PRIVACY POLICY AND INFORMED CONSENT NOTICE

CONSENT TO PROCESS PERSONAL INFORMATION IN TERMS OF THE PROTECTION OF INFORMATION ACT, 4 OF 2013 (POPIA)

The Protection of Personal Information Act, 4 of 2013 (POPIA) gives effect to the constitutional right to data privacy in terms of Section 14 of the Bill of Rights of the Constitution.

RED METAL MINING SOUTH AFRICA (PTY) LTD acknowledges and supports consumer rights and the right to privacy. Accordingly, our clients’ privacy and trust are extremely important to us. We will ensure that personal information (“information”) is collected and handled in a transparent and lawful manner in alignment with the Protection of Personal Information Act, 2013 (“POPIA”).

This Policy sets out the responsibilities and obligations of all persons who make use of, or access, or receive RED METAL MINING SOUTH AFRICA (PTY) LTD information and communications via its electronic communication facilities and resources including its social media platforms, app, website, email and/or messaging platforms, telephone facilities, and CCTV.

• By submitting any information to RMM, you provide consent to the processing of your personal information as set out in this Policy.
• The provisions of this Policy are subject to mandatory, unalterable provisions of applicable laws.
• Please do not submit any information to RMM if you do not agree to any of the provisions of this Policy. If you do not consent to the provisions of this Policy, or parts of the Policy, RMM may not be able to provide its information, products and/or services to you.

• To implement reasonable computer (logical), physical and procedural (process) safeguards to protect the security and confidentiality of the information we collect.
• To limit the information, collected to the minimum required, to provide a service and/or product.
• To permit only trained, duly authorized employees to access information.
• Not to disclose your information to external and/or third parties unless we are required or permitted by law, and authorized by our Information Officer to do so.

