Privacy Policy


At Pass Holder (Pty) Ltd. (PASS Holder) we are committed to protecting the privacy and security of the personal information that you share with us.

This personal information privacy policy (“Policy”) governs the processing of all personal information received by PASS Holder (“we”/“us”/“our”), irrespective of whether such information is obtained through electronic or verbal communication, via our websites or as a result of engagement in respect of any of our products or services with PASS Holder at its offices or partner locations.

Personal Information which we collect from you will be processed by PASS Holder, which consists of the legal entities listed in Annexure A and may be shared with our trade partners for purposes of facilitating your booking and the services we provide to you.

As we place a high premium on the privacy of every person, we recommend you read this Policy thoroughly so that you have a clear understanding as to

(i)       the type of Personal Information we may process,

(ii)      how your Personal Information may be collected and processed when engaging with PASS Holder,

(iii)      who is responsible for the processing, management and safeguarding of collected and /or processed Personal Information,

(iv)     the grounds on which we may share the Personal Information with 3rd Parties, and

(v)      how you can access, amend and/or delete Personal Information which we have collected from you.

By engaging with PASS Holder via electronic mail, continuing to use our websites, clicking on the “I Agree” button provided on our websites, or accessing and using our services, you acknowledge that you have read this Policy and consent to the processing of your Personal Information as provided for herein.

In the event that you do not wish to consent to the processing of your Personal Information, or no longer want us to continue processing your Personal Information in accordance with this Policy, you are kindly requested to indicate same by sending us an email to our PASS Holder Group Information Officer at


Personal Information may be collected either through or by electronic means, which includes, without limitation, the use of our websites (i.e. including all other websites and/or landing pages), electronic mail, text, voice, sound or image messages, or through non-electronic means which includes, without limitation, the capturing of Personal Information on hard copy documents.

When using our websites your Personal Information may be collected either actively where you or your appointed agent provide us with certain Personal Information or inactively where we collect information from you that you have not actively provided:

  1. a) Active Information Collection:

Active information collection refers to instances where you have directly provided us with Information, such as when you submit an enquiry in respect of a specific product or service, when you subscribe to our newsletter, or complete a questionnaire and provide us with your personal details which may include (without limitation) first name, last name, e-mail address, country of residence.

  1. b) Inactive Information Collection:

Inactive or passive Information collection refers to instances where we collect certain Information which you have not actively (i.e., knowingly) provided, which Information we may obtain through the use of certain technologies such as Cookies, Web Beacons, Embedded Scripts or Mobile Device identifiers when you visit our websites. Information obtained in this regard cannot be linked to you as a person (i.e., non –personally identifiable information) which information may include the type of web browser you use, the operating system you use, the date and time of your visit to our websites, the specific pages you may have visited and the address of the website which you have visited prior to entering our websites. PASS Holder does not link non-personally identifiable information with personally identifiable information.


We process the following information collected by means of electronic submission or physical forms (as may be applicable):

(i) Active Information:

Your name and surname

Your gender,

Your age group

Your physical address

Your e-mail address

Your telephone and mobile number

Your identity and/or passport number

Your company details

Your passport nationality, issue date and expiry date

Your personal opinion, views, interests and preferences


(ii) Inactive Information collection:

the type of web browser you use

the operating system you use

the date and time of your visit to our websites

the specific pages you may have visited

the address of the website

We do not receive or process credit card information and use the recognized and respected Paygate portal to securely receive credit card payments. We do not have access to any credit card information.


Personal Information will only be used in accordance with this Policy or as specifically disclosed to you and/or brought to your attention at the time you provide the Personal Information.

The Personal Information will be processed by us (or third parties approved by us for the purposes of fulfilling your booking), pursuant to and for the following purposes:

verifying your identity

transmitting and receiving correspondence in relation to our services or products, including the preparation of itineraries and submission of quotes

transmitting marketing material as specifically requested by you

processing payments

facilitating delivery of the services or the products

to monitor and analyze your conduct in respect of the Websites and/or services for research and statistical purposes

for compliance and risk purposes

to tailor-make marketing and promotional material which we believe may be of relevance and interest to you

to conduct market and / or academic research to identify potential markets and trends, to develop new products and services and to improve the nature of the products and/or services

We may share your Personal Information with our subsidiaries, associates or third party service providers in order and only to the extent necessary to render supporting and / or ancillary services or products to facilitate our service or product delivery to you, which service providers will be required to comply with/adhere to the same principles (as may be applicable) contained in this policy when processing your Personal Information.

We will not sell, transfer, share, or otherwise permit access to your Personal Information with any third parties other than as described in this Policy.

