Standard Website Privacy &
Cookies Policy

 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” or “us” or “our” includes
Our Company and any of its subsidiaries.
If you use our services, goods, products, and service channels you
agree that we may process your personal information as explained under this
Privacy Policy. Sometimes you may provide us with consent to process your
personal information. Read it carefully because it may limit your rights.
As a global organisation this Privacy Policy will apply to the
processing of personal information by any member of our company globally. If we
process personal information for another party under a contract or a mandate,
the other party’s privacy policy will apply to the processing.
We can change this Privacy Policy from time to time if the law or
its business practices requires it.
The version of the Privacy Policy displayed on our website will
apply to your interactions with us.

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 (like married, single, divorced).
  • ·  your national origin.
  • ·     your age.
  • ·   your language; birth; 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 (like residential address,
    work address or your physical location); telephone number.
  • ·        
    your biometric information (like fingerprints, your signature or
    voice).
  • ·        
    your race; gender; sex; pregnancy; ethnic origin; social origin;
    colour; sexual orientation.
  • ·        
    your physical health; mental health; well-being; disability;
    religion; belief; conscience; culture.
  • ·        
    your medical history (like your HIV / AIDS status); criminal
    history; employment history.
  • ·        
    your personal views, preferences, and opinions.
  • ·        
    your confidential correspondence; and / or

·        
another’s views or opinions about you and your name also
constitute your personal information.

·        
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 thereto.

·        
if a person legally authorised by you, the law, or a court, has
consented thereto.

·        
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 (like where a company submits reports to the Department
of Labour where the statistical information must be recorded).

·        your ethnic origin.

·        your trade union membership.

·        your health (like where you apply for an insurance policy).

·        your biometric information (like to verify your identity); and /
or 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; and / 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 the payroll or HR departments
of our clients when they capture financial and non-financial information.

·        
We collect personal information from 3rd parties that are directly
integrated with our software platform.

·        
We collect information about you based on your use of our
products, services, or service channels.

·        
We collect information about you based on how you engage or
interact with us such as via our support desk, emails, letters, telephone calls
and surveys.

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:

·        
Partners of our company for any of the purposes identified in this
Privacy Policy.

·        
your spouse, dependents, partners, employer, and other similar sources.

·        
people you have authorised to share your personal information,
like a person that makes a travel booking on your behalf or a medical
practitioner for insurance purposes.

·        
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, like EFT
transaction partners.

·        
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 of law.

·        
our service providers, agents and sub-contractors like couriers
and other persons we use to offer and provide products and services to you.

·        
courts of law or tribunals.

·        
participating partners, whether retail or online, in our customer
loyalty reward programmes.

·        
our joint venture partners; and / or

Reasons we need to process your personal information.

·        
We will process your personal information for the following
reasons:

o    to provide
you with products, goods, and services

o    to market
our products, goods, and services to you.

o    to respond
to your enquiries and complaints.

o    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.

o    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.

o    to develop,
test and improve products and services for you.

o    for
historical, statistical and research purposes, like market segmentation.

o    to process
payment instruments.

o    to create,
manufacture and print payment issues (like a payslip)

o    to enable
us to deliver goods, documents, or notices to you.

o    for
security, identity verification and to check the accuracy of your personal information.

o    to
communicate with you and carry out your instructions and requests.

o    for
customer satisfaction surveys, promotional offerings.

o    insurance
and assurance underwriting and administration.

o    to process
or consider or assess insurance or assurance claims.

o    to provide
insurance and assurance policies and products and related services.

o    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, goods, and
services you may be interested in or to inform our reward partners about your
purchasing behaviour.

o    to enable
you to take part in and make use of value-added products and services.

o    to assess
our lending and insurance risks; and / or

o    for any
other related purposes.

How we use your personal information for marketing

·        
We will use your personal information to market financial,
insurance, investments and other related banking products and services to you.

·        
We may also market non-banking or non-financial products, goods,
or 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 any 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 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; and / or

·        
if it’s 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 any one or more of the following circumstances:

·        
where your personal information will be adequately protected under
the other country’s laws or an agreement with the third-party recipient.

·        
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; and / or

·        
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.

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. Download the PAIA Manual.

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 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 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 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;
and

·        
safely destroying or deleting records.

·        
Ensure compliance with international ISO security standards.

·        
You can also protect your personal information. Please visit the
website of the relevant business you have established a business relationship
with for more information.

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 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; and / or

·        
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 the 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 on the websites or
applications. The cookie will also identify your device, like the computer or
smart phone.

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.