Venco, Inc. and it's subsidiaries Venco Platforms Ltd collectively known as Venco are dedicated to protecting the confidentiality and privacy of personally identifiable information entrusted to Us (“Personal Data”). As part of that fundamental obligation, We are committed to protecting the use of the Personal Data which We collect on https://venco.africa and Venco application software (the “App”).

The App allows users access a variety of application services and provide services which include collection of utilities, communications management, visitor management and check-ins (“Services”) to residents of residential estates. This privacy policy (“Privacy Statement”) sets out the basis upon which We will process, store, and disclose any Personal Data that is provided voluntarily by users of the App (“Data Subject” or “you” or “your”) in connection with the Services that We offer.

1.1. We note that the relevant data privacy regulations distinguishes between entities that are “controllers” of Personal Data and entities that “process” Personal Data. We note that We are a “Data Controller” where We determine the purposes for and the manner in which Personal Data is processed or is to be processed and We are a “Processor” for those Services where We only use Personal Data which are requested by other Data Controllers.

1.2. Where We make decisions on how Personal Data is used in connection with Our Services (where We are acting as a controller), We are responsible for the obligations of a “Controller” under the relevant data protection regulations in connection with the processing of Personal Data – for example, We use this Privacy Statement and other notices to provide you with information about Our use of personal information, as required by the relevant data protection regulations. Where We only use Personal Data requested by other Data Controllers (where We are acting as a processor), those other Data Controllers are similarly responsible for the obligations of a “Controller” under applicable laws in connection with the processing of personal information, and, if you are using Our Services through those other Controllers, you should contact them if you have questions or concerns about the processing of your personal information or compliance with the relevant data protection regulations and other applicable law

1.3. This Privacy Statement may change from time to time. Unless otherwise stated, any updates to this Privacy Statement become effective when We post the updates on Our website and App. Your continued use of the App for Our Services following an update to the Privacy Statement means that you accept the updated Privacy Statement.

2.1. Please read this Privacy Statement very carefully. If you do not wish to be bound by the provisions of this Privacy Statement, you should not access the App or sign up for Our Services. By using the App, and by signing up for Our Services, you hereby confirm that you have read, understand, and agree to be bound by the Privacy Statement.

2.2. Additionally, please note that the option to sign up on the App is intended solely for persons who are 18 (Eighteen) years of age and above, and any registration by, use of or access to the Services by any person under 18 (Eighteen) is unauthorized and in violation of this Privacy Statement. Venco does not knowingly collect Personal Data from children under the age of 18 (Eighteen). We therefore also ask you, if you are under the age of 18 (Eighteen), please do not send us or submit your Personal Data.

2.3. By Clicking “Accept” at the bottom of the page, you hereby confirm that:

• you have read, understand, and agree to be bound by the Privacy Statement and you hereby expressly consent to the processing of Personal Data for the purpose of accessing the Services;
• you hereby give Us consent to the collection and processing of your Personal Data for the purpose of providing the Services;
• you hereby certify that all the information provided by you are true and correct and that any misrepresentations or falsity, whether intentional or not, therein will be considered as an act to defraud Us and Our partners;
• you authorize Us to verify and investigate the above statements/information as may be required, from the references provided and other reasonable sources; and
• For this purpose, you hereby waive your rights on the confidentiality of client information and expressly consent to the processing of any Personal Data and records relating to you that might be obtained from third parties, including government agencies, your employer, business associates, and other entities.

3.1. This Privacy Statement describes your privacy rights regarding Our collection, use, storage, sharing and protection of your Personal Data. It applies to Our website, App and all other related applications, services, tools and physical contact with Us regardless of how you access or use them.

3.2. You have the following rights:

• right to request from Us access to and rectification or erasure of your Personal Data;
• right to restrict processing or object to processing of your Personal Data;
• right to data portability;
• right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
• right to lodge a complaint with the relevant authority.

4.1. This section details the Personal Data We may collect about you. We explain why, and how, We use it in later sections. If you decide to create an account or enquire about one of Our products or Services, We’ll ask You to provide Us with some specific information, for example: Basic personal details – such as name, surnames, passport photograph, age, gender and date of birth; Personal contact details – such as home address, home phone number, mobile phone number, and email address; Work details – such as job title, department, company name, company address; Log in details – such as username and password; Usage Information and Browsing History – such as usage metrics (including usage rates, occurrences of technical errors, diagnostic reports, settings preferences, content and advertising interactions; Banking details –account number. We may also collect additional information involving Your opinion of Our products and Services and Your preferences regarding other services such as newsletter subscription, and any other information required to provide the Services to you.

4.2. Information about your computer and mobile device hardware and software may be automatically collected by Us. This information can include: your IP address and location, browser and device name, type and version, operating system type and version, language preferences, domain names, the information you search for on the Services, access times and dates, referring website addresses and other statistics. This information is used for the operation of the Service, to maintain quality of the Service, and to provide general statistics regarding use of the App.

