Linkedin-in
Twitter Linkedin-in
Search
Close this search box.

QUICK
LINKS

ESG

Growthpoint R2bn-plus mixed-use development in Sandton

by

Growthpoint announces R2bn-plus mixed-use development in Sandton Summit

Growthpoint Properties Limited (JSE: GRT), South Africa’s leading real estate investment trust (REIT), today announced it is commencing a landmark residential and retail development, Olympus Sandton, in partnership with leading luxury residential developer Tricolt.

Olympus Sandton will be situated in the mixed-use Sandton Summit precinct, anchored by the Discovery Head Office on the corner of Rivonia Road, where Katherine Street becomes Sandton Drive. This strategic investment aligns with Growthpoint’s vision to create South Africa’s premier walkable mixed-use precinct, capitalising on Sandton’s status as Africa’s leading financial district.

Growthpoint has been rolling out different elements of the Sandton Summit vision for over a decade now, and Olympus Sandton is its first development positioned to capture the increased demand for residential property in Sandton Central.

The R2bn-plus Olympus Sandton development will comprise two towers. The first residential tower of 26 storeys will be the first phase of the development along Rivonia Road. It will include a premium dining experience from Marble Hospitality Group on one of the tower’s upper floors, as well as its extraordinary Pantry convenience retail offering in Grade-A ground floor retail space. The second phase is a tower of at least 16 storeys, located east of the first.

The sale of the development’s more than 400 residential apartments by Tricolt has commenced and will launch to the public on 27 February 2025, with prices starting from R1.49 million. Together Growthpoint and Tricolt will retain ownership of the two retail sections of the tower. Construction of Olympus Sandton is estimated to start in the latter half of 2025.

Sandton Summit is situated at the crest of Sandton Ridge, which is the highpoint of the area. Olympus Sandton’s 26-storey tower, although not the tallest building in the area, will become the highest in Sandton, offering unmatched views across Johannesburg and beyond.

Neil Schloss, Head of Asset Management South Africa at Growthpoint Properties, says: “We believe that commencing the Olympus Sandton development is well-timed for the reawakening of the powerhouse that is Sandton Central, and aligned with its accelerated transformation into a vibrant neighbourhood as it evolves with the trend of people wanting to live closer to workplaces and amenities, to offer an exceptional mix of residential, office, retail and other types of properties.”

Timothy Irvine, Growthpoint’s Head of Asset Management for Offices, adds, “Sandton is experiencing a significant revival. After years of office downsizing, companies are now maintaining their physical presence and even starting to grow it again as return-to-office becomes standard practice. Vacancy rates in Growthpoint’s office portfolio are declining nationwide, with Sandton — the country’s cosmopolitan business capital — showing the start of a particularly promising recovery. Despite a slow initial post-pandemic resurgence, the district is adapting not only its office spaces to meet growing demand but its entire lifestyle, with more living and gathering spaces.”

Growthpoint is among those leading Sandton Central into an even more vibrant future. Taking advantage of other opportunities arising from increased demand for residential property in Sandton Central, in line with the trend of living closer to offices, Growthpoint also recently sold its 151 on 5th building in Sandton to a residential developer. Growthpoint is also investing in taking Sandton into a new green era with its revolutionary e-co2 solution launching at 10 Sandton office buildings in mid-2025. The e-co2 scheme will provide tenants with access to wheeled renewable hydro, wind and solar electricity at fixed escalations, sharing the benefits of Growthpoint’s milestone Power Purchase Agreement (PPA) for renewable energy, with which it secured 195GWh of green power.

This is one of several projects Growthpoint is undertaking that will make Sandton Central even more friendly for people, businesses and the environment.

Olympus Sandton’s striking and innovative design matches its prominent position on the Sandton skyline. It was created through collaboration between Australian architectural practice ClarkeHopkinsClarke (CHC) and one of South Africa’s foremost architectural studios, dhk Architects, and will be developed jointly by Growthpoint and Tricolt – all award-winning leaders in their fields.

Growthpoint’s development team has an established record of excellence in investment-grade commercial property development, which also extends to a signature range of residential developments. This includes its Riverwoods office-to-residential conversion to BlackBrick Bedford, various award-winning purpose-built student accommodation developments, and its recently completed major residential development, the fully sold-out The Kent, La Lucia, in KwaZulu-Natal.

