Emnotweni Casino Privacy Policy

Information on how personal data is collected, used and protected at Emnotweni Casino.

Emnotweni Casino processes personal information of guests, visitors and users of services in a manner intended to protect privacy and comply with applicable law. This Privacy Policy sets out how personal information is collected, used, disclosed, stored and safeguarded in terms of the Protection of Personal Information Act, 2013 (POPIA) and other laws of the Republic of South Africa.

This policy applies to all personal information collected by Emnotweni Casino through physical premises, Wi-Fi services, the Emnotweni Rewards Card programme, hotel accommodation, restaurant and bar services, conference facilities, and other services provided at Government Boulevard, Riverside Park Ext 1, Nelspruit, Mpumalanga 1200, South Africa.

Emnotweni Casino operates as part of the Tsogo Sun group. Where applicable, personal information may also be processed in accordance with the Tsogo Sun group privacy framework, available at https://www.tsogosun.com/privacy-policy/.

1. Information Collected

The following categories of personal information may be collected and processed:

1.1 Identification Information

Full name
Date of birth
Identity or passport number
Nationality
Residential address
Photographic identification

Such information may be collected for account registration, age verification, regulatory compliance or access to restricted areas.

1.2 Contact Information

Telephone numbers
Email addresses
Postal addresses

This information may be used for communication, service delivery, booking confirmations and, where consent has been provided or law permits, marketing communications.

1.3 Financial and Transaction Information

Payment card details
Banking information
Transaction history
Gaming activity records
Spending patterns

This information may be collected in connection with casino gaming, hotel bookings, restaurant and bar purchases and participation in the Emnotweni Rewards Card programme.

1.4 Device and Usage Information

Device identifiers
IP addresses
Connection times
Bandwidth usage
Browsing activity

Such information may be collected when the guest Wi-Fi service is used or when digital platforms associated with Emnotweni Casino are accessed.

1.5 Security and Surveillance Information

CCTV footage
Access logs
Security incident records

This information is collected on the premises for safety and security, protection of property and compliance with regulatory obligations.

1.6 Loyalty Programme Information

Membership details
Tier status
Points balance
Redemption history
Stated preferences
Visit frequency

This information is collected and processed through the Emnotweni Rewards Card programme.

2. Use of Personal Information

Personal information may be processed for the following purposes:

2.1 Service Delivery

Provision of casino gaming services
Hotel accommodation
Restaurant and bar services
Conference and event facilities
Wi-Fi access
Other amenities available at the property

2.2 Account and Programme Management

Registration, maintenance and administration of Emnotweni Rewards Card accounts
Allocation of tier levels and benefits
Processing of redemptions
Management of participation in the loyalty programme

2.3 Legal and Regulatory Compliance

Verification of age and identity
Prevention of underage gambling
Compliance with anti-money laundering obligations
Responses to lawful requests from authorities
Fulfilment of reporting and record-keeping requirements under South African gambling and financial legislation

2.4 Security and Fraud Prevention

Monitoring of premises via CCTV and access systems
Detection and prevention of fraudulent or suspicious activity
Investigation of security incidents
Enforcement of house rules
Protection of the safety of guests and staff

2.5 Communication and Marketing

Sending of booking confirmations and service-related notices
Provision of updates on services and facilities
Distribution of promotional offers, event invitations and loyalty programme communications where consent has been provided or law permits

Users may opt out of direct marketing communications at any time, subject to technical and administrative processing times.

2.6 Business Operations and Analysis

Analysis of usage patterns and service utilisation
Improvement of service quality
Conduct of internal audits
Customer relationship management
Business planning and reporting within the Tsogo Sun group

3. Disclosure of Personal Information

Personal information may be shared with the following categories of recipients, in each case only to the extent necessary for the relevant purpose and subject to appropriate safeguards:

3.1 Tsogo Sun Group Entities

Personal information may be shared with other companies, casinos, hotels and properties within the Tsogo Sun group for centralised customer profiling, loyalty programme administration, group-wide marketing, compliance, risk management and operational purposes.

3.2 Service Providers and Contractors

Third-party service providers may be engaged to perform functions on behalf of Emnotweni Casino, including:

Payment processing
Information technology and network support
Security services
Cleaning and maintenance
Catering
Marketing and communication services

Such providers are required by contract to protect personal information and to process it only in accordance with documented instructions and for specified purposes.

3.3 Regulatory and Law Enforcement Authorities

Personal information may be disclosed to:

Mpumalanga Economic Regulator
South African Police Service
Financial Intelligence Centre
Other competent regulatory or governmental authorities

Such disclosure occurs where required by law, regulation or a lawful request, or where necessary to comply with legal obligations.

