External Privacy Notice
Contents
1. Introduction
2. What Is Personal Information?
3. Where and When Do We Collect Personal Information?
4. When Will We Process Your Personal Information?
5. When Will We Process Your Special Personal Information?
6. What Information Do We Collect and How Do We Use It?
7. Collection of Information by Cookies
8. How We Share Your Information
9.Your Rights and Obligations
10. Changes to Our Privacy Notice
11. Other Important Information
12. Contact Information
13.Document Control
1. Introduction
In this document, references to Invictus Security Services Pty Ltd, “we”, “us”, or “the Group” refer to Invictus Security Services Pty Ltd and its subsidiary companies.
Invictus Security Services Pty Ltd recognises its accountability in terms of the Protection of Personal Information Act (POPIA), other applicable privacy protection legislation, and associated regulations in relation to its clients, suppliers, service providers, and other third parties.
Invictus Security Services Pty Ltd needs to collect personal information from clients, suppliers, service providers, and other third parties in order to conduct its business.
To maintain a relationship of trust with our stakeholders, we are committed to complying with both the spirit and the letter of POPIA and other applicable privacy protection legislation. We undertake to act with due skill, care, and diligence when dealing with personal information.
2. What Is Personal Information?
According to POPIA, Personal Information means information relating to an identifiable, living natural person and, where applicable, an identifiable, existing juristic person.
This includes, but is not limited to:
- Information relating to a person’s race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language, and birth.
- Information relating to a person’s education or medical, financial, criminal, or employment history.
- Any identifying number, symbol, email address, telephone number, location information, online identifier, or other particular assignment to a person.
- Biometric information.
- Personal opinions, views, or preferences.
- Correspondence sent by a person that would reveal the contents of the original correspondence.
- The views or opinions of another individual about the person.
- A person’s name where it appears with other personal information relating to that person, or where disclosure of the name itself would reveal information about the person.
3. Where and When Do We Collect Personal Information?
Information You Provide to Us
We may collect information from our clients through:
- Direct communication, including email and telephone.
- Completion of a Client Form on our website.
- Completion of a Vendor Form.
Suppliers and Service Providers
Information may be obtained from:
- Invoices.
- Other documentation provided as part of the business relationship.
Website Usage
Information may also be collected through the use of cookies, which allow us to collect standard internet visitor and website usage information.
4. When Will We Process Your Personal Information?
We will only process your personal information for lawful purposes relating to our business where one or more of the following circumstances apply:
- You have consented to the processing.
- A person legally authorised by you, or a court, has consented to the processing.
- Processing is necessary to conclude or perform a contract we have with you.
- The law requires or permits the processing.
- Processing is required to protect or pursue your legitimate interests, our legitimate interests, or those of a third party.
- You are a child and a competent person, such as a parent or guardian, has consented to the processing on your behalf.
5. When Will We Process Your Special Personal Information?
Special personal information includes information concerning:
- Religious or philosophical beliefs.
- Race.
- Ethnic origin.
- Trade union membership.
- Political beliefs.
- Health, including physical or mental health, disability, and medical history.
- Biometric information.
- Criminal behaviour where it relates to the alleged commission of an offence or proceedings relating to that offence.
We may process special personal information where:
- You have consented to the processing in circumstances where we are legally required to obtain your consent.
- Processing is necessary to exercise or defend a right or obligation in law.
- Processing is necessary to comply with an international legal obligation of public interest.
- Processing is required for certain historical, research, or statistical purposes that would not adversely affect your privacy.
- You have deliberately made the relevant personal information public.
6. What Information Do We Collect and How Do We Use It?
The following list is not comprehensive. It sets out the main purposes for which information is collected by Invictus Security Services Pty Ltd and the principal data elements that may be processed.
Clients
Purposes
Information may be processed for:
- Quotations and invoicing.
- Service delivery.
- Insurance purposes.
- Contact and communication.
- Audit and record-keeping purposes.
Information We May Collect
Business information may include:
- Company name.
- Company registration number.
- Certificate of incorporation.
- VAT number.
- VAT registration information.
- Tax Clearance Certificate.
- Date on which the business commenced.
- Physical address.
- Postal address.
- Banking details.
- Bank confirmation letter.
- Designated contact person.
- Updated GIT Cover.
- Bond Removal Code.
Suppliers and Service Providers
Purposes
Information may be processed for:
- Purchase orders.
- Purchasing services.
- Contact and communication.
- Audit and record-keeping purposes.
Information We May Collect
Business information may include:
- Business name.
- Trading name.
- CIPC registration number.
- VAT number.
- Contact person’s name.
- Contact person’s surname.
- Contact numbers.
- Email addresses.
- Physical address.
- Postal address.
- Banking details.
7. Collection of Information by Cookies
We want to make you aware that information and data may be automatically collected through the standard operation of internet servers and through the use of cookies.
Cookies are small text files that a website can use to recognise repeat users, facilitate ongoing access to and use of the website, track usage behaviour, and compile aggregate data that can be used to improve website content and targeted advertising.
