Bulungula Lodge

PRIVACY NOTICE

Last updated 01 July 2024

Welcome to our privacy policy. This is our plan of action when it comes to protecting your privacy. We respect your privacy and take the protection of personal data very seriously. Thank you for choosing Bulungula Lodge Backpackers. (“Company“, “we“, “us“, “our“). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at paradise@bulungula.com. When you visit our website https://bulungula.com (the “Website“), and more generally, use any of our services (the “Services“), which include the Website. In this privacy policy, we seek to explain to you what information we collect, how we use it and what rights you have in relation to it. Please take time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately. This privacy notice applies to all information collected through our Services (which, as described above, includes our Website), as well as, any related services, sales, marketing or events.

TABLE OF CONTENTS

WHAT INFORMATION DO WE COLLECT?
HOW DO WE USE YOUR INFORMATION?
WILL YOUR INFORMATION BE SHARED WITH ANYONE?
WHO WILL YOUR INFORMATION BE SHARED WITH?
DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
HOW DO WE HANDLE YOUR SOCIAL LOGINS?
HOW LONG DO WE KEEP YOUR INFORMATION?
HOW DO WE KEEP YOUR INFORMATION SAFE?
WHAT ARE YOUR PRIVACY RIGHTS?
CONTROLS FOR DO-NOT-TRACK FEATURES
DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
DO WE MAKE UPDATES TO THIS NOTICE?
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT? Personal information you disclose to us

Briefly: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Website, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Website (such as by posting messages in our online forums or entering competitions, contests or giveaways) or otherwise when you contact us. The personal information that we collect depends on the context of your interactions with us and the Website, the choices you make and the products and features you use. The personal information we collect may include the following:

Personal Information Provided by You. We collect names; phone numbers; email addresses; usernames; passwords; contact preferences; billing addresses; contact or authentication data; and other similar information.

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by Datatrans and Nedbank card processing and Iveri. You may find their privacy notice link(s) here: https://www.datatrans.ch/en/privacy-policy/ and https://personal.nedbank.co.za/home/nedbank- privacy-notice.html

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the Information described in the section called “HOW DO WE HANDLE YOUR SOCIAL LOGINS” below. All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

Briefly: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Website.

We automatically collect certain information when you visit, use or navigate the Website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Website and other technical information. This information is primarily needed to maintain the security and operation of our Website, and for our internal analytics and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings).

Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access the Website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.

Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Website. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services.

2. HOW DO WE USE YOUR INFORMATION?

Briefly: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Website for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

To facilitate account creation and logon process. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the See the section below headed “HOW DO WE HANDLE YOUR SOCIAL LOGINS” for further information.
To post testimonials. We post testimonials on our Website that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the If you wish to update, or delete your testimonial, please contact us at paradise@bulungula.com and be sure to include your name, testimonial location, and contact information.
Request We may use your information to request feedback and to contact you about your use of our Website.
To enable user-to-user We may use your information in order to enable user-to-user communications with each user’s consent.
To manage user We may use your information for the purposes of managing our account and keeping it in working order.
To send administrative information to We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
To protect our We may use your information as part of our efforts to keep our Website safe and secure (for example, for fraud monitoring and prevention).

§ To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.

To respond to legal requests and prevent If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
Fulfill and manage your We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Website.
Administer prize draws and We may use your information to administer prize draws and competitions when you elect to participate in our competitions.
To deliver and facilitate delivery of services to the We may use your information to provide you with the requested service.
To respond to user inquiries/offer support to We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
To send you marketing and promotional We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our

Website, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS” below).

Deliver targeted advertising to you. We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

Briefly: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share your data that we hold based on the following legal basis:

Consent: We may process your data if you have given us specific consent to use your personal information for a specific
Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are

More specifically, we may need to process your data or share your personal information in the following situations:

Business We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Vendors, Consultants and Other Third-Party Service We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Website, which will enable them to collect data on our behalf about how you interact with our Website over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, pages or features, and better understand online activity. Unless described in this notice, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.

Business We may share your information with our business partners to offer you certain products, services or promotions.

4. WHO WILL YOUR INFORMATION BE SHARED WITH?

Briefly: We only share information with the following third parties.

We only share and disclose your information with the following third parties. We have categorized each party so that you may be easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us using the contact details

provided in the section below titled “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?“.

