1. Introduction

Chartwell Country Estate (“CCE”, “we”, “us”, “our”) is committed to safeguarding the privacy of individuals and ensuring the lawful processing of personal information in accordance with the Protection of Personal Information Act 4 of 2013 (POPIA) and other applicable South African laws.

This Privacy Policy outlines how we collect, use, store, and protect your personal information when you visit our website or interact with our services

2. Responsible Party

• Responsible Party: Chartwell Country Estate
  Address: P.O. Box 70534, Bryanston,2021
• Email: jenni@chartwell.co.za
• Phone: 082 950-2335      
• Information Officer: Jenni Brown

3. What Personal Information We Collect

We may collect the following types of personal information:

3.1 Information You Provide Directly

• Name and contact details (email address, phone number)
• Comments and feedback submitted through our website
• Account registration information (if applicable)
• Any other information you voluntarily provide

3.2 Information Collected Automatically

• IP address and browser user agent string
• Website usage data and analytics
• Cookies and similar tracking technologies
• Images with embedded location data (EXIF GPS) if uploaded

3.3 Comments

When you leave comments on our site, we collect:

• The data shown in the comments form
• Your IP address and browser user agent string for spam detection
• An anonymized string (hash) from your email address for Gravatar service integration

4. Purpose and Lawful Basis for Processing

We process your personal information for the following purposes under POPIA:

4.1 Legitimate Interests (Section 11(1)(f))

• Enhancing website functionality and user experience
• Detecting and preventing spam and security threats
• Conducting website analytics and optimization

4.2 Consent (Section 11(1)(a))

• Sending marketing communications (where applicable)
• Utilizing optional cookies and tracking technologies
• Managing newsletter subscriptions (if applicable)

4.3 Contractual Necessity (Section 11(1)(b))

• Managing user accounts and login functionality
• Providing requested services

5. How We Use Your Information

Your personal information is used to:

• Provide and maintain our website services
• Respond to your comments and inquiries
• Detect and prevent spam and security threats
• Improve our website functionality and user experience
• Comply with legal obligations
• Send you relevant updates (with your consent)

6. Cookies and Tracking Technologies

6.1 Comment Cookies

If you leave a comment, you may opt-in to save your name, email, and website in cookies for convenience. These cookies last for one year.

6.2 Login Cookies

• Temporary cookies to test browser compatibility (discarded when browser closes)
• Login information cookies (last two days)
• Screen display preference cookies (last one year)
• “Remember Me” functionality (lasts two weeks)
• Post editing cookies (expire after one day)

6.3 Managing Cookies

You can control cookie settings through your browser preferences. However, disabling cookies may affect website functionality.

7. Data Sharing and Third Parties

7.1 Service Providers

We may share your information with:

• Gravatar service for profile pictures (subject to their privacy policy: https://automattic.com/privacy/)
• Automated spam detection services
• Website hosting and technical service providers

7.2 Legal Requirements

We may disclose your information when required by law or to:

• Comply with legal processes
• Protect our rights and property
• Ensure user safety and security

7.3 No Sale of Personal Information

We do not sell, trade, or rent your personal information to third parties.

8. Embedded Content

Our website may include embedded content from other websites (videos, images, articles). This embedded content behaves as if you visited the third-party website directly, and those sites may collect data about you according to their own privacy policies.

9. Data Security

We implement appropriate technical and organizational security measures to protect your personal information against:

• Unauthorized access, alteration, disclosure, or destruction
• Accidental loss or damage
• Unlawful processing

Security measures include secure data transmission, access controls, and regular security assessments.

10. Data Retention

10.1 Comments

Comments and their metadata are retained indefinitely to facilitate automatic approval of follow-up comments and maintain website functionality.

10.2 User Accounts

Personal information in user profiles is retained while your account is active and for a reasonable period thereafter as required for business purposes.

10.3 Other Data

Other personal information is retained only as long as necessary for the purposes outlined in this policy or as required by law.

11. Your Rights Under POPIA

You have the following rights regarding your personal information:

11.1 Right of Access

You can request confirmation of whether we process your personal information and access to such information.

11.2 Right to Correction

You can request correction of inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or unlawfully obtained personal information.

11.3 Right to Deletion

You can request deletion of your personal information where:

• It’s no longer necessary for the original purpose
• You withdraw consent (where consent was the basis for processing)
• It’s been unlawfully processed
• Deletion is required for legal compliance

11.4 Right to Object

You can object to the processing of your personal information in certain circumstances.

11.5 Right to Data Portability

You can request to receive your personal information in a structured, commonly used format.

12. Exercising Your Rights

To exercise any of your rights or make inquiries about your personal information:

Contact our Information Officer:

• Email: [Insert Email]
• Phone: [Insert Phone Number]
• Address: [Insert Address]

We will respond to your request within 30 days as required by POPIA.

13. Complaints

If you believe we have not handled your personal information in accordance with POPIA, you may:

1. Lodge a complaint with our Information Officer (contact details above)
2. Lodge a complaint with the Information Regulator:
   • Website: www.inforegulator.org.za
   • Email: complaints.IR@justice.gov.za
   • Phone: 012 406 4818

14. Cross-Border Data Transfers

If we transfer your personal information outside South Africa, we ensure adequate protection through:

• Adequacy decisions by competent authorities
• Appropriate safeguards such as binding corporate rules or standard contractual clauses
• Your explicit consent where required

15. Children’s Privacy

Our website is not directed at children under 18. We do not knowingly collect personal information from children under 18 without parental consent.

16. Changes to This Privacy Policy

We may update this Privacy Policy periodically. We will notify you of material changes by:

• Posting the updated policy on our website
• Updating the “Last Updated” date
• Sending email notifications for significant changes (where we have your email address)

17. Contact Information

• For any questions about this Privacy Policy or our privacy practices, please contact our Information Officer:
• Name: Jenni Brown
  Address: P.O. Box 70534, Bryanston,2021
• Email: jenni@chartwell.co.za
• Phone: 071 403-3487      

18. Governing Law

This Privacy Policy is governed by the laws of South Africa, including POPIA and other applicable privacy legislation.