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// Legal — Circle Core Apartments

Privacy Statement

Effective 26 May 2026 — Applies to the Circle Core Apartments management system

This privacy statement applies to the Circle Core Apartments property and tenant management system (“the System”), developed and supplied by Circle Core Technologies (Pty) Ltd (“we”, “us”, “Circle Core”). This statement describes how personal information is collected, used, stored, and protected when the System is deployed by property owners and managers (“Operators”) to manage their residential or commercial rental properties.

A. Information Collected

The System is used by Operators to record and manage information about their tenants and properties. The categories of personal information that may be captured include:

Tenant Information
Full name, identity or passport number, contact number, email address, emergency contact details, employment information, and references as provided during tenant onboarding.
Lease & Occupancy Information
Lease start and end dates, unit assignment, rental amount, deposit amount and status, lease terms, and occupancy history per unit and per tenant.
Payment Records
Rent charges, payment dates, amounts received, outstanding balances, arrears history, payment reference numbers, and payment method indicators (cash, EFT, bank deposit). The System does not store full banking credentials or card numbers.
Maintenance & Operational Records
Maintenance requests submitted against units, including descriptions, costs, contractor details, and resolution records. No personal medical or sensitive data is collected through maintenance records.
Device & Browser Data
Standard server logs may record browser type, device type, IP address, and access timestamps for security and diagnostic purposes. This data is not used for commercial profiling.

B. Purpose of Data Collection

Personal information collected and stored in the System is used for the following operational purposes:

Tenant identification, onboarding, and record management
Lease creation, monitoring, and expiry tracking
Rent billing, payment capture, and arrears management
Statement and invoice generation for tenants
Maintenance request tracking and resolution
Document storage related to tenancies and units
Portfolio reporting and occupancy management for the Operator
Customer support and dispute resolution

Circle Core Technologies does not use tenant data stored in the System for any marketing, profiling, or commercial purpose unrelated to the operation of the System.

C. Data Protection

Circle Core Technologies applies reasonable technical and organisational safeguards to protect personal information stored in the System. These include:

Access controls restricting System access to authorised Operator staff
Secure hosting practices aligned with standard industry requirements
Encrypted data transmission over HTTPS
Internal data handling policies limiting access to tenant data within Circle Core

While Circle Core Technologies implements reasonable safeguards, no system can guarantee absolute security. Operators are responsible for maintaining the security of their own access credentials, managing staff permissions within the System, and implementing appropriate internal controls over tenant data access.

D. Third-Party Services

The System may interact with or rely on the following categories of third-party services:

Hosting providers: The System is hosted on commercial web hosting infrastructure. Hosting provider terms govern their handling of infrastructure-level data.
Email delivery services: Where the System sends tenant statements, notices, or other correspondence by email, a third-party email delivery service may be used. Such services handle only the content of emails and are bound by applicable data processing terms.
Document storage (future): If cloud document storage integrations are added in future versions, any storage provider used will process documents under their own security and privacy terms. Operators will be notified of such integrations before they are activated.

Circle Core Technologies does not sell, rent, or trade tenant personal information to any third party for commercial purposes.

E. User Rights

Tenants whose personal information is recorded in the System have the following rights, which they may exercise by contacting the Operator who holds their information:

Request access to personal information held about them
Request correction of inaccurate or incomplete personal information
Request deletion of their personal information where no legal or contractual retention obligation applies
Object to processing of their personal information in specific circumstances

Operators using Circle Core Apartments are the responsible parties for tenant data held in their System account. Tenants should direct data access, correction, or deletion requests to their Operator (property owner or manager). Where requests relate to Circle Core Technologies’ direct handling of information, contact us at info@circlecore.co.za.

F. Data Retention

Tenant and lease records held in the System may be subject to legal data retention obligations under South African property law, tax legislation, and financial record-keeping requirements. Operators are responsible for understanding and applying applicable retention periods to records held in their System account. Circle Core Technologies does not automatically delete records and will retain System data for as long as the Operator account remains active or as required to fulfil contractual and legal obligations.

G. POPIA Compliance

Circle Core Technologies is committed to responsible handling of personal information in accordance with the Protection of Personal Information Act 4 of 2013 (POPIA). We process personal information lawfully, for specific and legitimate purposes, and retain it only as long as necessary for those purposes. We support Operators in meeting their own POPIA obligations by providing a System with appropriate access controls, data management tools, and documented data handling practices. Operators who deploy Circle Core Apartments as their property management system are themselves responsible parties under POPIA for the personal information of their tenants.

H. Contact

Questions, requests, or concerns regarding this privacy statement or the handling of personal information in the Circle Core Apartments system should be directed to Circle Core Technologies at info@circlecore.co.za. We will respond to written requests within a reasonable timeframe in accordance with applicable legislation.

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