ABOUT THIS POLICY

FinChoice is committed to business practices in compliance with all applicable legislation, including the Protection of Personal Information Act 4 of 2014 (‘POPI’). FinChoice refers to FinChoice (Pty) Limited, an authorised financial services and registered credit provider (NCRCP 434) and FinChoice Africa Ltd, an authorised financial services and registered credit provider (NCRCP 8162). This policy sets out the categories of personal information we may collect from you or other sources when you make use of our mobi site or services, enter, or apply to enter into agreements with us as well as how we process your personal information. This privacy policy applies together with the general mobi site terms of use located on www.finchoice.mobi. We may amend this policy from time to time, in line with changes required by legislation or otherwise. You therefore agree to review the Privacy Policy whenever you visit the mobi site for any such change. Unless expressly provided to the contrary in this Privacy Policy, the amended version of the Privacy Policy shall supersede and replace all previous versions thereof. If you have any questions about this policy or do not agree with it, please contact us directly at info@finchoice.com. By entering into any agreement with us, or by applying to enter any such agreement, or by using our mobi site, you consent to our terms of collection and processing of your personal information as set out in this Privacy Policy.

SECURITY

• We take reasonable steps to protect and manage information that we hold about you.
• We make use of electronic and computer safeguards such as firewalls and data encryption.
• We have physical and electronic access control to our buildings.
• We only authorise access to information to those employees who require it to fulfil their designated responsibilities.
• We are committed to appropriate technical and other security measures to safeguard your information.

When you use the mobi sites, you may be given an access number, username, password and/or personal identification number (PIN). You are responsible for maintaining the secrecy and confidentiality of your username, access number, password and/or PIN.

COLLECTING YOUR INFORMATION

‘personal information' (or referred to herein, simply as ‘information’) includes any personal information as specified in the protection of personal information act. We collect information about you as follows:

• Information you provide to us through our applications or on our mobi site;
• Information you provide through communications with us;
• Information received from outside sources such as credit bureaus.

We may also record calls for quality checks and staff training and if personal information is shared during these calls, the information will be processed and stored in terms of FinChoice policies. When you use our mobi site, we automatically receive and record information on our server logs from your browser which may from time to time, include your location, IP address, cookie information, and the page you requested. This is statistical data regarding browsing actions and patterns and does not identify any individual. We may also obtain information about your general internet usage by using cookie files stored on the hard drive of your computer. Cookies enable us to improve our service to you, estimate our audience size and usage patterns, store information about your preferences and recognise you when you return to our mobi site. You can set your web browser to refuse cookies, but if you do this you may not be able to enjoy full use of our mobi site and you may not be able to take advantage of certain promotions we may run from time to time. Please note that third parties who advertise on our site may also use cookies, but we do not have access to, or control over them and therefore cannot take responsibility for them.

USE OF YOUR INFORMATION

Information we hold We may hold and use the following details about you:

• Your name, address, phone numbers, e-mail addresses, date of birth, employment, banking and financial details;
• IP address or cookie information;
• Demographic information;
• Information we receive when making a decision about your application (including information we received from the credit bureaus);
• And any other information which we reasonably need to perform our duties in pursuance of any agreement we may have with you, or to operate your account, make decisions about you or fulfil our regulatory or other business obligations.

Personal information about children and special personal information FinChoice will only process information about children with the consent of a competent person (someone like the parent or guardian) or if required to establish, exercise or defend a right or obligation in law. We do not intend to process any ‘special personal information’ about you, as defined in POPI, which includes, for example political, religious or health-related information, except if we are under a legal obligation to do so, or receive your consent. Information we share We will keep your personal information confidential and only share it with others for the purposes explained in this policy, insofar as you have consented thereto, or insofar as we are legally obliged or entitled to do so. We have trusted relationships with carefully selected third parties who perform services on our behalf. All service providers are bound by contract to maintain the security of your personal information and to use it only as permitted by us. We may hold and use the following details about you:

• With any firm, organisation or person we use to help us to collect payments and recover debts or to provide a service on our behalf;
• With any firm, organisation or person who provides us with products or services;
• With any person who has told us and who we reasonably believe to be your parent, carer or helper where you are unable to handle your own affairs because of mental capacity or other similar issues;
• With any payment system we may use;
• With regulatory and governmental authorities, ombudsmen, or other authorities, including tax authorities, where we are requested by them to do so;
• With Credit Bureaus that collect information about credit applications; and
• With any other third party if allowed to do so in law.

How we use your information We undertake to only process your information insofar it is adequate, relevant and not excessive for the purposes set out below. We will use your information to:

• Perform our duties in pursuance of any agreement we may have with you;
• Make, or assist in making, credit decisions about you and to check the details that you have let us have;
• Operate and manage your account and manage any application, agreement or correspondence you may have with us;
• Carry out, monitor and analyse our business;
• Contact you as allowed for in law by email, SMS, letter, telephone or in any other way about our products and services, unless you tell us that you prefer not to receive 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 be of interest to you;
• Carry out market research, business and statistical analysis;
• Carry out audits;
• Perform other administrative and operational purposes including the testing of systems;
• Trace your whereabouts, should it become reasonably necessary to do so;
• Recover any debt you owe us;
• Comply with our regulatory or other obligations;
• Carry out any other reasonable business operation considering our business and the relationship between the parties.

Your information may also be used for other purposes for which you give your permission or where we are permitted to do so or it is in the public interest to disclose the information You may on reasonable grounds object to the processing of your personal information, after which we undertake not to continue to process such information, except as provided for in legislation or in terms of any other lawful obligation. You may also lodge a complaint to the Information Regulator, with the following contact details:

CREDIT BUREAUS

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 lenders. Large numbers of applications within a short time period may affect your credit profile.

BREACH

We will report any security breach to both the Regulator and the individuals or companies involved.