Head Office

Branch Office

36 St James Street

Somerset West 7130

PO Box 2372

Somerset West

7129 South Africa

Tel:+27 21 850 1800

Johannesburg

PO Box 86101

City Deep 2049

Tel:+27 11 613 6255

www.Tru-Cape.co.za

info@tru-cape.co.za

www.Facebook.com/TruCape

@TruCapeFruit

Directors: PJ Graaff (Chairman) • DA Corder (Vice Chairman) • R Pienaar* (Managing) • C Fick* (Marketing)

P Reuvers • SS Loubser • D Jacobs • HAB Goosen • RF Niven • PR Cillié • JF Malan • WA van Zyl • J-J Cilliers* (Financial/Secretary) *Executive Directors

Registration No. 2000/025533/07 • VAT Reg No. 4070190808

THE PROTECTION OF PERSONAL INFORMATION ACT (POPIA)

CLIENT/ USER PRIVACY PROTOCOLS POLICY

Preamble

The purpose of this policy is to advise the client / user (data subject) of Tru-Cape Fruit

Marketing (Pty) Ltd, Tru Cape Holdings (Pty) Ltd and Kweli Cape (Pty) Ltd services,

both electronic and otherwise, why data is collected and processed, what data is in

focus as well as how it is processed. Tru-Cape Fruit Marketing (Pty) Ltd, Tru Cape

Holdings (Pty) Ltd and Kweli Cape (Pty) Ltd are committed to full compliance with the

POPI Act insofar as the utilisation and disclosure of data subject personal information

(PI) is concerned. Hence, technical and operational measures have been put in place

to protect data subject privacy and Tru-Cape Fruit Marketing (Pty) Ltd, Tru Cape

Holdings (Pty) Ltd and Kweli Cape (Pty) Ltd invites all data subjects and/ or requesters

to engage with its Information Officer (IO) in respect of any matter related hereto.

Scope of application

This policy applies to data subjects under the POPI Act and its principles extend to the

Promotion of Access to Information Act (PAIA) in respect of requesters of records held

by Tru-Cape Fruit Marketing (Pty) Ltd, Tru Cape Holdings (Pty) Ltd and Kweli Cape

(Pty) Ltd. PI applies to both natural and juristic persons. Data subjects and requesters

are invited to engage with the Tru-Cape Fruit Marketing (Pty) Ltd, Tru Cape Holdings

(Pty) Ltd and Kweli Cape (Pty) Ltd IO about any matter pertaining to the POPIA and

PAIA, including but not limited to updating PI, deletion of PI and complaints in respect

of how PI is being processed. The “Information Officer” tab on the website facilitates

these types of engagement.

About Tru-Cape Fruit Marketing (Pty) Ltd, Tru Cape Holdings (Pty) Ltd and Kweli Cape

(Pty) Ltd

Tru-Cape Fruit Marketing is one of South Africa’s largest apple and pear marketers

and sells fresh produce on behalf of its principal shareholders and external fruit

producers. Since 2001 we have come to work to add value to our grower

shareholders and external fruit producers, improve the lives of our people, and work

in harmony with our environment. More details in this regard can be obtained in the

“About us ” link on our website.

Tru Cape Holdings (Pty) Ltd and Kweli Cape (Pty) Ltd are investment Holding

Companies.

Definition of Personal Information (PI)

‘‘Personal information’’ means information relating to an identifiable, living, natural

person, and where it is applicable, an identifiable, existing juristic person, including,

but not limited to—

(a) information relating to the race, gender, sex, pregnancy, marital status, national,

ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-

being, disability, religion, conscience, belief, culture, language and birth of the person;

(b) information relating to the education or the medical, financial, criminal or

employment history of the person;

number, location information, online identifier or other particular assignment to the

person;

(d) the biometric information of the person; (e) the personal opinions, views or

preferences of the person;

(f) correspondence sent by the person that is implicitly or explicitly of a private or

confidential nature or further correspondence that would reveal the contents of the

original correspondence;

(g) the views or opinions of another individual about the person; and

(h) the name of the person if it appears with other personal information relating to the

person or if the disclosure of the name itself would reveal information about the person;

Purpose of Collecting and Processing PI

Tru-Cape Fruit Marketing (Pty) Ltd, Tru Cape Holdings (Pty) Ltd and Kweli Cape (Pty)

Ltd processes PI for various purposes including for –

• Facilitating transactions with data subjects

• Collecting data for statistical purposes to improve its services

• Fulfilling its contractual obligations to its clients and client contacts

• Complying with the provisions of statute and regulations

• Attending to the legitimate interests of data subjects

• Identifying prospects for enhanced service delivery and business

sustainability

• Providing data subject information to Tru-Cape Fruit Marketing (Pty) Ltd, Tru

Cape Holdings (Pty) Ltd and Kweli Cape (Pty) Ltd partners in order for Tru-

Cape Fruit Marketing (Pty) Ltd, Tru Cape Holdings (Pty) Ltd and Kweli Cape

(Pty) Ltd partners to use the information to fir the benefit of data subjects.

