1. INTRODUCTION

1.1. By registering for, entering or participating in the auction and/or associated golf event (“the Event”), each participant acknowledges that Harvest Floor NPC (“the Organiser”) will collect and process certain personal information relating to each participant.

1.2. This Privacy Notice explains how the Organiser process such personal information in accordance with the Protection of Personal Information Act 4 of 2013 (“POPIA”) and other applicable laws.

2. COLLECTION OF PERSONAL INFORMATION

2.1. The Organiser may collect and process the following personal information:

2.1.1. the participant’s full name and surname;

2.1.2. email address and telephone number;

2.1.3. company or team name (where applicable);

2.1.4. registration, entry and participation details;

2.1.5. bidding activity, bid amounts, player selections and auction results;

2.1.6. payment and transaction information (excluding complete payment-card details processed by authorised payment-service providers); and

2.1.7. correspondence and other information reasonably required to administer the Event.

3.    PURPOSE

3.1.    The participant’s personal information may be processed for the following purposes:

3.1.1. registering and verifying the participant’s entry into the auction and/or golf event;

3.1.2. administering the auction, golf event, four-ball entries and player or guest allocations;

3.1.3. communicating material information concerning the Event, including changes to its date, venue, format, bidding periods, rules or arrangements;

3.1.4. sending auction-related news, reminders and live-bidding updates, including notifications regarding:

3.1.4.1. the commencement and closing of bidding periods;

3.1.4.2. new, competing or higher bids;

3.1.4.3. the participant’s bidding status;

3.1.4.4. available sports stars, guests, players or auction lots;

3.1.4.5. successful bids, payment requirements and player allocations; and

3.1.4.6. other information reasonably related to the auction or golf event;

3.1.5. processing payments and maintaining transaction records;

3.1.6. preventing fraud, unauthorised bidding and misuse of the auction platform;

3.1.7. complying with applicable legal, regulatory, accounting and reporting obligations; and

3.1.8. addressing enquiries, complaints or disputes relating to the Event.

4.    COMMUNICATIONS

4.1. Event and auction communications may be sent by email, SMS, WhatsApp, telephone call, website notification or another electronic communication method selected by the participant or reasonably used by the Organiser.

4.2. Certain communications are operationally necessary for participation in the Event. These may include registration confirmations, bidding notifications, payment instructions, and final auction results.

4.3. Where the Organiser wishes to send marketing communications that are unrelated to the Event, the participant’s separate consent will be obtained where required by law.

5.    CONSENT AND PREFERENCES

5.1. By voluntarily providing personal information and registering for the Event, the participant consents to the processing of that information for the purposes described in this Privacy Notice.

5.2. The participant may opt out of non-essential news or promotional communications at any time by:

5.2.1. selecting the unsubscribe option contained in an electronic communication;

5.2.2. changing the participant’s communication preferences, where that functionality is available; or

5.2.3. contacting the Organiser.

5.3. Opting out of non-essential communications will not prevent the Organiser from sending information reasonably necessary to administer the participant’s registration, bids, payments and/or participation in the Event.

6.    DISCLOSURE OF PERSONAL INFORMATION

6.1. The Organiser may disclose personal information only to persons who reasonably require access to it for the purposes set out in this Privacy Notice, including:

6.1.1. the Event’s auction platform, website, payment and communication-service providers;

6.1.2. professional advisers, auditors, insurers and event administrators;

6.1.3. participating sponsors, venues or service providers, but only to the extent reasonably necessary to administer the Event; and

6.1.4. governmental, regulatory or law-enforcement authorities where disclosure is required or permitted by law.

6.2. The Organiser will not sell participants’ personal information or disclose it to third parties for their unrelated direct-marketing purposes without the participant’s consent.

7.    LIVE-BIDDING INFORMATION

7.1. Participants acknowledge that certain bidding information may be displayed during the live auction to facilitate transparent and competitive bidding.

7.2. The Organiser will, where reasonably possible, display bidding activity using a bidder number, team name, abbreviated name or similar identifier rather than publishing unnecessary personal information.

7.3. The Organiser will not publicly display a participant’s private contact, payment or identity information unless required by law or expressly authorised by that participant.

8.    INFORMATION SECURITY

8.1. The Organiser will implement reasonable technical and organisational safeguards to protect personal information against loss, unauthorised access, interference, alteration, disclosure or destruction.

8.2. Where third-party service providers process personal information on the Organiser’s behalf, the Organiser will take reasonable steps to ensure that such service providers process and protect the information appropriately.

9.    RETENTION OF INFORMATION

9.1. Personal information will be retained only for as long as reasonably necessary to:

9.1.1. administer and conclude the Event;

9.1.2. resolve any enquiries, complaints or disputes;

9.1.3. comply with legal, tax, accounting and record-retention requirements; or

9.1.4. establish, exercise or defend a legal claim.

9.2. Thereafter, the information will be securely deleted or destroyed, subject to applicable law.

10. PARTICIPANT RIGHTS

10.1. Subject to POPIA and any applicable legal limitations, a participant may request:

10.1.1. confirmation that the Organiser holds personal information relating to that participant;

10.1.2. access to the participant’s personal information;

10.1.3. the correction or updating of inaccurate or incomplete information;

10.1.4. the deletion or destruction of information that the Organiser is no longer lawfully entitled to retain;

10.1.5. that the Organiser cease or restrict certain processing activities; or

10.1.6. the withdrawal of consent or objection to direct-marketing communications.

10.2. A participant may exercise these rights by contacting the Organiser using the details below.

11. CONTACT DETAILS

11.1. Any participant may direct enquiries regarding this Notice to the Organiser at [email protected].

11.2. A participant may also lodge a complaint with the Information Regulator of South Africa should the participant believes that his/her personal information has been processed unlawfully.

12. ACCEPTANCE

12.1. By registering for the auction and/or golf-event, the participant confirms that the participant has read and understood this Privacy Notice and consents to the processing of personal information for the administration of the Event and the delivery of auction news and live-bidding updates as described above.