We are committed to protecting the personal information of all visitors (“Visitors”) to our Platforms as well as all persons who use any of the services we offer (“Users”). Not only is this required by law but we respect your privacy and want to ensure that we treat it appropriately at all times.
This Policy describes the ways in which we collect, store, use and protect the personal information of our Visitors and Users. Throughout this Policy, we use the term “personal information” to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been made anonymous so that it does not identify a specific person (also known as de-identified information).
Each User and Visitor needs to accept all the provisions in this Policy when using our Platform/s and if signing up for any of our Services. If you do not agree with anything in this Policy, then you may not use our Platforms, register and/or use any of the services.
You may not access the Platforms or use the services if you do not have legal capacity to conclude legally binding contracts.
By accepting this Policy, you consent to our collection, storage, processing and disclosure of your personal information as described in this Policy, for so long as you are a Visitor or registered User of our services.
If you have questions or complaints regarding our Policy or practices, or your personal information, please contact us or email us at [insert].
References in this policy to “we”, “our” or “us” are references to Spot Money SA Proprietary Limited. Reference to “you” and ”your” mean each natural person who uses our website, mobile app or associated services as a Visitor or User.
1. GENERAL INFORMATION ABOUT EVERYONE
1.1. Types of Information we collect
As a Visitor or User, you agree that we may electronically collect, store and use the following of your information for the purposes set out in clause 2.3 below:
1.1.2. additional information you may provide on a voluntary basis, such as demographic information or information related to your favourite social networking site (e.g. the site name, address and description), or information relating to your participation in competitions, promotions, surveys, and/or additional services (“Optional Details”).
1.2. How we collect such information
1.2.1. Voluntarily provided by you: Optional Details may be submitted by you to us if you decide to upload or download certain content (or products) from the Platform, take advantage of promotions, respond to surveys, register and subscribe for certain additional services, or otherwise use the optional features and functionality of the Platforms.
1.2.2. Automatically gathered by us via various technologies:
188.8.131.52.Other tracking technology: When you access the Platforms or open one of our HTML emails or message links, certain Usage Details may be automatically collected and recorded by us from your system by using different types of tracking technology.
184.108.40.206.Web Beacons: Our Website may contain electronic image requests (called a “single-pixel gif” or “web beacon” request) that allow us to count page views and to access cookies. Any electronic image viewed as part of a web page (including an ad banner) can act as a web beacon. Web beacons are typically 1-by-1 pixel files (so small that you would likely not realize that they are there), but their presence can usually be seen within a browser by clicking on “View” and then on “Source.” We may also include web beacons in HTML-formatted newsletters that we send to opt-in subscribers in order to count how many newsletters have been read. Our web beacons do not collect, gather, monitor or share any personally identifiable information about our Users, they are just the technique we use to compile anonymous information about the Platforms and service usage.
1.3.The purpose for which we collect this information
1.3.1.We may use any Optional Details provided by you for such purposes as indicated to you at the time you agree to provide such Optional Details. We do not verify the accuracy of the information you provide to us, and it remains your responsibility to ensure correctness of the information supplied.
1.3.2.We may use your Usage Details to:
220.127.116.11. automatically provide you with the latest version of the solution;
18.104.22.168. remember your information so that you will not have to re-enter it during your visit or the next time you access our Platforms;
22.214.171.124. monitor aggregate Platform usage metrics such as total number of visitors and pages accessed; and
126.96.36.199. track your entries, submissions, and status in any promotions or other activities in connection with your usage of the Platforms.
2. INFORMATION ABOUT USERS
2.1. Types and sources of personal information we collect
We may collect, store and use the following personal information about our Users :
- General Identifying Information:
- Information that you give us when you interact with us in any way which may include your name, contact information, date of birth, identification number, financial information, or financial history.
- Financial information and account details
- Payment card number; bank account number and account details; credit history and credit score; assets; income; and other financial information.
- Telephone recordings
- Recordings of telephone calls to our representatives and call centers.
- Marketing preferences and customer feedback
- You may let us know your marketing preferences, enter a contest or prize draw or other sales promotion, or respond to a voluntary customer satisfaction survey.
- Credit Bureau Information and Credit Score
- Your credit score received from a credit bureau on your request.
