MANAGEMENT OF CUSTOMER’S PRIVATE INFORMATION AT OUR COMPANY

1. BASIC POLICY (LEGAL COMPLIANCE)

We make every effort to appropriately handle and to safely and reliably manage the protection of personal information and anonymously processed information (hereinafter collectively referred to as “Personal Information, etc.”), complying with the Act on the Protection of Personal Information, all other applicable laws and ordinances, and all related in-house regulations.

2. ACQUISITION AND USE OF PERSONAL INFORMATION

We acquire our customer’s personal information through appropriate and legitimate means within the necessary scope of our specific work. We shall not use such personal information beyond the scope of said work without the consent of the persons involved or unless otherwise provided for in the laws and regulations.

3. PURPOSE OF USING PERSONAL INFORMATION

Personal Information, etc. obtained from our customers shall be used only for the specific purposes described below once we obtain the person’s consent or unless otherwise provided for in the laws and regulations.

1. For Real Estate Sales/Purchases, Leases, and Lease brokerage services
   [Case of providing real estate information to a third party (such as advertisement).]
   • 1-(1) Real estate information to be advertised shall be about property types, location, price, local transportation, land and building sizes, room layouts, equipment, photos, location maps, etc. However, personal information, such as individual names, will not be included.
   • 1-(2) Real estate information shall be provided to the other party of a real estate contract or a person who desires to sell/buy or lease real estate; either directly through advertising media such as a website page, (own company website or other websites offering real estate information), real estate information journals, leaflets, newspapers, direct mail; or indirectly through the other real estate agencies (including the advertisement made by other real estate brokers with our consent).
   • 1-(3) In the event that an agreement is concluded, a report containing the concluded date, price, etc.)　shall be made to the advertising media for cancellation of the advertisement immediately after the agreement is concluded.
2. Real estate management business.
3. Price assessment related to real estate sales, purchase and leasing.
   
   • 3-(1) When using information upon the conclusion of an agreement provided by private advertisers (information only on real estate property, but individual names, etc. shall not be included), and when making an assessment for the price of real estate property (prices for sale and lease).
   • 3-(2) It may be provided as “the basis of opinion” to show the price for real estate property (price for sale or lease). However in this case, it shall be provided after trying various measures to keep out private information.
   • 3-(3) The details of the information upon the conclusion of an agreement to be provided are the property summaries (property types, location, prices, transportation, size of land and building, room layouts, equipment, etc.). However, individual names, etc. are not to be included. The aforementioned information shall be provided by electronic data, documents or on a PC monitor screen.
4. Consulting and support services for foreigners living in Zambia.
5. To use personal information within the necessary bounds concerning each business described in the above sub-number 1-4 such as after-sales service, information service, and customer development (for Direct Mail, etc.)
6. To provide the information to a third party within the necessary bounds required to accomplish the above mentioned (1-4) business purposes.
   
   • The parties who will be receiving may be as follows: the other party or a person who desires to be of the agreement, other real estate dealers, distributors of real estate information, financial institutes for financing, land and house investigators, lawyers, property insurance companies, real estate management dealers, clients for price assessment, property insurance agencies, guarantee trust companies, relocation companies,  transportation companies, furniture lease companies, embassies of countries where the property is located in case of the above sub-number 4, the third parties who obtained consent from the said person, etc.
   • Information to be provided shall meet the minimum requirements to accomplish the above mentioned purposes, such as names, addresses, telephone numbers, property information and information on the conclusion of an agreement, etc.
   • Information shall be provided through various methods such as documents, telephone, E-mail, Internet, advertising media and so forth.

4. DISCLOSURE, CORRECTION, ETC. OF RETAINED PERSONAL DATA

When we receive a written request in the prescribed manner for disclosure, correction, or suspension of the use of our retained personal data (hereinafter referred to as “Disclosure, etc.”), when we complete an identity verification of the requester through identity confirmation documents such as a copy of the residence certificate, and when we deem it appropriate, we shall disclose, correct, or suspend the use of such data.

