Privacy Policy

1. Introduction and Purpose

This manual provides a reference to the records held by LEMCO EPC (Pty) Ltd and the procedures for requesting access to such records under the Promotion of Access to Information Act (PAIA), Act 2 of 2000.

2. Company Information

3. Description of Company Activities

LEMCO EPC (Pty) Ltd specialises in structural steel design, fabrication, and construction services across Southern Africa and Sub-Saharan Africa, offering turnkey solutions across the agricultural, industrial, commercial, renewable energy, and mining sectors.

4. Applicable Legislation

LEMCO complies with, but is not limited to, the following Acts:

• Companies Act 71 of 2008
• Basic Conditions of Employment Act 75 of 1997
• Labour Relations Act 66 of 1995
• Occupational Health and Safety Act 85 of 1993
• Income Tax Act 58 of 1962
• Protection of Personal Information Act 4 of 2013 (POPIA)
• Electronic Communications and Transactions Act 25 of 2002 (ECT Act)
• Promotion of Access to Information Act 2 of 2000 (PAIA)

5. Categories of Records Held

• Corporate Records — company registration, resolutions, certificates
• Financial Records — tax returns, budgets, audit reports, invoices
• HR Records — employment contracts, leave, payroll, benefits
• Customer Records — enquiries, quotes, contracts, project correspondence
• Website Records — lead enquiries captured via lemco.co.za and campaigns.lemco.co.za
• Supplier and Contractor Records
• Health and Safety Records
• Policies and Procedures

6. Procedure to Request Access

Requests must be submitted in writing using Form C from the South African Human Rights Commission (SAHRC) website (www.sahrc.org.za). The request must include:

• Full name and ID number of the requester
• Description of the records requested
• Preferred method of access (email, copy, or viewing)

Submit requests to:

7. Grounds for Refusal of Access

Access may be refused if the records:

• Include confidential information of third parties
• Affect the safety of individuals or property
• Breach legal privilege or commercial confidentiality
• Are protected under another Act

8. Prescribed Fees

• Request fee (non-personal requests): R140.00
• Reproduction fee: R2.00 per A4 page
• Other reproduction or access preparation costs may apply
• No fee is charged for personal information requests by the data subject

9. Availability of the Manual

This manual is available:

• On the company website at https://lemco.co.za/privacy-policy
• In hard copy at the head office upon request

10. Information Regulator Contact

1. Introduction

LEMCO EPC (Pty) Ltd is committed to protecting the personal information of all individuals with whom we interact — including website visitors, clients, employees, suppliers, and contractors. This policy outlines how we collect, use, store, and protect personal information in accordance with the Protection of Personal Information Act (POPIA), Act 4 of 2013.

2. Definitions and Key Terms

• Personal Information: Any identifiable information relating to a natural or juristic person, including name, email address, phone number, location data, and company details
• Data Subject: The individual whose personal information is collected
• Responsible Party: LEMCO EPC (Pty) Ltd — the entity that determines the purpose and means of processing personal information
• Operator: A third party that processes personal information on behalf of LEMCO
• Processing: Any activity performed on personal information, including collection, storage, use, transmission, or deletion

3. Personal Information Collected via the Website

When you submit an enquiry via lemco.co.za or campaigns.lemco.co.za, we collect the following personal information:

• Full name
• Email address
• Phone number
• Company name (if provided)
• Project location — including GPS coordinates captured via Google Maps
• Province or region
• Project specifications (structure dimensions, delivery preference)

We also collect non-personal technical data through analytics tools, including:

• Browser type and device information
• Pages visited and time spent on the website
• Referring website or advertisement
• Geographic region (country/province level — not precise location unless submitted via form)

4. Purpose of Collection

Personal information collected via the website is used for the following purposes:

• To respond to your project enquiry and prepare a quotation
• To route your enquiry to the appropriate internal team (Quantity Surveying, Design, or Sales)
• To send you an automated acknowledgement of receipt
• To store your enquiry in our internal lead management system for follow-up
• To analyse website performance and improve our marketing campaigns
• To comply with legal and regulatory obligations

5. Collection Methods

Personal information is collected through the following methods:

• Website enquiry and contact forms on lemco.co.za
• Campaign landing page forms on campaigns.lemco.co.za
• Google Analytics 4 (GA4) — anonymous usage data
• Google Maps Platform — project location data submitted via the form pin drop feature
• Email correspondence

6. Third-Party Operators and Data Processors

LEMCO uses the following third-party services to process personal information on our behalf. All operators are required to maintain appropriate data protection standards:

7. Cross-Border Transfers

Some of our operators are based outside South Africa, including the United States. Where personal information is transferred across borders, LEMCO ensures that the receiving party maintains data protection standards equivalent to those required by POPIA.

8. Retention and Storage

Personal information is retained for the following periods:

• Website enquiry data: 5 years from the date of submission, or until the project is completed and all obligations are fulfilled
• Quote and contract records: 7 years in accordance with tax and financial record-keeping requirements
• Analytics data: As per Google Analytics retention settings — default 14 months
• Email correspondence: 5 years

After the applicable retention period, personal information is securely deleted or anonymised.

9. Security Safeguards

LEMCO implements the following technical and organisational measures to protect personal information:

• SSL/TLS encryption on all website traffic (HTTPS)
• Secure server hosting via Vercel with enterprise-grade infrastructure
• Access controls — only authorised LEMCO staff can access lead data
• Microsoft 365 enterprise security for SharePoint and email
• Confidentiality agreements with staff handling personal data
• Regular security reviews of third-party operators

10. Data Subject Rights

In accordance with POPIA, you have the right to:

• Request access to the personal information we hold about you
• Request correction of inaccurate or incomplete information
• Request deletion of your personal information, subject to legal retention requirements
• Object to the processing of your personal information
• Withdraw consent at any time, where processing is based on consent
• Lodge a complaint with the Information Regulator if you believe your rights have been violated

To exercise any of these rights, contact our Information Officer: nelius.stephan@lemco.co.za

11. Breach Notification Policy

In the event of a personal information breach, LEMCO will:

• Notify affected data subjects as soon as reasonably possible
• Notify the Information Regulator as required by POPIA
• Document the breach and the remedial steps taken

12. Consent and Opt-Out

By submitting an enquiry form on our website, you consent to the collection and processing of your personal information as described in this policy. You may withdraw consent or opt out of communications at any time by contacting us at info@lemco.co.za.

13. Cookies

Our website uses cookies and similar tracking technologies. Please refer to our Cookie Policy (available at lemco.co.za/cookie-policy) for full details of the cookies we use and how to manage your preferences.

14. Staff POPIA Awareness and Training

LEMCO provides regular training to all staff who handle personal information to ensure ongoing compliance with POPIA requirements.

15. Policy Updates

This policy is reviewed annually or whenever there is a material change to our data processing activities. The current version is always available on our website. Last updated: July 2026.