Privacy Policy

The Protection of Personal Information Act, 2013 ("POPI") came into complete commencement on 1 July 2021. In this regard, we have a number of obligations and duties in terms of POPI that we must comply with. The protection of your personal information is a high priority for us, and we have taken steps to ensure that your personal information is protected and remains private.

In addition to this document serving as our privacy policy, it will also serve as our data subject notification as contemplated in section 18 of POPI. This document informs you of what personal information we collect, why we collect it, how we use it and what safety measures are in place to protect it.

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, provide a product or carry out a transaction.

We may combine your personal information and use the combined personal information for any of the purposes stated in this Privacy Policy.

In this document, any reference to "we", "us" or "our" is a reference to Imveliso Group (Pty) Ltd.

If you use our services, goods and/or products, you agree that we may process your personal information as explained under this Privacy Policy.

We may change this Privacy Policy from time to time if the law or our business practices require it. The version of the Privacy Policy displayed on our website at the time of your interaction with us will apply.

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:

• Age
• Financial history
• Personal views
• Belief
• Gender
• Physical address
• Birth
• Identity number
• Physical health
• Biometric information
• Language
• Pregnancy
• Colour
• Location information
• Race
• Conscience
• Marital status
• Religion
• Correspondence
• Mental health
• Sex
• Criminal history
• Medical history
• Sexual orientation
• Culture
• Name
• Social origin
• Disability
• National origin
• Symbol
• Education
• Online identifier
• Telephone number
• Email address
• Other particular assignment
• Well-being
• Employment history
• Personal opinions
• Ethnic origin
• Personal preferences

Is the supply of personal information voluntary or mandatory?

The supply of certain personal information is mandatory, meaning we have to collect this personal information from you by law. If you do not supply this information, we cannot comply with our legal obligations and cannot do business with you. We collect personal information as required by the following legislation:

• Basic Conditions of Employment Act, No. 75 of 1997
• Continuing Education and Training Act (previously known as Further Education and Training Colleges Act), No. 16 of 2006
• Compensation for Occupational Injuries and Diseases Act, No. 130 of 1993
• Credit Agreements Act, No. 75 of 1980
• Criminal Procedure Act, No. 51 of 1977
• Debt Collectors Act, No. 114 of 1998
• Employment Equity Act, No. 55 of 1998
• Financial Intelligence Centre Act, No. 38 of 2001
• Higher Education Act, No. 101 of 1997
• Income Tax Act, No. 58 of 1962
• Labour Relations Act, No. 66 of 1995
• National Credit Act, No. 34 of 2005
• NQF Act, No. 67 of 2008
• Pension Funds Act, No. 24 of 1956
• Skills Development Act, No. 97 of 1998
• Unemployment Insurance Act, No. 63 of 2001
• Financial Advisory and Intermediary Services Act, No. 37 of 2002
• Occupational Health and Safety Act, No. 85 of 1993
• Prevention of Organised Crime Act, No. 121 of 1998

In other instances, the supply of personal information is voluntary, which means there is no law imposed on us to collect it. Even though there is no law that imposes the collection of the personal information, we require it to deliver products and/or services to you. If you do not supply it, we cannot do business with you.

When will we process your personal information?

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

• You have consented to it.
• A person legally authorised by you, the law or a court has consented to it.
• It is necessary to conclude or perform under a contract we have with you.
• The law requires or permits it.
• 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:

• Biometric information
• Philosophical beliefs
• Sex life
• Criminal behaviour
• Political persuasion
• Trade union membership
• Ethnic origin
• Race
• Health
• Religious beliefs

When will we process your special personal information?

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

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

When and from where do we obtain personal information about you?

We may collect personal information about you from the following sources:

• Directly from you.
• From a public record.
• From an area where you have deliberately made it public.
• Based on your use of our products, services or service channels.
• Based on how you engage or interact with us, such as via our support desk, emails, letters, telephone calls and surveys.
• From a third party.
• From another source if you give us consent to do so.

If the law requires us to do so, we will ask for your consent before collecting personal information about you from third parties. Third parties from whom we may collect your personal information include, but are not limited to:

• Partners of our company for any of the purposes identified in this Privacy Policy.
• Your spouse, dependents, partners, employer and other similar sources.
• Attorneys, tracing agents, debt collectors and other persons that assist with the enforcement of agreements.
• Payment processing service providers, merchants, banks and other persons that assist with processing your payment instructions, such as EFT transaction partners.
• Insurers, brokers, other financial institutions or other organisations that assist with insurance and assurance underwriting, providing insurance and assurance policies and products, assessing insurance and assurance claims and related purposes.
• Law enforcement and fraud prevention agencies and other persons tasked with the prevention and prosecution of crime.
• Regulatory authorities, industry ombudsmen, governmental departments, and local and international tax authorities.
• Trustees, executors or curators appointed by a court of law.
• Our service providers, agents and sub-contractors, such as couriers and others we use to offer and provide products and services to you.
• Courts of law or tribunals.

Reasons we need to process your personal information

We will process your personal information for the following reasons:

• To provide you with products, goods and services.
• To market our products, goods and services to you.
• To respond to your enquiries and complaints.
• 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, such as market segmentation.
• To process payment instruments.
• To create, manufacture and print payment issues, such as a payslip.
• To enable us to deliver goods, 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 and promotional offerings.
• For insurance and assurance underwriting and administration.
• To process, 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, determine your qualification for participation, earn reward points, determine your rewards level, monitor your buying behaviour with rewards partners to allocate the correct points, inform you of appropriate products, goods and services you may be interested in, or inform rewards partners about your purchasing behaviour.
• To enable you to take part in and make use of value-added products and 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 channels such as SMS, email and fax.
• If you are not our customer, or in other instances where the law requires, we will only market to you by electronic communications 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 do we share your personal information?

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

• You have consented to it.
• It is necessary to conclude or perform under a contract we have with you.
• The law requires it.
• It is necessary to protect or pursue your, our or a third party's legitimate interest.

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 one or more of the following circumstances:

• Your personal information will be adequately protected under the other country's laws or an agreement with the third-party recipient.
• 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.
• You have consented to the transfer.
• It is not reasonably practical to obtain your consent and 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, those laws will be agreed to and applied.

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:

• Keeping our systems secure, such as monitoring access and usage.
• Storing our records securely.
• Controlling access to our buildings, systems and/or records.
• Safely destroying or deleting records.
• Ensuring compliance with best practice 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 to us keeping 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.

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

Our cookie policy

A cookie is a small piece of data sent from our websites or applications to your computer or device 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. The cookie will also identify your device, such as your 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 enables us to know that you have visited the website or application before and will identify you. We may also use cookies to prevent fraud and for analytics.

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 contact our Information Officer to give effect to any of the rights below.

Access to your personal information

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.
• 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.

Correction or deletion

You have the right to request that we correct or delete 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. 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.

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

Objection and withdrawal of consent

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 processing is permitted by law, you have provided consent and our processing is done according to your consent, or processing is necessary to conclude or perform under a contract with you.

Where you have provided consent for processing, you may withdraw your consent. If you withdraw your consent, we will explain the consequences. We may continue to process your personal information 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.

Complaints

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.

The contact details for the Information Regulator are: