ALL PROPERTY PRIVACY POLICY

PRIVACY POLICY AND NOTICE

All Property is a data controller and operator in terms of the General Data Protection Regulation (GDPR) and has developed this privacy policy / notice in order to comply with the requirements of GDPR.

1. DEFINITIONS

1.1. “Data Breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Information under the control of or in the possession of All Property;

1.2. “Data Controller” means a person or entity who Processes Personal Information for a Responsible Party in terms of a contract or mandate, without coming under the direct authority of that Responsible Party.

1.3. “Data Subject” means the person to whom Personal Information relates;

1.4. “Direct Marketing” means to approach a person, by electronic communication, for the purpose of promoting or offering to supply, in the ordinary course of business, any goods or services to the Data Subject;

1.5. “Direct Marketer” means a supplier who employs Direct Marketing as an advertising mechanism;

1.6. “Employees” means any employee of All Property;

1.7. “GDPR” means Regulation (EU) 2016/679 of the European Parliament on the protection of natural persons with regard to the processing of personal data and free movement of such data (General Data Protection Regulation);

1.8. “All Property” means All Property, a sole proprietor who renders property inspection services, and includes the terms “we”, “us”, and “our”;

1.9. “Minor child” means any natural person under the age of 16 (sixteen) years (if the child is in Europe);

1.10. “Operator” means a person or entity who Processes Personal Information for a Responsible Party in terms of a contract or mandate, without coming under the direct authority of that Responsible Party;

1.11. “Personal Information” means information relating to a Data Subject including but not limited to (i) views or opinions of another individual about the Data Subject; and (ii) information relating to such Data Subject’s – Race, sex, gender, sexual orientation, pregnancy, marital status, nationality, ethnic or social origin, colour, age, physical or mental health, well-being, disability, religion, conscience, belief, cultural affiliation, language and birth; Education, medical, financial, criminal or employment history;

Names, identity number and/or any other personal identifier, including any number(s), which may uniquely identify a Data Subject, account or client number, password, pin code, customer or Data Subject code or number, numeric, alpha, or alpha-numeric design or configuration of any nature, symbol, email address, domain name or IP address, physical address, cellular phone number, telephone number or other particular assignment; blood type, fingerprint or any other biometric information;

personal opinions, views or preferences; correspondence that is implicitly or expressly of a personal, private or confidential nature (or further correspondence that would reveal the contents of the original correspondence); and corporate structure, composition and business operations (in circumstances where the Data Subject is a juristic person) irrespective of whether such information is in the public domain or not;

1.12 “Policy” means this Policy;

1.13 “GDPR” means the General Data Protection Regulation;

1.14 “Processing” and/or “Process” means any operation or activity or any set of operations,

whether or not by automatic means, concerning Personal Information, including –

1.14.1 the collection, receipt, recording, organisation, collation, storage, updating or

modification, retrieval, alteration, consultation or use;

1.14.2 dissemination by means of transmission, distribution or making available in

any other form by electronic communications or other means; or

1.14.3 merging, linking, blocking, degradation, erasure or destruction.

1.15 “Regulator” means the relevant supervisory authority under the GDPR;

1.16 “Responsible Party” means a public or private body or any other person which alone or

in conjunction with others, determines the purpose of and means for Processing Personal Information;

1.17 “Special Personal Information” means Personal Information concerning a Data Subject’s religious or philosophical beliefs, race or ethnic origin, trade union membership, political opinions, health, sexual life, sexual orientation, genetic information, biometric information or criminal behaviour;

1.18 “Third Party” means any independent contractor, agent, consultant, sub-contractor or

other representative of All Property; and

1.19 “Website” means the All Property website currently accessible at https://www.allpropertyeu.com/

2. PURPOSE OF THIS POLICY

The purpose of this Policy is to inform Data Subjects about how All Property will processes their Personal Information.

3. APPLICATION OF THIS POLICY

3.1. All Property, in its capacity as Data Controller and/or Responsible

Party and/or Operator, shall strive to observe and comply with its obligations under

the GDPR, as well as accepted information protection principles, practices and guidelines, when it Processes Personal Information from or in respect of a Data Subject.