The design of Olympus Sandton incorporates advanced sustainable building practices, including post-tension slabs and smart energy management systems, aligning with Growthpoint’s environmental, social and governance (ESG) commitments, including its 2050 carbon-neutral goal. The Olympus Sandton development will target at least a 4-Star Green Star rating from the Green Building Council of South Africa (GBCSA).

“Pedestrianised mixed-use precincts have tremendous environmental benefits, particularly when they are so well located, by reducing carbon emissions as a result of less private vehicle travel and traffic. Olympus Sandton is the next step in bringing our vision for Sandton Summit to life and delivers on our commitment to creating sustainable developments that deliver exceptional amenities for their uses and long-term value for our stakeholders,” says Schloss.

The best-known mixed-use asset in Growthpoint’s investment portfolio is the iconic V&A Waterfront, of which Growthpoint is a 50% owner. It also owns several other precincts and parks in its South African portfolio, such as the Longkloof precinct in Cape Town’s vibrant Kloof Street area of Gardens. Spanning 21,164sqm, this multi-use property has become a sought-after address for innovative, creative and entrepreneurial businesses, alongside the 154-room Canopy by Hilton hotel, the first in South Africa, which is set to open in late January 2025. In the vibrant Umhlanga Ridge New Town Centre, its three Green Star-rated office developments – Lincoln On The Lake, Mayfair On The Lake and The Boulevard – all offer a mix of P-grade office accommodation, ground floor retail and basement parking linked by a central landscaped courtyard with pedestrian access, and overlooking the gardens of a local park.

“Olympus Sandton exemplifies Growthpoint’s strategic approach to unlocking maximum value from prime real estate assets through thoughtful market-aligned development that improves our portfolio and progresses our sustainability goals,” notes Schloss.

Growthpoint and Serra® set a new benchmark 6-Star Green rating

by

Growthpoint and Serra® set a new benchmark for logistics and industrial properties with 6-Star Green rating

In an environmentally innovative achievement, the Serra® facility, owned by Growthpoint Properties (JSE: GRT), has become South Africa’s first industrial property to earn a prestigious 6-Star Green Star Existing Building Performance (EBP) rating from the Green Building Council South Africa (GBCSA), setting a new benchmark for logistics and industrial properties.

Located in Meadowbrook, Germiston, the 7,400sqm light manufacturing facility has consistently been an example of a strong commitment to leading green building standards. In 2020, it was awarded a 5-Star Green Star EBP rating, marking the first time an industrial building in Gauteng had achieved this certification.

The new 6-star rating recognises an ongoing sustainability journey. Underpinning the achievement are Growthpoint’s 15 years of recognised green building leadership and Serra®’s 40 years of experience in the commercial washroom industry, resulting in a deep focus on water efficiency and conservation at the property. This powerful partnership also earned the building the 2024 GBCSA Leadership Awards for theHighest Rated Building (EBP), with accredited professional Danika Taylor of Imbue Sustainability also playing a key role in achieving this milestone certification.

The building boasts several cutting-edge features that contribute to its impressive green credentials. The entire facility is 100% off the grid. It features solar PV energy generation and waste management, including recycling.

Yet it shines brightest in its positive impact on water resilience – the heart of sustainability. The property features substantial rainwater harvesting, including a petrol/oil separation system for water recycling, a water purification plant, and an underground water reservoir about the size of an Olympic swimming pool. This is particularly significant given the current water scarcity concerns in South Africa, especially the diminishing water security in the Gauteng region.

The alignment between Growthpoint and Serra® in their environmental commitments makes this property a standout example of cooperation between a property owner and occupier, especially when both are leaders in environmentally sustainable practices in their respective sectors.

Growthpoint’s goal is to be carbon neutral by 2050. Its progress includes 123 current green building certifications and securing access to a rapidly growing reliable mix of renewable energy sources – electricity from water, on-site and remote solar, and wind – for tenants to access through its e-co2 benefit scheme, being the first of its kind in South Africa. Thanks to a PPA with Etana Energy, Growthpoint will begin wheeling 195 GWh/y of renewable energy to select buildings starting from July 2025, which represents 32% of its total electricity consumption and demonstrates its commitment to innovative, scalable energy management.

These and other sustainable business practices not only move Growthpoint closer to its ESG (Environmental, Social, and Governance) targets but also help tenant businesses towards their own ESG goals.

