Please refer below to our commitment to you in terms of the POPI Act. 
 
DEFINITIONS
"User" a person who uses and/or access computer Software and/or material via the www.hotelrefubint.com  website; 
" www.hotelrefubint.com " This Website, its sponsors, affiliates and creators; 
"Data" means any data (including Personal Information) provided to www.hotelrefubint.com by a User; 
"Personal Information" Including but not limited any Data or information about an identifiable User, including an email address; 
 
INTRODUCTION
www.hotelrefubint.com wants to help you maintain your privacy on the internet. www.hotelrefubint.com  has formulated this Privacy Policy to explain how www.hotelrefubint.com  collects Data and for what purposes. 
In this agreement unless it appears to the contrary, the singular shall include the plural and visa versa, any reference to any gender shall also includes the opposite gender and any reference to a natural person, shall include legal person and visa versa. 
 
COLLECTION OF DATA / COOKIE POLICY
If a User registers with www.hotelrefubint.com  by completing a submission form, including but not limited to a newsletter registration form, an information enquiry form or a registration to gain access to a password protected zone, a User is not anonymous to www.hotelrefubint.com. For the purposes of online purchasing, a User may also be prompted to provide necessary Personal Information to process a credit card or payment via a payment gateway.
Information collected by www.hotelrefubint.com  is stored in a secure operating environment that is not available to the public. 
If a User does not wish to submit any personal identifying information, the User should not submit any information within submission form fields on www.hotelrefubint.com. 
www.hotelrefubint.com does not have any motive or intention to gather contact Data of visitors who are under the age of 13 and would prefer that parental Data be supplied instead on behalf of a child under the age of 13. 
It is the nature of the Internet and websites that www.hotelrefubint.com  by default records User information on www.hotelrefubint.com server traffic reports from the browser which the User is using to view www.hotelrefubint.com  including an IP address and which web pages were visited. 
www.hotelrefubint.com  uses cookie technology. Cookie technology consists of trace elements of data that is stored on the Users computer's hard drive and which contains information about the User, so that next time the User Visits www.hotelrefubint.com  the Cookie recognises the Users prior visit. 
 
USE OF DATA
Users of www.hotelrefubint.com  understand and agree that in order to offer certain services or functions, www.hotelrefubint.com must collect and use personal information about Users. 
www.hotelrefubint.com  may send to a User messages by Email and/or SMS regarding their account. 
It is an optional condition of a User submitting Data to www.hotelrefubint.com  that Users agree to receive future Promotional messages from www.hotelrefubint.com  by Email and/or SMS or to Opt-out from future communications. A User can choose to opt-out of promotional messages at any time by contacting www.hotelrefubint.com  or following the unsubscribe link or instructions on the future communication. 
www.hotelrefubint.com  uses cookie technology and generates and saves User and session ID to the Users Internet browser and computer to track and analyse website usage of the User. www.hotelrefubint.com  does this to be able to identify any technical problems with the workings of www.hotelrefubint.com  and to correct these to ensure a better online experience for the User. 
 
AUTHORISED ACCESS TO DATA
www.hotelrefubint.com  may disclose information to any authorized official if required to do so by law or if it is required to protect the safety of other www.hotelrefubint.com Users or the public, or if www.hotelrefubint.com believes that such action is necessary to protect and defend www.hotelrefubint.com  rights or properties. 
www.hotelrefubint.com will not sell, rent, share, or distribute Personal Information to any entity other than 3rd parties which are vital in the administration of www.hotelrefubint.com and the supply of goods or services that have been requested by the User, including but not limited to: hosting service providers, web administrators and online purchase and delivery service providers. 
www.hotelrefubint.com  may need to share Data with employees and employees of 3rd parties that require access to the Data to perform their day-to-day functions for www.hotelrefubint.com
www.hotelrefubint.com may disclose anonymous demographic and biometric statistics about the Data within the database for business purposes. 
In the event of www.hotelrefubint.com  changing ownership to a new entity, www.hotelrefubint.com
may transfer its rights to the Data to the new owner. The new owner of www.hotelrefubint.com  is required to notify each User of the transfer and the User may choose to modify its Personal Data at that time or choose to remove it. 
 