3.2. This Policy applies to Personal Information collected by All Property and includes

information collected directly from you as a Data Subject, as well as information we collect indirectly through our Direct Marketing campaigns and online through our websites, branded pages on Third Party platforms and applications accessed or used through such websites or Third Party platforms which are operated by or on behalf of All Property.

3.3. This Privacy Policy does not apply to the information practices of Third Party companies who we may engage with in relation to our business operations (including, without limitation, their websites, platforms and/or applications) which we do not own or control; or individuals that All Property does not manage or employ. These Third Party sites may have their own privacy policies and terms and conditions and we encourage you to read them before using them.

4. HOW PERSONAL INFORMATION IS COLLECTED

4.1. All Property collects Personal Information directly from Data Subjects, unless the Data Subject has made the Personal Information public or the Personal Information is contained in or derived from a public record and/or in some cases, from Third Parties.

4.2. All Property will always collect Personal Information in a fair, lawful and reasonable manner to ensure that it protects the Data Subject’s privacy and will Process the Personal Information based on legitimate grounds in a manner that does not adversely affect the Data Subject in question.

4.3. Where All Property obtains Personal Information from Third Parties, All Property will ensure that it obtains the consent of the Data Subject to do so or will only Process the Personal Information without the Data Subject’s consent where All Property is permitted to do so in terms of clause 4.1 above.

4.4. An example of such Third Parties include: (i) our clients when All Property handles Personal Information on t heir behalf; (ii) credit reference agencies; (iii) other companies providing services to All Property; and (iv) where All Property makes use of publicly available sources of information

5. LAWFUL PROCESSING OF PERSONAL INFORMATION

5.1. Where All Property is the Responsible Party, it will only Process a Data Subject’s Personal Information (other than for Special Personal Information) where –

5.1.1. consent of the Data Subject (or a competent person where the Data Subject is a Minor Child) is obtained;

5.1.2. Processing is necessary to carry out the actions for conclusion of a contract to which a Data Subject is party;

5.1.3. Processing complies with an obligation imposed by law on All Property

5.1.4. Processing protects a legitimate interest of the Data Subject;

5.1.5. Processing is necessary for pursuing the legitimate interests of All Property or of a third party to whom the information is supplied;and/or

5.1.6. Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in All Property

5.2. All Property will make the manner and reason for which the Personal Information will be Processed clear to the Data Subject.

5.3. Where All Property is relying on a Data Subject’s consent as the legal basis for Processing Personal Information, the Data Subject may withdraw his/ her/its consent or may object to All Property Processing of the Personal Information at any time. However, this will not affect the lawfulness of any Processing carried out prior to the withdrawal of consent.

5.4. If the consent is withdrawn or if there is otherwise a justified objection against the use or the Processing of such Personal Information, All Property will ensure that the Personal Information is no longer Processed.

6. SPECIAL PERSONAL INFORMATION AND PERSONAL INFORMATION OF CHILDREN

6.1 All Property acknowledges that it will generally not Process Special Personal Information unless

(i) processing is carried out in accordance with the Data Subject’s explicit consent; or

(ii) information has been deliberately made public by the Data Subject; or

(iii) processing is necessary for the establishment, exercise or defence of a right or legal claim or obligation in law); or (iv) processing is for historical, statistical or research purposes, subject to stipulated safeguards; or – for purposes of GDPR –

6.1.1 specific authorisation has been obtained in terms of GDPR –

6.1.2 Processing is necessary for the purposes of carrying out the obligations and exercising specific rights of All Property or of the Data Subject in the field of employment and social security and social protection law;

6.1.3 Processing is necessary to protect the vital interests of the data subject or of another natural person where the Data Subject is physically or legally incapable of giving consent;

6.1.4 processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity;

6.1.5 Processing is necessary for reasons of substantial public interest;

6.1.6 Processing is necessary for the purposes of preventative or occupational medicine; or

6.1.7 Processing is necessary for reasons of public interest in the area of public health.

7. PURPOSE FOR PROCESSING PERSONAL INFORMATION

7.1 All Property will only Process a Data Subject’s Personal Information for a specific, lawful and clear purpose (or purposes) and will ensure that it makes the Data Subject aware of such purpose(s) as far as possible.

7.2 All Property will generally use Personal Information for purposes required to operate and manage its normal business operations and these purposes include one or more of the following non-exhaustive purposes –

7.2.1 For the purposes of providing its services to the Data Subject from time to time;

7.2.2 Personal Information is processed as part of the “Know Your Customer”/“KYC” process as per the requirements of the Financial Intelligence Centre Act 38 of 2001;

7.2.3 Personal Information is processed in order to conduct due diligence processes on All Property Clients;

7.2.4 Personal Information is processed in connection with internal audit purposes ( i.e. ensuring that the appropriate internal controls are in place in order to mitigate the relevant risks, as well as to carry out any investigations where this is required);

7.2.5 Personal Information is processed for employment-related purposes such as administering payroll, assessing credit and criminal history and determining Employment Equity Act 55 of 1998 statistics;

7.2.6 To respond to any correspondence that the Data Subject may send to All Property, including via email, All Property site(s) or by telephone;

7.2.7 In connection with the execution of payment processing functions, including payment of All Property suppliers’ invoices;

7.2.8 To contact the Data Subject for direct marketing purposes subject to the provisions of clause 10 below;

7.2.9 For such other purposes to which the Data Subject may consent from time to time; and

7.2.10 For such other purposes as authorised in terms of applicable law.

8. ACCURACY OF PERSONAL INFORMATION

8.1 All Property will take reasonable steps to ensure that all Personal Information is kept as accurate, complete and up to date as reasonably possible depending on the purpose for which Personal Information is collected or further processed.

8.2 All Property may not always expressly request the Data Subject to verify and update his/her/its Personal Information, unless this process is specifically necessary.

8.3 All Property, however, expects that the Data Subject will notify All Property from time to time in writing of any updates required in respect of his/her/its Personal Information.

9. STORAGE AND PROCESSING OF PERSONAL INFORMATION

9.1 Storage of Personal Information
All Property may store your Personal Information in hardcopy and/or electronic format on secure on-site servers or other internally managed systems. Your information may also be stored by trusted third-party providers, including secure cloud-based services, with whom All Property has contracted to support business operations.

9.2 Access by Third-Party Service Providers
Authorised third-party service providers may access and process your Personal Information only for the purposes for which it was originally collected. Access is strictly limited to what is necessary to perform the contracted services.

9.3 Compliance with Policies and GDPR
All Property ensures that all third-party processors handle Personal Information in accordance with this Policy, relevant internal procedures, and the requirements of the GDPR.

9.4 Security Measures Required from Third Parties
Third-party processors are prohibited from using or accessing your Personal Information for anything other than the specified services. They are required to maintain security safeguards that meet or exceed the standards used by All Property to protect your data.

9.5 Third-Party Processors and Data Processing Agreements (DPAs)
When All Property appoints third-party processors, they act only on our documented instructions. All engagements are governed by GDPR-compliant Data Processing Agreements, which require processors to implement appropriate technical and organisational measures, assist All Property in fulfilling GDPR obligations, and ensure that personal data is processed securely and lawfully.

9.6 International Transfers of Personal Data
Your Personal Information may be processed in South Africa or in other countries where All Property, its affiliates, or authorised third-party providers operate. Any transfer of personal data outside the EU/EEA will comply with GDPR requirements, which may include:

transfers to countries recognised by the European Commission as providing adequate data protection;
the use of appropriate safeguards such as Standard Contractual Clauses (SCCs), Binding Corporate Rules (BCRs), or another approved mechanism;
reliance on a specific derogation under Article 49 of the GDPR when no other lawful basis is available (e.g., explicit consent or necessity for contract performance).

All Property takes all necessary steps to ensure that your Personal Information remains protected to GDPR standards, regardless of where it is processed.

10. DIRECT MARKETING

10.1 Compliance with GDPR
When All Property engages in Direct Marketing, it does so in accordance with the GDPR and all applicable data protection requirements. All marketing practices are implemented with respect for the rights and preferences of Data Subjects.

10.2 Lawful Basis for Marketing
All Property will only use Personal Information for Direct Marketing where it is legally permissible. This includes situations where consent has been provided or where another lawful basis exists.

10.3 When All Property May Contact You
All Property may use your Personal Information to contact you with marketing communications if:

you are an existing client;
you have asked to receive marketing materials; or
you have provided consent for direct marketing.

Marketing will relate only to All Property’s services.

