Data Protection Statement
1.
Overview
1.1. Where we refer to “process”, it means how we collect, use, store, make available, destroy, update,
disclose, or otherwise deal with personal information. As a rule, we will only process this personal information if it is required to deliver or offer a
service, provide a product, carry out a transaction, or fulfill an obligation in a
contract.
1.2. We may combine this personal information and use the
combined personal information for any of the purposes stated in this Privacy
Policy.
1.3. If you use our other services, goods, products, and service channels, you agree that we may process this personal information as explained
under this Privacy Policy. Sometimes you may provide us with consent to process this personal information.
1.4. The Company operates in a global setting, and as
such, this Privacy Policy will apply to the processing of personal information
by any member of the Company globally. If the Company processes personal information for another party under a
contract or a mandate, the other party’s privacy policy will apply to the
processing of
such information.
1.5. The Company can change this Privacy Policy from time to
time if the law or our business practices require such change.
1.6. This policy establishes a general standard for the
appropriate protection of personal information (POPI) within the Company environment. Furthermore, it provides
principles regarding the rights of individuals to privacy and reasonable safeguards of their personal information.
2. Scope Document
2.1. All employees, contractors, consultants, temporary and
other workers at the Company, including all personnel affiliated with third
parties, must adhere to this policy. This policy applies to information assets
owned or leased by the Company, or to devices that connect to a Company network or reside at a Company site.
3. Policy
Statement
3.1. What is personal information? Personal information
refers to any information that identifies you or specifically relates to you, or your employees, stored or processed on the Product/s. Personal information
includes, but is not limited to, the following information about you and/or your employees:
3.1.1. Marital status
3.1.2. National origin
3.1.3. Age
3.1.4. Language
3.1.5. Birthplace
3.1.6. Education
3.1.7. Relevant financial history
3.1.8. Identifying number (like an employee number, identity
number, or passport number)
3.1.9. E-mail address, physical address (like residential
address, work address, or your physical location), and telephone number
3.1.10. Biometric information (like fingerprints, signature,
or voice)
3.1.11. Race; gender; sex; pregnancy status; ethnic origin; social origin;
colour; sexual orientation
3.1.12. Physical health; mental health; well-being;
disability; religion; belief; conscience; culture
3.1.13. Medical history, criminal history, and employment
history
3.1.14. Personal views, preferences, and opinions
3.1.15. Another’s views or opinions about you
3.1.16. Full names and initials. Personal information
includes special personal information, as explained below.
3.2. When will we process your personal information?
We will only process this personal information for lawful
purposes relating to our business if the following applies:
3.2.1. If you have consented thereto
3.2.2. If a person legally authorised by you, the law, or a court, has
consented thereto.
3.2.3. If it is necessary to conclude or perform under a contract, we have with you.
3.2.4. If the law requires or permits it.
3.2.5. If it is required to protect or pursue your, our , or a third party’s legitimate interest.
3.3. What is special personal information?
Special personal information is personal information about
the following:
3.3.1. Race (like where a company submits reports to the
Department of Labour, where the statistical information must be recorded)
3.3.2. Ethnic origin. 3.3.3. Trade union membership
3.3.4. Health (like where you apply for an insurance policy)
3.3.5. Biometric information (like to verify your
identity); and / or your criminal behaviour and alleged commission of an offense.
3.4. When will we process your special personal
information?
We may process your special personal information in the
following circumstances:
3.4.1. If you have consented to the processing
3.4.2. If the information is being used for any Human Resource or payroll-related requirement
3.4.3. If the processing is needed to create, use, or protect
a right or obligation in law.
3.4.4. If the processing is for statistical or research
purposes and all legal conditions are met
3.4.5. If the special personal information was made public by you
3.4.6. If the processing is required by law
3.5. When and from where we obtain personal
information about you
3.5.1. We collect personal information from you directly.
3.5.2. We may collect personal information from a public
record or if you have deliberately made the information public.
3.5.3. We collect personal information from 3rd parties that are directly integrated
with our software platform. Document Number:
3.5.4. We collect information about you based on your use of our products, services, or service
channels.