§ Allow Users to Connect to Their Third-Party Accounts

Facebook account, Google account and Instagram account

§ Social Media Sharing and Advertising

Facebook, Google & other online advertising

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

Briefly: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

Briefly: If you choose to register or log in to our services using a social media account, we may have access to certain information about you.

Our Website offers you the ability to register and login using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, profile picture as well as other information you choose to make public on such social media platform. We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Website. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

Briefly: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

Briefly: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account at any time.

If you are a resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

If you have questions or comments about your privacy rights, you may email us at paradise@bulungula.com

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list — however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may:

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

12. DO WE MAKE UPDATES TO THIS NOTICE?

Briefly: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at paradise@bulungula.com.

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

You may have the right to access your personal data by sending a written request to

paradise@bulungula.com. We may charge you a fee for this service as set out in terms of Condition 8 of POPIA.

You may also request Bulungula Lodge Backpackers to correct or supplement any of your personal data which Bulungula Lodge Backpackers will undertake as soon as practicable, by sending a mail to paradise@bulungula.com
Request the destruction of your personal The Information Officer will consider your request in light of any other laws or regulations prohibiting Bulungula Lodge Backpackers from destroying your personal data.
We would appreciate it if you would keep your personal information Please update your information by contacting us at paradise@bulungula.com

15. HOW TO COMPLAIN.

If you have any concerns about our use of your personal information, you can make a complaint to us at paradise@bulungula.com

Should you believe that Bulungula Lodge Backpackers has utilised your personal information contrary to Applicable Laws, you undertake to first attempt to resolve any concerns with Bulungula Lodge Backpackers. If you are not satisfied with such process, you have the right to lodge a complaint with the Information Regulator, using the contact details listed below.

The Information Regulator (South Africa)

JD House, 27 Stiemens Street,

Braamfontein, Johannesburg, 2001

P.O Box 31533, Braamfontein, Johannesburg, 2017

POPIA Complaints email: POPIAcomplaints.IR@justice.gov.za PAIA Complaints email: PAIAcomplaints.IR@justice.gov.za

Bulungula Backpackers Lodge

Section 51 Manual in terms of the Promotion of Access to Information Act

CONTENTS

A . INTRODUCTION TO BULUNGULA BACKPACKERS LODGE

B. PARTICULARS IN TERMS OF TH SECTION 51 MANUAL

1. Contact Details

2. Guide on How to use the Act

3. Records available in terms of any other legislation

4. Access to the records held by Bulungula Backpackers Lodge

5. Other information as may be prescribed

6. Availability of the Manuel

7. Prescribed fees and prescribed form of request

A. INTRODUCTION TO BULUNGULA BACKPACKERS LODGE

Bulungula offers unique backpackers style accommodation in either private or dorm rondavel style rooms or permanent dome tents. It can sleep up to a maximum of 40 guests. The lodge is built on community land and is 100% run and owned by the local community.

B. PARTICULARS IN TERMS OF THE SECTION 51 MANUAL

1. Contact Details [Section 51(1)(a)] The Head: Lindile Mthiyo

Postal Address: P.O. Box 52913, Mthatha, 5099

Street Address: Farm 37, Xhora Mouth AA, Elliotdale District 5070

Telephone: 047 577 8900

Fax: 086 653 1327

Email: lindile@bulungula.com

Web: www.bulungula.com

2. Description of the Guide on how to use the Act [Section 51(1)(b)]

The Promotion of Access to Information Act grants a requester access to the records of a company, if the record is required for the exercise or protection of any rights. If a public body lodges a request, the public body must be acting in the public interest. Requests in terms of the Act are required to be made in accordance with the prescribed procedures, at the rates provided.

A Guide on how to use the Act has been compiled by the South African Human Rights Commission (SAHRC). The Guide is available in all the official languages, and is available on the website of the SAHRC or by contacting the SAHRC:

The South African Human Rights Commission PAIA Unit

The Research and Documentation Department Private Bag 2700, Houghton, 2041

29 Princess of Wales Terrace, c/o York and St. Andrews Street,

Parktown

http://www.sahrc.org.za; Email: paia@sahrc.org.za Tel (011) 484 8300; Fax (011) 484 0582

3. Records available in terms of any other legislation [Section 51(1)(d)]

Records are kept and are available upon specified conditions in accordance with such other legislation as is applicable to Bulungula Backpackers Lodge including:

