Privacy notice

1.Responsible party

Registered name

KIRAZ PARTNERS

Trading as

Rello

Country of registration

South Africa

Contact

hello@rello.work

2.Capacity

1. 2.1Where you hold a Rello account, Kiraz Partners is the responsible party under POPIA and the controller under the GDPR.
2. 2.2Where you are a resident, owner or contractor dealing with a client of ours, that client is the responsible party and Kiraz Partners acts on its instructions as operator under POPIA and processor under the GDPR.
3. 2.3A request made to us under clause 2.2 is referred to the relevant client and you are told to whom it was referred.

3.Information held

1. 3.1Name, contact telephone number and, where an account exists, email address.
2. 3.2The property and unit to which you are connected, and your role in relation to it.
3. 3.3Messages exchanged with our client, including attachments. Audio and video attachments are converted to text.
4. 3.4Work arising from those messages: what was reported, to whom it was allocated, what was undertaken and when it was completed.
5. 3.5Amounts owed and paid, where our client uses Rello for that purpose.
6. 3.6Technical records generated by use of the service, including IP address and access times.
7. 3.7No special personal information is requested or recorded. The categories of information Rello may record about a person are fixed and exclude health, race, religion, political persuasion, sexual life, biometrics and criminal behaviour.

4.Purpose and lawful basis

1. 4.1To provide the service our client has appointed us to provide, being the receipt and answering of messages and the recording and settlement of resulting work. POPIA section 11(1)(b); GDPR Article 6(1)(b) and 6(1)(f).
2. 4.2To maintain a record of what was requested, undertaken and done.
3. 4.3To comply with a legal obligation applying to us or to our client. POPIA section 11(1)(c); GDPR Article 6(1)(c).
4. 4.4Where processing is based on consent, that consent may be withdrawn at any time. Withdrawal does not affect processing carried out before it.

5.Messages sent by WhatsApp

1. 5.1Messages are carried by WhatsApp and are subject to Meta Platforms’ own terms in addition to this notice.
2. 5.2Rello sends messages only in relation to the property to which you are connected. It does not send direct marketing.
3. 5.3An employee of our client may take over a conversation at any time, after which replies are sent by that person.
4. 5.4To stop receiving messages, say so in the conversation and write to hello@rello.work.

6.Recipients

Personal information may be disclosed to the following categories of recipient.

1. 6.1The client whose property you are connected to, and its staff.
2. 6.2A contractor appointed to do work, limited to what the work requires.
3. 6.3Providers of hosting, data storage and message delivery, acting on our instructions.
4. 6.4Providers of language and transcription services used to read and answer a message.
5. 6.5Our professional advisers, and a public authority where the law requires it.

A list of the operators we engage is available on request to hello@rello.work. Personal information is not sold and is not disclosed for the direct marketing of any third party.

7.Transfer outside the country

Certain recipients under clause 6 process personal information outside South Africa and outside the United Kingdom and the European Economic Area. Each is bound by contract to a standard of protection substantially similar to that required by POPIA section 72 and Chapter V of the GDPR.

8.Retention

1. 8.1Records are retained for as long as our client requires them for the purpose in clause 4, and for any further period the law requires our client to retain them.
2. 8.2Rello keeps an append-only record, to which entries are added and not altered.
3. 8.3Where erasure is required, personal information is removed or de-identified and only the fact of the event, its date and the unit concerned are retained. See deleting your data.
4. 8.4On termination of a client’s use of Rello, information held for that client is returned or deleted on its instruction, subject to clause 8.1.

9.Your rights

1. 9.1To confirmation of whether we hold personal information about you, and to a copy of it.
2. 9.2To correction of information that is inaccurate, and completion of information that is incomplete.
3. 9.3To erasure of information we have no lawful basis to retain.
4. 9.4To object to processing, and to require restriction of processing pending resolution of an objection.
5. 9.5To receive information you provided in a portable form, where processing is based on contract or consent.
6. 9.6Not to be subject to a decision based solely on automated processing having legal or similarly significant effect. Rello drafts and sends messages; decisions affecting a tenancy, a payment or a property are taken by a person.
7. 9.7A right under this clause is exercised by written request to hello@rello.work, and is answered within 30 days.

10.Complaints

A complaint may be made to us at hello@rello.work. A complaint may also be made to the Information Regulator in South Africa, the Information Commissioner’s Office in the United Kingdom, or the supervisory authority of your Member State in the European Economic Area.

11.Children

Rello is provided to businesses and is not directed at children. Information is not knowingly collected from a child.

12.Amendment

This notice may be amended. The date on which the current version took effect appears above. Where an amendment affects information already held, our clients are notified.