10.4 Marketing to Existing Clients
Where the Data Subject is an existing client, All Property will only send marketing communications about services similar to those previously provided and only where the Personal Information was obtained during the provision of those services.

10.5 Right to Object
All Property will always provide a clear and easy opportunity for Data Subjects to object to the use of their Personal Information for Direct Marketing—both at the time information is collected and in every marketing communication sent.

10.6 Respecting Opt-Out Requests
If you request that All Property stop using your Personal Information for Direct Marketing, we will comply. We encourage the use of the opt-out links or forms included in our marketing communications to ensure requests are processed promptly.

11. RETENTION OF PERSONAL INFORMATION

11.1 All Property may keep records of the Personal Information it has collected, correspondence, or comments in an electronic or hard copy file format.

11.2 All Property will not retain personal information for a period longer than is necessary to achieve the purpose for which it was collected or processed and is required to delete, destroy (in such a way that it cannot be reconstructed) or de-identify the information as soon as is reasonably practicable once the purpose has been achieved. This prohibition will not apply in the following circumstances –

11.2.1 Where the retention of the record is required or authorised by law;

11.2.2 All Property requires the record to fulfil its lawful functions or activities;

11.2.3 Retention of the record is required by a contract between the parties thereto;

11.2.4 The data subject (or competent person, where the data subject is a child) has consented to such longer retention; or

11.2.5 the record is retained for historical, research or statistical purposes provided safeguards are put in place to prevent use for any other purpose.

11.2.6 Accordingly, All Property will, subject to the exceptions noted herein, retain Personal Information for as long as necessary to fulfil the purposes for which that Personal Information was collected and/or as permitted or required by applicable law.

11.2.7 Where All Property retains Personal Information for longer periods for statistical, historical or research purposes All Property will ensure that appropriate safeguards have been put in place to ensure that all recorded Personal Information will continue to be Processed in accordance with this Policy and the applicable laws.

11.2.8 Once the purpose for which the Personal Information was initially collected and Processed no longer applies or becomes obsolete, All Property will ensure that the Personal Information is deleted, destroyed or de- identified sufficiently so that a person cannot re-identify such Personal Information.

11.2.9 In instances where we de-identify your Personal Information, All Property may use such de-identified information indefinitely.

12. FAILURE TO PROVIDE PERSONAL INFORMATION

12.1 Should All Property need to collect Personal Information by law or under the terms of a contract that All Property may have with you and you fail to provide the Personal Information when requested, we may be unable to perform the contract we have or are attempting to enter into with you.

12.2 In such a case, All Property may have to decline to provide or receive the relevant services, and you will be notified where this is the case.

13. SAFE-KEEPINGOFPERSONAL INFORMATION

13.1 All Property shall preserve the security of Personal Information and, in particular, prevent its alteration, loss and damage, or access by non-authorised third parties.

13.2 All Property will ensure the security and integrity of Personal Information in its possession or under its control with appropriate, reasonable technical and organisational measures to prevent loss, unlawful access and unauthorised destruction of Personal Information.

13.3 Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of Data Subjects, All Property implements appropriate technical and organisational measures to ensure a level of security appropriate to the risk of Processing, including measures protecting any Personal Information from loss or theft, and unauthorised access, disclosure, copying, use or modification, including –

13.3.1 the pseudonymization and encryption of Personal Information;

13.3.2 the ability to ensure the ongoing confidentiality, integrity, availability and resilience of Processing systems and services; the ability to restore the availability and access to Personal Information in a timely manner in the event of a physical or technical incident; and

13.3.3 a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of Processing.

13.3.4 Further, All Property maintains and regularly verifies that the security measures are effective and regularly updates same in response to new risks.

14. BREACHES OF PERSONAL INFORMATION

14.1 A Data Breach refers to any incident in terms of which reasonable grounds exist to believe that the Personal Information of a Data Subject has been accessed or acquired by any unauthorised person.

14.2 A Data Breach can happen for many reasons, which include:

(a) loss or theft of data or equipment on which Personal Information is stored;

(b) inappropriate access controls allowing unauthorised use;

(d) human error;

(e) unforeseen circumstances, such as a fire or flood;

(f) deliberate attacks on systems, such as hacking, viruses or phishing scams; and/ or

(g) alteration of Personal Information without permission and loss of availability of Personal Information.