1. INTRODUCTION
   1. RED METAL MINING SOUTH AFRICA (PTY) LTD (also referred to herein as “RMM” “we” “us” “our”), in order to carry out its goals and objectives as a manufacturer, marketer and supplier of equipment and services, does, and will, on an ongoing basis receive, provide, and process Personal Information.
   2. In terms of the Protection of Personal Information Act, 4 of 2013 (POPIA), everyone has the right to privacy, including the right to the lawful collection, retention, dissemination, and use of one’s Personal Information.
   3. To give effect to this right, RED METAL MINING SOUTH AFRICA (PTY) LTD is under a duty to provide any person whose Personal Information is processed (“Data Subject”) with a number of details pertaining to the use of and subsequent processing of their Personal Information, before such Personal Information may be used or processed by RMM.
   4. In accordance with this requirement, RED METAL MINING SOUTH AFRICA (PTY) LTD sets out below:
      • the reasons why it will have to process a Data Subject’s Personal Information,
      • the conditions under which it will receive and use a Data Subjects Personal Information,
      • the manner in which Personal Information will be used and handled, as well as
      • the conditions under which it will provide its own Personal Information.
   5. “Personal Information” refers to information related to an identifiable, living, natural person or company, including but not limited to:
      • Identity number and/or passport number,
      • Date of birth, age, race, gender, sex, pregnancy, marital status, ethnic or social origin, color, sexual orientation, physical or mental health, well-being, disability, religion, conscience, belief, culture and language,
      • Information relating to education, medical, financial, criminal or employment history,
      • Contact information: telephone numbers, cell numbers, email addresses, physical addresses, etc.
      • Bio-metric information: blood group etc.
      • Photos, voice recordings, video’s CCTV material etc.
      • The views or opinions of an individual about another individual,
      • Membership of any organization or union.
2. APPLICATION
   1. The Privacy Policy of RED METAL MINING SOUTH AFRICA (PTY) LTD is applicable to:
      • all electronic platforms and facilities, including social media, apps, websites, email and/or messaging platforms, telephone facilities, and CCTV, whether owned by, established by, used by, hosted by and/or accessed by RMM, and
      • all and any Data Subject(s) who may access and make use of the aforementioned electronic platforms and facilities, including, without detracting from the generality thereof, RMM employees and staff, clients and visitors, vendors, contractors, service providers and/or other third parties,
      • all the Personal Information which is owned by RMM and which is provided to any responsible parties and/or operators as a result of such person accessing or making use of the RMM electronic platforms.
3. ACCOUNTABILITY
   1. RED METAL MINING SOUTH AFRICA (PTY) LTD takes the privacy and protection of a Data Subject’s Personal Information very seriously and will only process a Data Subject’s Personal Information for the purpose for which it was collected and in accordance with POPIA and the terms of this Privacy Policy.
   2. In turn, where RED METAL MINING SOUTH AFRICA (PTY) LTD provides any of its Personal Information to a Responsible Party or Operator, then such person will be required as a condition of receiving such information, to process such Personal Information in accordance with POPIA and the terms of this Privacy Policy.
   3. Accordingly, the relevant data privacy principles relating to the processing of Personal Information, whether that belonging to RED METAL MINING SOUTH AFRICA (PTY) LTD or that belonging to a data subject (including, but not limited to, the collection, handling, transfer, sharing, correction, storage, archiving and deletion), will apply without exception, except where POPIA provides for such an exception, to all and any Personal Information provided by RMM to another, or received by RMM as a result of the use of the RMM electronic platforms and facilities.
4. AGREEMENT TO BE BOUND AND CONSENT TO PROCESS
   1. By accessing or using the RED METAL MINING SOUTH AFRICA (PTY) LTD electronic platforms and facilities including our social media, apps, website, email, telephone facilities, and CCTV, the Data Subject:
      • acknowledges that it has read and understood this Privacy Policy and related provisions,
      • agrees to be bound by this Privacy Policy,
      • agrees to comply with this Privacy Policy, and
      • gives RMM consent to collect and further process the required Personal Information for the required purpose, in accordance with this Privacy Policy.
5. RECEIPT, USE AND SHARING OF PERSONAL INFORMATION BY RED METAL MINING SOUTH AFRICA (PTY) LTD.
   1. RED METAL MINING SOUTH AFRICA (PTY) LTD will receive Personal Information pertaining to a Data Subject when the Data Subject submits a query or request via our electronic platforms or facilities, including our social media, apps, website, email, telephone facilities, and CCTV.
   2. On receipt of the request or query, RED METAL MINING SOUTH AFRICA (PTY) LTD will thereafter use and process the Data Subject’s Personal Information for the purpose of the query and for a variety of related purposes, which will all depend on the query or request, and which without detracting from the generality thereof may include:
      • for the purposes of identifying and/or verifying the Data Subject’s details,
      • for the purposes of providing information, products and/or services or details in connection therewith or pertaining thereto, that the Data Subject, may have requested,
      • for trade application and/or purchasing purposes,
      • to enroll the Data Subject as a vendor,
      • for employment application purposes,
      • for the purpose of concluding an employment relationship with an applicant,
      • for the purposes of managing any information pertaining to the Data Subject,
      • for further processing or general administration purposes,
      • for legal or contractual purposes,
      • to help RED METAL MINING SOUTH AFRICA (PTY) LTD improve the quality of our products and services,
      • to help RED METAL MINING SOUTH AFRICA (PTY) LTD detect and prevent fraud and money laundering,
      • for the purposes of recovering unpaid monies and/or any other amount due to RED METAL MINING SOUTH AFRICA (PTY) LTD,
      • for the purpose of debt collection,
      • for the purposes of research, analytical and statistical purposes,
      • for the purpose of carrying out analysis and consumer/customer profiling,
      • for the purposes of identifying other products and services which might be of interest to the Data Subjects,
      • for the purposes of informing a Data Subject about RED METAL MINING SOUTH AFRICA (PTY) LTD products and services.
   3. In order to correctly handle any request or query, and in order to perform the purposes described above, RED METAL MINING SOUTH AFRICA (PTY) LTD may from time to time share a Data Subject’s Personal Information with the following parties:
      • RMM employees, which will only be done on a need-to-know basis,
      • RMM suppliers, which will only be done on a need-to-know basis,
