POPI Privacy Policy

(Introduction)

Where we refer to process, it means how we collect, use, store, make available, destroy, update, disclose, or otherwise deal with your Personal Information. As a general rule we will only process your personal information if this is required to deliver or offer a service or carry out a transaction.

In this Privacy Policy when we say “we” or “us” or “our” this includes our company and any of its subsidiaries.

If you use our services, you agree that we may process your personal information as explained in this Privacy Policy. Please read this Privacy Policy carefully because it may limit your rights.

We may change this Privacy Policy from time to time if the law or business practices require it.

The version of the Privacy Policy displayed on our website will apply to your interactions with us.

This Privacy Policy establishes a general standard for the appropriate protection of personal information within our company’s environment and it provides principles regarding the rights of individuals to privacy and to reasonable safeguards of their personal information.

(What is personal information?)

Personal information refers to any information that identifies you or specifically relates to you. Personal information includes, but is not limited to, the following information about you:

• your marital status;
• your national origin;
• your age;
• your language; birth place; education;
• your financial history (like your income, third party payments made on your behalf and the like)
• your identifying number (like an employee number, identity number or passport number);
• your e-mail address; physical address; telephone number;
• your biometric information (like fingerprints, your signature or voice);
• your race; gender; sex; pregnancy status; ethnic origin; social origin; colour; sexual orientation;
• your physical health; mental health; well-being; disability; religion; belief; conscience; culture;
• your medical history; criminal history; employment history;
• your personal views, preferences and opinions;
• your confidential correspondence;
• another’s views or opinions about you.

Personal information includes special personal information, as explained below.

(When will we process your personal information?)

We will only process your personal information for lawful purposes relating to our business if the following applies:

• if you have consented to us processing your personal information;
• if a person who is legally authorised by you, the law or a court, has consented;
• if it is necessary to conclude or perform under a contract we have with you;
• if the law requires or permits it;
• if it is required to protect or pursue your, our, or a third party’s legitimate interest.

(What is special personal information?)

Special personal information is personal information about the following:

• your race;
• your ethnic origin;
• your trade union membership;
• your health;
• your biometric information;
• your criminal behaviour and alleged commission of an offence.

(When will we process your special personal information?)

We may process your special personal information in the following circumstances:

• if you have consented to the processing;
• if the information is being used for any human resource or payroll requirement;
• if the processing is needed to create, use or protect a right or obligation in law;
• if the processing is for statistical or research purposes and all legal conditions are met;
• if the special personal information was made public by you;
• if the processing is required by law;
• if racial information is processed, and the processing is required to identify you; or if health information is processed, and the processing is to determine your insurance risk, or to comply with an insurance policy or to enforce an insurance right or obligation.

(When and from where we obtain personal information about you)

• We collect personal information from you directly.
• We collect information about you based on your use of our products or services.
• We collect information about you based on how you engage or interact with us such as via our support desk, emails, letters, telephone calls, website and surveys.
• We collect personal information from completed forms eg contact and billing information, booking forms, registration forms, feedback review forms, online enquiries and the like.
• We collect personal information from 3rd parties that are directly integrated with our software platform.
• We may collect personal information from a public record or if you have deliberately made the information public.

If the law requires us to do so, we will ask for your consent before collecting personal information about you from third parties.

The third parties from whom we may collect your personal information include, but are not limited to, the following:

• companies associated with our company for any of the purposes identified in this Privacy Policy;
• your spouse, dependents, partner, employer, and other similar sources;
• people you have authorised to share your personal information, such as a person who makes a booking on your behalf or a medical practitioner for insurance purposes;
• attorneys, tracing agents, debt collectors and other persons who assist with the enforcement of agreements;
• payment processing services providers, merchants, banks and other persons who assist with the processing of your payment instructions;
• insurers, brokers, other financial institutions or other organisations that assist with insurance and assurance underwriting, the providing of insurance and assurance policies and products, the assessment of insurance and assurance claims and other related purposes;
• law enforcement and fraud prevention agencies and other persons tasked with the prevention and prosecution of crime;
• regulatory authorities, industry ombudsman, governmental departments, local and international tax authorities;
• trustees, executors or curators appointed by a court or legal authority;
• our service providers, agents and sub-contractors and other persons we use to offer and provide services to you;
• courts of law or tribunals;
• participating partners, whether retail or online, in any customer loyalty reward programmes.