These Tru-Cape Fruit Marketing (Pty) Ltd, Tru Cape Holdings (Pty) Ltd and

Kweli Cape (Pty) Ltd partners who are recipients of PI are business

organizations who are permitted to use the information only for the benefit of

data subjects.

• Confirm and verify data subject identity or to verify that they are authorised

users for security purposes;

• Conduct market or customer satisfaction research

• Audit and record keeping purposes

• In connection with legal proceedings.

Lawful Basis

In respect of the processing of PI as provided for above, Tru-Cape Fruit Marketing

(Pty) Ltd, Tru Cape Holdings (Pty) Ltd and Kweli Cape (Pty) Ltd will adhere to the

conditions for the lawful processing of PI, based on its desire to provide data subjects

services in their best interests as well as a legitimate interest of Tru-Cape Fruit

Marketing (Pty) Ltd, Tru Cape Holdings (Pty) Ltd and Kweli Cape (Pty) Ltd to achieve

its business objectives.

Period of holding Personal Information

Tru-Cape Fruit Marketing (Pty) Ltd, Tru Cape Holdings (Pty) Ltd and Kweli Cape (Pty)

Ltd endeavours to provide the most accurate information possible to stakeholders,

including data subjects. Tru-Cape Fruit Marketing (Pty) Ltd, Tru Cape Holdings (Pty)

Ltd and Kweli Cape (Pty) Ltd seeks to verify the accuracy of its information as

frequently as possible and to remove information that it learns to be inaccurate. Thus,

Tru-Cape Fruit Marketing (Pty) Ltd, Tru Cape Holdings (Pty) Ltd and Kweli Cape (Pty)

Ltd intends to process the information it has about data subjects for so long as it is

accurate or until the data subject instructs Tru-Cape Fruit Marketing (Pty) Ltd, Tru

Cape Holdings (Pty) Ltd and Kweli Cape (Pty) Ltd to refrain from processing it – in

order to instruct Tru-Cape Fruit Marketing (Pty) Ltd, Tru Cape Holdings (Pty) Ltd and

Kweli Cape (Pty) Ltd to refrain from collecting and/ or processing PI please contact

the Information Officer.

Notwithstanding the above, Tru-Cape Fruit Marketing (Pty) Ltd, Tru Cape Holdings

(Pty) Ltd and Kweli Cape (Pty) Ltd shall hold PI for such period as may be required in

terms of statutes such as the Companies Act and various labour laws.

Data Subject Rights

Data subjects have the right to request that Tru-Cape Fruit Marketing (Pty) Ltd, Tru

Cape Holdings (Pty) Ltd and Kweli Cape (Pty) Ltd provide them with access to their

PI, to rectify or correct their personal information, erase PI or restrict the processing of

PI, including refraining from sharing it or otherwise providing it to any third parties.

Data subjects also have the right to raise complaints with the Information Regulator.

The afore-going rights may be subject to certain limitations pursuant to applicable law.

In order to access any of these rights, please contact the Information Officer.

Sources of Personal Information (PI)

Tru-Cape Fruit Marketing (Pty) Ltd, Tru Cape Holdings (Pty) Ltd and Kweli Cape (Pty)

Ltd gathers PI from several sources, which include directly from data subjects, publicly

available sources such as websites, social media, commercial transactions with Tru-

Cape Fruit Marketing (Pty) Ltd, Tru Cape Holdings (Pty) Ltd and Kweli Cape (Pty) Ltd

, referrals, prospects, partner agreements, training engagements, conferences and the

like. Given that PI can be extracted and/ or obtained from several sources and

consolidated into one system of record, it may be difficult or impossible to identify the

exact source of one particular piece of information.

Categories of Personal Information (PI) collected and processed

Tru-Cape Fruit Marketing (Pty) Ltd, Tru Cape Holdings (Pty) Ltd and Kweli Cape (Pty)

Ltd collects information about data subjects who may be clients, client contacts,

prospective clients and prospective client contacts. It also collects information on its

employees and suppliers as well as third parties that are part of its scope of operation.

