IPRIVACY POLICY FOR THE 925 COTERIE
Effective Date: 1 November 2026
Last Updated: October 2026
Entity Name: The 925 Coterie (Pty) Ltd
Location: 3rd Floor, The Colosseum, Century City, Cape Town, Western Cape, South Africa
1. Introduction & Purpose
The 925 Coterie ("we," "us," or "our") respects your privacy and is committed to protecting the personal information of our members, visitors, suppliers, and website users. This Privacy Policy outlines how we collect, use, store, disclose, and protect personal data in compliance with the Protection of Personal Information Act 4 of 2013 (POPIA) and applicable South African laws.
2. Information Officer Details
In terms of POPIA, The 925 Coterie has appointed an Information Officer responsible for overseeing compliance.
• Information Officer: Operations Manager
• Physical Address: 3rd Floor, The Colosseum, Century Way, Century City, Cape Town, 7441
• Email Address: brendon@the925coterie.co.za
• Phone: +27 64 976 8877
3. Personal Information We Collect
We collect personal information directly from you when you register for a membership, access our premises, use our website/portal, connect to our Wi-Fi, or communicate with us.
A. Member & User Data
• Identity & Contact Details: Full name, South African ID or passport number, email address, mobile number, business name, and job title.
• Billing & Financial Information: Banking details, payment history, tax/VAT numbers, and billing address (payment card processing is handled by secure third-party PCI-DSS compliant providers).
• Digital Profile Data: Profile photos, professional bio, and directory settings for the internal member directory (where consented to).
B. Physical Premises & Access Security
• Access Control Data: Keycard, key fob, or biometric entry/exit logs recorded at building and workspace turnstiles and doors.
• CCTV Footage: Video surveillance operates throughout common areas, corridors, and entry/exit points at The Colosseum facility for safety and security.
• Visitor Logs: Name, contact details, host member name, and arrival/departure timestamps for guests entering the premises.
C. Network & Technology Usage
• Wi-Fi Logs: IP addresses, device MAC addresses, device name, and bandwidth usage metadata when connected to The 925 Coterie Wi-Fi network.
• Website & Portal Analytics: Cookies, browser type, device information, and interaction data recorded when using our website or member management software.
4. How & Why We Process Your Information
We process your personal information only for lawful, specific, and declared purposes:
1. Service Provision & Contract Execution: To process membership applications, manage room/desk bookings, issue invoices, and grant physical and digital access.
2. Operations & Facility Security: To protect members, guests, and premises via access control systems, visitor registers, and CCTV monitoring.
3. Communication: To deliver operational announcements, security updates, invoices, and responses to support tickets.
4. Community & Networking: Displaying member details in our opt-in member portal/directory.
5. Marketing: Sending newsletters and event invitations (you may opt out at any time).
6. Legal & Compliance: Complying with tax laws, financial auditing, and lawful law enforcement
requests.
5. Legal Basis for Processing (POPIA)
We process personal information under the following POPIA lawful grounds:
• Consent: You have explicitly agreed to the processing (e.g., marketing or member directory inclusion).
• Contractual Necessity: Processing is required to perform our contractual obligations under your membership agreement.
• Legitimate Interest: Processing is necessary to protect our business interests, secure our physical property, or manage facility access.
• Legal Obligation: Processing is required to fulfil South African statutory requirements (e.g., SARS tax records).
6. Sharing & Disclosure of Personal Data
We do not sell, rent, or trade your personal information. We share data only with:
• Service Providers & Operators: Vetted third-party vendors who provide software infrastructure, CRM systems, access control, IT security, payment processing, and auditing services under strict confidentiality agreements.
• Property & Facility Management: Century City precinct/Colosseum building security management solely for building access control and safety protocols.
• Legal Authorities: Regulatory bodies, law enforcement, or courts when legally compelled to do so.
7. Cross-Border Data Transfers
Some of our software tools and cloud databases may host data outside South Africa. In line with Section 72 of POPIA, we ensure that foreign service providers are bound by data protection laws or binding agreements that offer an equivalent or higher level of protection than POPIA.
8. Data Security & Safeguards
We implement appropriate technical and organizational measures to safeguard your personal data against unauthorized access, loss, destruction, or alteration, including:
• Secure cloud storage with encrypted protocols (SSL/TLS).
• Access-controlled physical entry systems and encrypted Wi-Fi networks.
• Strict role-based staff permissions to sensitive member data.
• Regular security assessments and vendor reviews.
9. Data Retention
We retain personal information only for as long as necessary to fulfill the operational purposes outlined above or as required by South African law (e.g., financial records retained for 5 years per Companies Act and Tax Administration Act). CCTV footage is automatically overwritten on a rolling 30-day cycle, unless required for active security investigations.
10. Your Rights Under POPIA
As a data subject, you have the right to:
1. Access: Request confirmation of whether we hold personal information about you and receive a copy of that record.
2. Correction/Rectification: Request that inaccurate or outdated personal data be updated or corrected.
3. Objection: Object to the processing of your personal information on reasonable grounds or opt out of direct marketing.
4. Deletion/Destruction: Request the deletion of personal data where we no longer have a lawful ground to retain it.
5. Complain: File a complaint with the South African Information Regulator if you believe your rights have been infringed.
To exercise any of these rights, please contact our Information Officer at privacy@the925coterie.co.za using POPIA Form 1 or Form 2.
11. Contact Details for the Information Regulator
If you are unsatisfied with our handling of your privacy request, you have the right to lodge a complaint with the South African Information Regulator:
• Website: https://inforegulator.org.za/
• General Enquiries: enquiries@inforegulator.org.za
• POPIA Complaints: POPIAComplaints@inforegulator.org.za
12. Updates to This Policy
We may review and update this Privacy Policy periodically to reflect operational, legal, or regulatory changes. The latest version will always be accessible via our website and member portal.