This is an ever-evolving document, please see our website from time to time for the latest version.

Justine Del Monte & Associates Inc, a company registered in South Africa under registration number 2016/499327/21 having its registered address at Suite 20024, 2nd Floor, One Thibault, 17 Hans Strijdom Avenue, Cape Town (“Justine Del Monte & Associates”, “we”, “our”, “us”).

This notice sets out the basis on which any personal information Justine Del Monte & Associates collects from you, or that you provide to Justine Del Monte & Associates , will be processed by us. Please read the following carefully to understand our practices regarding your personal information and how we will treat it.

If you are an employee or consultant, please contact the Information Officer at justine@justinedelmonte.co.za or 021 001 4400 for a copy of the privacy notice applicable to you.

Information we collect from third parties

We collect names, identity numbers, contact details, billing address, financial and tax information and key employee information from clients for the purposes of onboarding you as a client, managing your account, delivering services to you, invoicing you, performing the contract we have with you, complying with tax obligations such as VAT and enforcing the terms of our contract with you.

We collect names, contact details, financial and tax information and key employee information from suppliers and professional service providers so that we can place orders/instruct you and make payment in respect of any goods or services we receive and comply with tax obligations such as VAT.

We may conduct ‘know your customer’ or ‘know your supplier’ or similar compliance screenings on you or your organisation, where we collect additional information such as your identification or passport documents and information, address, company incorporation documentation and share registers and tax information. We obtain this information either directly from you or from your employer, or the company you are shareholder or director of. In the context of conducting compliance screenings, we may also check the personal information provided to us against public information, including official sources (such as sanctions lists), media sources (such as news reports, journal articles), and additional government and official sources (such as court records, election results, company filings, official company websites and press releases).

In the exceptionally rare event of a compliance screening hit, we may potentially collect special personal information such as information regarding proceedings relating to alleged criminal conduct and/or political affiliations.

We may also collect names and contact details of third parties engaging with our clients for the purposes of assisting our client in the services we provide and performing the contract we have with our clients. We may collect this information from the third party or from our clients directly.

We may collect names and contact details and CCTV footage of persons visiting our premises. We collect this information for security purposes.

We collect names, identity numbers, contact details, billing address, financial and tax information and key employee information from clients for the purposes of onboarding you as a client, managing your account, delivering services to you, invoicing you, performing the contract we have with you, complying with tax obligations such as VAT and enforcing the terms of our contract with you.

We collect names, contact details, financial and tax information and key employee information from suppliers and professional service providers so that we can place orders/instruct you and make payment in respect of any goods or services we receive and comply with tax obligations such as VAT.

We may conduct ‘know your customer’ or ‘know your supplier’ or similar compliance screenings on you or your organisation, where we collect additional information such as your identification or passport documents and information, address, company incorporation documentation and share registers and tax information. We obtain this information either directly from you or from your employer, or the company you are shareholder or director of. In the context of conducting compliance screenings, we may also check the personal information provided to us against public information, including official sources (such as sanctions lists), media sources (such as news reports, journal articles), and additional government and official sources (such as court records, election results, company filings, official company websites and press releases).

In the exceptionally rare event of a compliance screening hit, we may potentially collect special personal information such as information regarding proceedings relating to alleged criminal conduct and/or political affiliations.

We may also collect names and contact details of third parties engaging with our clients for the purposes of assisting our client in the services we provide and performing the contract we have with our clients. We may collect this information from the third party or from our clients directly.

We may collect names and contact details and CCTV footage of persons visiting our premises. We collect this information for security purposes.

If you have opted in to receive our newsletter, we collect your name, surname, email and telephone number in order that we can direct market to you. We will only use the information you provide for this purpose and you will be able to opt-out of receiving this at any time.

If you have completed our contact form, we collect your name, surname, email and telephone number and any other information you provide in order that we can contact you or respond to your question. We will only use the information you provide for this purpose.

Our website uses automatic systems of data collection, such as cookies. A cookie is a device transmitted to the hard disk of a user. Cookies do not contain intelligible information but allow linking between you and your personal information, such as your IP address and other information about your experience on the website. The information and data are gathered directly and automatically by the website. We process information collected by cookies in a collective and anonymous way in order to optimize the website for the needs and preferences of the users. Please access the information on your Internet browser if you wish to delete cookies after using the website. If you have started the procedure of deleting cookies, we can’t ensure that all of our web pages will be displayed and that all of our services will be available to you.

We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help a website’s operator analyse how users use the site. The non-personal information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers located around the world. Google will use this information for evaluating your use of the website, compiling reports on website activity for website operators, and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by them. You may refuse the use of cookies by selecting the appropriate settings in your web browser; however, please note that if you do this, you may not be able to use the full functionality of the website. By using the website, you consent to the processing of data about you by Google in the manner and for the purposes set forth above.

Google Analytics collects information anonymously. It reports website usage trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you use the website. For more information on opting out of being tracked by Google Analytics across all websites you use, visit https://support.google.com/analytics/answer/181881. For more information on the Google Privacy Policy, visit https://policies.google.com/privacy.

Personal information held by us is processed by appropriate members of staff for the purposes for which the information was provided. We may share your personal information within our organisation and with third parties, namely suppliers, IT support providers, professional advisors such as accountants and lawyers, HR providers, investors and government bodies/regulators.

We may disclose your personal information to a prospective buyer or seller in the event that we intend merging our business or selling or purchasing assets.
While we generally store all of the personal information that we collect about you in the Republic of South Africa, it is possible that your personal information will be transmitted and hosted outside your region. For example, our email and storage, accounting software and messaging service providers have servers outside of South Africa.

We ensure that countries to which your information is being shared either have adequate laws in place or that we entered into contractual arrangements to ensure the protection of your personal information.

Subject to certain limitations on certain rights, you may have the following rights in relation to your information:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. For more information on how to exercise this right, please see our Promotion of Access to Information Act (PAIA) Manual on our website.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request deletion or destruction of your personal information. This enables you to ask us to delete or destroy your personal information. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

We will endeavour to respond to any such requests as soon as is reasonably practicable. In some instances, we may be able to charge a fee for responding to your request and will advise you of this and any applicable amount prior to responding.

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so. These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

You also have the right to lodge a complaint with the Information Regulator, details of which are set out below:

JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
P.O Box 31533
Braamfontein, Johannesburg, 2017

Complaints email: complaints.IR@justice.gov.za
General enquiries email: inforeg@justice.gov.za or enquiries@inforegulator.org.za

You should also be aware that in some instances, if you do not provide information or you exercise any rights regarding the deletion or restriction of your information or object to the processing of your information or withdraw consent, may not be able to engage with you or perform any contract we have with you.

Should you have any queries regarding this privacy notice or would like to enforce any rights you may have under applicable data protection laws, please contact us at:

Information Officer: Justine Del Monte
Address: Suite 2004, 2nd Floor, One Thibault, 17 Hans Strijdom Avenue, Cape Town
E-mail: justine@justinedelmonte.co.za

Any changes made to this privacy notice in the future will be posted on the website and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to this notice.

Last updated: 15 November 2023, Version 1