      • RMM carefully selected business partners who provide products and services which may be of benefit to a Data Subject which will only be done on a need-to-know basis, and
      • operators such as service providers and agents who perform services on behalf of RMM which will only be done on a need-to-know basis and in terms of a operator agreement.
   4. RED METAL MINING SOUTH AFRICA (PTY) LTD does not share a Data Subject’s Personal Information with any third parties who have not been described above, unless:
      • RMM is legally obliged to provide such information to another for legal or regulatory purposes,
      • RMM is required to do so for purposes of existing or future legal proceedings,
      • the onward transmission or sharing of Personal Information is necessary for the pursuance or protection of RMM legitimate interests or that of the Data Subject or a third party,
      • RMM is involved in the prevention of fraud, loss, bribery, or corruption and are using another agent or service provider under a mandate to provide such service, and the agent or service provider needs to process the Data Subject’s Personal Information for the purpose of investigating and or preventing any act of fraud, loss, bribery, or corruption,
      • and under all the above-mentioned circumstances, RED METAL MINING SOUTH AFRICA (PTY) LTD will take reasonable measures to ensure that such Personal Information is only provided to the recipient, if such recipient undertakes to keep the Personal Information confidential and secure.
   5. Where RED METAL MINING SOUTH AFRICA (PTY) LTD must transfer the Data Subject’s Personal Information across the South African borders, it will before it does so, ensure that the recipient thereof agrees to be bound by POPIA under and in terms of a set of binding corporate rules or binding agreements that provide an adequate level of protection and uphold the principles for the reasonable and lawful processing of such Personal Information.
6. RECEIPT, USE AND SHARING OF THE RED METAL MINING SOUTH AFRICA (PTY) LTD PERSONAL INFORMATION
   1. RED METAL MINING SOUTH AFRICA (PTY) LTD on receipt and in response to a query or request received from a Data Subject, referred to under section 5 above, may transmit via its website, or by way of email, telephone, or via social media, its own Personal Information, which Personal Information on receipt by the requesting or receiving party, may only be used for the purpose relating to the initiating of the request, or query and for no other purpose. Furthermore, the recipient undertakes that it will not use this Personal Information for any other purpose or share this information with any other party, save where it has been given express permission to do so by RED METAL MINING SOUTH AFRICA (PTY) LTD.
7. INFORMATION QUALITY/OPENNESS/DATA SUBJECT PARTICIPATION
   1. Whilst RED METAL MINING SOUTH AFRICA (PTY) LTD will make every effort to ensure the integrity and accuracy of a Data Subject’s Personal Information, this may always not be possible. Following this, the Data Subject accepts the responsibility for keeping his/her or its Personal Information up to date and undertakes to inform us of any changes to his/her and its Personal Information.
   2. A Data Subject has a right of access to any Personal Information which RED METAL MINING SOUTH AFRICA (PTY) LTD may have and, where applicable, may ask us to correct any inaccuracies in or to any such Personal Information.
8. SECURITY OF PERSONAL INFORMATION
   1. RED METAL MINING SOUTH AFRICA (PTY) LTD will make every reasonable effort to keep its electronic platforms, including social media, apps, website, email and telephone facilities, and CCTV secure. However, RMM cannot guarantee the security of any information provided to it through these electronic platforms. Consequentially, RMM will not be held responsible for any loss, or unauthorized use, or interception of personal information transmitted via these electronic platforms.
   2. The RED METAL MINING SOUTH AFRICA (PTY) LTD website may contain links to other websites outside of our control. RMM will not be held responsible for the content, privacy, or security of third-party websites.
   3. RED METAL MINING SOUTH AFRICA (PTY) LTD may have certain cookies on its website which may be kept on a Data Subject’s device to help improve the user experience on its electronic platforms.
   4. RED METAL MINING SOUTH AFRICA (PTY) LTD makes use of social platforms such as Facebook, YouTube, and LinkedIn. Please note that RMM has no influence or control over the extent of the data retrieved by these social networks’ interfaces and will therefore not be held responsible or liable for any processing or use of Personal Information transmitted via these social platforms. For information about the purpose and extent of data retrieval by the social network concerned, and the rights and settings which are available for you to access for the protection of your private information, please refer to the data protection information provided by the social network in question.
   5. Note that all RED METAL MINING SOUTH AFRICA (PTY) LTD electronic platforms including its social media, apps, website, email and telephone facilities, CCTV, and your use of them will be monitored on a regular basis. By using our electronic platforms and facilities you expressly acknowledge notice of such monitoring and give consent thereto.
   6. Subject to the provisions above, RED METAL MINING SOUTH AFRICA (PTY) LTD has implemented the appropriate technical and organizational security measures which are required in order to protect all Personal Information and related data which it holds against unauthorized access, accidental or willful manipulation, loss or destruction.
9. THIRD PARTY INFORMATION AND THAT BELONGING TO MINORS
   1. If a Data Subject provides RED METAL MINING SOUTH AFRICA (PTY) LTD with Personal Information on behalf of another, RMM will not be able to process the query or request unless such query or request is accompanied with the required permission and consent from the owner of that Personal Information.
   2. If a Data Subject is under the age of 18, such person’s Personal Information will only be processed if the minor’s parent or legal guardian gives the required consent or permission to the processing of the provided Personal Information.
10. CONTACT US
    You can contact RED METAL MINING SOUTH AFRICA (PTY) LTD in relation to this Privacy Policy by sending an email to info@redmetal.co.za or by calling 011 794 9498.
11. INFORMATION REGULATOR OF SOUTH AFRICA
    Should you believe that RED METAL MINING SOUTH AFRICA (PTY) LTD has utilized information contrary to applicable law, you undertake to first attempt to resolve any concerns with RMM. If you are not satisfied with such a process, you have the right to lodge a complaint with the Information Regulator of South Africa.
    The Information Regulator’s contact details are:
    JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
    P.O Box 31533, Braamfontein, Johannesburg, 2017
    inforeg@justice.gov.za
12. REVISION OF POLICIES
    RED METAL MINING SOUTH AFRICA (PTY) LTD reserve the right to and may from time to time update this Privacy Notice. Any such revision will be published as an amended version on the RMM website. Following this, any change to this Policy will be posted as an updated version and readers are advised to visit and re-read this policy on a regular basis.

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