4.3. Please keep in mind that if you directly disclose Personal Data through Venco public message boards, this information may be collected and used by third parties.

4.4. Our website and App may contain links to other resources not owned or controlled by Us and as such, We encourage you to review the privacy statements of websites you choose to link from Our website and App so that you can understand how those websites collect, use and share your information. Please bear in mind that Venco is not responsible and will not be liable for the privacy practices or other content of such other resources or third parties.

5.1. We may collect Personal Data about you either directly from You, from certain third parties (such as your employer or the subscriber providing access to Our Services), or from other sources (such as publicly available sources) when you:

• Search for, subscribe to Our Services.
• Use Our Services or otherwise interact with Us.
• Create or maintain a profile or account with Us.
• Purchase, use, or otherwise interact with content, products, or services from third party providers who have a relationship with Us.
• Create, post, or submit user content on Our Services.
• Register for or attend one of Our events or locations.
• Request or sign up for information.
• Communicate with Us by phone, email, chat, in person, or otherwise.
• Complete a questionnaire, survey, support ticket, or other information request form.
• When you express an interest in working with Us or apply for a job or position with Us.

• Your organization and others with whom you have a relationship that provide or publish Personal Data related to you, such as from Our customers when they arrange access to Our Services for you or from others when they create, post, or submit user content on Our Services that may include your Personal Data.
• Professional or industry organizations and certification/licensure agencies that provide or publish Personal Data related to you.
• Third parties and affiliates who resell or integrate with Our Services.
• Service providers and business partners who work with Us in relation to Our Services and that We may utilize to deliver certain content, products, or services or to enhance your experience.
• Marketing, sales generation, and recruiting business partners.
• Government agencies and others who release or publish public records.
• Other publicly or generally available sources, such as social media sites, public and online websites, open databases, the corporate affairs commission, and data in the public domain.

6.1. We only process Personal Data where We have a lawful basis for doing so, such as the following:

6.1.1. User consent – This is where you have given Us explicit permission to process Personal Data for a given purpose. For example, if you create a profile on Our App, We may additionally ask you to consent to Us processing your Personal Data.

6.1.2. Contractual necessity – This is where We have to process Personal Data to meet Our contractual obligations.

6.1.3. Legal obligation – This is where We have to process Personal Data in order to comply with the law.

6.1.4. Protection of vital interests – This is where We are constrained to process your Personal Data in order to protect your interests or those of another person, such as to prevent identity theft.

6.1.5. Public interest – This is where there is an overriding public interest or We have been vested with an official public mandate to take certain action in the interest of the public.

6.1.6. Legitimate/Commercial interest. This is where We process Personal Data in order to protect Our legitimate/commercial interests.

7.1. Venco acts as a Data Controller when using your Personal Data in providing you with Services. We use Personal Data about you in the following ways:

• to provide you access to Our Services;
• to improve and maintain performance of the App, by ensuring that the content on the App is presented in the most effective manner for you;
• to provide you with data about services that you request from Us or which We feel may interest you, where you have consented to be contacted for such purposes;
• for statistical analysis or market research;
• to develop and improve Our Services;
• to update Our records;
• to detect, investigate, prevent, or tackle illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of Data Subject;
• to ensure Our compliance with Our policies, terms, and other applicable laws and regulations;
• to respond to inquiries and offer support to you;
• to request your feedback and improve your user experience;
• to carry out Our obligations arising from and exercise Our rights under any agreements between you and Us;
• to allow you to participate in interactive features of our Services, when you choose to do so;
• to notify you about changes to Our Services or potential new services that We may offer;
• to provide you with customer service;
• for any legitimate business Interest;
• recruitment – If you apply for a role via one of Our sites, We will process your information in order to facilitate the application process;
• to process and assess your application for employment with Us; and
• in any other way that you have specifically consented to.

• Purpose: We access your contacts to streamline the process of creating a visitor booking by allowing you to select a contact from your phonebook directly. This ensures that the contact information is accurate and saves you time.
• Data Collection: When you select a contact from your phonebook for visitor booking, we collect the following information: Name, Phone Number, and any other information you choose to provide about that contact.
• Data Storage:The contact information collected is stored securely on our backend to process the visitor booking. It will be retained as part of the visitor booking data and will be used solely for this purpose.
• Control:You have the option to manually enter the contact information if you prefer not to grant this permission. You can also view, update, or delete the stored contact information at any time through your account settings.