3.5.5. We collect information about you based on how you engage or interact with us, such as via emails, letters, telephone calls, and surveys.
3.5.6. We collect personal information from completed forms, i.e., contact and billing information. If the law requires us to do so, we will ask for your consent before collecting personal
information.
The third parties from whom we may collect your personal information include, but are not limited to, the
following:
3.5.7. Our partners, your employer, employees directly, any of our other Bureau or channel partners and
any connected companies, subsidiary companies, its associates, cessionaries, delegates, assigns,
affiliates or successors in title and/or appointed third parties (like its
authorised agents, partners, contractors, and suppliers) for any of the
purposes identified in this Privacy Policy.
3.5.8. Your spouse, dependents, partners, employer, and other similar
sources.
3.5.9. People you have authorised to share your personal information, like a person who
makes a travel booking on your behalf or a medical practitioner for insurance purposes.
3.5.10. Attorneys, tracing agents, debt collectors, and other
persons who assist with the enforcement of agreements.
3.5.11. Payment processing services providers, merchants,
banks, and other persons that assist with the processing of your payment instructions, like EFT
transaction partners.
3.5.12. 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.
3.5.13. Law enforcement and fraud prevention agencies, and
other persons tasked with the prevention and prosecution of crime.
3.5.14. Regulatory authorities, industry ombudsman,
governmental departments, local and international tax authorities.
3.5.15. Trustees, Executors, or Curators appointed by a court
of law.
3.5.16. Our service providers, agents, and subcontractors, like couriers
and other persons, we use to offer and provide products and services to you. Document Number:
3.5.17. Courts of law or tribunals. 3.6. Reasons we need to
process your personal information.
3.6. We will process your personal information for the
following reasons:
3.6.1. To provide you with products, goods, and services.
3.6.2. To market our products, goods, and services to you.
3.6.3. To respond to your enquiries and complaints.
3.6.4. 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.
3.6.5. 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.
3.6.6. To develop, test, and improve products and services
for you.
3.6.7. For historical, statistical, and research purposes,
like market segmentation.
3.6.8. To process payment instruments.
3.6.9. To create, manufacture, and print payment advice.
3.6.10. To enable us to deliver goods, documents, or
notices to you.
3.6.11. For security, identity verification, and to check the
accuracy of your personal information.
3.6.12. To communicate with you and carry out your instructions and requests.
3.6.13. For customer satisfaction surveys, promotional
offerings.
3.6.14. To enable you to take part in and make use of
value-added products and services.
3.6.15. To assess our lending and insurance risks; and / or
3.6.16. For any other related purposes.
3.7. How we use your personal information
for marketing purposes
3.7.1. We will use your personal information to market our services, related products, and services to you.
3.7.2. We may also market non-banking or non-financial products, goods,
or services to you.
3.7.3. We will do this in person, by post, telephone, or electronic
channels such as SMS, email, and fax. Document Number:
3.7.4. If you are not our customer, or in any other instances where the law requires, we will only market to you by electronic communications with your consent.
3.7.5. In all cases, you can request us to stop sending marketing
communications to you at any time
3.8. 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:
3.8.1. If you have consented to this
3.8.2. If it is necessary to conclude or perform under a contract, we have with you
3.8.3. If the law requires it; and / or
3.8.4. If it’s necessary to protect or pursue your, our, or a third party’s legitimate interests. Where required, each member of the company may share your personal information with the
following persons. These persons have an obligation to keep your personal information secure and
confidential.
3.8.5. Other members of the Company, its associates,
cessionary, delegates, assigns, affiliates, or successors in title and/or
appointed third parties (like its authorised agents, partners, contractors, and
suppliers) for any of the purposes identified in this Privacy Policy.
3.8.6. Our employees as required by their employment conditions.
3.8.7. Attorneys, tracing agents, debt collectors, and other
persons who assist with the enforcement of agreements.
3.8.8. Payment processing services providers, merchants,
banks, and other persons that assist with the processing of your payment instructions, like 3rd party EFT service providers.