(Reasons we need to process your personal information)

We will process your personal information for the following reasons:

• to provide you with products and services;
• to market our products and services to you;
• to respond to your enquiries and complaints;
• to provide you with invoices, statements, reports, quotations and confirmations;
• to comply with legislative, regulatory, risk and compliance requirements (including directives, sanctions and rules), voluntary and involuntary codes of conduct and industry agreements or to fulfil reporting requirements and information requests;
• to conduct market and behavioural research, including scoring and analysis to determine if you qualify for products and services or to determine your credit or insurance risk;
• to develop, test and improve products and services for you;
• for historical, statistical and research purposes, like market segmentation;
• to process payment instruments;
• to create, manufacture and print payment advice;
• to enable us to deliver documents or notices to you;
• for security, identity verification and to check the accuracy of your personal information;
• to communicate with you and carry out your instructions and requests;
• for customer satisfaction surveys, promotional offerings;
• insurance and assurance underwriting and administration;
• to process or consider or assess insurance or assurance claims;
• to provide insurance and assurance policies and products and related services;
• to enable you to take part in customer loyalty reward programmes, to determine your qualification for participation, earning of reward points, determining your rewards level, monitoring your buying behaviour with our rewards partners to allocate the correct points or inform you of appropriate products and services you may be interested in or to inform our reward partners about your purchasing behaviour;
• to enable you to take part in and make use of value-added services;
• to assess our lending and insurance risks;
• for any other related purposes.

(How we use your personal information for marketing)

• We will use your personal information to market our products and services to you.
• We will do this in person, by post, telephone, or electronic communication such as SMS, email and fax.
• If you are not our customer, or in any other instances where the law requires, we will only market to you by electronic communication with your consent.
• In all cases you can request us to stop sending marketing communications to you at any time.

(When, how and with whom we share your personal information)

In general, we will only share your personal information if any one or more of the following apply:

• if you have consented to this;
• if it is necessary to conclude or perform under a contract we have with you;
• if the law requires it;
• if it’s necessary to protect or pursue your, our, or a third party’s legitimate interests.

Where required, the company may share your personal information with the following persons. These persons have an obligation to keep your personal information secure and confidential:

• other members of the company or appointed third parties (like its authorised agents, partners, contractors, cessionaries and suppliers) for any of the purposes identified in this Privacy Policy;
• our employees as required by their employment conditions;
• attorneys, tracing agents, debt collectors and other persons that assist with the enforcement of agreements;
• payment processing services providers, merchants, banks and other persons that assist with the processing of your payment instructions;
• law enforcement and fraud prevention agencies and other persons tasked with the prevention and prosecution of crime;
• Regulatory authorities, industry ombudsmen, governmental departments, local and international tax authorities and other persons the law requires us to share your personal information with;
• our service providers, agents and sub-contractors and other persons we use to offer and provide products and services to you;
• persons to whom we have ceded our rights or delegated our obligations to under agreements, like where a business is sold;
• courts of law or tribunals that require the personal information to adjudicate referrals, actions or applications;
• trustees, executors or curators appointed by a court of law or legal authority;
• participating partners in our customer loyalty reward programmes, where you purchase products and service or spend loyalty rewards;
• our joint venture and other partners with whom we have concluded business agreements, for your benefit.

(Under what circumstances will we transfer your information to other countries?)

