Williams Alicey Group
Effective Date: 25 August 2026

1. INTRODUCTION

Williams Alicey Group (“WAG“, “we“, “us or “our“) respects the privacy of individuals and is committed to protecting personal information entrusted to us.

This Privacy Policy explains how WAG and its subsidiaries, divisions, operating companies, websites, online platforms and related services collect, use, store, disclose and protect personal information.

This Policy applies to personal information processed by WAG in connection with:

  • Customers and prospective customers;
  • Suppliers and prospective suppliers;
  • Service providers and business partners;
  • Employees and prospective employees;
  • Website visitors and users of our online platforms;
  • Persons who communicate with WAG electronically, telephonically or in person; and
  • Other individuals whose personal information WAG processes in the ordinary course of business.

WAG is committed to processing personal information responsibly, lawfully and transparently.

2. APPLICABLE LAW

WAG processes personal information in accordance with applicable South African legislation, including, where applicable:

  • The Protection of Personal Information Act 4 of 2013 (“POPIA”);
  • The Promotion of Access to Information Act 2 of 2000 (“PAIA”);
  • The Electronic Communications and Transactions Act 25 of 2002;
  • The Consumer Protection Act 68 of 2008; and
  • Other applicable laws and regulations governing privacy, information security and electronic communications.

Where WAG operates outside South Africa, additional privacy legislation may apply depending on the jurisdiction concerned.

3. WHO WE ARE

Williams Alicey Group (WAG) is a diversified business group with interests in various commercial and operating activities.

For purposes of this Policy, WAG may act as a responsible party in terms of POPIA where it determines the purpose and means of processing personal information.

Individual WAG subsidiaries or operating companies may also act as separate responsible parties where appropriate.

Where a particular WAG company has its own privacy policy, that policy may apply to the relevant service or relationship in addition to this Group Privacy Policy.

4. INFORMATION WE COLLECT

Depending on the nature of our relationship with you, WAG may collect the following categories of personal information:

4.1 Identification information

This may include:

  • Full name;
  • Identity or passport number;
  • Date of birth;
  • Gender, where legally or operationally required;
  • Signature; and
  • Other information required to verify identity.

4.2 Contact information

This may include:

  • Physical address;
  • Postal address;
  • Email address;
  • Telephone or mobile number; and
  • Business contact information.

4.3 Transaction and commercial information

Where relevant, we may collect:

  • Orders and purchase history;
  • Invoices and payment information;
  • Delivery information;
  • Account information;
  • Quotations and contracts;
  • Supplier information;
  • Customer correspondence;
  • Credit-related information where lawfully permitted; and
  • Other information required to conduct commercial transactions.

4.4 Employment-related information

For employees and applicants, we may process information such as:

  • CVs and employment history;
  • Qualifications and professional registrations;
  • References;
  • Payroll information;
  • Banking details;
  • Tax information;
  • Performance information; and
  • Other information reasonably required for employment administration.

4.5 Website and technical information

When you interact with our websites or online platforms, we may collect:

  • IP address;
  • Browser type;
  • Device information;
  • Operating system;
  • Website activity;
  • Pages viewed;
  • Referring websites;
  • Approximate location information;
  • Login information; and
  • Other technical information generated through your interaction with our systems.

4.6 Communications

We may retain communications between you and WAG, including:

  • Emails;
  • Telephone records where lawfully permitted;
  • Online enquiries;
  • Customer service communications;
  • Contact forms; and
  • Other correspondence.

5. HOW WE COLLECT PERSONAL INFORMATION

We may collect personal information:

  • Directly from you;
  • When you purchase products or services;
  • When you create an account;
  • When you submit an enquiry;
  • When you communicate with us;
  • Through our websites and online platforms;
  • Through applications, forms and contracts;
  • From suppliers and business partners;
  • From publicly available sources;
  • From credit or verification providers where legally permitted;
  • Through recruitment processes; and
  • Through other lawful business processes.

Where reasonably practicable, we will inform you when personal information is collected directly from you.

