FinChoice is committed to business practices in compliance with all applicable privacy legislation. FinChoice operates in different jurisdictions and the “applicable legislation” to which we refer in this policy includes (i) the South African Protection of Personal Information Act 4 of 2013 (“POPI”), the Mauritian Data Protection Act 20 of 2017 (“MU DPA”) and the Botswanan Data Protection Act 535 of 2018 (“Botswana DPA”). “Personal information” (or referred to simply as “information”) includes any personal information as specified in the applicable legislation.
In this policy “FinChoice” refers to any or all of (i) FinChoice SA (Pty) Limited in South Africa; (ii) FinChoice Africa Ltd – incorporated in Mauritius, and (iii) FinChoice Botswana – incorporated in Botswana, whichever applies in the context. This policy applies whenever we process personal information of a customer or a person that we regard as a potential customer (“you” or “customer”) who visits or makes use of any of our platforms or communicates with us through any channel. It also applies if you are a third-party and we process your information as a result of your relationship with our customers (for example if you are a beneficiary under a policy of our customer).
We may amend this policy from time to time, in line with changes required by legislation or our business. You must therefore review the policy whenever you visit any of our channels for any such changes. The amended version shall supersede and replace all previous versions. If you have any questions about it or do not agree with it, please contact us directly at email@example.com or by calling our contact centre at 0861 346 246. By entering into any agreement with us, or by applying to enter any such agreement, or by using our mobi site, or any other FinChoice platform you agree to the terms of this policy.
Different privacy policies may apply to employee and supplier information.
Securing Personal Information
FinChoice intends to protect your personal information and shall take reasonable internal technical and organisational security measures to prevent loss of or damage to personal information, unauthorised access, disclosure, modification, or unauthorised destruction of the data. However, information transmitted to us online (via the internet) is done so at your own risk. When entering your personal information via the internet, it is your responsibility to ensure that you use a secure computer or other electronic device. The internet is an open and often vulnerable system and the transfer of information via the internet is not completely secure, it is your responsibility to ensure that you always use a secure and trusted internet connection. Once we have received your personal information, we will store all information in secured environments, for example on secured servers in a protected data centre.
We also have physical and electronic access controls to our buildings.
We only authorise access to information to those employees who require it to fulfil their designated responsibilities.
When you use some of our electronic channels for transactions, you may be given an access number, username, password and/or personal identification number (PIN). You are responsible to keep all of this information safe and confidential.
Links on our channels or platforms
The FinChoice channels, platforms and our correspondence with you may include links to other apps or third-party websites which do not fall under our supervision. We cannot accept any responsibility for your privacy or the content of these third-party sites, but we display these links in order to make it easier for you to find information about specific subjects, products or services. Your use of and reliance on these links is at your own risk.
Your legal rights
You have certain rights in relation to your personal information. As available and except as limited by POPI, the MU DPA and the Botswana DPA, you have the following rights in respect of your personal information:
- right of access: the right to be informed of and request access to the personal information that we process about you;
- right to rectification: you may request that your personal information be amended or updated where it is inaccurate or incomplete;
- right to erasure: the right to request that we delete your personal information, subject to applicable limitations and exceptions;
- right to restrict processing: you may request that we temporarily or permanently stop processing your personal information;
- right to object: you may object to us processing your personal information, including to object to your personal information being processed for direct marketing purposes or in terms of;
- right not to be subject to automated decision-making: where a decision that has a legal or other significant effect is based solely on automated decision making, including profiling, you may, subject to certain exceptions, or request that your personal information not be processed in that manner.
Where you have previously provided consent for us to process your personal information, you may also withdraw your consent. However, we may continue to process or store your personal information if another legal justification exists for the processing or storage.
Quality and access to your information
Quality: we want to ensure that your personal information is accurate and up to date. You may ask us to correct or remove any personal information that you think is inaccurate, by sending us an email at firstname.lastname@example.org or calling our contact centre at 0861 346 246. Please also inform us promptly of any updates to your personal information.
Access: you have the right to request that we provide you with personal information that we hold about you. You must contact us directly to do so or send an email to email@example.com. This request may be subject to an access to information request in terms of applicable laws and may require you to verify your identity, identify the rights you are wishing to exercise and pay a fee.
The right to access your personal information may further be limited in terms of applicable law.
Categories of information collected and processed
- general personal information and contact details like name, ID numbers, address, contact numbers, email address, employment etc;
- financial, payment, banking and account information;
- demographic information;
- credit bureau and fraud;
- cookies and device information like browser settings, IP address, time of logging on etc;
- advertising and online information like your interactions with websites and platforms where we advertise our products;
- payment behaviour;
- your views, opinions preferences; and
- consent records
Collecting your information
We collect information about you as follows:
- directly if you provide it to us through any communication with us or via any FinChoice channel, including but not limited to our electronic channels, applications, our mobi site or our call centre;
- third party sources with whom we have contractual relationships to regulate the use of the information. These include the credit bureaus, verification companies, business affiliates, fraud agencies, and other companies within the HomeChoice International PLC group
- public sources, including social media
- cookies’ and
- friends and family.
