, service providers and suppliers (this may include our CRM provider; search engine optimisation agency, creative, brand, digital and media agencies, Microsoft, Google and other research agents);
   (ii) To monitor web trace: web servers serving the Christopher Group website automatically collect information about you in relation to the Christopher Group website pages you visit; and
   (iii) For statistics purposes: Christopher Group may perform statistical analyses to measure interest in the various areas of the Website

6. SAFEGUARDING OF PERSONAL INFORMATION

Christopher Group will take all appropriate, reasonable, technical and organisational measures to safeguard your Personal Information to prevent loss of, damage to or unauthorised destruction of your Personal Information or unlawful access to or processing of your Personal Information.

7. HOW TO ACCESS AND UPDATE YOUR PERSONAL INFORMATION

1. 1. Christopher Group will take reasonable steps to keep your Personal Information accurate and complete.
   2. You can request access to any of your Personal Information that is held by us at any time and for any purpose, including to request that Christopher Group correct your Personal Information if it is inaccurate or delete the Personal Information if Christopher Group is no longer required to retain it by law or for a legitimate purpose.
   3. Requests to access Personal Information held on you in accordance with this Policy can be made to andre.burger@christophergroup.co.za.

8. USE OF COOKIES

1. 1. The Christopher Group website uses cookies, which are small text files sent by a web server to store on a web browser. They are used to ensure websites function properly, store user preferences when needed and collect anonymous statistics on website usage.
      (i)  First party cookies
      Session cookie – This cookie contains a randomly generated number and allows the browser to remember your selections. It expires when you close the browser and contains no personally identifiable information
      (ii) Third party cookies
      Google Analytics – These cookies are used to collect anonymous website statistics such as the number of visitors in a month, average duration of visits and popular pages viewed. This data is used to review and improve the site.
      Jetpack – Analytics and Performance. Performance cookies collect information on how users interact with our websites, including what pages are visited most, as well as other analytical data. We use these details to improve how our websites function and to understand how users interact with them.
      reCaptcha – reCAPTCHA API works by collecting hardware and software information, such as device and application data, and sending these data to Google for analysis. The information collected in connection with your use of the service will be used for improving reCAPTCHA and for general security purposes. It will not be used for personalized advertising by Google. Pursuant to Section 3(d) of the Google APIs Terms of Service, you agree that if you use the APIs that it is your responsibility to provide any necessary notices or consents for the collection and sharing of this data with Google.
   2. You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of the Christopher Group Unless you have adjusted your browser setting so that it will refuse cookies, the Group’s system will issue cookies when you log on to the Website. If you accept a “cookie” or fail to deny the use of “cookies”, you agree that the Group 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.

9. USE OF IP ADDRESSES

Christopher Group also collects information that does not identify you personally through the Internet log files, which record data such as IP addresses, browser types and other anonymous statistical data. This information may be used to analyse trends and to gather general demographic information. We do not link this information to personally identifiable information.