We will only transfer your personal information to third parties in another country in any one or more of the following circumstances:

• where the transfer is necessary to enter into or perform under a contract with you, or a contract with a third party that is in your interest;
• where you have consented to the transfer;
• where it is not reasonably practical to obtain your consent, the transfer is in your interest
• where your personal information will be adequately protected under the other country’s laws or an agreement with the third party recipient.

This transfer will take place within the requirements and safeguards of the law. Where possible, the party processing your personal information in the other country will agree to apply the same level of protection as available by law in our country or if the other country’s laws provide better protection, the other country’s laws would be agreed to and applied.

(Your duties and rights about the personal information we have about you)

• You must provide proof of identity when enforcing the rights below.
• You must inform us when your personal information changes.

Please refer to our Promotion of Access to Information Act 2 of 2000 Manual (PAIA Manual) for further information on how you can give effect to the rights listed below. The PAIA Manual can be found on our website.

You have the right to request access to the personal information we have about you by contacting us. This includes requesting:

• confirmation that we hold your personal information;
• a copy or description of the record containing your personal information; and
• the identity or categories of third parties who have had access to your personal information.

We will attend to requests for access to personal information within a reasonable time. You may be required to pay a fee to receive copies or descriptions of records, or information about third parties. We will inform you of the fee before attending to your request.

Please note that the law may limit your right to access information.

You have the right to request us to correct or delete the personal information we have about you if it is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, obtained unlawfully or we are no longer authorised to keep it. You must inform us of your request in writing. Please refer to our PAIA Manual for further information in this regard, like the process you should follow to give effect to this right. It may take up to 15 business days for the change to reflect on our systems. We may request documents from you to verify the change in personal information.

A specific agreement that you have entered into with us may determine how you must change your personal information provided at the time when you entered into the specific agreement. Please adhere to these requirements. If the law requires us to keep the personal information, it will not be deleted upon your request. The deletion of certain personal information may lead to the termination of your business relationship with us.

You may object on reasonable grounds to the processing of your personal information.

We will not be able to give effect to your objection if the processing of your personal information was and is permitted by law; you have provided consent to the processing and our processing was done according to your consent or the processing is necessary to conclude or perform under a contract with you.

Where you have provided your consent for the processing of your personal information, you may withdraw your consent. If you withdraw your consent we will explain the consequences to you. We may proceed to process your personal information even if you have withdrawn your consent if the law permits or requires it. It may take up to 15 business days for the change to reflect on our systems. During this time we may still process your personal information. You must inform us of any objection in writing. Please refer to our PAIA Manual for further information in this regard, like the process you should follow to give effect to this right.

You have a right to file a complaint with us or any Regulator with jurisdiction about an alleged contravention of the protection of your personal information by us. We will address your complaint as far as possible.

(How we secure your personal information)

We will take appropriate and reasonable technical and organisational steps to protect your personal information according to industry best practices. Our security measures (including physical, technological and procedural safeguards) will be appropriate and reasonable. This includes the following:

• keeping our systems secure (like monitoring access and usage);
• storing our records securely;
• controlling the access to our buildings, systems and/or records;
• safely destroying or deleting records;
• ensuring compliance with international security standards.

(How long do we keep your personal information?)

We will keep your personal information for as long as:

• the law requires us to keep it;
  
• a contract between you and us requires us to keep it;
• you have consented for us to keep it;
• we are required to keep it to achieve the purposes listed in this Privacy Policy;
• we require it for statistical or research purposes;
• a code of conduct requires us to keep it;
• we require it for our lawful business purposes.

Please note: We may keep your personal information even if you no longer have a relationship with us, for the historical data that may be required by your employer.

(Our cookie policy)

Cookies are small text files that websites place and store on the computers and mobile devices of website users. These files are generally used to recognise you, remember you and your preferences to improve your user experience. We may also use cookies to prevent fraud and for analytics.

Cookies may contain personal information. By using our websites or applications you agree that cookies may be used.

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