3.8.9. Law enforcement and fraud prevention agencies and
other persons tasked with the prevention and prosecution of crime.
3.8.10. Regulatory authorities, industry ombudsmen,
governmental departments, local and international tax authorities, and other
persons the law requires us to share your personal information with
3.8.11. Our service providers, agents, and subcontractors, like couriers
and other persons, we use to offer and provide products and services to you
3.8.12. Persons to whom we have ceded our rights or delegated our obligations under agreements, like
where a business is sold
3.8.13. Courts of law or tribunals that require the personal
information to adjudicate referrals, actions, or applications.
3.8.14. Trustees, Executors, or Curators appointed by a court
of law
3.8.15. Participating partners in our customer loyalty reward programmes,
where you purchase goods, products, and services
or spend loyalty rewards; and/or our joint venture and other partners with whom we have concluded business agreements,
for your benefit.
3.9. 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:
3.9.1. Where your personal information will be adequately protected under the
other country’s laws or an
agreement with the third-party recipient
3.9.2. 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.
3.9.3. Where you have consented to the transfer, and/or
3.9.4. Where it is not reasonably practical to obtain your consent, the transfer is in your interest.
This transfer will happen 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 your country, or if the other country’s
laws provide better protection, the other country’s laws would be agreed to and
applied.
An example of us transferring your personal information to another country is where foreign
payments take place if you purchase goods or services in a foreign country, or request
that we facilitate salary payments to your employees in the country.
3.10. 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. You have the right to request access to
the personal information we have about you by contacting us.
This includes requesting:
3.10.1. Confirmation that we hold your personal information.
3.10.2. A copy or description of the record containing your personal information; and
3.10.3. 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 reasonable 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 with us may determine how you must change your personal information provided at the
time 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
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 is done according to your consent or the processing is
necessary to conclude or perform under a contract with you.
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.
If 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 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.
3.11. How do 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:
3.11.1. Keeping our systems secure (like monitoring
access and usage)
3.11.2. Storing our records securely
3.11.3. Controlling access to our buildings, systems, and/or records;
and
3.11.4. Safely
destroying or deleting records
3.11.5. Ensure compliance with international security standards.
3.12. How long do we keep your personal information?
We will keep your personal information for as long as:
3.12.1. The law requires us to keep it
3.12.2. A contract between you and us requires us to keep it
3.12.3. You have consented to us keeping it
3.12.4. We are required to keep it to achieve the purposes listed in
this Privacy Policy.
3.12.5. We require it for statistical or research purposes.
3.12.6. A code of conduct requires us to keep it.
3.12.7. We require it for our lawful business purposes.
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 or employee.
3.13. Children's Privacy
Our Service does not address anyone under the age of 13.
We do not knowingly collect personally identifiable
information from anyone under the age of 13. If you are a parent or guardian
and you are aware that your child has provided the Company with Personal Data, please contact us.
If we become aware that We have collected Personal Data from
anyone under the age of 13 without verification of parental consent, we take steps to remove that information
from our servers.
If we need to rely on consent as a legal basis for processing
your information and your country requires consent from a parent, we may require your parent's consent
before we collect and use that information.
3.14. Our cookie policy
A cookie is a small
piece of data sent from our websites or applications to your computer or device's hard drive or
Internet browser, where it is saved. The cookie contains information to personalise your experience on our websites or applications and may
improve your experience on the websites or
applications.
The cookie will also identify your device, like a computer or smartphone. By using our websites or applications, you agree that cookies may be forwarded
from the relevant website or application to your computer or device. The cookie will
enable us to know that you have visited the website or
application before and will identify you. We may also use the cookie to prevent
fraud and for analytics.
3.15. Safekeeping Requirements
All records must be stored in the pre-allocation location.
All physical copies need to be stored in a lockable cabinet or drawer.
3.16. Enforcement
An employee found to have violated this policy may be subject
to disciplinary action, up to and including termination of employment. A
violation of this policy by a temporary worker, contractor, or vendor may result in the
termination of their contract or assignment with the Company. Any exception to the
policy must comply
with the exceptions Policy.