Cookies are not programs that enter your computer system and damage files.
Generally, cookies work by assigning a unique number to a user that has no meaning outside the website that assigned it.
If you do not want information to be collected using cookies, most browsers provide a procedure that allows you to accept or reject cookies.
Please note, however, that cookies may be necessary in order for us to provide certain features available through our website, including customised delivery of information.
8. How We Share Your Information
Third-Party Service Providers
Where appropriate and lawful, information may be shared with third parties such as:
- Auditors and accountants.
- Insurance companies.
- Tracker and recovery teams.
- Attorneys.
- Debt collectors acting in a business capacity.
- Credit bureaus.
- Regulatory bodies.
- Law enforcement agencies.
- Government agencies.
Legal Disclosures
We may need to share your information where we believe disclosure is required by law or legal process, or where it is necessary to protect the rights and safety of you, us, or others.
Where appropriate, we may attempt to notify affected individuals about legal demands for their information unless notification is prohibited by law, court order, or circumstances involving an emergency.
We may dispute requests that we believe are overly broad, vague, or lack proper authority. However, we do not undertake to challenge every request.
9. Your Rights and Obligations
Data Retention
We retain most personal information for as long as we have a lawful purpose for keeping it, need it to provide services, or are legally obligated to retain it.
We may also retain information where you have agreed or consented to us doing so.
Certain information may be retained after our business relationship with you has ended where reasonably necessary to:
- Comply with legal obligations.
- Meet regulatory requirements.
- Resolve disputes.
- Maintain security.
- Prevent fraud and abuse.
- Enforce agreements.
- Fulfil requests relating to objections to the processing of personal information.
Your Rights
You have rights relating to your personal information and choices concerning how your information is collected, used, and shared.
Depending on the circumstances and applicable law, these may include the following:
Request Access to Your Information
You may ask us what personal information we hold about you and request a copy of that information.
Requests should be submitted to:
Certain exemptions may apply, which means that we may not always be able to provide all the information we process.
Where a copy can be provided, a fee may apply. Any applicable fee will be communicated to you when your request is processed.
Change or Correct Information
You have the right to ask us to correct personal information that you believe is inaccurate.
You may also ask us to complete information that you believe is incomplete.
Delete Information
You may request that we delete or remove personal information in certain circumstances.
Object to Processing
You may object to processing where we rely on your legitimate interests, the public interest, or our legitimate interests or those of a third party, and circumstances relating to your particular situation give you grounds to object.
You also have the right to object where your personal information is being processed for direct marketing purposes.
Where processing is based on your consent, you may withdraw that consent.
Withdrawal of consent does not affect the lawfulness of processing that took place before your consent was withdrawn.
Request Restriction of Processing
You may ask us to suspend or restrict the processing of your personal information in certain circumstances.
For example, you may request restriction while the accuracy of information or the reason for processing it is being established.
10. Changes to Our Privacy Notice
Changes to this Privacy Notice may apply to your continued use of our services.
We may amend this Privacy Notice from time to time, including where changes are required as a result of legislation.
Where material changes are made, we may provide notice through our services or through other appropriate means, giving you an opportunity to review the changes before they become effective.
Your continued use of our services after changes to this Privacy Notice have been published means that the collection, use, and sharing of your personal information will be subject to the updated Privacy Notice.
11. Other Important Information
Security
We have implemented appropriate security measures designed to prevent personal information from being accidentally lost, used, accessed in an unauthorised manner, altered, or disclosed.
Access to personal information is limited on a business need-to-know basis and is subject to appropriate confidentiality obligations.
Transborder Information Transfers
We do not share information belonging to our clients, suppliers, service providers, or other third parties across borders.
12. Contact Information
Should you have a query regarding this Privacy Notice or the processing of your personal information, please contact:
Email: payroll@invs.co.za
Information Officer
Name: Matthew Erich Hittinger
Email: matthew@littletreedaycare.co.za
Deputy Information Officer
Name: Christine Shannon Hittinger
Email: payroll@invs.co.za
Deputy Information Officer
Name: Gavin Walker
Email: hr@invs.co.za
Information Regulator
You have the right to lodge a complaint with the South African Information Regulator.
Address:
Woodmead North Office Park
54 Maxwell Drive
Woodmead
Johannesburg
POPIA Complaints: POPIAComplaints@inforegulator.org.za
13. Document Control
Creation Date: 28 October 2025
Division Name: Invictus Security Services Pty Ltd
Author Name: Christine Hittinger
Author Position: Deputy Information Officer
Last Updated: 28 October 2025
Version: Version 1
Approval: Latest version approved by the Board of Directors of Invictus Security Services Pty Ltd
Company Details
Invictus Security Services Pty Ltd
PSIRA No.: 3141759
Telephone: +27 64 529 1734
Email: admin@invs.co.za
Website: www.invictussecurityservices.co.za
Address: 90 Jean Avenue, Dooringkloof, Centurion, 0157
Director: Matthew Hittinger