Legal

    Privacy Policy

    Effective 23 October 2026 • How we collect, use, and protect your personal information.

    At Blokstay (Pty) Ltd (registration number: 2023/882769/07), trading as Fluent ("Fluent", "we", "us" or "our"), we are committed to protecting your personal information when you use our website, booking platform, serviced-apartment accommodation, guest communications, or related services (collectively, the "Services”), or otherwise provide personal information to us. This Privacy Policy explains how we collect, use, store, share and protect your personal information and how you may exercise your privacy rights (“Privacy Policy”).

    Fluent is a private company duly registered and operating in accordance with the laws of the Republic of South Africa.

    Please ensure that you read all the provisions below, and our policies and guidelines which may apply from time to time, to understand all of your, and our, rights and duties.

    1. Important Information and Who We Are

    Purpose of this Privacy Policy

    This Privacy Policy explains how we collect and process your personal information through your engagement with us. It is intended to support compliance with the Protection of Personal Information Act 4 of 2013 (“POPIA”), as amended, and other applicable data-protection laws.

    It is important that you read this Privacy Policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are fully aware of how and why we are using your personal information. This Privacy Policy supplements the other notices and is not intended to override them.

    Our Services are intended for persons aged 18 or older. Where a minor stays with a booking guest or is included in a registration card, we may process the minor's personal information only as necessary to provide the accommodation, comply with applicable law, protect safety, or where otherwise permitted by law. A parent or legal guardian must provide any personal information relating to a minor.

    We may process special personal information only where necessary and permitted by law, including identity-verification information collected through digital registration cards and limited health information voluntarily supplied to support a refund, cancellation or similar request. We will limit such information to what is relevant to the request, restrict access to authorised personnel, and process it only for a lawful purpose with appropriate safeguards.

    Closed-circuit television and other building-security systems may be operated by a Body Corporate or security provider. Where Fluent does not determine the purpose and means of that processing, the relevant Body Corporate's or security provider's privacy notice will apply. Any use of facial-recognition or other biometric security systems will be subject to confirmation of the relevant roles, lawful basis, safeguards and applicable notice requirements.

    Responsible Party and Operator

    Blokstay (Pty) Ltd, trading as Fluent, is the “Responsible Party” for personal information where we determine the purpose and means of processing, including in connection with our direct booking platform, serviced-apartment operations, guest communications and related business activities. In some circumstances, we process personal information as an “Operator” on behalf of a property owner, Body Corporate, online travel agent, corporate client or other Responsible Party; in those circumstances, that Responsible Party's privacy notice may also apply.

    We have appointed an Information Officer responsible for overseeing questions relating to this Privacy Policy. If you have questions about this Privacy Policy or wish to exercise your legal rights, please contact our Information Officer using the details below.

    Our Contact Details

    • Legal entity: Blokstay (Pty) Ltd, trading as Fluent (registration number: 2023/882769/07)
    • Information Officer: Bradley Wilson
    • Email address: legal@fluentliving.com

    You have the right to lodge a complaint with the Information Regulator. We would, however, appreciate the chance to deal with your concerns before you approach the Information Regulator, so please contact us in the first instance.

    Changes to this Privacy Policy

    This Privacy Policy was last updated on 23 October 2026. Previous versions may be available on request.

    It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

    We may update this Privacy Policy from time to time. The updated version will be effective when we publish it on the Platform, and we will take reasonable steps to notify you of material changes where appropriate. We encourage you to review this Privacy Policy periodically.

    Third-Party Links and Booking Channels

    The Platform may include links to third-party platforms, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We do not control these third-party platforms and are not responsible for their privacy statements or terms. When you leave our Platform, or engage with such third parties, we encourage you to read the distinct privacy policy of every third-party you engage with.

    2. What We Collect About You

    Personal information, or personally identifiable information, means any information about an individual, both natural and juristic entities (people and companies), from which that entity can be identified. It does not include information where the identity has been removed (anonymous data).

    We may collect, use, store, and transfer (“process”) different kinds of personal information about you which we have grouped together as follows:

    Identity and Contact Data, such as your name, email address, telephone number, address, emergency-contact details and, where applicable, the details of additional guests, visitors, property owners, corporate contacts, suppliers, service providers, employees, contractors or job applicants. This includes persons who contact us by WhatsApp, chat or email, whether or not they make a booking, and referral partners and guest-perk partners.

