PRIVACY POLICY

This Privacy Notice (or "Notice") is provided by Walters and Koch Inc and our group companies (the "Company", "we", "our" or "us") and is intended to provide you with all of the information that you need to understand the personal data that we may have about you.

In particular, the Notice describes the categories of personal data we may process, how your personal data may be processed and how your privacy is safeguarded in the course of our relationship with you. It is intended to comply with our obligations to provide you with information about the Company's processing of your personal data.

We take your data protection rights and our legal obligations seriously. Your personal data will be treated in a secure and confidential manner and only as detailed in this Notice.

The Notice is divided into sections, which relate to the type of relationship that you have with the Company. Each section will give you information relating to the way we manage personal data in each of the types of relationship or interaction that we may have with you. Please ensure that you review the Overview pages carefully, as these will apply to you regardless of our relationship with you.

Of course, not all of the sections in the Notice will be relevant to everyone. The Notice is intended to provide details of all the processing activities that we undertake and therefore the mere listing of an activity in this Notice does not mean that we are processing your personal data in this manner and for these purposes. If you have any questions about how the information presented relates to you, please do contact us using the relevant contact details appearing in the contact us section.

Each of the sections below will give you information relating to the way we manage personal data in each of the types of relationship or interaction that we may have with you:

Website Users

We will process personal data that you provide to us through your use of our Websites.

Generally you can visit the Websites without revealing who you are, or disclosing any personal data about you. However, there may be times when we require personal data about you or when you wish to disclose such personal data to us. Such personal data is obtained only when voluntarily submitted by you.

Please note that our Websites are not intended for children and we do not knowingly collect data relating to children in connection with them.

You might find external links to third party websites on our Websites. This Privacy Notice does not apply to your use of a third party site.

If you wish to find out more information about how we use your personal data if you choose to provide it to us, please see below.

What Processing Activities Does The Company Undertake That Includes Your Personal Data?

This section of the Notice should be read in conjunction with the Overview.

If you provide us with personal data through the Websites, we will process your personal data in order to, in accordance with applicable law:

• allow you to participate in the registration-only features of the Websites and to download relevant brand content, when you choose to do so
• ensure that content from the Websites is presented in the most effective manner for you and for your computer
• provide you with information that you request from us or which we feel may interest you, including through subscribed alerts (where applicable)
• notify you about changes to the Websites and branding which may be relevant to you
• serve you with relevant advertising on third party websites, such as Google, YouTube and LinkedIn.
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What Categories Of Personal Data Are Included In These Processing Activities?

We process the following personal data in connection with our Websites:

If you contact us using the "contact us" section of our Websites:

• The personal data that we process to do so will be the personal data that you provide to us, such as your name, your contact details (such as email address and telephone number) and the content of your query.

If you leave a comment on a blog or other post on our Websites:

• The personal data that we process to do so will be the personal data that you provide to us, such as the content of your comment and any personal data you choose to provide.

If you sign up to subscriber alerts:

• The personal data that we process to do so will be the personal data that you provide to us, such as your name, your email address, your country of residence and your occupation.

General use:

• We process any other personal data which you choose to disclose to us during the course of your use of the Websites, whether through email or otherwise.
• We may automatically process some technical data such as your Internet Protocol (IP) address to identify what companies have interacted with the website. This processing only identifies a company name and will not be used to identify an individual.
• We use your IP address to track traffic flows and to make our websites easier for you to use and to better understand how our websites are used.

Cookies:

• Cookies will collect personal data about you. The personal data that is collected by these cookies is IP address, operating system and browser type. Please see our Cookie Statement for details.
• One of the analytics tools that our website uses is Google Analytics, to learn more about Google Analytics, you can visit www.google.com/policies/privacy/partners/

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.

Whats The Reason For These Processing Activities?

We use this personal data to provide services that you request under an agreement between us or take steps you request prior to entering into such an agreement. Some of these activities may be required by law or regulation.

If you contact us via the “contact us” page on our Websites, we will process your personal data in order to consider and respond to those queries. We also process your personal data to facilitate your comments or posts and any subscription requests.

In addition, your personal data is necessary for to improve the Websites and provide a better service and source of information to you. If you visit our Websites, we use cookies to understand who has seen which webpages, to determine how frequently particular pages are visited and to determine the most popular areas of our Websites. Please see our Cookie Statement for further information.

Does The Processing Include Sensitive Personal Data?If Yes,In Addition To Above,What Are The Additional Legal Grounds Relied On To Justify This Processing?

(See “What are the legal grounds for processing special category personal data?” in the Overview section.)

No. We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

To The Extent That The Company Did Not Get This Personal Information From You,How Was Information Collected?

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration purposes. This is statistical data about your browsing actions and patterns and does not identify you as an individual. The source of personal data gathered by cookies will be you. Some information may also come from analytics providers (such as Google). For further details please see our Cookie Statement

We may also generate personal data internally if this is needed to respond to your query or request.

We may receive information from other sources as set out in this Notice (see “Where do you get my personal data from?” in the Overview.

Who Does The Company Share This Personal Data?

Your personal data is shared internally, as set out in this Notice (see “When do you share my personal data with others?” in the Overview section).

In addition, some of your personal data will be shared externally with our partners as needed and as otherwise set out in this Notice (see “When do you share my personal data with others?” in the Overview section).

In particular, your personal data may be shared with the following third parties in connection with your use of our Websites:

• Retailconnection.za, who operate our Websites and manage subscriber alerts on behalf of the Company
• Xneelo to assist with the provision of supplier related content and services on our Websites

We may share in aggregate, statistical form, non personal data regarding the visitors to our Site, traffic patterns, and website usage with our partners, affiliates or advertisers.

How Does Subscriber Alerts Work In Practice?

As set out above, if you sign up to our subscriber alerts, we will use your personal data to let you know about our products and services that we believe will be of interest to you. We will do so by email. We will respect your preferences for how you would like us to manage marketing activity with you.

To protect privacy rights and to ensure you have control over how we manage marketing with you:

• we will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you;
• you can ask us to stop direct marketing at any time ‑ you can ask us to stop sending email marketing, by following the "unsubscribe" link you will find on all the email marketing messages we send you. Alternatively you can contact us. Please specify whether you would like us to stop all forms of marketing or just a particular type; and
• you can change the way your browser manages cookies, which may be used to deliver online advertising, by following the settings on your browser as set out in our Cookie Statement.

We recommend you routinely review the privacy notices and preference settings that are available to you on any social media platforms as well as your preferences within your account with us.

QUESTIONS AND CONTACT INFORMATION

If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact our Privacy Compliance Officer at SALES@WALTERSKOCH.COM or by mail at WALTERS + KOCH INC

[Re: Privacy Compliance Officer]

[16192 Coastal Highway, LEWES, DE, 19958, United States]