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.
We may combine your personal information and use the
combined personal information for any of the purposes stated in this Privacy
Policy.
In this document any reference to “we” or “us” or “our”
includes Our Company and any of its subsidiaries.
If you use our services, goods, products and service
channels you agree that we may process your personal information as explained
under this Privacy Policy. Sometimes you may provide us with consent to process
your personal information. Read it carefully because it may limit your rights.
As a global organisation this Privacy Policy will apply to
the processing of personal information by any member of our company globally.
If we process personal information for another party under a contract or a
mandate, the other party’s privacy policy will apply to the processing.
We can change this Privacy Policy from time to time if the
law or its business practices requires it.
The version of the Privacy Policy displayed on our website
will apply to your interactions with us.
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:
·
Partners of our company for
any of the purposes identified in this Privacy Policy;
·
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 are required to keep it
to achieve the purposes listed in this Privacy Policy;
·
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.
Our cookie policy
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.
Cookies are small text files placed on your device to store data that can be recalled by a web server in the domain that placed the cookie. We use cookies and similar technologies for storing and honouring your preferences and settings, enabling you to sign-in, providing interest-based advertising, combating fraud, analysing how our products perform and fulfilling other legitimate purposes.Tarsus Technology Group together with its subsidiaries and all associated companies, collectively referred to as ‘TTG’, use additional identifiers, such as the advertising ID in Windows described in the Windows section of this statement, for similar purposes.
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.
You have a variety of tools to control the data collected by cookies, web beacons and similar technologies. For example, you can use controls in your Internet browser to limit how the websites you visit are able to use cookies and to withdraw your consent by clearing or blocking cookies.
Our Use of Cookies and Similar Technologies
TTG uses cookies and similar technologies for several purposes, depending on the context or product, including:
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.
PAIA Manual :- https://www.tarsusondemand.co.za/wp-content/uploads/2022/01/Tarsus_Technology_Group_PAIA_Manual.pdf
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