- Information to investigate crime, including fraud and money laundering
- Organisations may share information about their previous dealings with customers for this purpose.
- Partner Information
- Information that we receive about you that is either publicly available or available through service providers that we may interact or partner with or that you may have provided your consent in respect of to share or that you may have provided to us previously when interacting with us for one of our other service offerings.
- Product Enquiries
- Information that you provide to us in respect of products or services that you may be interested in.
- Affiliate and group company information
- General Identifying Information:
2.2. How we collect information about Users
Your personal information is provided by you directly to us during your registration as a User and/or thereafter by your actively updating or supplementing such details when using our products and services.
2.3. How we may use your personal information and the purpose for its collection
We may use your personal information to:
- Obtain your credit score on your behalf from a credit bureau.
- Provide you with bespoke and tailor-made financial services and products.
- Work with our service providers to inform you about financial products and services that may be of interest to you
- Notify you about changes to our services.
- Improve the service we offer you.
- Administer your account.
- Verify your identity.
- Communicate with you and others as part of our business.
- Send you important information regarding changes to our policies or products, other terms and conditions, our site and other administrative information.
- Provide improved quality, training, and security (for example, with respect to recorded or monitored phone calls to our contact numbers).
- Prevent, detect, and investigate crime, including fraud and money laundering, and analyse and manage other commercial risks.
- Carry out market research and analysis, including satisfaction surveys.
- Check your credit history.
- Check your details on applications for credit or credit-related facilities.
- Provide marketing information to you (including information about other products and services offered by selected third-party partners) in accordance with the preferences you have expressed.
- Personalize your experience on our website by presenting information and advertisements tailored to you.
- Identify you to anyone to whom you send messages through our Platforms.
- Allow you to participate in contests, prize draws, and similar promotions, and to administer these activities. Some of these activities have additional terms and conditions, which could contain additional information about how we use and disclose your personal information, so we suggest that you read these carefully.
- Manage our infrastructure and business operations, and comply with internal policies and procedures, including those relating to auditing; finance and accounting; billing and collections; IT systems; data and website hosting; business continuity; and records, document and print management.
- Resolve complaints, and handle requests for data access or correction.
- Comply with applicable laws and regulatory obligations (including laws outside your country of residence), such as those relating to anti-money laundering and anti-terrorism; comply with legal process, and respond to requests from public and governmental authorities (including those outside your country of residence).
- Establish and defend legal rights; protect our operations or those of any of our group companies or business partners, our rights, privacy, safety or property, and/or that of our group companies, you or others; and pursue available remedies or limit our damages.
3. HOW WE SHARE PERSONAL INFORMATION WITH OTHERS
3.1. Who we may share your personal information with
We may share your personal information with
3.2. Our company
We are responsible for the management and security of personal information. Access to personal information Spot is restricted to those individuals (including our staff, contractors, consultants, and/or professional advisors) who have a need to access the information for our business purposes. We may also share personal information with purchasers and prospective purchasers or other parties in any actual or proposed reorganization, merger, sale, joint venture, assignment, transfer or other transaction relating to all or any portion of our business, assets or shares.
3.3. Other companies within our group of companies (the Ignition Group of companies)
3.3.1. The Ignition Group comprises of various subsidiary and affiliate companies (both directly and indirectly controlled by the Ignition Group) and conducts strategic business activities with these various group companies that support the Ignition Group’s service offering and enable the delivery of their products and services across various platforms. These subsidiaries and affiliates do transfer personal information amongst one another as part of operating the Ignition Group’s business and to assist the Ignition Group to comply with their obligations towards data subject(s) and third parties.
3.3.2. We may share your personal information with subsidiaries and affiliates of the Ignition Group so as to propose additional services or products. Members of our corporate family will only use this information to send you marketing communications if you have requested their services.
3.4. Service providers
3.4.1. In the course of marketing and providing our services, we may make personal information available to third parties such as related financial services providers, intermediaries and agents; appointed representatives; affinity marketing partners; reward partners, financial institutions and credit reporting agencies. Our contracts dictate that these service providers and/or agents only use your information in connection with the services they perform for us and not for their own benefit.
