Privacy Policy

We collect information you provide directly to us, including: • **Personal Information**: Name, email address, phone number, ID number (for FICA compliance where applicable) and physical address when you create an account or contact us. • **Property Information**: Details about properties you list, including location, price, features, and ownership documentation. • **Payment Information**: Payment details when you subscribe to our agent services (processed via secure third-party gateways). • **Communications**: Records of your communications with us and other users through our platform. • **Usage Data**: Information about how you use our services, including pages visited, search queries, device information, and interactions with listings.

We use the information we collect to: • Provide, maintain, and improve our services • Process transactions and send related information • Send you technical notices, updates, security alerts, and support messages • Respond to your comments, questions, and requests • Communicate with you about products, services, offers, and events • Monitor and analyze trends, usage, and activities • Detect, investigate, and prevent fraudulent transactions and other illegal activities • Personalize and improve your experience on our platform • Comply with legal obligations (e.g., FICA, Tax Administration Act)

We may share your information in the following circumstances: • **With Agents/Buyers**: Property inquiries are shared with the relevant agents; listings are visible to potential buyers. • **Service Providers**: Third-party vendors who perform services on our behalf (hosting, analytics, payment processing, email delivery). • **Legal Requirements**: When required by law (e.g., pursuant to a subpoena or court order) or to protect our rights, privacy, safety, or property. • **Business Transfers**: In connection with any merger, sale, or acquisition of company assets. We do not sell your personal information to third parties for marketing purposes.

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include: • Encryption of data in transit (TLS) and at rest • Regular security assessments and penetration testing • Access controls and authentication mechanisms • Employee training on data protection • Incident response procedures However, no method of transmission over the Internet is 100% secure, and we cannot guarantee absolute security.

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, including limiting retention to: • **Account Data**: Retained while your account is active plus 3 years thereafter. • **Transaction Records**: Retained for 5 years as required by the Tax Administration Act and FICA. • **Communication Records**: Retained for 3 years for dispute resolution and quality assurance. • **Marketing Data**: Retained until you opt-out or unsubscribe. When data is no longer needed, it is securely deleted or anonymized.

Your information may be transferred to and maintained on servers located outside of South Africa. We ensure that such transfers comply with POPIA, utilizing: • **Adequacy Decisions**: Transferring to countries with data protection laws substantially similar to POPIA (e.g., GDPR zone). • **Binding Agreements**: Ensuring data recipients are bound by binding corporate rules or standard contractual clauses that uphold POPIA standards. By using our service, you consent to this transfer.

You have the following rights regarding your personal data under POPIA: • **Access**: Request a copy of your personal data we hold. • **Correction**: Request correction of inaccurate or incomplete data. • **Deletion**: Request deletion of your personal data under certain circumstances ("Right to be Forgotten"). • **Objection**: Object to processing of your data for certain purposes. • **Portability**: Request transfer of your data to another service provider. • **Withdrawal**: Withdraw consent at any time where processing is based on consent. To exercise these rights, please contact our Information Officer at privacy@luxeza.co.za.

We use cookies and similar tracking technologies to enhance your experience: • **Essential Cookies**: Necessary for the website to function (e.g., authentication). • **Functional Cookies**: Remember your preferences (e.g., language, search filters). • **Analytics Cookies**: Help us understand how visitors use our site (e.g., Google Analytics). • **Marketing Cookies**: Deliver relevant advertisements (enabled only with your consent). You can control cookies through your browser settings. Disabling cookies may affect some functionality of our services.

Our services are not directed to children under 18. We do not knowingly collect personal information from children. If we become aware that we have collected data from a child, we will take steps to delete it.

If you have questions about this Privacy Policy or our data practices, please contact our Information Officer: **Information Officer**: Chief Privacy Officer **Email**: privacy@luxeza.co.za **Address**: 123 Main Street, Sandton, Johannesburg, 2196 **Phone**: +27 11 123 4567 **Information Regulator (South Africa)**: If you are unsatisfied with our handling of your data, you may complain to the Information Regulator: Email: complaints.IR@justice.gov.za Website: https://www.justice.gov.za/inforeg/