• Purpose: We request access to your media library to empower you to better describe and report issues to your community managers. By allowing you to attach images and videos, you can provide a visual context that greatly aids in problem-solving and issue resolution.
• Data Collection: When you choose to attach media to your issue reports, we collect the following data:
  - Images and Videos: These visual materials are meant to complement your descriptions and provide valuable context to your community managers.
• Data Storage: Your collected images and videos are stored securely on our backend servers. They are accessible exclusively to your assigned community managers who need access to these materials for issue resolution. We are committed to maintaining the privacy and confidentiality of your media.
• Control:You have full control over your media. You can choose to attach or not attach media to your issue reports as per your preference. You can also rest assured that the collected media will only be visible to the community managers assigned to the reported issues. Your trust in us is important, and we want to assure you that we will never use your media for any other purpose than facilitating issue reporting and resolution. Please grant access to your media library to enhance the effectiveness of issue reporting.

8.1. We do not share Personal Data with unaffiliated third parties, except as necessary for Our legitimate business interest, to provide you with Our Services, and/or as required or permitted by law or professional standards and generally to facilitate the running of Our business or to provide specific services you have requested. We would only transfer Personal Data to the following categories or situations, when they meet Our strict standards on the processing of data and security. We only share Personal Data that is necessary for them to provide their services. Venco will not transfer your Personal Data to any third parties for their own direct marketing use except as stated herein. Commonly, We may share your Personal Data with:

8.1.1. Service providers – We engage service providers who help to support Our business and improve Our products. These service providers may include payment processors, customer service agencies, hosts, organizers and sponsors of Our events; organizations that host Our website, App or databases and providers of online surveys. We have contracts in place with these data processors and they can only use your Personal Data under Our instruction.

8.1.2. Advertisers – We, and Our advertising partners, use cookies to collect Personal Data and serve you with advertisements that We believe are relevant to you and your interests.

8.1.3. –Audits – disclosures of Personal Data may also be needed for data privacy, financial or security audits and/or to investigate or respond to a complaint or security threat. We, and Our advertising partners, use cookies to collect Personal Data and serve you with advertisements that We believe are relevant to you and your interests.

8.1.4. Legal processes and successors in title – We, and Our suppliers, may also disclose your Personal Data to comply with applicable laws, court orders or other valid legal processes, and to enforce or apply Our terms of use, any subscription agreement, or any of Our other rights. We may transfer or disclose your Personal Data to any entity which takes over or acquires the relevant Venco company. We also share aggregated, non-identifiable information with third parties. Before sharing this information, We ensure that it cannot identify you as an individual. For example, We may share information about the size and growth of Our customer base with investors.

9.1. We retain your Personal Data for as long as your account is active and therefore open; this allows you to continue accessing Our content, products and Services.

9.2. If you become inactive and are not a subscriber, We retain your Personal Data only for the period within which it is reasonably needed and may delete elements of your Personal Data associated with your account. We will normally warn you if your access is going to be withdrawn and give you the opportunity to retain your account.

9.3. Where We don’t need to keep all of your Personal Data in full, We may obfuscate or aggregate it, for example, web activity logs and survey responses. This is to ensure that We do not retain your Personal Data for any longer than is necessary.

9.4. It is sometimes necessary for Us to keep your Personal Data for longer periods of time, for example:

9.4.1. If there is a statutory requirement to retain it;

9.4.2. If We require the Personal Data for legal reasons or there is a legitimate business need for Us to retain same;

9.4.3. To ensure We do not contact you if you have asked Us not to; and

9.4.4. To use aggregated data derived from incorporating your Personal Data after your user account becomes inactive, but not in a manner that would identify you personally.

10.1. We employ all reasonable efforts to keep your Personal Data secure by taking appropriate technical and organizational measures against its unauthorized or unlawful processing and against its accidental loss, destruction or damage. We store and process your Personal Data on computers outside your jurisdiction. Where We need to transfer your Personal Data to another country, We would take reasonable steps to ensure that such country has an adequate data protection law. You hereby consent to the transfer of your Personal Data to countries which may not be on the white list specified by the relevant data protection regulations where such transfers become expedient for us. We protect your Personal Data using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards We use are firewalls and data encryption, physical access controls to Our data centers, and information access authorization controls.

10.2. However, no data transmission over the internet or wireless network can be 100% guaranteed. Therefore, whilst We strive to protect your Personal Data, you acknowledge that:

10.2.1. there are security and privacy limitations of the internet which are beyond Our control;

10.2.2. the security, integrity, and privacy of any and all information and data exchanged between you and Us cannot be 100% guaranteed; and

10.2.3. any such information and data may be viewed or tampered with in transit by a third party, despite Our best efforts.

11.1. In the event We become aware that the security of Our Services have been compromised or users’ Personal Information have been disclosed to unrelated third parties as a result of an external activity, including, but not limited to, security attacks or fraud, We reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, We will make reasonable efforts to notify affected individuals if We believe that there is a reasonable risk of harm to the user as a result of the breach.