As a proudly South African family-run business with a strong passion for ESG principles, Serra® is wholly invested in sustainable green practices and has voluntarily pursued rigorous sustainability certifications. This goes well beyond its manufacturing and showroom facility. Serra® has made substantial investments in developing sustainable products and practices. For instance, it supplies floor covering and mats from recycled fishing lines recovered from the ocean. It is aiming for Net Zero emissions.

Paul Thomaz, CEO of the Serra® Group (Pty) Ltd, comments, “Our business is dedicated to creating a positive impact on the environment and communities we serve. Working with Growthpoint to achieve the 6 Star Green Star reinforces our long-term vision of minimising harm and promoting sustainable practices throughout our operations and product offerings.”

The Serra® building’s 6 Star Green Star EB rating sets a new benchmark for logistics and industrial properties in South Africa. It continues Growthpoint’s pioneering approach to green logistics and industrial buildings in South Africa. The company jointly developed the GBCSA’s certification tool for industrial facilities in a progressive move that enabled more building types to be certified green. It was also awarded South Africa’s first-ever Green Star SA rating for industrial property, for Greenfield Industrial Estate in Cape Town.

Errol Taylor, Growthpoint’s Head of Asset Management: Logistics & Industrial Property, says, “Growthpoint is committed to providing relevant spaces that support occupants while addressing key global and local efforts in response to environmental concerns. We are incredibly proud of this achievement and the strong partnership with Serra® that has made it possible.”

The environmental commitment of both businesses is being put into action in other ways too.

As a leading hygiene services provider and washroom accessory manufacturer, Serra®’s commitment to environmental responsibility extends to its service agreements, and the company currently services around 90 of Growthpoint’s Johannesburg buildings. This not only benefits Growthpoint as the owner but also enhances the experience of the tenants.

The 6-Star Green Star rating for the Serra® building underscores the growing importance of certified green credentials. As businesses increasingly prioritise ESG considerations, buildings that can demonstrate exceptional operational performance are increasingly attractive to tenants and investors.

For Growthpoint, the Serra® building’s new rating is a testament to the value and impact of its green initiatives. The company continues to explore and collaborate on opportunities to enhance the sustainability of its portfolio, creating properties that benefit both the environment and those who occupy them.

For Serra®, its manufacturing and showroom facilities serve as a living inspiration for environmental sustainability, and it welcomes designers, facility managers, property developers and built environment professionals to visit the property to encourage greater green building excellence.

Greenovate Awards 2024 celebrate student innovation

by

Greenovate Awards 2024 celebrate student innovation in sustainability

The 2024 Greenovate Awards have once again highlighted the remarkable ingenuity of South African university students in developing sustainable solutions for the built environment. This annual competition, a partnership between Growthpoint Properties (JSE: GRT) and the Green Building Council of South Africa (GBCSA), challenges students to address real-world obstacles in property and engineering with cutting-edge green thinking.

This year’s awards saw 23 students from eight universities participate, submitting projects that ranged from finding new uses for manganese mining by-products in construction materials to keeping buildings cool inside with biomimicry, the circular economy potential in the construction industry and even making 3D printing more environmentally sustainable. The winners were announced at a gala dinner held at The Galleria in Sandton.

In the engineering category, North-West University received top honours for a project on compact filament production for 3D printing. University of Cape Town (UCT) claimed second place with a project on termite-mound-inspired energy-saving building design, and Stellenbosch University took third with a solution that reduces traffic in the town.

The Property category saw Nelson Mandela University win the top spot with the project on carbon management implementation for quantity surveying professional practice and University of Pretoria took second for exploring the role manganese mining by-products can play in sustainable property development. Two UCT teams took joint took third place with their focus on the impacts of green building certification on different aspects of real estate.

The International Finance Corporation (IFC) Excellence in Design for Greater Efficiency (EDGE) Award was presented to Nosipho Hadebe and Masego Mngomezulu from University of Pretoria for their work on how timber construction in extreme conditions and remote locations impacts indoor air quality.