6. PURPOSES FOR PROCESSING PERSONAL INFORMATION

WAG may process personal information for legitimate business purposes, including:

  • Providing products and services;
  • Processing orders and payments;
  • Delivering products;
  • Managing customer and supplier relationships;
  • Responding to enquiries;
  • Providing customer support;
  • Managing accounts;
  • Processing returns, refunds and warranties;
  • Performing contractual obligations;
  • Communicating important service information;
  • Marketing products and services where legally permitted;
  • Managing employees and recruitment;
  • Maintaining financial and accounting records;
  • Preventing fraud and other unlawful activity;
  • Protecting WAG’s systems and property;
  • Improving our websites, products and services;
  • Conducting analytics and business planning;
  • Complying with legal and regulatory obligations;
  • Establishing, exercising or defending legal rights; and
  • Performing other functions reasonably necessary for conducting our business.

7. LEGAL BASIS FOR PROCESSING

WAG will process personal information only where there is a lawful basis to do so.

Depending on the circumstances, this may include:

  • Your consent;
  • Performing a contract with you;
  • Taking steps at your request before entering into a contract;
  • Compliance with a legal obligation;
  • Protecting legitimate interests;
  • Protecting rights or legitimate interests of another person; or
  • Other lawful grounds recognised under applicable legislation.

Where consent is required, WAG will obtain it in an appropriate manner.

You may withdraw consent where the law permits you to do so. Withdrawal of consent will not affect processing that was lawfully undertaken before withdrawal.

8. MARKETING COMMUNICATIONS

WAG may communicate with customers and prospective customers regarding products, services, promotions, developments and other business-related information where permitted by law.

Marketing communications may be sent by:

  • Email;
  • SMS;
  • Telephone;
  • WhatsApp or similar communication platforms;
  • Digital advertising; or
  • Other lawful communication channels.

Where required by law, WAG will obtain appropriate consent before sending direct marketing communications.

You may request that WAG stop sending you direct marketing communications.

Each electronic marketing communication should, where applicable, provide an appropriate mechanism to unsubscribe.

9. COOKIES AND WEBSITE TECHNOLOGIES

Our websites may use cookies and similar technologies.

Cookies may be used to:

  • Enable website functionality;
  • Remember preferences;
  • Maintain sessions;
  • Improve website performance;
  • Understand how visitors use our websites;
  • Measure marketing effectiveness; and
  • Improve the user experience.

Some cookies may be essential to the operation of the website, while others may be optional.

You may be able to control or disable certain cookies through your browser settings or available cookie-management tools.

Disabling certain cookies may affect website functionality.

10. SHARING PERSONAL INFORMATION

WAG does not sell personal information as a business practice.

We may disclose personal information where reasonably necessary to conduct our business or where legally permitted, including to:

  • WAG group companies;
  • Employees and authorised personnel;
  • Delivery and logistics providers;
  • Payment service providers;
  • IT and technology providers;
  • Website and hosting providers;
  • Professional advisers;
  • Accountants and auditors;
  • Legal advisers;
  • Financial institutions;
  • Credit and verification providers;
  • Government authorities and regulators;
  • Insurance providers;
  • Business partners; and
  • Other service providers acting on our behalf.

Where appropriate, WAG will require third-party service providers to implement appropriate confidentiality and information-security measures.

11. CROSS-BORDER TRANSFERS

WAG may use service providers or technology platforms located outside South Africa.

Where personal information is transferred across borders, WAG will take reasonable steps to ensure that the transfer complies with applicable legal requirements and that appropriate safeguards are in place.

Such safeguards may include contractual protections, appropriate security measures and other mechanisms required by applicable law.

12. PROTECTION OF PERSONAL INFORMATION

WAG takes reasonable technical and organisational measures to protect personal information against:

  • Loss;
  • Theft;
  • Unauthorised access;
  • Unauthorised disclosure;
  • Unauthorised alteration;
  • Destruction; and
  • Other unlawful processing.

Security measures may include:

  • Access controls;
  • Password protection;
  • User permissions;
  • System monitoring;
  • Secure storage;
  • Backups;
  • Network and endpoint security;
  • Staff awareness and training; and
  • Appropriate contractual controls with service providers.

No electronic system can be guaranteed to be completely secure. WAG therefore cannot guarantee absolute security of information transmitted to or from our systems.

13. DATA RETENTION

WAG will retain personal information only for as long as reasonably necessary for the purpose for which it was collected, unless a longer retention period is required or permitted by law.

