Baroque Real Estate (Pty) Ltd ("Baroque", "we", "us", or "our") respects your constitutional right to privacy and is committed to safeguarding your personal information in accordance with:

• The Protection of Personal Information Act, 2013 (Act 4 of 2013) ("POPIA")
• The Promotion of Access to Information Act, 2000 (Act 2 of 2000) ("PAIA")
• The Financial Intelligence Centre Act, 2001 (Act 38 of 2001) ("FICA")
• The Property Practitioners Act, 2019 and related regulations

This Policy explains how we collect, process, store, disclose, and protect personal information when you use our website or engage our services.

By accessing our website or providing us with your personal information, you acknowledge that it will be processed in accordance with this Policy and applicable legislation.

Responsible Party

Baroque Real Estate (Pty) Ltd

Registered in the Republic of South Africa

201809024307

The Els Club, 1 Ernie Els Boulevard, Copperleaf Golf & Country Estate, Centurion

Email: [email protected]

Personal Information

We may collect the following information:

• Full names and surname
• Identity number or passport number
• Contact details (email, telephone number)
• Physical and postal address
• Property ownership details
• Banking and financial information (where required for transactions)
• Company registration documents (for juristic entities)

FICA Verification Information

In terms of FICA, we are legally required to collect, verify, and retain:

• Proof of identity
• Proof of residential address
• Source of funds (where applicable)
• Beneficial ownership information
• Company registration and director details

Failure to provide required FICA documentation may prevent us from proceeding with a property transaction.

Automatically Collected Data

When you visit our website, we may automatically collect:

• IP address
• Browser type and version
• Device identifiers
• Pages visited and usage patterns
• Mobile device information

Purpose of Processing

Your personal information is processed for the following purposes:

• To market, sell, lease, or manage property
• To prepare and administer mandates, offers to purchase, lease agreements, and related documentation
• To conduct Comparative Market Analyses
• To verify identity in compliance with FICA
• To comply with legal and regulatory obligations
• To communicate with you regarding property services
• To improve our website and service delivery
• To provide property market updates (subject to opt-out rights)

We process personal information only where we have a lawful basis to do so in terms of POPIA.

Disclosure of Information

Personal information may be shared with:

• Conveyancers and transfer attorneys
• Financial institutions and bond originators
• Regulatory authorities (including the Financial Intelligence Centre, SARS, PPRA)
• Service providers acting under confidentiality agreements
• Courts or law enforcement where legally required

We do not sell personal information to third parties.

Retention of Records

In compliance with FICA:

• Customer due diligence and transactional records are retained for a minimum of five (5) years from the date of the transaction or termination of the business relationship.

Other records are retained only as long as necessary to fulfil the purpose for which they were collected or as required by law.

Security Safeguards

We implement appropriate technical and organisational measures to protect personal information against:

• Unauthorised access
• Loss or theft
• Unlawful processing
• Destruction or damage

Access to sensitive information is restricted and managed in accordance with industry best practices.

Your Rights Under POPIA

You have the right to:

• Access your personal information
• Request correction or deletion of inaccurate data
• Object to processing (where legally permissible)
• Withdraw consent (where applicable)
• Lodge a complaint with the Information Regulator

Requests must be submitted in writing to our Information Officer.

PAIA Manual Notice (Section 51 Manual)

In accordance with the Promotion of Access to Information Act (PAIA), Baroque Real Estate has prepared a PAIA Manual outlining:

• The categories of records held
• The procedure for requesting access to records
• Applicable request fees
• Contact details of the Information Officer

A copy of our PAIA Manual is available:

• On request via email; or
• At our registered office during normal business hours.

Requests for access to information must be made using the prescribed PAIA Form 2 and submitted to the Information Officer.

Information Officer

In terms of POPIA and PAIA, Baroque Real Estate has appointed an Information Officer.

Information Regulator (South Africa)

The Information Regulator oversees compliance with POPIA and PAIA. You may lodge a complaint directly with the Information Regulator if you believe your personal information has been processed unlawfully.

Cookies & Website Analytics

Our website may use cookies and tracking technologies to enhance user experience and analyse website performance. You may disable cookies in your browser settings, although certain features may be limited.

Amendments

We reserve the right to update this Policy periodically. Any amendments will be published on this page and reflected by the revised "Last Updated" date. Continued use of our website constitutes acceptance of any updated terms.

Last Updated - February 2026