All references to “personal information” (or also referred to as “information“) in this Policy includes any personal information as defined in the Protection of Personal Information Act 4 of 2013 and updated on 1 July 2020 (“POPI“).
We are committed to ensuring that your privacy is protected when using our services and to business practices which are compliant with all relevant legislation, which includes the POPI and the Electronic Communications and Transactions Act 25 of 2002 (“ECTA“). We wish to balance our legitimate business interests and your reasonable expectation of privacy and will take all reasonable steps to prevent the unauthorised access to, or disclosure of your personal information. However, we cannot guarantee that your Personal Information will be one hundred percent secure.
Any reference in this Policy to “website” includes our mobile application (“app”) should we have one.
This Policy sets out how your personal information will be processed and protected, as well as how we may use personal information that we collect about you when you visit our website, enter, or apply to enter into an agreement with us. By using our website, you acknowledge that you have read and agree to be bound by this Policy. If you do not agree with any part of this Policy or our Website User Terms and Conditions (located at http://moovguide.co.za/privacy-policy/ and at http://moovguide.co.za/terms-conditions/), you must immediately cease your access and use of the website.
We may amend this Policy from time to time, in line with any changes that may be required by legislation or our internal business operations, and the version available on our website at www.moovguie.co.za, at the time that you interact with us, will apply. You must therefore review this Policy whenever you visit our website.
If you have any questions about this Policy or do not agree with its content, please contact us directly at:
Department: Executive Board
Contact No.: 0021 813 60 98
Email Address: email@example.com
Physical Address: 9 Ranelagh Road, Rondebosch, Cape Town, South Africa, 7700
- COLLECTING YOUR INFORMATION
- Methods of Collection
We collect information about you as follows:
- information you provide to us through our applications or on our website;
- information you provide through communications with us;
- information from external sources such as credit bureaus and social media services like Facebook, Twitter, provided you have consented to us obtaining information from such sources;
- information from website interaction with us; and
- information from other third parties related to our operations or within our business structure including third party service providers who provide services through our website.
We may record calls as required by law, or for quality checks, staff training and/or for purposes relating to your relationship with us.
When you use our website, 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 about browsing actions and patterns and does not identify any individual. We may also obtain information about your general internet usage by using a cookie file which is 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 when you return to our website.
The website may include links to other websites which do not fall under our supervision. We cannot accept any responsibility for the protection of privacy or the content of these websites, but we offer these links to make it easier for our visitors to find more information about specific subjects and/or services.
- USE OF YOUR INFORMATION
- How do we use your personal data?
In providing your personal information, you consent to us using the information collected in order to meet our commitments to you for third party service providers to meet their commitments to you and to provide you with the service you expect.
- Information we hold
We may generally store and use the following information (depending on the reason why we collected the information):
- your first name(s), surname, address, phone numbers, e-mail address, date of birth, employment, banking and financial details;
- IP address or cookie information;
- location information;
- demographic information including your age and gender;
- information we require in order for third party service providers to provide you with the services you request;
- debit order details; and
- any other information which we reasonably need to perform our obligations in terms of the agreement we have with you including but not limited to any other information we require you to provide when filling in an assessment questionnaire for purposes of submission to third party service providers via the Moovguide platform, or for purposes of marketing to you, to make decisions about you or fulfil our regulatory, compliance or other business obligations.
Third parties, including third party service providers who provide services to you through our website, who may be responsible parties in their own right, may collect your payment details via our website and other information they require in order to perform services you have requested. Those details will only be stored by such payment gateways, and not by us.
- Personal information about children and special personal information
We refer to our Website Terms and Conditions in terms of which you warrant that you are 18 (eighteen) years of age or older.
We do not intentionally collect or use information of children unless with consent. Our intention is therefore to 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, or if otherwise allowed in law to process it.
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;
- receive your consent to process it; or
- otherwise allowed in law to process such information.
- Information we share
We will keep your personal information confidential and only share it with others for the purposes set out in this policy, or if you have otherwise consented thereto, or if 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.