    Booking, Stay and Account Data, including booking and stay details, property and unit information, arrival and departure details, preferences, enquiries, tickets, communications, account details, user role, login and authentication information, support enquiries, workspace and parking bookings, and, where applicable, owner, supplier, corporate-client, employment or contractor records relevant to our business relationship with you. This also includes corporate-client company accounts and their authorised users, booking amendments and booking requests, and purchases of supplementary services during a stay.

    Payment and Transaction Data, including payment confirmations, receipts, refunds and reconciliation references. We do not store payment-card numbers; direct payments are processed by our payment gateway, PayFast, or by the relevant online travel agent or other payment provider. This also includes quotes, invoices, payment links, EFT and card-machine references, and virtual card details received from booking channels to settle a booking, which we do not store in full.

    Registration and Verification Data, including digital registration-card information, identity or passport details, images of identity documents, identity-verification-session information, signatures, accepted terms, marketing choices and, where applicable, after-hours visitor-registration information.

    Correspondence Data, including communications and attachments exchanged with us through email, WhatsApp, online travel agent messaging systems, our website, tickets, social-media channels or other support channels. This includes attachments to tickets and client-portal messages and conversations with our online booking assistant.

    Technical and Usage Data, including internet-protocol address, login data, browser and device information, time-zone setting, cookies and similar technologies, operating system,

    website and booking-session activity, searches, property views, checkout progress and failures, and other information about how you use our website and Services.

    Security and Access Data, including access logs, audit records and information used to protect our systems, prevent fraud, investigate incidents and manage access to our Services.

    Marketing Data, including your marketing-consent status, communication preferences, campaign engagement, unsubscribe and suppression records, and details of marketing communications sent to you.

    Property and Owner Data, including details of the units owners place with us, listing links and platform settings, bank details for owner payouts, and owner performance reports.

    Housekeeping and Inspection Records, including cleaning, inspection and maintenance records and photographs of the unit and its contents, which are not intended to capture guests.

    Limited Health Information, including a medical certificate or sick note, to support a refund, cancellation or other request, which we will only use to assess and administer that request, comply with applicable legal obligations, or establish, exercise or defend legal claims. Please provide only the information reasonably necessary for the request. We will restrict access and retain it only for as long as necessary or otherwise permitted or required by law.

    We also collect, use, and share Aggregated Data. Aggregated Data may be derived from your personal information but is not considered personal information in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Privacy Policy.

    Where we need to collect personal information by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel your access to our Platform or services, but we will notify you if this is the case at the time.

    3. How Is Your Personal Information Collected?

    We use different methods to collect personal information from and about you, including through:

    Direct interactions: You may provide personal information when you make or manage a booking, complete a digital registration card, contact us through our website, email, WhatsApp or another channel, or otherwise interact with us. This includes personal information you provide when you:

    • make, amend or pay for a booking or use our Services;
    • use our website, booking platform, workspace or parking booking services;
    • complete a registration card or identity-verification process;
    • request information, support or a priced offer from us;
    • give us feedback, make a complaint or submit a data-subject request.

    Automated technologies or interactions: As you interact with our website and booking platform, we may automatically collect Technical and Usage Data about your device, browsing actions, booking session and patterns through cookies, server logs, analytics tools, tracking technologies and similar technologies. This may include information about searches, property views, checkout progress and checkout failures.

    Third parties: We may receive personal information about you from third parties, including:

    • online travel agents and booking intermediaries;
    • property-management and channel-management providers;
    • analytics, advertising and marketing providers;
    • communications providers;
    • identity-verification, security and fraud-prevention providers; and
    • payment service providers and, where applicable, property owners, Body Corporates,

    corporate clients or approved service providers.

    4. How We Use Your Personal Information

    We will process your personal information only where permitted by law and for a lawful purpose. Most commonly, we process your personal information in the following circumstances:

    • where we have your express consent to do so;
    • where it is necessary to enter into or perform a contract with you, including to process

    and manage your booking and stay;

    • where it is necessary for our legitimate business interests (or those of a third party)

    and your interests and fundamental rights do not override those interests; and/or

    • where we need to comply with a legal or regulatory obligation.