SECURE STORAGE OF DATA
Information collected by www.hotelrefubint.com  is stored in a secure operating environment that is not available to the public. 
All Data is available only to the User and those authorized employees to whom www.hotelrefubint.com has granted permissions by issuing a username and password. 
It is the responsibility of each User to maintain the confidentiality and security of their password and to alert www.hotelrefubint.com  or reset their password if compromise of security is suspected. 
Any unauthorized use of www.hotelrefubint.com systems and attempts to access Data without express authorization is a violation of the Agreement, the act of which is prosecutable by Law. 
 
EDITING OR REMOVING DATA
A User is able to update or remove the Data they have submitted to www.hotelrefubint.com, either by logging in or by contacting www.hotelrefubint.com  User updates or removal will reflect in www.hotelrefubint.com  active database, but www.hotelrefubint.com may retain Data in backup files and archives or to prevent a User from being accidentally re-added to the database after they have expressly unsubscribed. 
 
LIMITATION
www.hotelrefubint.com has no control over information or privacy policies of 3rd party websites hyperlinked to from www.hotelrefubint.com.  These 3rd party links are being provided for the convenience of the Users of www.hotelrefubint.com and www.hotelrefubint.com does not endorse and is not responsible or liable for the content, nature or reliability of any linked website or any link contained in a linked website www.hotelrefubint.com  takes no responsibility for monitoring, updating, supplementing or correcting any information on any linked website and makes no representation or warranties regarding such information. Please be aware that in linking to these outside websites, Users are leaving www.hotelrefubint.com  and that www.hotelrefubint.com is not responsible for the content of any other site. 

This policy explains how we obtain, use and disseminate your personal information, within the limitations and subject to the requirements set by the Protection of Personal Information Act (“POPI” or ‘the Act’).
Policy Provider is committed to protecting your privacy and ensuring that your personal information is collected and used properly, lawfully and transparently.

POPI ACT

KEY PRINCIPLES
The purpose of this policy is to explain how we deal with your personal information within the parameters set by POPI.  From the outset, it is important to know that you are entitled to all rights which you may have in terms of the Act, and for more information on what these rights involve, we refer you directly to the Act.  Furthermore, the Regulator may from time to time issue Codes of Conduct for various industries. www.hotelrefubint.com will adhere to those Codes of Conduct which apply to it.  For this reason and as set out in more detail below, this policy is subject to the Act and any applicable Codes of Conduct issued by the regulator from time to time.
However, the key principles of this policy are:

1. We value the trust that you place in us by giving us your personal information. We will always use your personal information in a way that is fair and worthy of that trust.

2. We are entitled to clarity on how we use your personal information. We shall always be transparent with you about what information we collect, what we do with it, with whom we share it and whom you should contact if you wish to know more or have any concerns.                                                                                                                                
3. We will work with you to promptly resolve any query or concern which you may have on how we use your information.                                                                                               
4. We will take all reasonable steps to protect your information from misuse and keep it secure.                                                                                                                         
5. We will comply with all applicable data protection laws and regulations and we will co-operate with data protection authorities. In the absence of data protection legislation, we will act in accordance with generally accepted principles governing data protection. 
 
WHO WE ARE
In this policy, “Policy Provider" or “we” refers to one or more of the companies that operate in South Africa.
 
THE INFORMATION WE COLLECT
We collect and process your personal information mainly to provide you with access to our products and services, to help us improve our offerings to you and for certain other purposes explained below. he type of information we collect will depend on the purpose for which it is collected and used. We will only collect information that we need in order to provide you with the product which you have selected and services flowing therefrom at the standard which you are entitled to expect.

We collect information directly from you where you provide us with your personal details, for example when you take out an insurance product with us or when you submit enquiries or claims to us or contact us. Where possible, we will inform you what information you are required to provide and what information you may choose to provide, or not. We also collect information about you from other sources as explained below. Website usage information is collected using “cookies” (Refer to the above "COOKIE" clause) which allows us to collect standard internet visitor usage information.

