Legal
Privacy Policy
Lomaneva processes personal information in terms of the Protection of Personal Information Act 4 of 2013. This policy explains what we hold, why we hold it, who sees it and how you take control of it.
01Scope of this policy
This policy applies to personal information we process about guests, prospective guests, website visitors, people who enquire about a tour, suppliers and job applicants. It covers information collected through this website, by email, telephone and WhatsApp, at reception, and on our premises.
“Personal information”, “processing”, “data subject”, “responsible party” and “operator” carry the meanings given to them in POPIA.
02Responsible party and Information Officer
Lomaneva Hotel is the responsible party for the personal information described in this policy. It determines why and how that information is processed.
- Responsible party
- Lomaneva Hotel and Lomaneva Journeys
- Physical address
- 5500 Kokolufute Street, Windmill Park Estate, Boksburg 1459, South Africa
- Information Officer
- The Information Officer, reachable at info@lomaneva.com or +27 63 943 8491
Our Information Officer is registered with the Information Regulator as required by section 55 of POPIA and is responsible for our compliance, for handling your requests, and for our manual under the Promotion of Access to Information Act 2 of 2000.
03What personal information we collect
| Category | Examples |
|---|---|
| Identity | Full name, title, date of birth, nationality, passport or identity number, and a copy of the identity document where the guest register requires it |
| Contact | Physical address, email address, telephone and WhatsApp number, and emergency contact details |
| Booking | Arrival and departure dates, room and rate, tours booked, flight details, party composition, preferences and special requests |
| Financial | Invoices, amounts paid, payment method, proof of payment, and the last four digits and expiry of a card. We never hold a full card number |
| Health and dietary | Allergies, dietary requirements, mobility needs, pregnancy and medical conditions relevant to an activity |
| Correspondence | Emails, WhatsApp messages, enquiry forms, reviews and complaints |
| Security | CCTV footage of the public areas and perimeter of the property, and vehicle registration numbers at the gate |
| Technical | IP address, browser type and pages viewed, where this is generated by ordinary web server logs |
04How we collect it
- Directly from you, when you enquire, book, check in, order a service or write to us. This is our main source.
- From the lead guest, where one person books for a party. That person warrants they have authority to share the others' details.
- From a travel agent, tour operator or corporate booker acting for you.
- From our CCTV system, which records the public areas and perimeter of the property and is signposted at the entrance.
- From our web server logs, automatically, when you visit this website.
We do not buy marketing lists and we do not collect personal information from public sources to market to you.
05Why we process it, and on what lawful basis
Section 11 of POPIA permits processing only on a recognised basis. Ours are set out below.
| Purpose | Lawful basis |
|---|---|
| Taking, confirming and delivering your booking | Necessary to conclude and perform our contract with you |
| Booking tours and activities with suppliers on your behalf | Necessary to perform our contract with you |
| Invoicing, taking payment and keeping accounting records | Contract, and compliance with the Tax Administration Act and the VAT Act |
| Keeping a guest register and recording identity documents | Compliance with an obligation imposed by law |
| Catering for allergies, dietary needs and medical conditions | Your explicit consent, and protection of your legitimate interests |
| CCTV for the safety of guests, staff and property | Our legitimate interests in security, balanced against your privacy |
| Responding to enquiries and complaints | Contract, and our legitimate interests |
| Sending you offers and news about Lomaneva | Your consent, or the existing-customer basis in section 69(3) of POPIA |
| Defending or bringing a legal claim | Establishment, exercise or defence of a right at law |
06Special personal information and children's information
- Health, dietary and medical information is special personal information under section 26 of POPIA. We process it only with your consent, only to keep you safe and comfortable, and we share it only with the specific member of staff or supplier who needs it, such as a chef or an activity operator.
- We do not process information about your religious or philosophical beliefs, race, political persuasion, trade union membership, sexual life or criminal behaviour, except where you volunteer a religious dietary requirement, which we treat as a catering instruction and nothing more.
- Information about a child is processed under section 34 of POPIA only with the consent of a competent person, being the parent or guardian who makes the booking, and only for the purposes of the stay, safety and age eligibility for activities.
- Where an activity operator imposes a minimum age or requires a medical declaration, we pass on only the information that operator requires.
08Cross-border transfers
Some of our service providers, particularly for email, hosting and payment processing, operate servers outside South Africa. Section 72 of POPIA permits such a transfer only in defined circumstances, and we rely on the following:
- The recipient is subject to a law, binding corporate rules or a binding agreement that provides an adequate level of protection substantially similar to POPIA; or
- The transfer is necessary for the performance of our contract with you, for example booking an international flight or a service abroad; or
- You have consented to the transfer.
We contract with providers who commit in writing to protection standards equivalent to POPIA, and we will tell you which providers are involved if you ask.