14.3 All Property will address any Data Breach in accordance with the terms of the GDPR.

14.4 All Property will notify the Regulator and the affected Data Subject (unless the applicable law requires that we delay notification to the Data Subject) in writing in the event of a Data Breach (or a reasonable belief of a Data Breach) in respect of that Data Subject’s Personal Information.

14.5 All Property will provide such notification as soon as reasonably possible and, where feasible, not later than 72 (seventy two) hours after having become aware of any Data Breach in respect of such Data Subject’s Personal Information.

14.6 Where All Property acts as an ‘Operator’ and should any Data Breach affect the data of Data Subjects whose information All Property Processes as an Operator, All Property shall (in terms of the GDPR) notify the relevant Responsible Party immediately where there are reasonable grounds to believe that the Personal Information of relevant Data Subjects has been accessed or acquired by any unauthorised person.

15. DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTY SERVICE PROVIDERS

15.1 All Property may disclose Personal Information to Third Parties and will enter into written agreements with such Third Parties to ensure that they Process any Personal Information in accordance with the provisions of this Policy, and the GDPR.

15.2 All Property notes that such Third Parties may assist All Property with the purposes listed in paragraph 7.4 above – for example, service providers may be used, inter alia:

(i) to notify the Data Subjects of any pertinent information concerning All Property,

(ii) or data storage and/or

(iii) to assist All Property with auditing processes (external auditors).

15.3 All Property will disclose Personal Information with the consent of the Data Subject or if All Property is permitted to do so without such consent in accordance with the applicable laws.

15.4 Third-Party Processors and Data Processing Agreements

When All Property engages third-party service providers to process personal data on our behalf, these parties (acting as data processors) will do so only for specified purposes and under our instructions. We will enter into legally binding Data Processing Agreements (DPAs) with these third parties, as required by the GDPR. These DPAs will include obligations on the processor to implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, to process personal data only on documented instructions from All Property, and to assist us in meeting our obligations under the GDPR.

15.5 International Transfers of Personal Data

Your personal data may be processed in South Africa or in another country where All Property, its affiliates, and their third-party service providers maintain servers and facilities. When we transfer personal data outside the European Union and the European Economic Area (EU/EEA), we will do so in compliance with the GDPR's requirements for international transfers. This includes ensuring that:

The recipient country has been deemed by the European Commission to provide an adequate level of protection for personal data.

Appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) approved by the European Commission, Binding Corporate Rules (BCRs) of the data importer, or another valid transfer mechanism recognized under the GDPR.

Where none of the above apply, the transfer is based on a specific derogation under Article 49 of the GDPR (e.g., explicit consent, necessity for the performance of a contract).

All property will take steps, including by way of contracts incorporating GDPR-approved safeguards, to ensure that your personal data continues to be protected to the standards required by the GDPR, regardless of its location.

16. ACCESS TO PERSONAL INFORMATION

16.1 A Data Subject has certain rights under the GDPR, including the following:

16.1.1 a right of access:a Data Subject having provided adequate proof of identity has the right to:

(i) request a Responsible Party to confirm whether any Personal Information is held about the Data Subject; and/or

(ii) request from a Responsible Party a description of the Personal Information held by the Responsible Party including information about Third Parties who have or have had access to the Personal Information. A Data Subject may request:

16.1.1.1 All Property to confirm, free of charge, whether it holds any Personal Information about him/ her/it; and

16.1.1.2 to obtain from All Property the record or description of Personal Information concerning him/her/it and any information regarding the recipients or categories of recipients who have or had access to the Personal Information. Such record or description is to be provided:

16.1.1.3 within a reasonable time; and

16.1.1.4 in a reasonable manner and format and in a form that is generally understandable.

16.1.2 a right to request correction or deletion:a Data Subject may also request All Property to –

16.1.2.1 correct or delete Personal Information about the Data Subject in its possession or under its control that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully; or

16.1.2.2 destroy or delete a record of Personal Information about the Data Subject that All Property is no longer authorised to retain records in terms of the GDPR’s retention and restriction of records provisions.