“In an industry with tremendous power for positive environmental impact that is seeking sustainability solutions, the creativity and passion of these students shines through,” says Engelbert Binedell, Chief Operating Officer of Growthpoint Properties. “Greenovate isn’t just an awards programme – it’s a catalyst, introducing top young talent to cutting-edge sustainability concepts and connecting them with industry visionaries. This is more than career development; Greenovate expands South Africa’ green talent pool for Growthpoint, the property sector, the green building movement and country as a whole. The future of sustainable development starts here.”

“The Green Building Council South Africa is consistently proud to partner with Growthpoint in the Greenovate competition and awards. But more than that, we enjoy our participation as mentors and judges and being part of the celebration during the awards event. The students inspire us with their vision, enthusiasm and innovation. Greenovate is indeed a catalyst towards the actualisation of green jobs in an innovative green economy within the built environment,” says Lisa Reynolds CEO, GBCSA.

Prizes to advance planet purpose

The top three winners of both categories received a share of R142,000 in total prize money, and the Greenovate. Additional prizes included EDGE training and certification and tickets to the GBCSA Convention, which includes opportunities to present and showcase winning solutions.

Advantageously, participants get access to valuable mentorship, networking opportunities and expert-led workshops. They gain access to knowledge and resources needed to turn their research into practical products or services for the property industry. This experience fosters lasting networks and partnerships among participants.

Mentorship from market leaders

This year’s mentors for the property stream included Marlene Senne and Abigail Godsell of GBCSA, Iphendule Ndzipho and Hlologelo Manthose of WSP, Wardah Peters of Solid Green Consulting, Mapula Matlakala of African Bank, and Siphesihle Mankahla of EPMO. Engineering stream mentors included Alex Varughese of GBCSA, Mary Anne Fetcher of Zutari, Makhosazana Mthethwa and Thato Molapo of Solid Green Consulting, Tumanga Qholosha of Blackstone Design Consulting, and Kutlwano Dikgwatlhe of Joburg Water.

A panel of change-making judges

The 2024 judges for the property category included Tsholofelo Makgwa of the City of Tshwane, Jennifer Lombard of GBCSA, Kushinga Kambarami of IFC, Adrie Fourie of Solid Green and Brian Unsted of Liberty2Degrees. Judges for the engineering category included Mike Aldous of MPAMOT, Dash Coville of GBCSA, Werner van Antwerpen of Growthpoint Properties, Mischa Tessendorf of Attacq Limited.

The innovating, planet-shaping 2024 Greenovate Student Awards winners:

ENGINEERING WINNERS:

1st – Leon Uys, North-West University: Compact filament production plant for sustainable 3D printing.

2nd – Jacqui Hully, University of Cape Town: Thermal design and analysis of termite-mound-inspired energy saving buildings.

3rd – Sebastiaan Whitward, Stellenbosch University: An optimist’s solution to Stellenbosch’s high influx of commuters.

PROPERTY WINNERS:

1st – Dylan Minaar, Nelson Mandela University: Exploring carbon management implementation for quantity surveying professional practice in South Africa.

2nd – Liam Galloti and Neil Johnston, University of Pretoria: Exploring sustainable housing solutions in Hotazel using mining by-products.

3rd – Oratile Masia and Mihlali Solombela, University of Cape Town: An examination of the impact of green certification on valuation variables and office real estate valuation determination.

3rd – Paige Waberski and Kiah Wallace, University of Cape Town: The investigation into the impact of the Green Star Existing Building Performance (EBP) tool on the office real estate sector in South Africa.

IFC EDGE PRIZE – Nosipho Hadebe Masego Mngomezulu, University of Pretoria: Indoor environmental quality improvement through timber construction in extreme environments and remote locations.

Students from all South African universities are invited to participate in the Greenovate Awards and can register at https://www.greenovatecompetition.co.za/register/

South African REITs are poised for strong growth in 2025

by

The ongoing strengthening of property fundamentals, combined with rising demand and increased market activity, alongside declining interest rates, will position South African REITs for a strong growth trajectory heading into 2025.

The REIT sector, which made a strong recovery in October 2024, has outpaced other asset classes, delivering a 34% return year-to-date. In comparison, the broader equity market has returned 15.9%, while South African bonds have gained 16.7%.

Key factors contributing to this outperformance include the formation of the Government of National Unity (GNU) and a stable power supply, both of which have positively impacted the sector and driven improvements in property fundamentals.