09How we protect it
Section 19 of POPIA requires us to secure the integrity and confidentiality of personal information through appropriate, reasonable technical and organisational measures. Ours include:
- Encryption of this website in transit using HTTPS, on every page.
- Access control, so that staff see only the information their role requires.
- Written confidentiality undertakings from every member of staff, and contractual security obligations on every operator who processes information for us.
- Storing paper records, including registration cards, in locked storage and destroying them securely once their retention period expires.
- Not storing full card numbers anywhere in our systems.
- CCTV footage kept on access-controlled equipment and reviewed only where there is a security reason to do so.
- Periodic review of our safeguards against reasonably foreseeable risks.
No system is perfectly secure, and we do not claim otherwise. What we do undertake is to keep our safeguards current and to tell you promptly if something goes wrong.
10How long we keep it
Section 14 of POPIA prohibits keeping records longer than necessary, unless a law requires it. Our periods are:
| Record | Retention period |
|---|---|
| Financial records, invoices and supporting documents | 5 years from the end of the tax period, as required by the Tax Administration Act 28 of 2011 |
| Booking and guest register records | 5 years, aligned to the above |
| Health and dietary information | Deleted within 12 months of departure, unless needed for a claim |
| CCTV footage | 30 days, unless retained for a specific security incident or investigation |
| Marketing consent records | Until you unsubscribe, and then a suppression record indefinitely so we do not contact you again |
| Enquiries that do not become bookings | 18 months |
| Unsuccessful job applications | 6 months |
11Your rights
As a data subject you have the following rights under POPIA, and exercising them is free.
- To be told whether we hold personal information about you, and to be given a record of it, under section 23.
- To have information corrected, or destroyed or deleted where it is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully, under section 24.
- To object, on reasonable grounds, to our processing of your information, under section 11(3).
- To withdraw consent at any time, where processing was based on consent. Withdrawal does not affect processing already carried out.
- To object at any time to direct marketing, and to require us to stop, under section 69.
- Not to be subject to a decision based solely on automated processing, under section 71. We do not make such decisions.
- To complain to the Information Regulator, and to institute civil proceedings under section 99.
12Exercising your rights
- Write to our Information Officer at info@lomaneva.com, describing what you want. You do not need to use a form or cite a section.
- We will verify your identity before disclosing or changing anything, to protect you against someone impersonating you.
- We respond within 30 days. Where a request is complex we may extend that period once, and we will tell you why before the original period expires.
- A request for access to a record under the Promotion of Access to Information Act is made on Form 2 of that Act, and prescribed fees may apply to reproduction. Requests to correct your own information under POPIA carry no fee.
- If we decline a request in whole or in part, we will tell you the reason and how to take the matter further.
14Direct marketing
- Section 69 of POPIA prohibits electronic direct marketing to a person who is not an existing customer unless that person has consented.
- If you have stayed with us or booked with us, we may send you occasional news and offers about our own services on the existing-customer basis in section 69(3). We will not do this if you have already objected.
- If you have not booked with us, we contact you only in response to your enquiry, or with your consent.
- Every marketing message carries a working unsubscribe link, and you may also simply reply asking to stop. We action it within 5 business days.
- We never share your details so that another business can market to you.
15Security compromises
Section 22 of POPIA requires us to notify both the Information Regulator and you where there are reasonable grounds to believe that your personal information has been accessed or acquired by an unauthorised person.
- We will notify you as soon as reasonably possible after discovering the compromise, unless a public body tells us to delay so as not to impede a criminal investigation.
- The notification will describe the possible consequences, what we are doing about it, what we recommend you do, and the identity of the unauthorised person if we know it.
- Notification will be in writing to your email or postal address, and prominently on this website where we cannot reach you directly.
16Complaints to the Information Regulator
Please raise a privacy concern with us first, at info@lomaneva.com. If you are not satisfied with our response, or you would rather go straight to the regulator, you may lodge a complaint with:
- Regulator
- The Information Regulator (South Africa)
- Address
- JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
- Postal
- PO Box 31533, Braamfontein, Johannesburg, 2017
- Telephone
- +27 10 023 5200
- POPIA complaints
- POPIAComplaints@inforegulator.org.za
- PAIA complaints
- PAIAComplaints@inforegulator.org.za
- Website
- https://inforegulator.org.za
17Changes to this policy
We review this policy at least annually and whenever our processing changes. The current version is always published here, with its effective date. Where a change materially affects how we use your information, we will tell you directly rather than relying on you noticing.
This policy should be read with our Terms & Conditions. Last updated: 10 September 2026.
Questions about this policy
Talk to us directly.
Lomaneva Hotel answers every legal, privacy and billing query itself. There is no call centre in between.
- 5500 Kokolufute Street, Windmill Park Estate, Boksburg 1459, South Africa
- +27 63 943 8491
- info@lomaneva.com