Privacy Notice

Privacy Notice
Last reviewed: 17 August 2021


  1. Introduction
    Zwartkloof Private Game Reserve (“ZPGR”) Homeowners’ Association (“HOA”, “the HOA” or “we”) is committed to protect Personal Information which is collected, processed and stored when you interact with us.

    This Privacy Notice (“this Notice”) will inform you about what we collect, how it is processed, and the reasonable technical and organisational measures put in place to protect Personal Information.

  2. What is Personal Information?
    Personal Information means any information that can be used to identify you or relates specifically to you. Comprehensive definitions are available in the Protection of Personal Information Act 4 of 2013 (“POPIA”), legislation enacted to protect the Constitutional right to privacy by establishing minimum requirements for the processing of such information.

  3. Personal Information we collect
    Depending on the purpose related to collection, we may collect some or all of the following Personal Information from you:
    • Full names, nickname and surname
    • Identity and/or passport number(s) and nationality
    • Telephone numbers
    • Email addresses
    • Residential, postal and/or business address(es)
    • Bank account information
    • Biometric information (fingerprints, facial images)
    • Race, gender, language, date of birth, marital status
    • Correspondence (electronic, voice, other)
    • Cookies (refer to section 7 of this Notice)
    • Vehicle identification information (make, model, colour, registration number, VIN)
    • Firearm identification information (make, model, calibre, serial number)
    • Educational, employment, financial, criminal history

  4. How we collect Personal Information
    We may collect your Personal Information during the course of:
    • Using our website
    • Communicating with us (voice, electronic, other)
    • Becoming a member of the HOA, including co-owners of property, their family members and the trustees, directors and authorised representatives of juristic persons
    • Entering or accessing ZPGR as a visitor, guest, tenant, service provider, contractor, employment, recruitment, prospective buyer or for any other reason
    • Performing video surveillance for security purposes

      The collection and processing of Personal Information may be performed on behalf of the HOA by third party service providers (“Operators”) mandated to perform these activities.

  5. How we use Personal Information
    The HOA will collect and process Personal Information only for specific lawful purposes related to its activities, including to:
    • Validate personal identity and control access to ZPGR
    • Enable safety and security on ZPGR within practical limits and within reasonable control of the HOA and its service providers
    • Preserve, enhance, manage and maintain the land (inclusive of fauna and flora), environment, infrastructure, buildings and services for the common good of ZPGR and the HOA
    • Enforce the Codes, Rules, Regulations and Policies of ZPGR
    • Protect the interests of the HOA Members
    • Enable you to make use of our website and the services offered thereon, including to enhance your website use (browsing) experience by understanding how you use it, and which pages you visit

      The HOA will not use your Personal Information for a secondary or unrelated purpose (further processing) not compatible with the original purposes without your consent.

  6. How we safeguard Personal Information
    The HOA will implement all reasonable steps and measures to safeguard your Personal Information to secure it from loss, unauthorised use or alteration, including:
    • Appointing an Information Officer responsible for ensuring compliance with POPIA
    • Ensuring that the people processing your Personal Information are aware of and informed on their responsibilities and subject to a duty of confidentiality
    • Limiting the number of people with access to your Personal Information to only those that need to process it in the execution of their duties in performing the HOA’s lawful purposes
    • Ensuring that our information systems incorporate the relevant safety and security measures to protect your Personal Information against unauthorised access

  7. About cookies
    Cookies are text files containing small amounts of information, which are downloaded to your computer or mobile device when you visit a website, including ours. They allow the website to recognise your device and to personalise and enhance your browsing experience.

    Cookies perform a number of functions, such as letting you navigate between pages efficiently, remembering your preferences and generally improving the user experience.

    You can manage your device’s cookie and tracking mechanism settings in the browser settings. The settings you make will only apply to the browser you use. You may deactivate all cookies, but this may affect the functionality of the website.

    For more information, visit

  8. Third party collection and processing
    Our website may contain hyperlinks to the websites of third parties. The HOA cannot assume responsibility for the confidential processing of your Personal Information on these websites as we have no control on whether these third parties comply with POPIA and other information protection regulations.

    The HOA cannot assume responsibility for the confidential processing of your Personal Information by any member of the HOA not specifically mandated to process such information on its behalf or in any act that involves processing of your Personal Information that is unrelated to the activities of the HOA (e.g. property sales transactions and vacation rentals).

  9. You and your Personal Information
    The HOA would like to ensure that you are aware of the rights POPIA confers on you with regards to your Personal Information.
    • You have the right to be informed if your Personal Information is being collected (this Notice) and if there are reasonable grounds to believe that this information has been accessed by an unauthorised person
    • You have the right to request access to your Personal Information
    • You have the right to request that your Personal Information be corrected or deleted, where relevant or necessary.
    • You have the right to object to the processing of your Personal Information to the extent that it does not prevent the HOA from performing its obligations and duties or any statutory requirements.
    • You have the right to object to the processing of your Personal Information for the purposes of Direct Marketing, including by means of unsolicited electronic communications.
    • You have the right to submit a complaint to the Information Regulator regarding any perceived infringement of any of your rights (

      If you would like to exercise any of these rights, please contact the HOA on the email address provided below.

  10. Our contact details
    Zwartkloof Private Game Reserve Homeowners’ Association NPC

    Reg No 2005/027184/08
    (incorporated under Section 21 of the Companies Act)

    Please contact the HOA on

    All queries regarding this Notice or your Personal Information will be forwarded to the Information Officer.

  11. Changes to this Notice
    The HOA may at any time review and change this Notice by making an amended Notice available on its website.

    This Notice was last updated on 17 August 2021.