Estienne De Klerk, Chairperson of the SA REIT Association and Growthpoint Properties South African CEO commented:

“In 2024, we have seen notable improvements in key property performance indicators, signalling strong investment potential and supporting expectations for future net rental growth. The anticipation of additional interest rate cuts has further bolstered investor confidence and sentiment, creating a positive outlook for the sector as we head into 2025.

However, the cumulative 50 basis point rate cut so far is not a panacea –  it is essential for stimulating market demand and activity, as well as supporting growth in company earnings. While not immediate, additional rate cuts will support REITs in raising capital, refinancing maturing loans, and acquiring new assets.”

To ensure long-term liquidity and a solid balance sheet, REITs have remained focused on strategically disposing of non-core assets, optimising their portfolios to enhance quality and implementing proactive asset management strategies to increase property values, he said.

De Klerk noted that sentiment in the office sector has strengthened, evidenced by a surge in space inquiries and a decline in vacancies. In coastal regions, demand is now outpacing supply in certain areas as more people return to the office. However, oversupply still exists in Gauteng.

Meanwhile, the retail sector is growing. As consumer sentiment improves, De Klerk expects to see better trading densities and rental growth in 2025. The industrial property sector continues to outperform, driven by strong demand, limited supply and rising construction costs, all of which are fuelling rental growth—this trend is set to continue into 2025.

Sustainability

Shifts in how and where tenants occupy commercial space has resulted in increased demand for sustainable buildings, new and high-quality refurbished buildings across the industrial, retail and office sectors.

REITs have made substantial investments in solar power and water supply infrastructure, continually enhancing their buildings to reduce carbon footprints while offering occupiers high-quality, sustainable spaces to operate from.

For many, sustainability is embedded in their organisational DNA and core business strategies for long-term benefits.

“In November, we launched the SAREIT Sustainability Disclosure Guide to set clear sustainability standards and best practices for South Africa’s real estate sector. We are confident that this initiative will play a pivotal role in supporting our members on their sustainability journeys,” said Joanne Solomon, CEO of SA REIT.

As a key player in addressing environmental, social and governance (ESG) challenges, the guide will provide strategic direction for the industry, helping to shape a future where sustainable practices are seamlessly integrated into business strategies, driving both resilience and long-term value,” she added.

Growthpoint’s shines with four prestigious green building awards 

by

Growthpoint’s property portfolio shines with four prestigious green building awards 

Growthpoint Properties (JSE: GRT), the leading real estate investment trust, has been honoured with four prestigious awards for environmentally innovative initiatives at its buildings by the 2024 Green Building Council of South Africa (GBCSA) Leadership Awards. These accolades recognise Growthpoint’s unwavering commitment to environmental sustainability, pioneering work in green building practices and collaboration with leading lights who, together, are driving a greener, more sustainable South Africa.

The 2024 GBCSA Leadership Awards are presented to those who have demonstrated an unwavering commitment to the goal of a climate positive future and acknowledge excellence in green building initiatives, which includes energy efficiency, water conservation, indoor environmental quality, transport, materials, land-use ecology, management, and innovation.

“We are incredibly proud of these prestigious GBCSA awards,” says Engelbert Binedell, Growthpoint’s Chief Operations Officer. “These honours reflect the valuable contributions of our tenants, accredited green building professionals, business partners and the team at Growthpoint. They underscore our dedication to creating sustainable, environmentally responsible properties that benefit our stakeholders, and especially our tenants and the communities we serve.”

The four awards for certified green building excellence at Growthpoint properties include:

Best Quality Submission – Existing Building Performance: Recognising excellent performance in Green Star existing building ratings

  • Joint winner: Woodmead Estate, which holds a 4-Star Green Building Performance certification
  • GBCSA Accredited Professional: Mary-Anne Fechter, Zutari

Highest Rated Building (Existing Building Performance): Honouring the highest-rated building in Green Star existing building ratings

  • Winner: Serra Services, Meadowbrook Estate, boasting a 6-Star Green Star Building Performance certification
  • GBCSA Accredited Professional: Danikay Taylor, Imbue Sustainability

Best Quality Submission – Asset Rating Design: Recognising excellent quality in Green Star design tools

  • Winner: The Anglo American fit-out at 144 Oxford, certified 6-Star Green Star Interiors
  • Accredited Professional: Yovka Raytcheva-Schaap, Zutari

Highest-Rated Building – Asset Rating Design: Honouring the highest-rated building in Green Star design tools

  • Winner: The Anglo American fit-out at 144 Oxford, 6-Star Green Star Interiors
  • Accredited Professional: Yovka Raytcheva-Schaap, Zutari

“These awards demonstrate our ongoing commitment to developing, owning and managing properties that minimise environmental impact while providing healthy, productive workspaces and working with others to help address global and local climate challenges,” adds Binedell. “We are dedicated to continuing our leadership in green building practices and contributing to a more sustainable future.”