Basic Conditions of Employment Act 75 of 1997
Companies Act 61 of 1973
Compensation for Occupational Injuries & Disease Act 130 of 1993
Income Tax Act 58 of 1962
Labour Relations Act 66 of 1995
Non Profit Organisations Act 71 of 1997
Occupational Health & Safety Act 85 of 1993
Skills Development Act 9 of 1999
Skills Development Levies Act 9 of 1999
Unemployment Contributions Act 4 of 2002
Unemployment Insurance Act 63 of 2001
Value Added Tax Act 89 of 1991

4. Access to the records held by Bulungula Backpackers Lodge [Section 51(1)(c)]and [Section 51(1)(e)]

The categories of records that are available without a person having to request access in terms of the Act [Section 51(1)(e)]
Annual Reports (from mid-2006)
Brochures
Newsletters

4.2 Records that may be requested

A. Company Records

Memorandum and Articles of Association
Minutes of Board of Directors meetings
Proof of company registration
Proof of SETA registration (Services SETA)
Proof of Workmen’s Compensation Registration
Records relating to the appointment of directors and auditor
Tax clearance certificate

B. Financial Records

Accounting records
Asset register
Annual Financial Statements (only available from mid-2006, first financial year ends on 28 February 2006
Banking records
Contracts
invoices
Rental agreement

C. Tax Records

Documents issued to employees for income tax purposes
Documents issued to consultants for income tax purposes
Records of PAYE payments made to SARS on behalf of employees
Records of payments made in relation to VAT, Skills Development Levy, UIF and Workmen’s Compensation
Tax returns (from 2006 on)

D. Personnel Records

Employment contracts
Performance management records
Personnel records
Remuneration records and policies

E. Company policies

Crisis communications policy
Financial policies and procedures
Internship policy
Partnership policy
Website link policy
Workplace policies and procedures manual

F. Operational documents and records

Budgets
Business plan
Certification records
Client records
Correspondence
Funding proposals
Legal records and correspondence
Marketing strategies and related records
Monitoring and evaluation reports
Reports to donors
Research reports
Training materials

4.3 The request procedure

Address your request:

Postal Address: P.O. Box 52913, Mthatha, 5099

Telephone: 047 577 8900 Email: lindile@bulungula.com Web: www.bulungula.com

Forms of Request:

The requester must use the prescribed format (Form C, example attached) to make the request for access to a record. This must be made to the head of Bulungula Backpackers Lodge. This request must be faxed or electronically mailed or hand delivered to the body concerned [Section 53(1)].
The requester must provide sufficient details on the request form to enable the head of Bulungula Backpackers Lodge to identify the record and the requester. The requester should also indicate which form of access is required. The requester should also indicate if any other manner is to be used to inform the requester and state the necessary particulars to be so informed [Section 53(2)(a) and (b) and (c)].
The requester must identify the right that is sought to be exercised or to be protected and provide an explanation of why the requested record is required for the exercise or protection of that right [Section 53(2)(d)].
If a request is made on behalf of another person, the requester must then submit proof of the capacity in which the requester is making the request to the satisfaction of the head of Bulungula Backpackers Lodge [Section 53(2)(f)].

5. Other information as may be prescribed [Section 51(1)(f)]

The Minister of Justice and Constitutional Development has not made any regulations in this regard.

6. Availability of the Manual [Section 51(3)]

This Manual is available for inspection at the offices of Bulungula Backpackers Lodge free of charge, and on the Bulungula Backpackers Lodge website. The Manual is also available at the offices of the SAHRC

7. Prescribed Fees and Prescribed Forms of Request

A requester who seeks access to record containing personal information about that requester is not required to pay the request fee. Every other requester, who is not a personal requester, must pay the request fee:

The head of Bulungula Backpackers Lodge must notify the requester (other than a personal requester) by notice, requiring the requester to pay the prescribed fee (if any) before further processing the request [Section 54(1)].
The fee that the requester must pay to Bulungula Backpackers Lodge is The requester may lodge an application to the court against the tender or payment of the request fee [Section 54(3)(b)].
After the head of Bulungula Backpackers Lodge has made a decision on the request, the requester must be notified in the required
If the request is granted then a further access fee must be paid for the research, reproduction, preparation and for any time that has exceeded the prescribed hours to search and prepare the record for disclosure [Section 54(6)].

Attached is a list of fees in respect of private bodies as well as a copy of Form C, which is the request form. This information is also available on the website of the SAHCR: http://www.sahrc.org.za/fees forms priv bodies.PDF