3.4 Legal and Professional Advisors

Information may be shared with lawyers, auditors, accountants and other professional advisors in connection with legal proceedings, dispute resolution, compliance audits, investigations or business transactions.

3.5 Other Third Parties

With the consent of the data subject, or where permitted by law, information may be shared with event partners, sponsors or other third parties in connection with specific services, events, promotions or collaborations.

4. Data Retention

Personal information is retained for as long as necessary to achieve the purposes for which it was collected and for additional periods required or permitted by law. Retention is also applied where needed to resolve disputes, enforce agreements, or demonstrate compliance.

Gaming and transaction records are retained in accordance with South African gambling legislation and financial record-keeping requirements.
CCTV footage is retained for a limited period and may be kept for longer where required for investigations, disciplinary processes, insurance matters or legal proceedings.
Loyalty programme data is retained for the duration of programme membership and for a reasonable period thereafter to manage programme benefits, handle queries and comply with tax and audit obligations.

When personal information is no longer required for permitted purposes, it is securely deleted, destroyed or anonymised in line with documented data retention and destruction procedures, subject to legal and regulatory requirements.

5. Data Security

Appropriate technical and organisational measures are applied to protect personal information against unauthorised access, loss, destruction, alteration or disclosure. These measures may include:

Access controls and role-based permissions
Encryption and secure communication protocols where appropriate
Secure storage systems
Staff training and confidentiality obligations
Regular security assessments and monitoring

No method of transmission over a network or method of electronic or physical storage can be guaranteed as fully secure. Users are responsible for maintaining the confidentiality of any passwords, PINs or access credentials associated with their accounts and for securing their own devices.

Use of the guest Wi-Fi service is at the user’s own risk. It is recommended that sensitive personal or financial information is not transmitted over public Wi-Fi networks.

6. Rights Under POPIA

Under the Protection of Personal Information Act, data subjects have specific rights in relation to their personal information, subject to applicable grounds of refusal and legal requirements.

6.1 Right of Access

A data subject may request confirmation of whether personal information is held and may request access to such information, subject to the procedures and fees permitted under applicable legislation.

6.2 Right to Correction

A data subject may request the correction or updating of inaccurate, incomplete or outdated personal information.

6.3 Right to Deletion

A data subject may request deletion of personal information where:

It is no longer necessary for the purposes for which it was collected or processed
Consent has been withdrawn and there is no other legal ground for processing
Processing is unlawful

This right is subject to legal and regulatory obligations to retain certain records for defined periods.

6.4 Right to Object

A data subject may object, on reasonable grounds, to the processing of personal information, including processing for direct marketing purposes or processing based on certain legitimate interests, where applicable.

6.5 Right to Lodge a Complaint

A data subject who believes that privacy rights have been infringed may lodge a complaint with the Information Regulator of South Africa in accordance with the procedures prescribed by the Regulator.

To exercise any of the above rights, a request may be submitted using the contact details in section 8. A response will be provided within a reasonable time and in accordance with applicable law. Proof of identity may be required before a request is processed.

7. Cookies and Online Tracking

When the Emnotweni Casino website is accessed or the Wi-Fi service is used, cookies, web beacons and similar tracking technologies may be employed to collect information about the device and usage patterns. This may include:

Browser type and version
Pages viewed and time spent
Referring websites
Interaction with content and features

This information is used for purposes such as improving service performance, enhancing usability, analysing usage trends and delivering content that is considered relevant.

Cookie preferences can be managed through browser settings. Disabling certain cookies may affect the availability or functionality of some website features or online services.

8. Contact Information

Questions, requests or complaints regarding this Privacy Policy or the processing of personal information by Emnotweni Casino may be directed to the following contact details:

Emnotweni Casino
Government Boulevard, Riverside Park Ext 1
Nelspruit, Mpumalanga 1200
South Africa

Telephone: +27 13 757 4300
Fax: +27 13 753 2779

Email: Correspondence may be directed to the corporate office using the tsogosun.com domain.

For group-level privacy queries and additional information on the Tsogo Sun privacy framework, reference can be made to the Tsogo Sun privacy policy at https://www.tsogosun.com/privacy-policy/.

9. Changes to This Policy

This Privacy Policy may be updated from time to time to reflect changes in legal requirements, industry practices or operational needs. Updated versions will be published on the official website of Emnotweni Casino or the Tsogo Sun group website. Continued use of services after publication of an updated policy will be treated as acknowledgment of the applicable version.

10. Governing Law

This Privacy Policy and any processing of personal information by Emnotweni Casino are governed by the laws of the Republic of South Africa. Any dispute arising from or in connection with this policy, its interpretation or its application is subject to the exclusive jurisdiction of the courts of the Republic of South Africa.