Data Protection Policy for Crowned Heirs

In accordance with the Protection of Personal Information Act 4 of 2013

About Crowned Heirs

Crowned Heirs is an online store based in Nelspruit, South Africa, offering handmade leather footwear, health-promoting products, and fashionable items.

Information Officer

Laura Beaurain has been appointed as the Information Officer for Crowned Heirs. She serves as the primary contact for any matters related to the Protection of Personal Information Act 4 of 2013 ("the Act").

Purpose of This Document

This document outlines the following:

       The types of personal information processed by Crowned Heirs

-            The reasons for collecting this information and its intended use

-            The methods of storing personal information and retention periods

-            Contact information for queries regarding personal data

This policy is accessible on the Crowned Heirs website: https://crownedheirs.net/ and can be requested from the Information Officer.

The Purpose of the Act

The Protection of Personal Information Act aims to safeguard personal information processed by public and private institutions by:

-            Establishing minimum requirements for processing personal information

-            Creating a regulatory authority to enforce the Act’s provisions

-            Enabling the issuance of codes of conduct for bodies processing personal information

-            Protecting data subjects against unsolicited electronic communications and automated decision-making concerning their personal information

-            Regulating the transfer of personal information outside South Africa

Important Definitions

-            Data Subject: The individual to whom the personal information pertains.

-            Personal Information: Includes details such as race, gender, sex, pregnancy, marital status, national, ethnic, or social origin, colour, sexual orientation, age, health, disability, religion, belief, culture, language, birth, education, medical, financial, criminal or employment history, identifying numbers, contact details, biometric data, personal opinions, confidential correspondence, and related information.

-            Processing: Refers to actions such as collection, recording, organisation, storage, retrieval, use, dissemination, modification, restriction, erasure, or destruction of personal information.

-            Record: Any documented form of personal information, whether written, electronic, labelled, mapped, or visual.

-            Responsible Party: The entity that determines the purpose and means of processing personal information. For this policy, Crowned Heirs is the Responsible Party.

-            Operator: A person or entity processing personal information on behalf of the Responsible Party under contractual or mandated terms.

-            Filing System: Any structured collection of personal information accessible according to specific criteria.

Contact Details of Information Officer

-            Attention: Laura Beaurain

-            Postal Address: Kiaat Estate, 11 Mandolin Street, Sonheuwel, Mbombela, Mpumalanga, SA 1206

-            Physical Address: Kiaat Estate, 11 Mandolin Street, Sonheuwel, Mbombela, Mpumalanga, SA 1206

-            Telephone: +27 (0)82 737 2883

-            E-mail: admin@crownedheirs.net

Types of Personal Information Processed by Crowned Heirs

Customers

-            Juristic Persons: Bank account details, company or close corporation registration numbers, business logos, business email addresses, physical and postal addresses, telephone numbers, location information, and relevant terms and conditions.

-            Natural Persons: Bank account details, identity numbers, business logos, email addresses, physical and postal addresses, telephone numbers, location information, and relevant terms and conditions.

-            Representatives of Juristic Persons: South African identity number, business email address, place of employment, employer address, and work/personal telephone numbers.

Employees

-            Personal details such as name, race, gender, sex, pregnancy, marital status, origin, colour, sexual orientation, age, health, disability, religion, belief, language, and birth.

-            Education, medical, financial, criminal, or employment history.

-            South African identity number, personal email address, physical address, personal telephone numbers, location information, and online identifiers.

-            Private and confidential correspondence.

-            Records kept in physical or electronic filing systems.

Third-Party Service Providers

-            Bank account details.

-            Company or close corporation registration number, South African identity number, business logo, business email addresses, physical and postal addresses, telephone numbers, location information, and VAT numbers.

Reasons for Collecting Personal Information

Customers

The information is required to provide ordered goods and services. If customers do not provide the required information, Crowned Heirs cannot deliver its services. Information may be shared with operators solely for service provision, under strict compliance with the Act. Operators are contractually bound to use personal information only for its intended purpose and must maintain Act-compliant systems.

Employees

Personal information is used exclusively for managing the employment relationship. Employee information is not shared with third parties except in compliance with the Act, relevant Labour Law, or with the employee’s explicit consent.

