1. Introduction

The right to privacy is an integral human right recognised and protected in the South African Constitution and the Protection of Personal Information Act 4 of 2013 (“POPIA”).

POPIA aims to promote the protection of privacy by providing guiding principles that are intended to be applied to the processing of personal information in a context-sensitive manner.

Through the provision of coaching, consulting, and related services, Lifestyle Freedom (Pty) Ltd is necessarily involved in the collection, use and disclosure of certain aspects of the personal information of clients, customers, employees and other stakeholders.

A person’s right to privacy entails having control over his or her personal information and being able to conduct his or her affairs relatively free from unwanted intrusions.

2. Commitment to Compliance with POPI

Given the importance of privacy, Lifestyle Freedom (Pty) Ltd is committed to effectively managing personal information in accordance with POPIA’s provisions.

To meet the requirements of POPIA, Lifestyle Freedom (Pty) Ltd has implemented a POPI Risk Framework which includes:

• Development and implementation of information processing plans and procedures, including safeguards of personal information

• Development and implementation of a compliance monitoring plan

• Appointment of an Information Officer

• Delegation of duties to staff and training on their responsibilities

• Development of disclosures and client POPI engagement processes

• Documentation of relationships with third parties for the sharing of personal information and outsourcing where applicable

3. Information Officer

Lifestyle Freedom (Pty) Ltd has appointed an Information Officer - Tatenda Macheka

All correspondence to the Information Officer may be submitted via email to:

tatenda@lifestylefreedom.co.za

4. Privacy Statement

Lifestyle Freedom (Pty) Ltd is committed to processing personal information in accordance with the following principles when collecting, recording, storing, disseminating, and destroying personal information, and when responding to lawful requests:

• We shall not contact or solicit you unless you have given consent or where it forms part of an existing relationship

• We shall process personal information for a specific, lawful purpose and only collect information that is adequate, relevant, and limited to that purpose

• If you cancel your services, we will delete or de-identify your personal information after the required statutory retention periods

• We take reasonable measures to protect personal information from loss, damage, unauthorised access, or unlawful processing

Lifestyle Freedom (Pty) Ltd collects information directly from you when you provide us with your details.

In addition:

• We may obtain further information from third parties where necessary to deliver coaching or consulting services

• We will only do so with your consent or where required to fulfil our service agreement

Lifestyle Freedom (Pty) Ltd does not collect or process special personal information unless required by law or necessary for service delivery, in which case your consent will be obtained.

We do not knowingly collect personal information from children (under 18 years of age) without the permission of a parent or guardian.

Lifestyle Freedom (Pty) Ltd and its employees may disclose personal information:

• To service providers involved in delivering coaching, consulting, or support services

• To professional partners such as accountants, compliance providers, or administrative support

• Where required by law or industry regulation

• Where necessary to protect the legal rights and interests of Lifestyle Freedom

Access to personal information within the organisation is limited to authorised personnel and contractors who are required to maintain confidentiality and comply with POPIA.

Lifestyle Freedom (Pty) Ltd will not transfer personal information to a third party in a foreign country without ensuring compliance with POPIA requirements.

5. Request to Access Personal Information Procedure

In terms of POPIA, data subjects have the right to:

• Request what personal information the organisation holds about them and why

• Request access to their personal information

• Be informed on how to keep their personal information up to date

Requests may be made via email to the Information Officer.

The Information Officer will provide a Personal Information Request Form where required.

Once received, identity verification will be conducted before any information is released.

All requests will be processed in accordance with the organisation’s PAIA Policy.

Requests will be handled within a reasonable time.

6. POPI Complaints and Objections Procedure

Clients have the right to object to the processing of personal information.

However, in certain cases, failure to provide personal information may result in:

• Inability to deliver services

• Limited service delivery

Data subjects have the right to lodge complaints where their rights under POPIA have been infringed.

Lifestyle Freedom (Pty) Ltd will address complaints as follows:

• Complaints must be submitted in writing

• The Information Officer will acknowledge receipt of the complaint

• The complaint will be reviewed and addressed fairly in line with POPIA principles

• Where necessary, a POPI Complaint Form will be provided

If the data subject is not satisfied with the outcome, they may escalate the complaint to the Information Regulator.

Information Regulator Contact Details:

Complaints email: complaints.IR@justice.gov.za
General enquiries email: inforeg@justice.gov.za