Privacy Policy

Kent Gush Properties (Pty) Ltd | Kent Gush Sales (Pty) Ltd | Kent Gush Letting (Pty) Ltd

Effective Date: April 2026

1. Introduction

Kent Gush Properties (Pty) Ltd and its associated entities (“Kent Gush”, “we”, “us”, “our”) are committed to protecting your personal information.

This Privacy Policy explains how we collect, use, store, and protect your personal information in accordance with the Protection of Personal Information Act (POPIA) and guidance issued by the Information Regulator South Africa.

2. Who This Policy Applies To

This policy applies to:

  • Purchasers and prospective purchasers
  • Sellers and landlords
  • Tenants and prospective tenants
  • Website users and enquiries
  • Agents and contractors engaging with us

3. What Personal Information We Collect

Depending on the nature of your interaction with us, we may collect:

3.1 Identification Information

  • Full name, ID number or passport number
  • Date of birth
  • Nationality

3.2 Contact Information

  • Email address
  • Telephone number
  • Physical address

3.3 Financial Information

  • Bank statements
  • Source of funds / source of wealth
  • Income details

3.4 Entity Information (Where Applicable)

  • Company / trust registration documents
  • Directors, trustees, beneficiaries, shareholders
  • Beneficial ownership information

3.5 Property & Transaction Information

  • Property preferences
  • Reservation and contract details

3.6 Website & Technical Data

  • IP address
  • Browser type
  • Website usage behaviour

4. How We Collect Information

We collect personal information:

  • Directly from you
  • Through onboarding systems (e.g. DocFox or similar platforms)
  • Via our website and cookies
  • From third parties (developers, agents, attorneys, etc.)

When collecting personal information, we take reasonably practicable steps to ensure that you are aware of:

  • The information being collected
  • The purpose for which it is being collected
  • Whether the provision of the information is voluntary or mandatory
  • The consequences of failing to provide the information
  • Any legal authority requiring the collection of the information
  • The recipients or categories of recipients of the information
  • Your rights to access, correct, or object to processing
  • Your right to lodge a complaint with the Information Regulator

5. Purpose for Processing Personal Information

We process your information for the following purposes:

5.1 Property Transactions

  • Facilitating property sales, rentals, and developments
  • Preparing and managing contracts

5.2 Legal and Regulatory Compliance

  • Compliance with FICA and related obligations
  • Identity verification and due diligence

5.3 Marketing and Communication

  • Sending property listings and opportunities
  • Marketing campaigns (where appropriate)

5.4 Business Operations

  • Internal administration and record keeping

6. FICA and Regulatory Compliance

Kent Gush Properties (Pty) Ltd and its associated entities operate as accountable institutions in terms of applicable South African legislation.

Accordingly, we are legally required to:

  • Identify and verify the identity of our clients
  • Establish and verify beneficial ownership
  • Obtain information relating to source of funds and/or source of wealth
  • Conduct risk assessments and ongoing due diligence

We may utilise third-party compliance platforms (such as DocFox or similar systems) to facilitate this process. We are further required to retain records and report suspicious or unusual transactions to the relevant authorities.

Clients acknowledge that:

  • The provision of personal information for compliance purposes is mandatory
  • Failure to provide the required information may result in delays or inability to proceed
  • Certain reporting obligations may not be disclosed where prohibited by law

7. Legal Basis for Processing

We process personal information based on:

  • Your consent
  • Performance of a contract
  • Compliance with legal obligations
  • Legitimate business interests

8. Legitimate Interests

In certain circumstances, we process personal information on the basis of our legitimate business interests, including:

  • Facilitating property transactions efficiently
  • Preventing fraud and ensuring compliance
  • Providing relevant property opportunities
  • Improving our services and marketing effectiveness

We ensure that such processing is reasonable and does not override your rights.

9. Special Personal Information

In certain instances, we may process special personal information (including financial and identification information) where required for legal compliance, including FICA obligations, and only where permitted by law.

10. Children’s Information

We do not knowingly collect personal information of individuals under the age of 18 without the consent of a competent person, unless permitted by law.

11. Marketing and Communication

We may use your personal information to provide:

  • Property listings
  • Development launches and investment opportunities
  • Market updates

We will only send direct marketing communications by electronic means where:

  • You have provided consent; or
  • You are an existing client and the communication relates to similar services, and you have been given an opportunity to opt out

You may opt out at any time. We may also use limited personal information for targeted digital marketing (e.g. Google and Meta), subject to your cookie preferences.

12. Digital Tracking and Profiling

We may analyse website and digital behaviour to:

  • Understand user preferences
  • Improve user experience
  • Provide relevant marketing

This may include limited profiling based on browsing behaviour. Such processing will only take place in accordance with applicable law and with your consent where required. We do not use automated decision-making that produces legal consequences.

13. Sharing of Personal Information

We may share your information with:

  • Developers and sellers
  • Attorneys and conveyancers
  • Financial institutions
  • Compliance service providers
  • CRM and marketing platforms
  • Regulatory authorities

Where third-party service providers process information on our behalf, we ensure that they are contractually required to safeguard personal information and process it only in accordance with our instructions.

14. International Transfers

Some service providers may process data outside South Africa. We ensure that such transfers occur only where:

  • The recipient provides an adequate level of protection; or
  • Appropriate safeguards or consent are in place

15. Data Security

We implement appropriate technical and organisational measures to protect your personal information. We take reasonably practicable steps to:

  • Identify risks
  • Implement safeguards
  • Regularly review security measures
  • Update protections where necessary

16. Data Retention

We retain personal information:

  • As required to fulfil its purpose
  • In accordance with legal requirements (including FICA)

Thereafter, information is securely deleted or anonymised.

17. Your Rights

You have the right to:

  • Access your personal information
  • Request correction or deletion
  • Object to processing
  • Withdraw consent
  • Lodge a complaint with the Information Regulator

These rights are subject to applicable legal limitations.

18. Cookies

Our website uses cookies. Please refer to our Cookie Policy for more information.

19. Breach Notification

In the event of a data breach, we will notify affected parties and the relevant authorities as required by law.

20. Information Officer

The Information Officer is responsible for ensuring compliance with applicable data protection laws, handling data subject requests, and liaising with the Information Regulator.

21. Updates to This Policy

We may update this Privacy Policy from time to time.

22. Contact Details

Information Officer
Kent Gush Properties (Pty) Ltd
Email: compliance@kentgush.co.za