Privacy Policy & POPIA Compliance

Last Updated: December 2025

1. Introduction

At Harrino Holdings (Pty) Ltd (and our subsidiaries Noja, Spinnovations, and SLT Odyssey), we are committed to operating with transparency and integrity—two of our core “ARTIST” values. We respect your privacy and take the protection of your personal information seriously.

This Privacy Policy explains how we collect, use, disclose, and protect your personal information in accordance with the Protection of Personal Information Act (POPIA) Act 4 of 2013.

2. Information We Collect

We collect personal information directly from you when you use our website, specifically when you complete our “Contact Us” forms or our “Request a Quote” pop-up.

The types of personal information we may collect include:

• Identity Data: Your full name.
• Contact Data: Your email address and phone number.
• Service Interests: Information regarding the specific services you are interested in (e.g., Financial Advice, Travel Incentives, Fleet Services).
• Enquiry Details: Any specific information you provide in the “Message” or “Project Details” fields regarding your requirements.

3. Purpose of Collection

We collect and process your personal information for the following specific purposes:

• To Provide Services: To generate accurate quotes for the services you requested (e.g., calculating insurance premiums via Noja or planning travel itineraries via SLT Odyssey).
• Communication: To contact you regarding your enquiry and provide customer support.
• Internal Record Keeping: To maintain a database of client enquiries and manage our relationship with you.
• Legal Compliance: To comply with applicable laws, including financial regulations (FICA), where applicable to our financial services division.

4. How We Share Your Information

Harrino Holdings is a diversified group. We may share your information internally within our subsidiaries (Noja (Pty) Ltd, Spinnovations (Pty) Ltd, and SLT Odyssey (Pty) Ltd) solely for the purpose of fulfilling the service you requested.

• Third-Party Providers: We may share necessary details with trusted third-party service providers (such as insurance underwriters or travel accommodation partners) strictly to deliver the products or services you have requested.
• No Sale of Data: We will never sell your personal information to third parties for marketing purposes.

5. Security of Your Information

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the information we collect online.

6. Your Rights Under POPIA

As a data subject, you have the right to:

• Access: Request a copy of the personal information we hold about you.
• Correction: Request us to update or correct any out-of-date or incorrect personal information.
• Deletion: Request that we delete your personal information (subject to any legal obligations we may have to retain certain records).
• Objection: Object to the processing of your personal information on reasonable grounds.

To exercise any of these rights, please contact our Information Officer using the details below.

7. Contact Us

If you have any questions about this Privacy Policy or how we handle your personal information, please contact us:

Harrino Holdings Head Office

Phone: +27 878 087 826

Physical Address: 30177A Petra Street, Hillside, Bloemfontein, 9301

Email: info@harrinoholdings.co.za