Growthpoint’s goal is to be carbon neutral by 2050. Moving closer to its ESG (Environmental, Social, and Governance) targets, its progress includes 123 current green building certifications for its properties, as well as securing access to a rapidly growing reliable mix of renewable energy sources – electricity from water, on-site and remote solar, and wind – for tenants to access through its e-co2 benefit scheme, being the first of its kind in South Africa. Thanks to a PPA with Etana Energy, Growthpoint will begin wheeling 195 GWh/y of renewable energy to select buildings starting from July 2025.

South African REITs Sustainability Disclosure Guide launched

by

The South African Real Estate Investment Trust Association (SA REIT) Association in partnership with Nedbank Corporate and Investment Banking (CIB) have launched the SAREIT Sustainability Disclosure Guide, aimed at establishing sustainability standards and best practice benchmarks for the real estate sector in South Africa.

This guide is a valuable resource for SA REIT members and property organisations starting their sustainability reporting. It provides key information to improve their reports and outlines a framework of recommendations for sustainability and climate-related disclosures, aligning with international standards in the South African property sector and the global sustainability landscape.

Joanne Solomon, Chief Executive Officer of SA REIT Association comments:

“As industry partners, we are proud to launch the inaugural SA REIT Sustainability Disclosure Guide, marking a significant advancement in fostering a unified approach to sustainability within the South African real estate sector.

The property sector plays a crucial role in tackling environmental, social, and governance (ESG) challenges. Our goal is to guide the industry toward a future where sustainable practices are seamlessly integrated into business strategies, enhancing both resilience and value.”

Sustainability has become a key priority for businesses, with capital markets increasingly evaluating performance based on ESG metrics in their investment decisions. This trend is supported by compelling evidence linking strong ESG performance to an organisation’s ability to secure long-term competitive and financial advantages.

Furthermore, sustainability reporting offers investors valuable insights into a company’s long-term viability, risk management, and growth potential. This transparency empowers investors to make informed decisions that align with their values and financial goals.

“Meaningful sustainability disclosure is essential for attracting financial capital, enhancing accountability, improving business performance, and fostering a resilient property sector.”

The guide aims to enhance the reliability, consistency, and comparability of ESG data among South African REITs, promoting objectivity, facilitating analysis, improving valuations, supporting benchmarking, and encouraging cross-organisational comparisons, said Solomon.

Gary Garrett, Managing Executive of Property Finance: Nedbank CIB commented:

“As a purpose led organisation, we aspire to be a key participant in promoting a more sustainable future for the real estate sector. We are intentional about sustainability and about contributing positively to the communities in which we operate.”

The SA REIT Sustainability Disclosure Guide highlights the significance of accurate and reliable ESG reporting, aligning with global best practices and standards. These include the Global Reporting Initiative, the Sustainability Accounting Standards Board, and the Task Force on Climate-related Financial Disclosures.

Garrett said the practices outlined in the guide foster transparency, enhance stakeholder trust, and promote sustainable growth in the property market.

Solomon said the guide aligns with the voluntary JSE Sustainability and Climate Change Disclosure Guidance of 2022 and global best practices, specifically for the South African property sector. SA REIT recommends using this guide alongside the JSE guidance which serves as its foundation.

Many recommendations in these frameworks are not industry-specific and often overlook the unique challenges faced by property owners in South Africa. For instance, an international decarbonisation disclosure framework may not account for local municipality restrictions on electricity wheeling or the lengthy process of obtaining water-use licenses.

“This guide will assist issuers and investors in the South African property sector by standardising key sustainability concepts and their reporting. While it serves as a valuable voluntary tool, its application is not mandatory,” she added.

Download the SAREIT Sustainability Disclosure Guide here or email info@sareit.co.za for more information.

Copyright SA REIT Association

© 2024
Privacy Policy