How we use your personal information
We typically use your information for the following purposes:
- credit checks, fraud checks and affordability assessments;
- continuously determine your internal credit score with us, including receiving and considering any available information from the credit bureau, to identify and determine the products, services or credit for which you may reasonably qualify and market these to you and assist us with our compliance obligations in law;
- continuously use credit bureau information we hold for our compliance obligations in law;
- reporting to the credit bureau as required by law;
- update information from time to time through batch updates received from the credit bureau;
- perform in terms of any agreement with you;
- make, or assist in making, credit decisions about you and to verify the details that you have provided to us;
- operate and manage your account and manage any application, agreement or correspondence with us;
- manage any benefits you may receive as a result of an agreement between us and a customer;
- linking all information about you available within the HomeChoice International PLC group of companies to use it for legitimate business purposes, including but not limited to updating records, debt collection, making marketing selections and contacting you;
- carry out, monitor and analyse our business operations;
- contact you as allowed for in law by email, SMS, letter, telephone or in any other way about our products and services, or a third party’s products or services that may interest you, unless you tell us that you do not want to receive these marketing communications;
- identify or prevent fraud and money laundering;
- form a view of you as an individual and to identify, develop or improve products that may interest you;
- market research and the building of marketing or credit models;
- data science, modelling, statistical and analytical purposes,
- perform other administrative and operational processes including the testing of systems;
- trace you;
- recover any debt you owe us and/or for the purposes of on selling debt to a third-party;
- comply with our regulatory or other legal obligations;
- share information as set out in this policy, including with other companies within the HomeChoice International PLC group;
- carry out any other reasonable business operation considering our legitimate business interests and our relationship with you; and
- your information may also be used for other purposes for which you give your permission or where the law allows us to use it.
We aim to only process personal information in a manner that is adequate, relevant and not excessive, considering our purposes of use.
Some marketing and credit risk decisions are done solely through automated processes. In instances where these may have a legal impact or affect you significantly, we implement adequate measures to protect your legitimate interests.
If you qualify as our customer or we obtained your details in the context of a sale we will market to you unless you opt out. We share your information with other HomeChoice International PLC group companies, and they may also market to you unless you opt out. Where we believe that third party products outside of the group may interest you, we will also market these third-party products to you. You can always opt out from these. We will never sell your information to third-parties for marketing purposes.
Personal information about children and special/sensitive personal information
We will only process information about children with the consent of a competent person (someone like the parent or guardian) or if the applicable laws otherwise allow it.
We do not intend to use any ‘special/sensitive personal information’ as defined in the applicable laws, other than health related information when we offer you credit insurance, criminal behaviour for the purposes of assessing insurance claims or fraud related information when conducting compliance and risk assessments
Information we share
We will keep your personal information confidential and only share it for purposes set out in this policy or if you have consented thereto, or if we otherwise have a legal right or obligation to share it.
We have trusted relationships with various third-parties who provide services to us or on our behalf and who may process your personal information on our behalf. We will share information with them on a need-to-know basis and subject to a contract to maintain the security of your personal information and to use it for our specified purposes only.
In addition, we may share information with the following parties:
- debt collectors and payment distribution agencies for purposes relating to the credit agreement, including refunds to be processed;
- payment system service providers;
- regulatory and governmental authorities, ombudsmen, or other authorities, including tax authorities;
- credit Bureaus that collect information about credit applications;
- fraud prevention agencies or third-party fraud prevention applications;
- other companies within the HomeChoice International PLC group, to prepare offers and market to you and for other legitimate business purposes like providing services to companies within the HomeChoice International PLC group or for retention purposes;
- affiliates with whom you also hold a relationship, mostly to confirm details around your engagement with us.
- any third party to whom we sell or transfer a portion of our business; and
- any other third-party if we allowed to do so in law.
When you apply to us for any financial product or service, we may request your credit report which will provide us with your credit profile. Whether or not your application is successful, the credit bureau will place an enquiry (footprint) on your credit profile that may be seen by other credit providers. Large numbers of applications within a short time period may affect your credit profile.
We will report any security breach to both the Regulator and the individuals or companies involved. If you want to report any concerns about our privacy practices or if you suspect any breach regarding your personal information, kindly notify us by sending an email to firstname.lastname@example.org.
Right to object
You may, on reasonable grounds, object to us using your Information. If you object, we will stop using your information, except if the law allows its continued use or retention.
Lodging a complaint
If you believe we are using your information unlawfully, you may lodge a complaint directly to us at:
Contact Centre:0861 346 246
Alternatively, you may lodge a complaint to the appropriate Information Regulator with the following contact details:
South Africa: The Information Regulator
Address: SALU Building, 316 Thabo Sehume Street, Pretoria
Contact number: 012 406 4818
Fax number: 086 500 3351
Mauritius: Data Protection Office
Address: Level 5, SICOM Tower, Wall Street, Ebene Cyber City, Ebene
Contact number: +230 460 0251
Fax number: +230 489 7341
Email address: email@example.com
Botswana: Information and Data Protection Commission
The Information and Data Protection Commission has not yet been established. Contact us directly by sending an email to firstname.lastname@example.org to assist with your complaint.
Quality and access to your Information
We want to ensure that your information is accurate and up to date. You may ask us to correct any personal information that you think is inaccurate or request us to remove your information by sending an email to email@example.com. Please note that such a request may require you to verify your identity and may be subject to the requirements set out in the Promotion of Access to Information Act (PAIA).
You may request a record of personal information that we hold about you by sending an email to firstname.lastname@example.org.
Retention of Information
We retain personal information in accordance with the required retention periods in law or for legitimate business purposes. We will only retain your personal information for the purposes explicitly set out in this policy. We may keep personal information indefinitely in a de-identified format for statistical purposes.
Trans-border flow of Information
We may transfer your personal information to foreign countries mainly for the business purposes of the companies within the HomeChoice International PLC group, for retention or if our service providers are cross border or make use of cross border systems. If you continue to use our website or apply to or enter into an agreement with us, you expressly agree that we may transfer the personal information cross border for these purposes. We will only share information cross border to recipients who have laws similar to the applicable laws, or who have entered into an agreement with us to include the relevant principles prescribed by the applicable laws.