In respect of clients, client contacts, prospective clients and prospective client contacts

Tru-Cape Fruit Marketing (Pty) Ltd, Tru Cape Holdings (Pty) Ltd and Kweli Cape (Pty)

Ltd profiles business organizations and the contacts who work for the said

organisations and it may have some or all of the following categories of personal

information on data subjects, historical or current –

• Name and surname

• Identity Number

• Equity, Gender & Disability status

• Contact details (email, mobile)

• Birth date

• Position held and responsibilities

• Areas of interest in respect of Ceres Fruit Growers (Pty) Ltd offerings

• Record of services used

• Email correspondence and attachments

• Organisation details

• Office address

• Office contact details

• Organisation email Address

• Organisation and data subject Social media URL’s

• Other information that is available in the public domain.

We collect and process your personal information mainly to contact data subjects for

the purpose of understanding their requirements and delivering services

accordingly. Where possible, we will inform data subjects what information they are

required to provide to Tru-Cape Fruit Marketing (Pty) Ltd, Tru Cape Holdings (Pty) Ltd

and Kweli Cape (Pty) Ltd and what information is optional, as well as the

consequences of not providing the said information.

Disclosure of information

Tru-Cape Fruit Marketing (Pty) Ltd, Tru Cape Holdings (Pty) Ltd and Kweli Cape (Pty)

Ltd may disclose data subject PI to its service providers who are involved in the

delivery of products or services data subjects. Tru-Cape Fruit Marketing (Pty) Ltd, Tru

Cape Holdings (Pty) Ltd and Kweli Cape (Pty) Ltd has agreements in place to ensure

that it complies with the privacy requirements as required by the POPI Act.

Tru-Cape Fruit Marketing (Pty) Ltd, Tru Cape Holdings (Pty) Ltd and Kweli Cape (Pty)

Ltd may also disclose data subject PI:

• Where it has a duty or a right to disclose in terms of law and/ or industry codes;

• Where it believes it is necessary to protect its rights.

Information Security

Tru-Cape Fruit Marketing (Pty) Ltd, Tru Cape Holdings (Pty) Ltd and Kweli Cape (Pty)

Ltd is legally obliged to provide adequate systems, technical and operational

protection for the PI that it holds and to prevent unauthorized access to as well as

prohibited use of PI. Tru-Cape Fruit Marketing (Pty) Ltd, Tru Cape Holdings (Pty) Ltd

and Kweli Cape (Pty) Ltd will therefore on a regular basis review its security controls

and related processes to ensure that the PI of data subjects remains secure.

Tru-Cape Fruit Marketing (Pty) Ltd, Tru Cape Holdings (Pty) Ltd and Kweli Cape (Pty)

Ltd has conducted an impact assessment across all of its functions and used the

findings thereof to manage risk optimally as well as to provide iterative improvements

on an ongoing basis. Tru-Cape Fruit Marketing (Pty) Ltd, Tru Cape Holdings (Pty) Ltd

and Kweli Cape (Pty) Ltd policies and procedures cover the following aspects -

• Physical security;

• Computer and network security;

• Access to personal information;

• Secure communications;

• Security in contracting out activities or functions;

• Retention and disposal of information;

• Acceptable usage of personal information;

• Governance and regulatory issues;

• Monitoring access and usage of private information;

• Investigating and reacting to security incidents.

Tru-Cape Fruit Marketing (Pty) Ltd, Tru Cape Holdings (Pty) Ltd and Kweli Cape (Pty)

Ltd also ensures that it contracts with Operators as required by POPI and it requires

appropriate security, privacy and confidentiality obligations of these operators in order

to ensure that personal information is kept secure. The same protocols apply to any

party to whom Tru-Cape Fruit Marketing (Pty) Ltd, Tru Cape Holdings (Pty) Ltd and

Kweli Cape (Pty) Ltd may pass PI on to for the purposes mentioned herein.

How to contact us - Head Office and Information Officer

Our Head Office physical address is -

36 St James Street, Somerset West, 7130, South Africa

The information officer is –

Tru-Cape Fruit Marketing (Pty) Ltd

Jean-Jacques Cilliers

Email – jeanc@tru-cape.co.za

Mobile – 082 492 9991

Tru Cape Holdings (Pty) Ltd

Elton Landman

Email – eltonl@tru-cape.co.za

Mobile – 082 826 0616

Kweli Cape (Pty) Ltd

Roelf Pienaar

Email – roelfp@tru-cape.co.za

Mobile – 079 517 0777