Privacy Policy

---

 1. Introduction

1.1. Loom Property Insights (“Loom”) is a data analytics and solutions service provider.

1.2. This document sets out our privacy policy (our "Privacy Policy") and describes how we collect, use, share, process and store your Personal Information (as described in our Terms).

1.3. The expressions or words defined in the Terms shall, where used in our Privacy Policy in their capitalised form, bear a similar or corresponding meaning.

1.4. If you use our Website (as described in our Terms), you consent to the collection, use, sharing, processing and storage of your Personal Information in terms of our Privacy Policy and, furthermore, you agree to our Terms.

1.5. We provide you with the choice of closing your Loom account and to no longer use our Website.

1.6. We take great care (and follow best worldwide industry practices) in protecting your Personal Information and keeping it confidential.

1.7. Loom is a responsible party in terms of POPIA (the Protection of Personal Information Act, No. 4 of 2013).

2.1. We obtain from you such of your Personal Information as is necessary to provide the services to you.

2.2. We process your Personal Information and enter it into a secure information repository – we do all this in a completely automated/electronic environment.

2.3. Once you have subscribed to our services, your own service providers may request your Personal Information from us for the purpose of providing/rendering (or wishing to provide/render) their products and/or services to you.

3.1. To create your account with us and register, you need to provide us with the following Personal Information:

• 3.1.1. Your full names, surname, email address, telephone/ cell phone number as well as the Estate Agency details if you are employed by one.

3.2. This information is used by us to open your Loom account and allows us to contact you. If you have accepted the Terms, you are prompted to verify your details and to then create your secure login and password details. Once you have done this, you will be prompted to upload the remainder of your Personal Information (you may choose which aspects of your Personal Information you upload).

3.3. If your own service provider requests Personal Information from us and such request contains information that you have not uploaded, we will send you a notification of the request. When you log in to your Loom account, we will flag the information that you have not uploaded, and you will be unable to approve the request of your own service provider until you have uploaded the relevant information.

3.4. You should change your secure password at least quarterly as an additional measure to keep your account as secure as possible. We also provide additional security measures such as Two-Factor Authentication.

3.5. Should there be changes to your security information (such as your login information), we will send you a verification alert via our service (or through e-mail, mobile phone or otherwise) to confirm that you want to make the changes. If you did not request to make the changes, please contact us by sending an email to support@loom.co.za.

3.6. We provide you with the opportunity to provide feedback on features and to rate your experience when visiting the Website. We will track and keep record of any feedback given by you.

4.1. We use your Personal Information to enable us to render our services to you and to fulfil our contractual obligations to you under the Terms, including confirming and verifying your identity/information with third party service providers.

4.2. We may contact you through our service or through e-mail, mobile phone, notices posted on the Website, messages to your account, push notifications or any other effective way.

4.3. Service-related announcements or technical notices will be sent to you through the alert’s module. You can opt to receive these communications via e-mail by adjusting your preferences.

4.4. Support requests and user feedback is stored by us for record-keeping and quality assurance purposes. Should you wish to provide feedback, lodge a complaint or query, or request technical support, please contact our support by sending an email to support@loom.co.za. This information also facilitates the resolution of similar issues and allows us to improve our overall service to our subscribers and customers.

4.5. Should you wish your information to be removed from our servers, you must close your account with Loom.

5.1. Any Personal Information that you include on your account will be shared with your own service providers if you approve a request by such service provider for your Personal Information (via our service).

5.2. We might make use of third party service providers to, amongst other things, verify the authenticity and validity of information supplied by you. The relationships between us and all third party service providers are strictly protected and regulated by contracts. All the data protection policies of third party service providers are reviewed by us regularly.

5.3. We do not share any more information than what is required by third party service providers to validate and verify your information. We maintain these requirements to meet the criteria of POPIA and similar Personal Information protection legislation.

6.1. We will not process your Personal Information for any purpose other than what is required to provide our services.

6.2. We store your Personal Information in our information repository while your Loom account is in existence or as needed to provide you with our services.

6.3. The Loom servers where we store your Personal Information may also be based in territories outside of South Africa, meaning that your Personal Information may be transferred across borders to countries that may have personal information protection laws that differ from those of South Africa. By using our services, you agree to the transfer of your Personal Information across borders.

7.1. In terms of POPIA, you have the right to have your personal information processed in accordance with the conditions for the lawful processing of personal information. Amongst other things, you may object to your personal information being processed pursuant to section 11(3) of the POPIA. To do so, please lodge your request in the prescribed manner using the prescribed form, which you may submit to the email address support@loom.co.za.

7.2. Pursuant to section 23 of the POPIA, you may request us to confirm, free of charge, whether we hold any of your personal information. You may also, against payment of the prescribed fee, request the record or a description of the personal information about you held by us, including information about the identity of all third parties, or categories of third parties who have access to this information. You are required to provide adequate proof of identity in order to exercise these rights. To do so please send an email to support@loom.co.za.

