1. Who We Are

1.1 Pathway Partners SA (Pty) Ltd is a company registered in the Republic of South Africa (registration number 2025/710598/07), with its registered address at 21 Ndongeni Drive, Amanzimtoti, 4126, KwaZulu-Natal, South Africa.

1.2 We are the responsible party for the personal information described in this policy.

1.3 Our Information Officer is Francesca De Gennaro, contactable at info@pathwaypartners.co.za.

2. Information We Collect

We collect the following categories of personal information:

Name, email address, phone number and postal address
To respond to enquiries and administer your booking.
Lawful basis: contract / consent

Passport number, nationality and date of birth
Required by the lodge and reserve for guest registration and for emergency purposes.
Lawful basis: contract / legal obligation

Emergency contact details
To contact your nominated person in the event of a medical emergency.
Lawful basis: explicit consent, collected via the Guest Registration Form

Medical conditions, allergies, medication and dietary requirements
To keep you safe in a remote location, cater appropriately, and inform emergency responders.
Lawful basis: explicit consent — Special Personal Information under Sections 26 and 27 of POPIA

Travel insurance details
To facilitate medical evacuation or emergency assistance.
Lawful basis: explicit consent, collected via the Guest Registration Form

Payment information
To process your booking payment.
Lawful basis: contract

Photographs and video taken during retreats
Marketing, with your prior consent.
Lawful basis: consent

Website usage data and cookies
To operate and improve our website.
Lawful basis: consent / legitimate interest

2.1 We do not store your card details. Payments are processed by our third-party payment provider, which handles card data directly.

3. How We Collect It

3.1 Directly from you — through enquiry forms, the booking process, the Guest Registration and Indemnity Form, and correspondence with us.

3.2 Automatically — through cookies and analytics when you use our website.

3.3 From third parties — occasionally from a travel agent, a partner artist, or a person booking on your behalf.

4. Health and Special Personal Information

Health information receives additional protection under POPIA.

4.1 Our retreats take place in a remote wilderness location where medical facilities are not immediately available. We therefore ask you to disclose medical conditions, allergies, medication, and mobility limitations.

4.2 We process this information only with your explicit consent, given when you complete the Guest Registration & Indemnity Form.

4.3 In accordance with statutory regulations relating to the processing of health information, we maintain strict technical and organisational measures to ensure that your medical and insurance records are structurally segregated from general booking files, restricted to authorised safety personnel, and securely deleted within the timeframe set out in Clause 9.

4.4 We use it solely to keep you safe, to cater appropriately, and to respond to a medical emergency. We share only what is necessary, and only with the lodge, medical personnel, or emergency services.

4.5 You may withdraw consent at any time, but we may then be unable to accept your booking where we cannot reasonably assure your safety.

5. Why We Process Your Information

• To respond to your enquiry and provide information about our retreats.

• To administer your booking, process payment, and issue confirmation.

• To arrange accommodation, transfers, game drives and activities with our suppliers.

• To keep you safe during your retreat and respond to any emergency.

• To cater for your dietary requirements.

• To send you pre-departure information and post-retreat follow-up.

• To send you marketing communications, where you have consented.

• To comply with our legal, accounting and tax obligations.

• To improve our website and understand how it is used.

6. Who We Share It With

We share your personal information only where necessary, and only with:

• Zebra Hills Lodge and Manyoni Private Game Reserve — for accommodation, guest registration, catering and safety.

• Activity and transfer providers — including the elephant experience and airport transfers.

• The artist hosting your retreat — limited to your name and any information relevant to the workshops.

• Our payment provider — to process your payment.

• Medical personnel and emergency services — where necessary to protect your life or health.

• Our accountants and professional advisers — where required.

• Service providers supporting our business, such as email, website and booking platforms.

6.1 We do not sell your personal information, and we do not share it with third parties for their own marketing purposes.

7. Cross-Border Transfers

7.1 Some of our service providers — including website hosting, email, and booking platforms — store information on servers outside South Africa.

7.2 Where we transfer personal information outside South Africa, we do so only where permitted by section 72 of POPIA, and where the recipient is subject to laws or binding agreements providing an adequate level of protection.

8. Security

8.1 We take reasonable technical and organisational measures to protect your personal information against loss, unauthorised access, and misuse.

8.2 Access to guest information is limited to those who need it to deliver your retreat.

8.3 If a security compromise occurs affecting your personal information, we will notify you and the Information Regulator as required by section 22 of POPIA.

9. How Long We Keep It

9.1 Enquiries that do not result in a booking: 12 months.

9.2 Booking and financial records: 5 years, or as required by South African tax and company law.

9.3 Signed indemnity forms: 3 years from the date of the conclusion of the retreat, in accordance with the statutory prescription periods for personal injury claims under the Prescription Act 68 of 1969.

9.4 Medical and dietary information: deleted within 1 month after your retreat ends, unless needed for an ongoing operational or legal matter.

9.5 Marketing contact details: until you unsubscribe or ask us to delete them.

10. Your Rights

Under POPIA you have the right to:

• Ask what personal information we hold about you, and request a copy.

• Ask us to correct or delete information that is inaccurate, irrelevant, excessive, or out of date.

• Object to our processing of your information in certain circumstances.

• Withdraw consent where processing is based on consent.

• Unsubscribe from marketing communications at any time.

• Complain to the Information Regulator.

10.1 To exercise any of these rights, contact our Information Officer at info@pathwaypartners.co.za. We may need to verify your identity before responding.

10.2 You may lodge a complaint with the Information Regulator of South Africa at enquiries@inforegulator.org.za, or via www.inforegulator.org.za.

11. Cookies

11.1 Our website uses cookies to operate correctly, remember your preferences, and understand how the site is used.

11.2 You can control cookies through your browser settings. Disabling some cookies may affect how the website works.

12. Marketing

12.1 We send marketing emails only where you have consented, or where you are an existing guest and the communication relates to similar retreats.

12.2 Every marketing email includes an unsubscribe link. You may also email us to opt out at any time.

13. Children

13.1 We do not knowingly collect personal information from children under 18 except where a parent or legal guardian has provided it and given consent as part of a booking.

14. Changes to This Policy

14.1 We may update this policy from time to time. The current version is always available on our website, and the date of the most recent update appears at the top.

15. Contact Us

Pathway Partners SA (Pty) Ltd
Information Officer: Francesca De Gennaro
Registration number: 2025/710598/07
21 Ndongeni Drive, Amanzimtoti, 4126, KwaZulu-Natal, South Africa
info@pathwaypartners.co.za
+27 76 123 3493