1. Responsible Party

Photizo (Pty) Limited (“Photizo”, “we”, “us”) is a technology company that develops and operates digital platforms for property portfolio administration and related services.

Proprietatum is a web-based platform offered by Photizo to support the administration, oversight, and management of property portfolios, stakeholders, and related records.

For purposes of the Protection of Personal Information Act, 2013 (“POPIA”), Photizo acts as the Responsible Party in respect of personal information processed through its platforms, unless otherwise stated.

2. Categories of Personal Information

We may process the following categories of personal information:

• Identifying information (names, identity numbers, registration numbers);
• Contact details (email addresses, telephone numbers, physical addresses);
• Account, user profile, and access credentials;
• Property-related information linked to identifiable persons;
• Technical and usage data generated through interaction with our platforms.

3. Purpose of Processing

Personal information is processed for purposes that are lawful, reasonable, and relevant to Photizo’s business operations, including:

• Providing access to and operating Proprietatum and related platforms;
• Managing user accounts, authentication, and authorisation;
• Administering property portfolios and associated records;
• Communicating with users regarding platform usage or support;
• Complying with legal, regulatory, and contractual obligations.

4. Lawful Basis for Processing

Personal information is processed in accordance with section 11 of POPIA, including where:

• Processing is necessary to perform or conclude a contract;
• Processing complies with a legal obligation;
• Processing protects a legitimate interest of the data subject;
• The data subject has provided consent, where required.

5. Mandatory vs Voluntary Supply

Certain personal information is mandatory to enable access to and use of Photizo’s platforms. Failure to provide mandatory information may result in limited functionality or denial of access.

6. Disclosure to Third Parties

Photizo may disclose personal information to operators and service providers who process information on our behalf, under written agreements that require compliance with POPIA.

Personal information is not sold or disclosed to unauthorised third parties.

7. Security Safeguards

We implement appropriate technical and organisational measures to safeguard personal information against loss, unauthorised access, or unlawful processing, as required by section 19 of POPIA.

8. Retention of Personal Information

Personal information is retained only for as long as necessary to fulfil the purposes for which it was collected, or as required by law, after which it is securely deleted or anonymised.

9. Data Subject Rights

Data subjects have the right to:

• Request access to personal information;
• Request correction or deletion of information;
• Object to or restrict processing;
• Lodge a complaint with the Information Regulator at enquiries@inforegulator.org.za.