Protection of Personal Information Act (POPI Act)
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.
In this document any reference to “we” or “us” or “our” includes Our Company and any of its subsidiaries.
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:
· 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 interests.
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.
TAKE NOTE: We are a global organisation your personal information may be shared within all our company entities in other countries and processed in those countries.
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 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.
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.
We also use “web beacons” to help deliver cookies and gather usage and performance data. Our websites may include web beacons, cookies or similar technologies from third-party service providers.
Some of the cookies we commonly use are listed below. This list is not exhaustive, but it is intended to illustrate the primary purposes for which we typically set cookies. If you visit one of our websites, the site will set some or all of the following cookies:
In addition to the cookies TTG sets when you visit our websites, third parties can also set cookies when you visit TTG sites. For example:
How to Control Cookies
Most web browsers automatically accept cookies but provide controls that allow you to block or delete them. For example, in Microsoft Edge, you can block or delete cookies by clicking Settings > Privacy > Cookies. Please refer to your browser’s privacy or help documentation to find Instructions for blocking or deleting cookies in other browsers.
Certain features of TTG products depend on cookies. If you choose to block cookies, you cannot sign in or use some of those features, and preferences that are dependent on cookies will be lost. If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, will be deleted and may need to be recreated.
Additional privacy controls that can impact cookies, including the Tracking Protection feature of web browsers, are described in the Access and Control section of this privacy statement.
Our Use of Web Beacons and Analytics Services
Some TTG web pages contain electronic tags known as web beacons that we use to help deliver cookies on our websites, count users who have visited those websites and deliver co-branded products. We also include web beacons or similar technologies in our electronic communications to determine whether you open and act on them.
In addition to placing web beacons on our own websites, we sometimes work with other companies to place our web beacons on their websites or in their advertisements. This helps us develop statistics on how often clicking on an advertisement on a TTG website results in a purchase or other action on the advertiser’s website.
Finally, TTG products often contain web beacons or similar technologies from third-party analytics providers, which help us compile aggregated statistics about the effectiveness of our promotional campaigns or other operations. These technologies enable the analytics providers to set or read their own cookies or other identifiers on your device, through which they can collect information about your online activities across applications, websites or other products. However, we prohibit these analytics providers from using web beacons on our sites to collect or access information that directly identifies you (such as your name or email address). You can get help on how opt out of data collection or use by some of these analytics providers by clicking the following links:
Other Similar Technologies
In addition to standard cookies and web beacons, our products can also use other similar technologies to store and read data files on your computer. This is typically done to maintain your preferences or to improve speed and performance by storing certain files locally. But, like standard cookies, these technologies can also store a unique identifier for your computer, which can then track behaviour. These technologies include Local Shared Objects (or “Flash cookies”) and Silverlight App Storage.
Local Shared Objects or “Flash cookies”. Websites that use Adobe Flash technologies can use Local Shared Objects or “Flash cookies” to store data on your computer. To manage or block Flash cookies, go to http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html
Silverlight Application Storage. Websites or applications that use Microsoft Silverlight technology also have the ability to store data by using Silverlight Application Storage. To learn how to manage or block such storage, see the Silverlight section of this statement.
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