PRIVACY POLICY

Date of Compilation: 30 June 2021

Date of Last Revision: 30 June 2021

This Privacy Policy applies to Assheton-Smith Ginsberg Incorporated’s website (www.asg.law), social network platforms and the utilisation of our services and related offerings. This policy sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us.

For the purpose of the Protection of Personal Information Act 4 of 2013 (the Act), our nominated Information Officer is: Craig Assheton-Smith. It is Assheton-Smith Ginsberg Incorporated’s policy to respect your privacy regarding any information we may collect from you while utilising our websites and/or services.

Date of Compilation: 30 June 2021

Date of Last Revision: 30 June 2021

1. ONLINE SERVICE SUBSCRIBERS / WEBSITE VISITORS

We may collect and process the following Information about you:

1.1 NON-PERSONALLY IDENTIFIABLE INFORMATION

Assheton-Smith Ginsberg Incorporated collects information typically made available by web browsers and servers, such as, but not limited to browser type, language preference, referring site and date and time of each visit, to better understand how visitors use its website.

1.2 Potentially personally identifiable information

With regard to each of your visits to our site we may automatically collect technical information, including but not limited to the Internet protocol (IP) address used to connect your computer to the Internet, your login information (where applicable) and other similar useful technical information about your visit to our sites. Assheton-Smith Ginsberg Incorporated will only use and disclose this information under the same circumstances as those applicable in respect of personally identifying information as described below.

2. PERSONALLY IDENTIFYING INFORMATION

2.1 When you engage our services, we require personal information including, but not limited to, your name, identity number, contact details, home, or work physical address, municipal accounts, bank financial statements and other records typically required for Financial Intelligence Centre Act, 2001 (“FICA”) or related legislative or regulatory purposes. Assheton-Smith Ginsberg Incorporated uses this collected information for service delivery, billing, identification and authentication and communications purposes.

2.2 We use your Personal Information in the ordinary course of our business to provide you with our legal services, to administrate and improve our sites, to analyse the use of our sites and to keep you informed about other services and/or legal service relatedproducts that we belief may be of interest to you. We also use your personal information to send you our monthly newsletter, connect with you on social media, provide legal updates, or invite you to events we organise for our clients and contacts.

2.3 Assheton-Smith Ginsberg Incorporated may potentially disclose personally identifying information with our personnel and contractors, such as counsel, opposing attorneys where relevant to a matter and other persons (cost consultants, judges, registrars, tracing agents, etc.), in order to effectively perform our services as utilised or requested.

2.4 Depending on the circumstances, certain of the persons mentioned above may be situated outside of your home country. By using Assheton-Smith Ginsberg Incorporated’s website and/or services you consent to the possible transfer and storage of such information outside of your home country for the purposes outlined above, and therefore you accept that such transfer is not in violation of any laws.

2.5 If you do not want us to use your personal information as stipulated in 2.3 and 2.4 above, you are free to refrain from submitting your personal information to us, or where you have already submitted personal information to us you can either request in writing via info@asg.law that we refrain from using your personal information. This however may inhibit and/or prevent us from providing services to you or from providing optimal services to you.

2.6 Occasionally the personal information collected will be transferred to, and stored at a destination outside of the Republic of South Africa (“RSA”) for more effective provision of our services.

2.7 Whilst we cannot guarantee the absolute security of your personal information, Assheton-Smith Ginsberg Incorporated takes all measures reasonably necessary to protect against the unauthorised access, use, alteration or destruction of potentially personally identifiable information or personally identifiable information.

2.8 Although we will use appropriate and reasonable technical and organisational measurements to protect your personal information, we cannot guarantee the security of your data transmitted to our site or to any other location by electronic means; any transmission is at your own risk. Once we have received your personal information, we will use appropriate and reasonable technical and organisational measurements to try to prevent unauthorised access.

2.9 Records of personal information will not be retained for longer that is necessary for operational or archiving purposes for which the information was collected, unless retention of record is required or authorised by law. Records of personal information may be retained for periods in excess of those contemplated for historical, statistical or research purposes, subject to us establishing appropriate safeguards against the records being used for any other purpose and or we have de-identified the record(s).

2.10 Submission of Personal Information on behalf of another: Kindly take note that if you provide information on behalf of someone else, then it is your responsibility to obtain the necessary consent from such person before making the information available to us. On receipt of personal information, we assume that the necessary consent has been obtained and will process the Personal Information as per your instructions. You indemnify us against any third party claim where a third party claim that personal information have been processed without the necessary consent or other available exception under the Act (see Promotion of Access to Information Act 2 of 2000 for more information).

2.11 Assheton-Smith Ginsberg Incorporated will not intentionally collect and process the personal identifiable information of a child unless we have the permission of a competent person or unless such information is provided to us as part of the provision of legal services.

3. COOKIES & SIMILAR TECHNOLOGIES

3.1 We may use cookies or similar technologies to help identify and track visitors to our website, understand the use of our site better and access preferences.

4. DIRECT MARKETING

4.1 We may Process your Personal Information for the purposes of providing you with information regarding services that may be of interest to you. You may unsubscribe for free at any time.

4.2 If you currently receive marketing information from us which you would prefer not to receive in the future, please email us at info@asg.law or click on the Unsubscribe option on electronic communications.

5. CHANGES TO OUR PRIVACY POLICY

Assheton-Smith Ginsberg Incorporated may change its Privacy Policy from time to time. Any subsequent changes will be posted to the website and therefore you should check Assheton-Smith Ginsberg Incorporated’s Privacy Policy regularly, as your continued use of our website and services will constitute your acceptance of such change. We will notify you about any significant changes in the way we deal with your potentially personally identifying information and your personally identifying information by sending a notice to the primary email address specified in your account or by placing a prominent notice on our websites.

6. CONTACT DETAILS

Questions, comments, and requests regarding this privacy policy are welcomed and should be addressed to:

CRAIG ASSHETON-SMITH

craig@asg.law

+27 21 424 7390