Thaba Moshate Casino Privacy Policy

1. Introduction

This document sets out the official Privacy Policy of Thaba Moshate Casino, which operates as part of Thaba Moshate Hotel Casino Convention Resort in South Africa. The policy describes the basis on which personal information collected from guests, visitors, and users is processed, stored, and protected in connection with the resort.

Processing of personal information is conducted in accordance with the Protection of Personal Information Act 4 of 2013 (POPIA), which regulates the lawful processing of personal information in South Africa. By accessing the premises, using services, or engaging with Thaba Moshate Casino through any channel, individuals acknowledge the terms of this policy.

This policy applies to personal information collected in connection with casino operations, hotel accommodation, convention services, loyalty programmes, and any other services provided under the Thaba Moshate brand.

2. Information Collected

2.1 Categories of Personal Information

Thaba Moshate Casino may collect and process the following categories of personal information:

• Identity information, including full name, date of birth, identity document number, and passport details where applicable.
• Contact information, including residential address, telephone number, and email address.
• Financial information required for anti-money laundering and know-your-customer compliance, including source of funds documentation and transaction records.
• Biometric and surveillance data, including images captured by closed-circuit television systems operating on the premises.
• Loyalty and membership data, including programme enrolment details, visit history, and preferences recorded in connection with any guest rewards scheme.
• Correspondence records, including communications submitted through contact forms, email, or in-person interactions with staff.

2.2 Sensitive Information

Where the processing of special personal information is required by law or takes place with the explicit consent of the data subject, such information will only be processed to the extent permitted under POPIA and applicable gambling legislation.

3. Purpose of Processing

Personal information collected by Thaba Moshate Casino is processed for the following purposes:

• Compliance with legal obligations under South African gambling legislation, including identity and age verification, anti-money laundering requirements, and reporting duties to relevant provincial gambling authorities.
• Administration of guest accounts, hotel bookings, and convention reservations.
• Operation and management of loyalty or membership programmes.
• Security and fraud prevention, including use of surveillance systems on the casino premises.
• Communication with guests regarding bookings, account matters, or regulatory requirements.
• Internal record-keeping and audit functions.

Personal information is not processed for purposes that are incompatible with the purposes listed above, unless prior consent is obtained from the data subject or processing is otherwise permitted by law.

4. Legal Basis for Processing

Processing of personal information by Thaba Moshate Casino takes place on one or more of the following lawful grounds:

• Compliance with a legal obligation applicable to the resort as a licensed casino operator in South Africa.
• Performance of a contract to which the data subject is a party, including accommodation agreements and membership terms.
• Legitimate interests of the resort, where such interests are not overridden by the rights and interests of the data subject.
• Consent of the data subject, where no other lawful basis applies.

5. Retention of Personal Information

Personal information is retained only for as long as necessary to fulfil the purposes for which it was collected, or for periods required by applicable law. Retention periods are determined with reference to:

• Statutory obligations under South African gambling and financial legislation.
• The duration of any contractual relationship with the data subject.
• Operational requirements for audit, dispute resolution, and legal proceedings.

Upon expiry of the applicable retention period, personal information is securely destroyed or anonymised in accordance with internal data management procedures.

6. Disclosure of Personal Information

6.1 Third-Party Disclosure

Thaba Moshate Casino does not sell, rent, or trade personal information to third parties. Disclosure of personal information to third parties may occur in the following circumstances:

• Where required by law, court order, or direction from a competent regulatory authority, including provincial gambling boards.
• To service providers engaged to perform functions on behalf of the resort, subject to contractual obligations of confidentiality and compliance with POPIA.
• To the extent necessary to protect the rights, property, or safety of the resort, its guests, or the public.

6.2 Cross-Border Transfers

Where personal information is transferred to a recipient in a foreign country, adequate protection is implemented as required under section 72 of POPIA. This includes contractual safeguards or confirmation that the recipient jurisdiction provides an equivalent level of protection for personal information.

7. Rights of Data Subjects

Under POPIA, individuals whose personal information is processed by Thaba Moshate Casino have the following rights:

• The right to be notified that personal information is being collected and the purpose for which it is processed.
• The right to access personal information held about them.
• The right to request correction or deletion of inaccurate, irrelevant, or outdated personal information.
• The right to object to the processing of personal information on reasonable grounds.
• The right to lodge a complaint with the Information Regulator of South Africa where it is believed that personal information has been processed in violation of POPIA.

Requests to exercise any of these rights should be submitted in writing to the designated Information Officer of Thaba Moshate Casino. Responses to such requests will be provided within the timeframes prescribed by applicable law.

8. Security Measures

Thaba Moshate Casino implements appropriate technical and organisational measures to protect personal information against unauthorised access, loss, destruction, or disclosure. These measures include physical access controls on the casino premises, restricted access to data systems, and staff training on data protection obligations.

In the event of a security compromise that is likely to prejudice the rights of data subjects, the Information Regulator and affected individuals will be notified in accordance with the requirements of POPIA.

9. Cookies and Digital Channels

Where Thaba Moshate Casino operates digital platforms, including any official website or online booking system, cookies or similar tracking technologies may be used to support the operation and functionality of those platforms. Users of such platforms will be informed of cookie use and provided with options to manage their preferences in accordance with applicable requirements.

Interactions conducted through third-party platforms, including professional networking services, are governed by the privacy policies of those respective platforms and not by this Privacy Policy.

10. Updates to This Policy

Thaba Moshate Casino may amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or internal data processing practices. The current version of the policy is the operative version and supersedes all prior versions. Guests and users are advised to review this document periodically.

11. Contact

Enquiries regarding this Privacy Policy or the processing of personal information by Thaba Moshate Casino should be directed to the Information Officer at the resort. Contact details for the Information Officer are available on request at the resort’s reception or administrative offices.