    5. Purposes For Which We Will Use Your Personal Information

    We process your personal information for the following purposes:

    • to respond to your enquiries, requests, complaints and support communications;
    • to provide, administer and manage bookings, accommodation stays, registration,

    check-in, check-out, workspaces, parking and related Services;

    • to communicate with you about your booking, stay, service requests, security,

    administrative matters and other operational matters through email, WhatsApp, and other appropriate channels;

    • to share information with authorised service providers, property owners, Body

    Corporates, corporate clients and other recipients where necessary to provide the relevant Services or where otherwise permitted by law, including providing relevant property owners with limited booking and stay information for property management, owner reporting, payment reconciliation or administration of the relevant owner arrangement;

    • to process payments, issue receipts, administer refunds, reconcile transactions and

    manage fees and charges;

    • to complete digital registration cards, verify identity where required, maintain visitor

    records and comply with applicable safety, security and legal requirements;

    • to manage our relationship with you, including notifying you about changes to our

    Terms, Privacy Policy or Services;

    • to administer, secure, maintain and protect our business, website, booking platform

    and Services, including troubleshooting, fraud prevention, access control, monitoring and logging where appropriate, data analysis, testing, system maintenance, support, reporting and hosting;

    • to use aggregated or irreversibly anonymised information to improve our Services,

    accommodation operations, booking experience, customer relationships and reporting;

    • to use appropriately controlled technology tools, including AI-enabled functionality, to

    assist with customer support, translation, content preparation, internal administration and service improvement, where permitted by law and subject to appropriate safeguards and contractual controls;

    • to allocate and manage housekeeping, maintenance, inspections and related service

    providers, including maintaining task, inspection and repair records and investigating incidents, damage or service issues, where permitted by law;

    • to send direct marketing where permitted by law and in accordance with your marketing

    preferences and explicit consent; and

    • to manage corporate-client accounts, their authorised users and the bookings made

    through them; to comply with our obligations under any applicable law.

    Direct Marketing

    Where permitted by applicable law, we may process your personal data to send you direct marketing communications about our products, features, events, promotions and related updates via channels such as email or SMS. We will only send direct marketing where we have a valid lawful basis to do so (including, where required, your prior consent).

    You may object to, or opt out of, direct marketing at any time by using the unsubscribe/opt-out mechanism included in the relevant message, updating your preferences in the "My Account" section of the Platform, or contacting us using the details set out in this Privacy Policy. If you opt out, we will stop sending you direct marketing communications; however, we may still send you non-marketing communications that are necessary to provide the Services (such as service notices, security alerts, and administrative messages). Your opt-out will not affect our processing of your personal information for other lawful purposes.

    Where a data subject has objected to direct marketing, opted out, or withdrawn consent, we will retain a minimal suppression record for the sole purpose of ensuring that no further direct marketing is sent to that data subject.

    Third-Party Marketing

    We will not sell your personal information. We will not share your personal information with third parties for their own direct-marketing purposes unless we have a lawful basis to do so, including your consent where required by law.

    Change of Purpose

    We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

    If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

    6. Disclosures Of Your Personal Information

    We may share your personal information with the following recipients where necessary for the purposes described above, where required by law, or where otherwise permitted by law.

    • Internal recipients, including our directors, employees and authorised personnel with a

    legitimate need to know, and our affiliates and related entities (if any), where permitted by law;

    • External Third Parties include:
    • property-management, channel-management and online travel agent

    providers to administer bookings and accommodation operations; online booking channels and distribution partners; referral partners, who receive credit for bookings they refer; advertising platforms, for marketing audiences where permitted by applicable law;

    • payment, accounting and financial-service providers to process payments,

    issue receipts, administer refunds, reconcile transactions and comply with financial obligations;

    • communications, cloud-hosting, database, file-storage, application-hosting,

    deployment, security, identity-verification, email and document-storage providers;

    • marketing, advertising, analytics, pricing, benchmarking and social-media

    providers;

    • property owners, Body Corporates, corporate clients and approved service

    providers with a legitimate need to know in order to provide relevant services, including, where necessary for property management, owner reporting, payment reconciliation or administration of the relevant owner arrangement, limited information relating to bookings for the relevant owner's unit, such as guest name, booking reference, stay dates, booking value, fees and related financial information;

    • competent government authorities, regulators, law-enforcement agencies and

    other persons where required or permitted by law.