Request For Disclosure, Etc. To:

1. WhatsApp:Homes Platinum Ltd.
   ATTN: Person in charge of personal information
   +260974950033 / +260 213325061
2. E-mailPlease send the request by email through the form on our website or info@homesplatinum.co.zm

Documents Required To Be Submitted

1. Request for Disclosure, etc. of our retained personal data in our designated form

2. Personal identification documents

1. When the person requests for himself/herself Either of the followings shall be submitted:

   – Copy of a document issued by a public institution such as the person’s driver’s license or passport.

   – The original copy of the person’s seal registration certificate (the present address to be described on and the issuance date to be within three months).

2. When an agent makes a request on behalf of the person

   In addition to the person’s personal identification document as stated above ①, the same documents of an agent on behalf of the person and the documents to identify a specific individual as the agent of the person shall be submitted.

   Personal identification documents of an agent

   Either of the followings shall be submitted:

   – Copy of the document issued by a public institution such as an agent’s driver’s license or passport.

   – The original copy of an agent’s seal registration certificate (the present address to be described on and the issuance date to be within three months).

   Documents to identify an individual as an agent of the person

   Either of the followings shall be submitted:

   – In case of a statutory agent, the documents which certify the legal power of attorney.

   – In case of a privately appointed agent, a power of attorney (sealed by the registered seal of the person)

Our Reply

We will send a reply to a request in writing to a requester within a reasonable period of time and scope after our confirmation and research of the details of a request as well as confirming the receipt for the handling fee. We will reply directly to a requester when a request is made by an agent of the requester unless a request is made by a statutory agent. However, we may not accept a request of Disclosure, etc. in the following cases.

1. When disclosure is likely to harm the life, body, property, or other rights or interests of the person or a third party.
2. When disclosure is likely to seriously impede the proper execution of our business.
3. When disclosure violates other laws and regulations

5. DISCLOSURE TO THIRD PARTIES

We shall not disclose or provide personal data about our customer to a third party without obtaining the person’s consent beforehand unless otherwise provided for in the laws and regulations. We shall voluntarily discontinue the use of our retained personal data when there is a request from the person to do so.

6. SHARING USAGE OF RETAINED PERSONAL INFORMATION

We may share the usage of our retained personal information among our following affiliated companies within the scope necessary for the said usage objectives. The items of such information to be shared may include name, company, department, position, address, phone number, e-mail address, assets information, etc., which are the minimum required for achieving the said usage objectives. Each affiliated company is responsible for sharing the usage of such personal information.

7. ABOUT SECURITY CONTROL MEASURES

We shall carry out thorough control of personal information that we acquire from our customer as follows:

1. To ensure accuracy of personal information. We shall keep our customer’s personal information accurate and current.
2. Security control measures. Regarding systematic security control measures of the customer’s personal information, we have a company rule established for a strict information handling and carry out careful handling based on it.
3. Supervision of our employees. We strictly enforce rules for handling our customer’s personal information in accordance with our in-house regulations.
4. Supervision of Contractors. When it is necessary for us to assign the handling of our retained personal information to outsourcing contractors, we shall select contractors who satisfy the required conditions in accordance with our in-house regulations, and supervise them accordingly.
5. Preservation period and disposal. We establish the period of preservation for personal information acquired from our customers, and dispose of it after the preservation period has ended. We will also dispose of it immediately if within the preservation period it becomes unneeded.

8. OUTSOURCING OF THE HANDLING OF PERSONAL INFORMATION AND SUPERVISION OF THE OUTSOURCED PARTIES

We may outsource the handling of personal information to outside parties within the scope of the use objectives. In this case, we shall ensure necessary and appropriate supervision of the outsourced parties in accordance with the Act on the Protection of Personal Information and all other applicable laws and ordinances.

9. CONTACT INFORMATION FOR INQUIRIES AND COMPLAINTS ABOUT PERSONAL INFORMATION

For questions, inquiries, and complaints about our handling of the Personal Information, etc., please contact to the following person in charge:

Person In Charge Of Inquiries

Homes Platinum Ltd.
ATTN: Person in charge of personal information
Phone: +260 974950033, E-mail: info@homesplatinum.co.zm
Reception time ：08:00～17:00（Except. Sun, and Holidays)

10. OTHERS

In response to the change of social standards, and the progress of information technology, we shall ensure periodical review and improvement of this privacy policy and our security control measures on personal information for more thorough protection. When we revise this policy, we will announce it on our website.

Established on March, 2017
Revised on May, 2021