Privacy Policy

Who this policy covers

This policy explains how personal information is handled when you visit the Three Fountains Shopping Centre website, contact our leasing service, use our WhatsApp enquiry service, request a site visit or submit a tenant application.

The leasing service is administered by Assegai Assetco (Pty) Ltd, registration number 2020/713940/07, the developer of Three Fountains Shopping Centre. Our correspondence address is 13 Azalea Lane, Mount Michael, Hilton, 3245, South Africa. In this policy, "we", "us" and "our" refer to Assegai Assetco in this role.

The project company is Three Fountains Assetco (Pty) Ltd, registration number 2019/499967/07. Relevant application information may be provided to the project company and its authorised leasing representatives for assessment and lease administration. Your written lease will identify the contracting landlord.

For privacy enquiries, requests or complaints, email [email protected], marked For the Information Officer — Privacy request. This is also the contact address for the Three Fountains Meta integration, which may appear as N8N in Meta's app settings.

Information we process

Depending on your interaction with us, information may include:

• Your name, contact details, business name, proposed business activity, preferred premises and correspondence.
• Your WhatsApp number, profile name where provided, message contents, message identifiers, timestamps, delivery information and communication preferences.
• Application and supporting information: entity registration, ownership and control, relevant identity documents, business address evidence, bank confirmation, financial statements or bank statements, business history, store or concept photographs, references, consent and signatory details.
• Site-visit requests and arrangements, application records and records of our responses.
• Technical information associated with website or service use, such as IP addresses, browser information, request times and security or error records, where collected by the services involved.

We normally receive information directly from you. We may also receive it from an authorised representative, the messaging platform you use, supplied company records and references you identify. Any separate credit or background check must have an appropriate lawful basis and any required notice or authorisation; submission of a chat message does not authorise unrestricted checks.

If you provide another person's information, you must be entitled to do so and make this policy available to them. Please provide only information relevant to the enquiry or application. Do not send passwords, banking login details, card PINs or unnecessary sensitive information.

Why we use information

We use relevant information to answer enquiries, explain available space and application requirements, assess and administer applications, identify missing information, arrange visits, communicate decisions and manage a resulting tenancy. We also use necessary records to maintain service security, investigate errors or misuse, resolve disputes and meet applicable legal obligations.

The lawful basis depends on the activity. It may include steps requested before entering a contract, performance of a contract, an applicable legal obligation, a legitimate interest permitted by law, or your consent where required. This policy is a notice; using the website does not provide blanket consent to all processing or to marketing.

Enquiries and applications are voluntary. Certain information is needed to respond meaningfully or assess an application. If essential information is not provided, we may be unable to complete that assessment. A document requested for our application process is not necessarily a document that legislation requires every person to supply.

Automated assistance and AI

Our leasing service uses, or is being configured to use, automation to route enquiries, send service replies and assist with document-completeness checks. Public enquiry responses may be generated with AI. Application documents submitted by email may be processed using AI to identify missing, unreadable or inconsistent information.

An automated acknowledgement does not establish that documents are authentic, that credit has been approved, or that a lease or reservation exists. Automated completeness checks do not make the final leasing decision. You can ask for a human review or correction of an automated response by emailing [email protected].

WhatsApp and application documents

Use WhatsApp for enquiries and application guidance. Send completed KYC forms and supporting identity or financial documents to [email protected], not through WhatsApp or public social-media comments.

If you send an attachment through WhatsApp, it is not automatically accepted into your application. The message or attachment may nevertheless be held by the messaging platform or received in business messaging systems. Contact us if you sent sensitive information by mistake.

Service providers and disclosures

Relevant information may be accessible to authorised leasing personnel, the project company, professional advisers and service providers supporting the leasing process. The intended automation uses Meta/WhatsApp for messaging, n8n for workflow processing, Google Drive for application files, email providers for correspondence and OpenAI for AI-assisted responses and document checks. Each provider should receive only information needed for its role.

Meta and other platforms may also process information for their own purposes under their own privacy notices. We may disclose information when lawfully required by a court, regulator or other competent authority, or where necessary and lawful to protect rights or investigate misuse. We do not sell applicant information.

Some service providers process or store information outside South Africa. Where we arrange such processing, we must use a lawful transfer basis and appropriate safeguards under POPIA. Contact us for information about the providers and safeguards relevant to your records.

Security and retention

We are responsible for taking reasonable technical and organisational measures to protect the personal information under our control. No website, email or messaging service can guarantee absolute security. Please notify us promptly if you suspect that your application information has been accessed or disclosed improperly.

We retain information only for as long as needed for its stated purpose or another lawful retention basis. This may include an active enquiry or application, tenancy administration, a legal record-keeping obligation or an actual or reasonably anticipated dispute. Different record categories may have different retention periods.

Information no longer needed must be securely deleted, destroyed or de-identified, as appropriate. A minimal record may be retained to document a privacy request or preserve an opt-out. Backup copies may remain until the relevant backup cycle expires; they should remain protected and should not be restored to ordinary use contrary to an accepted deletion request. We can explain the applicable retention position when responding to your request.

Messages and marketing preferences

We may respond to enquiries you initiate and send necessary service communications about an application. Optional marketing requires a lawful basis and any consent required by law. Providing a telephone number or submitting a KYC form does not, by itself, give blanket consent to optional WhatsApp marketing.

To stop optional WhatsApp follow-ups, reply STOP or email [email protected]. If you receive no confirmation, use the email address to ensure your request is recorded. You may still ask a new question and receive a service response. An opt-out does not delete your application or prevent communications that remain necessary and lawful.

Website technologies and external links

Your browser may process cookies or similar technologies used by the website or services embedded in it. Where optional analytics, advertising or similar technologies require consent, they must not be enabled without the required choice. You can also manage cookies through your browser, although some website functions may be affected.

External websites and services operate under their own notices. Following a link does not extend this policy to another provider's independent processing.

Your rights and requests

Subject to applicable law, you may request access to your personal information, correction of inaccurate information, deletion or destruction where appropriate, or object to processing. Where processing relies on consent, you may withdraw that consent without affecting processing that was lawful before withdrawal. Some requests are subject to identity verification, legal exceptions or an applicable formal access procedure.

Email [email protected] and explain your request. We will request only proportionate information needed to verify your identity and authority. Do not send identity documents or bank statements with an initial privacy request unless specifically required through an appropriate channel. See our Data Deletion Instructions for the deletion process.

You may complain directly to South Africa's Information Regulator:

• Website and complaints information: inforegulator.org.za/complaints/
• POPIA complaints: [email protected]
• Telephone: 010 023 5200

Changes

We may update this policy when our services or processing practices change. The published page will show its latest effective date. Material changes will be brought to your attention where required.