INTRODUCTION

FinChoice is committed to business practices in compliance with all applicable legislation, including the Protection of Personal Information Act 4 of 2014 (‘POPI’).

In this policy, “FinChoice” refers to any or all of (i) FinChoice a division of HomeChoice (Pty) Limited; (ii) FinChoice Africa Ltd – incorporated in Mauritius, and (iii) FinChoice Botswana – incorporated in Botswana, whichever applies in the context.

This policy sets out the categories of personal information we may collect from you or other sources, also when you make use of our mobi site or services, enter, or apply to enter into agreements with us. It also explains how we use your personal information.

This 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 our business. You must therefore review the policy whenever you visit the mobi site for any such change.

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 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 agree to the terms of this policy.

SECURITY

• We take all reasonable steps to protect and secure all personal information that we hold and implement appropriate technical and organisational measures to prevent loss of, damage to or unauthorised access to personal information that we hold.
• We use electronic and computer safeguards like firewalls and data encryption
  Remember: When entering your personal information, ensure that you always use a secure computer.
• When you enter the secure areas of the FinChoice website, you’ll see a locked padlock symbol on your browser. This is usually at the bottom right-hand corner of the screen. This padlock indicates that the screen is in secure mode and that any details you provide on that page will be encrypted for your security.
• We also 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.

When you use some electronic channels for transactions, like the mobi sites, you may be given an access number, username, password and/or personal identification number (PIN). You are responsible to keep all if this information confidential.

COLLECTING YOUR INFORMATION

"Personal information" (or referred to simply as "information") includes any personal information as specified in POPI.

We collect information about you as follows:

• Information you provide to us through our electronic channels, applications or on our mobi site;
• Information you provide through communications with us;
• Information received from third party sources such as credit bureaus, list providers or friends and family.

USE OF YOUR INFORMATION

We typically use and hold the following information 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 or other third parties);
• And any other information which we reasonably need to perform our duties in terms of any agreement with you, or to operate your account, make decisions about you or fulfil our regulatory or other business obligations.

We typically use personal information for the following purposes:

• Perform our duties in terms of any agreement with you;
• Make, or assist in making, credit decisions about you and to check the details that you have provided to us;
• Operate and manage your account and manage any application, agreement or correspondence 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 interest 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, if reasonably necessary;
• Recover any debt you owe us;
• Comply with our regulatory or other obligations;
• Share information as set out in this policy;
• Carry out any other reasonable business operation considering our business and our relationship with you.
• 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 process personal information in a manner that is adequate, relevant and not excessive, considering our purposes of use.

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 POPI otherwise allows it. We do not intend to use any ‘special personal information’ as defined in POPI, other than health related information when we offer you credit insurance. Other special personal information for example includes political, religious or health-related information.

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 have a legal right or obligation to share it.

We have trusted relationships with 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 for our purposes only.

We may share information with the following parties:

• Debt collectors; Other service providers that provide a product or service to us or provide a product or service on our behalf;
• Payment system service provider;
• Regulatory and governmental authorities, ombudsmen, or other authorities, including tax authorities, where we are requested by them to do so;
• Credit Bureaus that collect information about credit applications;
• The different FinChoice companies within the group, for marketing and business purposes like providing services to companies within the group or for retention purposes; and
• With any other third party if allowed to do so in law.

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 credit providers. 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.

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 info@finchoice.com.

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.

LODGING A COMPLAINT

If you believe we are using your information unlawfully, you may lodge a complaint to the Information Regulator with the following contact details:

• Website: https://www.justice.gov.za/inforeg/index.html
• Address: SALU Building, 316 Thabo Sehume Street, Pretoria.
• Fax number: 086 500 3351.
• Email: inforeg@justice.gov.za.

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 info@finchoice.com.

You may request a record of personal information that we hold about you by sending an email to info@finchoice.com.

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.

This policy also applies when we retain your personal information.

TRANS-BORDER FLOW OF INFORMATION

We may transfer your personal information to foreign countries mainly for business purposes of companies within our group or for retention or if our service providers are cross border or use systems cross border.

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 POPI that apply to them, or who have entered into an agreement with us to include the relevant POPI principles.