HOW WE USE YOUR INFORMATION
We will use your personal information only for the purposes for which it was collected or agreed with you, for example:
•    To provide our products or services to you, to carry out the transaction you requested and to maintain our relationship with you;
•    For underwriting purposes;
•    To assess and process claims;
•    To conduct credit reference searches or verification;
•    To confirm and verify your identity or to verify that you are an authorised user for security purposes;
•    For operational purposes, and where applicable, credit scoring and assessment and credit management;
•    For purposes of claim checks;
•    For the detection and prevention of fraud, crime, money laundering or other malpractice;
•    For debt tracing or debt recovery;
•    To conduct market or customer satisfaction research or for statistical analysis;
•    For audit and record keeping purposes;
•    For liaising with third-party-service-providers to offer those services to you which may be necessary in terms of the policy we have with you;
•    In connection with legal proceedings.

We will also use your personal information to comply with legal and regulatory requirements or industry codes to which we subscribe or which apply to us, or when it is otherwise allowed by law (for example to protect Western’s interests).
The processing of your personal information will at all times be done lawfully and not in a manner that infringes on your privacy.

DISCLOSURE OF INFORMATION
We may disclose your personal information to our service providers who are involved in the delivery of products or services to you, in terms of the policy. We have agreements in place with them to ensure that they comply with these privacy terms. We may share your personal information with, and obtain information about you from:

•    Third parties for the purposes listed above, for example credit reference and fraud prevention agencies, law enforcement agencies;
•    Other insurers to prevent fraudulent claims;
•    Other third parties from whom you have chosen to receive marketing information.
 
We may also disclose your information:
•    Where we have a duty or a right to disclose in terms of law or industry codes;
•    Where we believe it is necessary to protect our rights.

INFORMATION OF SECURITY
We are legally obliged to provide adequate protection for the personal information we hold and to stop unauthorised access and use of personal information. We will, on an ongoing basis, continue to review our security controls and related processes to ensure that your personal information is secure.

Our security policies and procedures include, amongst others:
•    Physical security;
•    Computer and network security;
•    Access to personal information;
•    Secure communications;
•    Security in contracting out activities or functions;
•    Retention and disposal of information;
•    Acceptable usage of personal information;
•    Governance and regulatory issues;
•    Monitoring access and usage of private information;
•    Investigating and reacting to security incidents.

When we contract with third parties, we impose appropriate security, privacy and confidentiality obligations on them to ensure that personal information that we remain responsible for, is kept secure. We may need to transfer your personal information to another country for processing or storage. We will ensure that anyone to whom we pass your personal information agrees to treat your information with the same level of protection as we are obliged to.

YOUR RIGHTS: ACCESS TO INFORMATION
You have the right to request a copy of the personal information which we have on record for you. To do this, simply contact us and specify what information you would like. We will take all reasonable steps to confirm your identity before providing details of your personal information. Please note that any such access request may be subject to a payment of a legally allowable fee.

CORRECTION OF INFORMATION
You have the right to ask us to update, correct or delete your personal information. You may do this by contacting us at the numbers/addresses provided on our website, subject to the requirements to which we must comply in terms of the law.
We will take all reasonable steps to confirm your identity before making changes to the personal information we may hold about you.
We would appreciate it if you would keep your personal information accurate. In the event that there are changes to your personal information such as, but not limited to, a change in contact detail and or a residential address, please contact us in order that we may update your records.

COMMENTS
If you have any questions, comments or concerns about how we handle your personal information, then you may contact us.
 
You have the right to tell us if you:
•    don't want to be contacted in the future by us
•    would like a copy of the personal information which we hold about you
•    would like us to correct, update, or delete your personal information in our records
•    wish to report any misuse of your personal information
To assist us in dealing with your request, please provide your full name and details.

CHANGES TO THIS POLICY
This document might change as required from time to time.  Please check this website periodically to inform yourself of any changes.
 
ENQUIRIES
Any questions or concerns related to our privacy policy please contact us.