The purpose of our Privacy Statement is to inform the reader of how The Company manages and processes (any operation or set of operations performed on data by any means such as collecting, recording, organisation, storage, adaptation, or alteration of personal information etc.) personal information. The way The Company manages Personal Information (personal data, as defined in the data protection laws, includes, but is not limited to, names, postal address, email address, telephone number, date of birth etc.), is subject to the Electronic Communications and Transactions Act 25 of 2002; Protection of Personal Information Act 4 of 2013 and the European Union General Data Protection Regulations (“Data Protection Laws”). When users (individuals who make use of any The Company website and/or applications) interact with The Company, submit information to The Company, or sign up for any products and/or services offered by The Company, all personal information, which may be collected through our website or other channels, is treated as confidential and private. The Company manages the user’s personal information in the following ways:
- By collecting personal information.
- Using such personal information.
- Sharing (amongst ourselves) the users personal information; and
- Disclosing such personal information to The Company’s authorised service providers as well as relevant third parties in the manner set forth in this Privacy Statement.
The Company may from time to time update this document to ensure that it is consistent with future developments, industry trends and/or any changes in legal or regulatory requirements.
Generally, The Company collects user Personal Information in the following ways:
- Upon submission of an application form or other forms relating to any of The Company’s products and services.
- When making use of any The Company service i.e., Websites and/or applications.
- Upon submission of a request for The Company to contact them, or request to be included in an email or other mailing lists.
- When there is a response to The Company promotions, initiatives or to any request for additional Personal Data.
- When The Company receives references from business partners and third parties.
- When The Company seeks information from third parties in connection with the products and services applied for; and
- Upon submitting Personal Information to The Company for any other reason.
When a user browses The Company Website, it is generally done anonymously. The Company does not automatically collect Personal Information unless such information is provided, or login credentials are used.
If The Company is provided with any Personal Information relating to a third party (e.g., information about a spouse, children, parents and/or employees), by submitting such information, a user confirms that the consent of the third party to provide The Company with such personal information has been obtained.
Users must ensure that all Personal information submitted to The Company is complete, accurate, true, and correct. Failure to do so may result in The Company’s inability to provide users with the products and services requested.
Generally, The Company collects, uses, and discloses Personal Information of users for the following purposes:
- To respond to queries and requests.
- To manage the administrative and business operations of The Company and comply with internal policies and procedures.
- To resolve complaints and handle requests and/or enquiries.
- To prevent, detect, investigate a crime, analyse, and manage commercial risks.
- To monitor or record phone calls and client-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes.
- For legal purposes (including but not limited to obtaining legal advice and dispute resolution).
- To conduct investigations relating to disputes, billing, suspected illegal activities or fraud.
- To meet or comply with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on The Company (including but not limited to responding to regulatory complaints, reporting to regulatory bodies, and conducting audit checks, due diligence, and investigations); and
- For purposes which are reasonably related to the aforementioned.
By providing Personal Information to The Company, users acknowledge that the information has been collected from them directly and there is consent for The Company to process such information.
Where users submit Personal Information (such as name, address, telephone number and email address) via The Company Website (e.g., through completing any online form) the following principles are observed in the processing of such information:
- The Company will only collect Personal Information for a purpose consistent with the purpose for which it is required. The specific purpose for which information is collected will be apparent from the context in which it is requested.
- The Company will only process Personal Information in a manner that is adequate, relevant, and not excessive in the context of the purpose for which it is processed.
- Personal Information will only be processed for a purpose compatible with that for which it was collected, unless the user has agreed to an alternative purpose in writing, or The Company is permitted in terms of national legislation of general application dealing primarily with the protection of Personal Information.
- The Company will keep a record of all Personal Information collected and the specific purpose for which it was collected for a period of 1 (one) year from the date on which it was last used.
- The Company will not disclose user Personal Information relating to any third party, unless prior written consent from the user is obtained, or where The Company is required to do so by law.
- If Personal Information is released with consent of the user, The Company will retain a record of the information released, the third party to which it was released, the reason for the release and the date of release, for a period of 1 (one) year from the date on which it was last used.
- The Company will destroy or delete any Personal Information that is no longer needed by The Company for the purpose it was initially collected, or subsequently processed.
The Company will take reasonable steps to protect Personal Information of users against unauthorised disclosures. Subject to the provisions of any applicable law, Personal Information may be disclosed for the purposes listed above (where applicable) to the following:
- The Company’s employees to provide content, products, and services to address user questions and requests in relation to client accounts, subscription, and billing arrangements with The Company as well as products and services.
- Companies providing services relating to insurance and consultancy to The Company.
- Agents, contractors, or third-party service providers who provide operational services to The Company, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security, or other services to The Company.
- Vendors or third-party service providers in connection with marketing promotions and services offered by The Company.
- Other telecommunications, content, or other service providers to facilitate their provision of content or services, or for interconnection, inter-operability, system operation and maintenance and billing between service providers.
- Collection and repossession agencies in relation to the enforcement of repayment obligations for debts.
- Credit bureaus for the purpose of preparing credit reports or evaluation of creditworthiness.
- External banks, credit card companies and their respective service providers.
- The Company’s professional advisers such as auditors and lawyers.
- Relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and
- Any other party to whom users authorised The Company to disclose Personal Information to.
If a user:
- Would like to withdraw consent to any use of their Personal Information as set out in this Privacy Statement, they may contact the business unit executive that manages their account.
- Would like to obtain access and make corrections to their Personal Information records, they may contact the business unit executive that manages their account.
If your Personal Information has been provided to The Company by a third party (e.g., a referrer), users should contact that organisation or individual to make such queries, complaints, and access correction requests to The Company on their behalf.
If a user withdraws their consent to any or all use of Personal Information, depending on the nature of such a request, The Company may not be able to continue to provide its products and services to users. In addition, The Company may not administer any contractual relationship in place, which in turn may also result in the termination of any agreements with The Company and may result in the user being in breach of contractual obligations or undertakings. The Company’s legal rights and remedies in such event are expressly reserved.
This Privacy Statement and use of the Website shall be governed in all respects by the laws of South Africa.