Retention periods may depend on:

  • The nature of the information;
  • The purpose for processing;
  • Contractual requirements;
  • Legal and regulatory requirements;
  • Accounting and tax requirements;
  • Dispute resolution requirements; and
  • Legitimate business requirements.

When personal information is no longer required, WAG will take reasonable steps to securely delete, destroy or anonymise it where appropriate.

14. ACCURACY OF PERSONAL INFORMATION

WAG seeks to maintain accurate and reasonably up-to-date personal information.

You may request that inaccurate or incomplete personal information be corrected.

Where appropriate, WAG may request additional information to verify your identity before making changes to personal information.

15. YOUR PRIVACY RIGHTS

Subject to applicable law, you may have the right to:

  • Request access to personal information held by WAG about you;
  • Request correction or updating of inaccurate information;
  • Request deletion of information where legally permissible;
  • Object to certain forms of processing;
  • Object to direct marketing;
  • Withdraw consent where processing is based on consent;
  • Request information about how your personal information is being processed; and
  • Lodge a complaint regarding the processing of your personal information.

Certain rights may be subject to legal limitations or exceptions.

16. REQUESTING ACCESS TO INFORMATION

Requests for access to personal information should be submitted in accordance with WAG’s applicable PAIA Manual and relevant procedures.

WAG may require sufficient information to verify the identity of the requester before processing an access request.

WAG reserves the right to refuse access where permitted or required by law.

17. CHILDREN’S INFORMATION

WAG does not knowingly collect personal information from children where such collection is prohibited by law.

Where personal information relating to a child is required for a legitimate business purpose, WAG will process such information in accordance with applicable legal requirements.

18. SPECIAL PERSONAL INFORMATION

Certain categories of information receive additional protection under POPIA.

WAG will process special personal information only where there is an appropriate lawful basis and where required safeguards are in place.

WAG does not ordinarily seek to collect special personal information unless it is reasonably necessary for a legitimate business or legal purpose.

19. THIRD-PARTY WEBSITES

Our websites may contain links to third-party websites, platforms or services.

WAG is not responsible for the privacy practices, security or content of third-party websites.

Users should review the privacy policies of third-party websites before submitting personal information to them.

20. DATA BREACHES

If WAG becomes aware of a security compromise involving personal information, WAG will take reasonable steps to investigate, contain and address the incident.

Where required by applicable law, WAG will notify affected individuals and/or the relevant regulatory authority.

21. INFORMATION OFFICER

WAG will designate an Information Officer and, where appropriate, Deputy Information Officers in accordance with applicable legislation.

The Information Officer is responsible for overseeing WAG’s compliance with applicable information-protection requirements.

Information Officer: Williams Alicey Group Information Officer
Email: info@williams.africa

Requests, privacy enquiries and complaints relating to personal information may be directed to the Information Officer.

22. PRIVACY COMPLAINTS

If you believe that WAG has processed your personal information unlawfully or contrary to this Policy, you may contact our Information Officer so that the matter can be investigated and addressed.

You may also have the right to lodge a complaint with the Information Regulator of South Africa where applicable.

23. CHANGES TO THIS PRIVACY POLICY

WAG may update this Privacy Policy from time to time to reflect:

  • Changes in legislation;
  • Changes to our business;
  • Changes to our websites or technology;
  • Changes to our information-processing practices; or
  • Improvements to our privacy practices.

The latest version will be made available through the relevant WAG website or other appropriate communication channel.

The Effective Date at the beginning of this Policy indicates when the current version came into effect.

24. CONTACT US

For privacy-related enquiries, requests or complaints, please contact:

Williams Alicey Group (WAG)
Email: info@williams.africa
Information Officer: Williams Alicey Group Information Officer

Please include sufficient information in your correspondence to allow us to identify your request and respond appropriately.

25. GOVERNING LAW

This Privacy Policy is governed by the laws of the Republic of South Africa.

Any dispute concerning this Policy will be subject to the applicable laws and jurisdiction of South Africa.

END OF POLICY

Document Owner: Williams Alicey Group
Policy: Group Privacy Policy
Version: 1.0
Effective Date: 25 August 2026
Review Cycle: At least annually or when material legal/business changes occur.