7.3. You are also advised of your rights pursuant to section 24 of the POPIA to request us to:

• 7.3.1. Correct or delete your personal information in our possession or under our control that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully; or
• 7.3.2. Destroy or delete a record of your personal information if we are no longer authorised to retain it in terms of section 14 of the POPIA. To do so, please send an email to support@loom.co.za.

8.1. If you choose to close your Loom Account, we will, as soon as reasonably possible thereafter, destroy your Personal Information contained in our secure information repository. You do acknowledge and agree, however, that your own service providers, whom you have shared your Personal Information with, will continue to have your Personal Information in their possession.

8.2. We may retain your Personal Information even after you have closed your Loom Account if it is reasonably necessary to comply with our legal obligations, for dispute resolution purposes or to be able to confirm previous verifications of your identity.

9.1. The security of your Personal Information is of utmost importance to us. To ensure the security of your Personal Information we implement strict security safeguards designed to protect your Personal Information.

9.2. We regularly monitor our systems for possible vulnerabilities and attacks. We use secure socket layer (SSL) technology to encrypt the Personal Information that you send to us.

9.3. We cannot, however, warrant the security of any information that we store in our secure information repository. There is no guarantee that your Personal Information will not be accessed, disclosed, altered, or destroyed by breach of any of our physical or technical barriers/safeguards.

10.1. It is possible that we will need to disclose your Personal Information when required by law, subpoena, or other legal process, or if the Information Regulator is satisfied that:

• 10.1.1. The public interest in the disclosure outweighs, to a substantial degree, the interference that the disclosure will cause to your privacy; or
• 10.1.2. The disclosure involves a clear benefit to you that outweighs, to a substantial degree, any interference that the disclosure will cause to your privacy.

10.2. We may also need to disclose your Personal Information to:

• 10.2.1. Enforce the Terms,
• 10.2.2. Investigate and defend ourselves against any third party claims or allegations,
• 10.2.3. Protect the security or integrity of our service; or
• 10.2.4. Exercise or protect the rights and safety of Loom, our customers and/or third party service providers.

10.3. We will attempt to notify you about any legal demands for the disclosure of your Personal Information when appropriate, unless it is prohibited by law or court order, or when the request is an emergency. We may dispute legal demands when we believe, in our sole discretion, that the requests are vague or lack authenticity and/or proper authority. However, we do not promise to challenge every demand.

11.1. Whilst we will do all things reasonably necessary to protect your Personal Information, we cannot guarantee or accept any liability whatsoever for any unauthorised or unlawful disclosures of your Personal Information, whilst in our possession, made by third parties who are not subject to our control, unless such disclosure is as a result of our gross negligence.

11.2. If you disclose your Personal Information to a third party, such as an entity which operates a website or app linked to the Loom Website, or anyone other than us, we will not be liable for any loss or damage suffered by you as a result of the disclosure of such information to the third party concerned. You should always ensure that you read the privacy policy of any third party (such privacy policy will not be accessible on the Website).

12.1. We can amend/change our Privacy Policy at any time.

12.2. If we make material changes to our Privacy Policy, we will provide notice thereof to you through our service (or by e-mail, mobile phone or by any other effective means) to provide you with the opportunity to review the amendment/change before it becomes effective. If we change/modify this Privacy Policy, the Terms or our Cookie Policy, we will prompt you to accept the updated Privacy Policy before you can continue the use of our Services.

12.3. If you object to any change, you may close your Loom Account. You acknowledge that your continued use of our Website and services after we publish or send a notice about the amendment/change to our Privacy Policy means that the collection, use, sharing, processing and storage of your Personal Information is and will be subject to our updated Privacy Policy.

13.1. A computer cookie is a small piece of data stored on your device by our Website when you use or access the Website. The purpose of a cookie is to identify specific users and improve your web browsing experience. Our Website uses cookies to give you a personalised experience that suits your online behaviour, which include personalising content and advertisements, providing social media features and to analyse our traffic. We may also from time to time share information about your use of our Website with our social media, advertising and analytics partners.

14.1. We recommend that you read through the privacy policy of any website you visit via a link on the Website, as sharing your Personal Information on any other sites will be governed by their privacy policies (not ours).

14.2. We are not responsible for the privacy policies of other entities. Our Privacy Policy applies solely to your Personal Information collected via the Loom Website and processed and stored by us.

15.1. If you have any questions, complaints or objections regarding this Privacy Policy, please contact us at:

• 15.1.1. Full name: Loom Property insights (Pty) Ltd
• 15.1.2. Registration number: 2020/780782/07
• 15.1.3. Physical address & Registered Address: The Wedge Office Park, 43 Garsfontein Road, Pretoria, Gauteng, 0181.
• 15.1.4. Telephone number: 011 516 5500
• 15.1.5. Website address: www.loom.co.za
• 15.1.6. E-mail address: support@loom.co.za

15.2. If you want to send us notices, please use our e-mail address (see clause 15.1.6 above).

15.3. If you want to serve process on us, please use our physical address (see clause 15.1.3 above).

15.4. We will provide notices to you:

• 15.4.1. Within our System, or
• 15.4.2. By sending it to your contact information provided to us (e.g., e-mail, mobile number, physical address, etc.).