16.1.2.3 On receipt of such a request, All Property is required to, as soon as is reasonably practicable –

16.1.2.3.1 correct the information;

16.1.2.3.2 delete or destroy the information;

16.1.2.3.3 provide the Data Subject with evidence in support of the information; or

16.1.2.3.4 where the Data Subject and Responsible Party cannot reach agreement on the request and if the Data Subject requests this, All Property will take reasonable steps to attach to the information an indication that correction has been requested but has not been made;

16.1.3 a right to withdraw consent and to object to processing: a Data Subject that has previously consented to the Processing of his/her/its Personal Information has the right to withdraw such consent and may do so by providing All Property with notice to such effect at the address set out in paragraph 21. Further, a Data Subject may object, on reasonable grounds, to the Processing of Personal Information relating to him/her/it.

16.2 Accordingly, All Property may request the Data Subject to provide sufficient identification to permit access to, or provide information regarding the existence, use or disclosure of the Data Subject’s Personal Information.

16.3 Any such identifying information shall only be used for the purpose of facilitating access to or information regarding the Personal Information.

16.4 The Data Subject can request in writing to review any Personal Information about the Data Subject that All Property holds including Personal Information that All Property has collected, utilised or disclosed, as well as the following information:

(i) the purposes of Processing;

(ii) the categories of Personal Information concerned;

(iii) where possible, the envisaged period for which the Personal Information will be stored or, if not possible, the criteria used to determine that period;

(iv) the existence of the right to request from All Property rectification or erasure of Personal Information or restriction of Processing of Personal Information concerning the Data Subject or to object to such processing;

(v) the right to lodge a complaint with the Regulator;

(vi) where the Personal Information is not collected from the Data Subject, any available information as to their source; and (vii) the existence of automated Processing, including profiling and, at least in those cases, meaningful information about the logic involved as well as the significance and the envisaged consequences of such processing for the Data Subject. All Property shall respond to these requests in accordance with the GDPR and will provide the Data Subject with any such Personal Information to the extent required by law and any of All Property policies and procedures which apply in terms of the General Data Protection Regulation (GDPR).

16.5 The Data Subject can challenge the accuracy or completeness of his/her/its Personal Information in All Property records at any time in accordance with the process set out in All Property’s manual developed in terms of GDPR for accessing information.

16.6 If a Data Subject successfully demonstrates that their Personal Information in All Property’s records is inaccurate or incomplete, All Property will ensure that such Personal Information is amended or deleted as required (including by any Third Parties).

17. TIME PERIODS

17.1 All Property will respond to each written request of a Data Subject not later than 30 (thirty) days after receipt of such requests. Under certain circumstances, All Property may, however, extend the original period of 30 (thirty) days once for a further period of not more than 30 (thirty) days.

17.2 A Data Subject has the right to make a complaint to All Property in respect of this time limit by contacting All Property using the contact details provided in paragraph 21 below.

18. COSTS TO ACCESS TO PERSONAL INFORMATION

The prescribed fees to be paid for copies of the Data Subject’s Personal Information are listed in the GDPR Manual.

19. USE OF WEBSITE COOKIES

19.1 Our Website uses cookies, which are small text files sent by a web server to store on a web browser. They are used to ensure websites function properly, store user preferences when needed and collect anonymous statistics on website usage.

19.2 You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to the website. If you accept a “cookie” or fail to deny the use of “cookies”, you agree that we may use your personal information collected using “cookies” (subject to the provisions of this Policy). Where you either reject or decline cookies, you are informed that you may not be able to fully experience the interactive features of our Website.

20. CHANGES TO POLICY

20.1 All Property reserves the right to make amendments to this Policy from time to time and will use reasonable efforts to notify Data Subjects of such amendments.

20.2 The current version of this Policy will govern the respective rights and obligations between you and All Property each time that you access and use our Website.

21. All Property CONTACT DETAILS PHYSICAL & POSTAL ADDRESS

Physical Address: Av. Gaspar Corte Real 198,

Cascais,

Lisboa

Portugal.

Postal Address:

INFORMATION OFFICER: Jeffrey Zive : jdzive@gmail.com

DEPUTY INFORMATION OFFICER: Carlene le Roux connect@alchemy.co.za

If a Data Subject is unsatisfied with the manner in which All Property addresses any complaint with regard to All Property Processing of Personal Information, the Data Subject can contact the office of the relevant Regulator.

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