3.4.2. Service providers and/or financial institutions that we partner with to jointly create and offer products and services. These organisations may only use this information to market Spot related products or offers, unless you have given consent for other uses.
3.5. To comply with legal obligations including statutory and regulatory requirements
We may be obliged by law to share your information Law enforcement, government officials, fraud detection agencies or other third parties when –
3.5.1. we are compelled to do so by a subpoena, court order or similar legal procedure;
3.5.2. we need to do so to comply with any law; and/or
3.5.3. we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our User Agreement;
3.6. Other Third Parties
Other third parties, with your consent or direction to do so.
3.6.1. We will not sell or rent any of your personal information to third parties for their marketing purposes and only shares your personal information with third parties as described in this Policy.
3.6.2. Personal information may also be shared by you, on message boards, chat, profile pages and blogs, and other services on the website to which you are able to post information and materials. Please note that any information you post or disclose through these services will become public information and may be available to visitors to the website and to the general public. We urge you to be very careful when deciding to disclose your personal information, or any other information, on our Platforms.
4. HOW WE PROTECT & STORE PERSONAL INFORMATION
4.1. We store and process the personal information of our Users and Visitors on cloud-based servers (AWS) that are protected by firewalls and data encryption. The Platforms do not store data on the mobile device or computer and communicates with the cloud servers through Secure Socket Layers (SSL’s). We authorize access to personal information only for those employees who require it to fulfil their job responsibilities.
4.2. We may store the data we collect from you outside of South Africa, or transfer it to organisations outside South Africa. When we do this, we make sure that your data is protected in accordance with our legal obligations to do so.
4.3. You should not divulge your account password to anyone. We will never ask you for your password or PIN in an unsolicited telephone call or e-mail. YOU ARE RESPONSIBLE FOR MAINTAINING THE SECRECY OF YOUR UNIQUE PASSWORD, ACCOUNT INFORMATION AND LINKED CARD OR ACCOUNT INFORMATION AT ALL TIMES.
4.4. We will take appropriate technical, physical, legal and organizational measures, which are consistent with applicable privacy and data security laws. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any personal information you might have with us has been compromised), please immediately notify us.
4.5. If we provide personal information to another service provider, the service provider will be selected carefully and required to use appropriate measures to protect the confidentiality and security of the personal information.
5. MARKETING PREFERENCES
We will provide you with regular opportunities to tell us your marketing preferences, including in our communications to you.
If you no longer want to receive marketing-related e-mails from us, you may opt out of receiving these marketing-related communications by sending your opt-out request to firstname.lastname@example.org
We aim to comply with your opt out request(s) within a reasonable time period. Please note that if you opt out as described above, we will not be able to remove your personal information from the databases of third parties with whom we have already shared your personal information (i.e., to those to whom we have already provided your personal information as of the date on which we respond to your opt out request). Please also note that if you do opt out of receiving marketing communications from us, we may still send you other important administrative communications from which you cannot opt out.
6. THIRD-PARTY WEBSITES
This Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website to which our Platform/s contain a link. The inclusion of a link on our Platform/s does not imply endorsement of the linked website by us or by our group companies.
8. REQUESTING A COPY OF YOUR PERSONAL INFORMATION
Please contact us on email@example.com if you wish to check if we hold information about you and the details thereof if we do (provided you provide us with proof of identity in a form acceptable to us). We will do this within a reasonable time; at a prescribed fee; in a reasonable manner and format; and in a form that is generally understandable. Kindly see our PAIA manual for more information in this regard.
9. DELETING YOUR INFORMATION AND OUR RETENTION OF INFORMATION
If you are a User, you can deactivate your account at any time in accordance with the provisions of your contract with us. If you wish to withdraw your consent to retain this information, your access to our services shall also be terminated or suspended. We shall remove your personal information from our database within a reasonable period but no longer than 7 (seven) business days subject to any retention periods.
Please note: Certain information, including transaction data, may be retained for legal purposes and will only be held for so long as required by applicable law.
Reasonable steps will be taken to ensure that the personal information we process is reliable for its intended use, and as accurate and complete as is necessary to carry out the purposes described in this Policy. Personal information will be retained for the period necessary to fulfil the purposes outlined in this Policy or unless a longer retention period is required or permitted by law.