Subject to this policy, we may share information about you with:
- third party service providers who you have requested services from, through our website;
- any firm, organisation or person we use to help us to collect payments and recover debts or to provide a service on our behalf;
- any firm, organisation or person who provides us with products or services, and or delivery of those products or services, reasonably require access to your information;
- any payment gateway we may use;
- regulatory and governmental authorities, ombudsmen, or other authorities, including tax authorities, if we are requested by them to do so; and
- any other third party, if we are legally obliged or entitled to do so.
- How we use your information
We undertake to only process your information insofar as it is adequate, relevant and not excessive for the purposes set out below.
We may collect your information and use it for purposes related to:
- performing our duties in terms of any agreement or proposed agreement we may have with you;
- enabling third party service providers to perform their duties to you in terms of any agreement or proposed agreement we have with them or they have with you;
- operating and managing your account, any application, agreement or correspondence you may have with us;
- carrying out, monitoring and analysing our business;
- contacting you, including for purposes of marketing our products and services to you, by email, SMS, letter, telephone or in any other way about our products and services, unless you inform us that you prefer not to receive marketing communications;
- identifying or preventing fraud and money laundering;
- forming a view of you as an individual and to identify, develop or improve products and services that may be of interest to you;
- carrying out market research, business and statistical analysis;
- carrying out audits;
- performing other administrative and operational tasks including the testing of systems;
- tracing your whereabouts, should it be required for delivery of our services to you, or it otherwise becomes reasonably necessary to do so;
- recovering any debt you may owe to us, should we charge you for products and services; and
- complying with our regulatory or other obligations.
Your information may also be used for other purposes for which you give your permission, or where we are permitted to do so in law, or when 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 law.
We will only keep your information for as long as necessary to carry out our services to you or for as long as we are required by law. We cannot remove your information when there is a legal storage requirement, such as book-keeping rules or when there are other legal grounds to keep the data, such as an ongoing contractual relationship.
If you believe we are using your information unlawfully, you may lodge a complaint with the Information Regulator (South Africa), with the following contact details:
We are committed to implementing appropriate technical and other security measures to protect the integrity and confidentiality of your information.
We protect and manage information that we hold about you, by using electronic and computer safeguards such as firewalls and data encryption and stored on the servers at third party service providers on our behalf.
We only authorise access to information to those employees who require it to fulfil their designated responsibilities.
When you use the website, we may give you an access number, username, password and/or personal identification number (“PIN“). You are responsible to maintain the secrecy and confidentiality of your username, access number, password and/or PIN. Should you misplace or have these details stolen from you it is your responsibility to inform us and to take steps to change these details.
- 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 or remove any information that you think is inaccurate, by logging into your Moovguide account and following the steps to amend, update or remove your information.
You have the right to request us to provide you with information that we hold about you. You must contact us directly to do so or send an e-mail to firstname.lastname@example.org. Fees to obtain a copy of your records may be prescribed in terms of POPI, for which we will provide you with a quote before disclosing such records.
- RETENTION OF INFORMATION
We retain information in accordance with the required retention periods in law or for legitimate business purposes. We will however only retain your information for the purposes explicitly set out in this Policy.
Should we keep your information longer than is strictly necessary for purposes of our agreement or as required in law, we will either de-identify your information, or keep it for statistical purposes only.
Whilst we retain your information, we will continue to abide by our non-disclosure obligations and will not sell or share your information without your consent.
We will report any security breach to both the Information Regulator (South Africa) and the individuals or companies involved. If you suspect any breach regarding your information, kindly notify us immediately by sending an email to email@example.com.
We are not responsible for, give no warranties, nor make any representations in respect of the privacy policies or practices of linked or any third party websites.
- TRANSBORDER FLOW OF INFORMATION
We may only transfer your information to foreign countries in order for us to perform services to you and/or for purposes of any agreement we have with you.
Such information shall only be transferred to recipients who are subject to laws, binding corporate rules or agreements, that provide an adequate level of protection that uphold the principles for processing of information that are substantially similar to those principles as set out in POPI.
- RESPONSIBLE PARTY DETAILS
Our details are as follows:
Name: Moovguide Proprietary Limited
Physical Address: 9 Ranelagh Road, Rondebosch, Cape Town, South Africa, 7700
E-mail Address: firstname.lastname@example.org
Telephone No.: 0021 813 60 98