    • Third parties to whom we may choose to sell, transfer, or merge parts of our company

    or our assets. Alternatively, we may seek to acquire other organisations or merge with them. If such a change happens to our company, we may continue to use your personal information in the same way as set out in this Privacy Policy.

    We require our service providers to protect personal information and process it in accordance with applicable law and our instructions where they act as our Operators. Some recipients, such as online travel agents, payment providers, property owners, Body Corporates and public authorities, may process personal information as independent Responsible Parties under their own privacy notices and legal obligations.

    7. Cookies

    Our website and booking platform may use cookies and similar technologies to operate the site, remember preferences, protect forms and checkout, understand website and booking activity, measure performance and support advertising. Cookies are small text files placed on your device that help us recognise repeat users and analyse how our website is used.

    Cookies and similar technologies may collect information that can identify you or be linked to you. You can manage cookies through your browser settings and, where available, our cookie-preference tools. Please note that strictly necessary cookies may be required for certain features of our Platform; if you disable them, some features or access to the Platform may be limited. Where consent is required for non-essential cookies or similar technologies, we will obtain it through the relevant cookie-preference tool.

    8. International Transfers

    We may transfer, store, host, access or otherwise process your personal information outside South Africa to provide, host, secure, maintain and support our accommodation-management, booking, guest-communications, marketing, reporting and related business operations. This includes processing through approved service providers.

    When we transfer personal information outside South Africa, we will take the steps required by POPIA to ensure that the recipient is subject to laws, binding agreements or other safeguards that provide an adequate level of protection for that personal information.

    Depending on the transfer, these safeguards may include contractual protections, technical and organisational measures, and transfer-risk assessments where appropriate.

    9. Data Security

    We use reasonable technical and organisational safeguards appropriate to the nature of the personal information and the risks of processing to protect personal information from accidental loss and unauthorised access, use, alteration or disclosure. These measures include access controls, authentication measures, monitoring and logging where appropriate, data-retention controls and procedures for managing suspected security incidents. Access to personal information is limited to authorised persons who require it for legitimate business purposes.

    We maintain procedures for identifying, escalating, containing and reviewing suspected personal information breaches, including reports received through our systems, hosting provider, staff or users. Where we have reasonable grounds to believe that personal information has been accessed or acquired by an unauthorised person, we will notify affected individuals as soon as reasonably possible, and the Information Regulator where required by law.

    10. Data Retention

    We will only retain your personal information for as long as necessary to fulfil the purpose we collected it for including any legal, accounting, or reporting requirements, or as required by applicable law.

    Where we collect identity-document or passport images for check-in verification, fraud prevention, security or legal compliance purposes, we retain those images only for the limited period reasonably necessary for those purposes and then securely delete them, unless a longer retention period is required or justified for a specific complaint, dispute, chargeback, incident, law-enforcement request or legal obligation. Identity-document and passport images captured with digital registration cards are deleted no later than 90 days after check-out. Booking, invoice and payment records are kept for the periods required by tax and accounting law. We retain marketing-consent and opt-out records as necessary to demonstrate and respect your preferences.

    To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purpose for which we process your personal information, any other South African applicable law requiring us to retain the personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

    We may anonymise your personal information so that it can no longer reasonably be associated with you for research or statistical purposes. We may use genuinely anonymised information indefinitely without further notice to you.

    11. Your Legal Rights

    You have rights in relation to your personal information where we are the relevant “Responsible Party” for that personal information. Please contact us to find out more about, or exercise, these rights:

    • request access to your personal information;
    • request correction of your personal information;
    • request erasure of your personal information;
    • object to the processing of your personal information;
    • request a restriction of processing your personal information;
    • request transfer of your personal information; and/or
    • right to withdraw consent.

    You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

    We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

    We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

    Users with citizenships from jurisdictions other than South Africa, please note that we comply with South African data protection laws when processing your personal information as we are a South African entity. Should foreign law be applicable to your use of the Services and/or the Platform in any way, including how we may process your personal information, please contact us and we will gladly engage with you on your rights.

    Our PAIA Manual, request forms and the PAIA Guide are available on our PAIA Manual & Forms page.