Third-Party Service Providers

Information is needed to conduct business and establish agreements. Crowned Heirs may share data with other operators to maintain high service standards, under strict contractual obligations to compliance and confidentiality. If service providers do not supply required information, agreements cannot be concluded.

Storage and Security of Personal Information

Personal information is stored both electronically and in hard copy. Electronic data is encrypted and kept on cloud-based systems, not on internal or external hard drives. Crowned Heirs maintains physical and electronic data security policies, managed internally by the Information Officer. These policies are not publicly available unless legally required for data protection.

Disclosure of Personal Information to Third Parties

Crowned Heirs will only disclose personal information to external parties if required by law, in the public interest, or to protect its rights. The company endeavours to keep all information accurate, secure, and up-to-date. Individuals may request corrections to their information as needed. Employees are bound by confidentiality agreements to safeguard customer privacy.

Transborder Information Flows

Personal information will not be transmitted internationally without consent, unless necessary for contractual obligations and beneficial to customers or third-party providers. If data is transferred, equivalent protection under laws similar to POPIA, such as the EU GDPR, will be ensured.

Retention of Personal Information

Companies Act No. 71 of 2008

-            Documents such as incorporation certificates, name change certificates, memoranda of incorporation, company rules, registers of secretary and auditors, disclosures of beneficial interest, security registers are kept indefinitely.

-            Records including meeting minutes, resolutions, annual reports, financial statements, accounting records, director information, written communications, and committee minutes are kept for seven years.

Closed Corporation Act No. 69 of 1984

-            Accounting records and annual financial statements are retained for fifteen years.

-            Records of current and past members, minutes, and resolutions are kept indefinitely.

Consumer Protection Act No. 68 of 2008

-            Consumer records such as names, addresses, ID numbers, service details, fees, advice, instructions, and promotional competition documentation are retained for three years.

Compensation for Occupational Injuries and Diseases Act No. 130 of 1993

-            Employee earnings records and related data are kept for four years.

-            Committee recommendations and incident reports are kept for three years.

Basic Conditions of Employment Act No. 75

-            Employee particulars, work time, remuneration, and relevant data are kept for three years.

Employment Equity Act No. 55 of 1998

-            Workforce records and equity plans are retained for three years.

Unemployment Insurance Act No. 63 of 2002

-            Employee personal records are kept for five years from the date of submission.

Access to and Correction of Information

Customers, employees, and third parties may request access to their personal information held by Crowned Heirs. They also have the right to ask for updates, corrections, or deletion of their data on reasonable grounds. Once an objection to processing is raised, Crowned Heirs may only continue processing if contractually obligated. Reasonable steps will be taken to verify identity before providing or amending personal information. Employees are obliged to maintain confidentiality regarding company and customer data. Disclosure to third parties is only permitted with written customer consent or legal requirement. If a record cannot be found, Crowned Heirs will inform the requester of the search steps taken.

Deletion and Destruction of Information

Individuals may request access, correction, or deletion of their personal information. Crowned Heirs will act on such requests unless contractually bound to retain the data. Identity verification will precede any access or changes.

Requests for Access or Changes

Requests must be made using the prescribed form addressed to the Information Officer, with sufficient detail to identify the record and requester. The specific form of access and notification preferences should be indicated. If acting on behalf of another person, proof of authorisation is required. Forms for access (Annexure A) and for objection, correction, or deletion (Annexure B) are appended to this policy.

Fees

The Information Officer will notify the requester of any applicable fees before processing, except for personal requesters who do not pay fees.

Requesters may challenge fees in court.

-       If access is granted, additional fees may apply for search, reproduction, and extended processing time.

Availability of the Manual

This manual is available for free inspection at Crowned Heirs’ offices, on the company website, or by request from the Information Officer.

Policy Amendments

The policy will be reviewed and amended as needed. Customers are encouraged to check the website regularly for updates. Material changes will be posted online, and the latest version will supersede previous editions.

Signed at: Crowned Heirs, Kiaat Estate, 11 Mandolin Street, Sonheuwel, Mbombela, South Africa on this 3^rd (third) day of October 2025.

INFORMATION OFFICER – Laura Beaurain