We further reserve the right to use or disclose your Personal Information to comply with applicable laws, regulations, legal processes, and law enforcement inquiries, as required by litigation, to take precautions against liability, and protect the security and integrity of our websites and the safety of its users.


Should you request to subscribe to our Newsletter and/or Blog Posts, we will, from time to time, send you promotional e-mails about PASS Holder special offers or other information using the e-mail address which you have provided.

We do not contact you via e-mail, short message service (sms)/text or similar electronic solutions for marketing purposes unless you have provided us with their consent to do so. Such engagement shall at all times be limited, be relevant and of interest to you as our PASS-Holder.

Please note that you can unsubscribe from any of these lists at any time should you wish to by selecting the “unsubscribe” button at the bottom of the newsletter or blog post, or by e-mailing us your request at or selecting the unsubscribe link at the bottom of every e-mail you receive from us.


You will be given reasonable access to your Personal Information to correct errors or to delete any information which you may have provided. If you wish to correct or delete any of your Personal Information, please contact us by e-mail at

To respond to your request or inquiry, we may require information to allow us to verify that you are the person authorized to view the Personal Information you are requesting access to as contemplated in this Policy. We reserve the right to, at our discretion, refuse to allow you access to certain information which, in our view, if provided to you, will compromise another person’s privacy or will violate any applicable law, in respect of which we are obliged to observe and adhere to pursuant to processing Personal Information.

Subject to legal and other permissible considerations we will make every effort to honour your request within 30 business days or we will inform you if we require further information to fulfil the request.


The transmission of information via the internet is not completely secure and we cannot guarantee the security of data transmitted to our site; any transmission of Personal Information will be solely at your own risk.

We will take steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. We have taken reasonable technical and organizational measures to secure the integrity and confidentiality of the Personal Information in our possession, in order to guard against the loss of, damage to, or unauthorized destruction of, Personal Information and unlawful access to, or processing of, Personal Information.

We restrict access to your Personal Information to our employees and contracted third-party service providers who have a legitimate operational reason for having access to such Personal Information. We endeavour to maintain physical, electronic and procedural safeguards so as to protect your Personal Information from any unauthorized access.


PASS Holder ’s head office is based in and operates from South Africa, and, regardless of where you use or access our websites or services, your information may be transferred to and/or maintained on servers located in South Africa, Africa, the UK, the EU or elsewhere in the world. Please note that any information we obtain about you will be stored in accordance with South African and UK privacy laws, regulations and standards, which may not be equivalent to the laws in your country of residence. By using our services, you consent to the transfer, storage and processing of information to and in a country other than the country you reside in.


Please note that we do not wish to collect and/or process any Personal Information from you that you do not want to be so collected and/or processed.

Should you at any point in time decide that you do not

(a) wish us to continue to process your Personal Information or

(b) do not wish to receive any further information from us regarding our products and services, you are welcome to, in the event of

(a) above, email us at with your request whereafter, upon receipt of your written request, we will endeavour to cease any processing of your Personal Information within 30 business days or, in the event of

(b) above, by clicking the “unsubscribe” button at the bottom of our newsletters and Blog Post RSS notifications, whereafter we will cease to send you any of our newsletters or blog posts. Your request will take no longer than 10 business days to process. During that time, you may continue to receive marketing e-mails.


On our marketing material or websites, you may see references or links to websites that are owned and/or managed by third parties, which third parties are unrelated to PASS Holder (“Third Party Websites”), which Third Party Websites are specifically excluded from this Policy.

These Third-Party Websites have separate and independent privacy policies applicable to their respective websites, services and or products and may follow different practices in the processing and securing of your Personal Information.

You are strongly advised to read the privacy policy of each Third-Party Website you engage with before providing your Personal Information as we cannot accept any liability should the Third-Party Website process your Personal Information in any unlawful manner.

We therefore make no warranties or representations and bear no responsibility or liability whatsoever regarding any services and /or products offered, promoted and/or advertised on Third Party Websites and/or services and/or products rendered by any third party which may have been accessed or used through or by means of our websites and/or their associated services.


The laws of South Africa will govern any dispute or claim arising out of this Policy.


Kindly take note that we reserve the right to change this Policy at any time and in our sole discretion. In the event that Policy is changed the new policy will be made available on our websites.


We welcome comments about this Policy. If you have any questions about this Policy or any part of our service, you may contact us by e-mailing


Should you believe that we have utilized your Personal Information contrary to applicable data privacy laws, you undertake to first attempt to resolve any concerns with us. If you are not satisfied with such process, you have the right to lodge a complaint with the relevant Information Regulator.


“PASS Holder” refers to the following entities:

Pass Holder

Winelands PASS