FASTA Privacy Policy

Welcome to FASTA (Pty) Ltd (“FASTA”), a subsidiary of Knickle Holdings (Pty) Ltd (“Knickle”). We believe you deserve a safe and secure environment and peace of mind in knowing how we process and store your personal information, so we have described our Privacy Policy as clearly as possible in the summary below.

Our Privacy Policy applies to all current as well as former customers who register with us and may change from time to time. It is important for you to read this Privacy Policy as we may use your personal information as set out herein even if you do not qualify for one of our services orproducts. If you successfully apply forcreditwith us, this Privacy Policy must also be read with the terms and conditions of your agreement with us (“your agreement”) as it provides further details of how we collect, process and use your personal information.

Your consent

By registering with us and submitting your details and/or using our services, you accept thetermsof this Privacy Policy and expressly provide your voluntary, specific and informed consent to process, store and disclose your personal information in the manner described below. If you object to any of the potential uses described in this Privacy Policy and/or your agreement (as the case may be), please don’t register on our website and/or accept the terms of your agreement to apply for a loan or any other offering from FASTA or other subsidiaries of Knickle.

Personal information

Personal information is defined in the Protection of Personal Information Act of 2013 (“POPIA”). This is information that identifies or relates specifically to you and includes, for example, your financial information, your name, age and identity number, your assets and liabilities, your income, your bank account number, your physical address, your email address, location information, your contact numbers, and your payment records.

How we collect your personal information

We collect information about you in two ways – directly from you when you register with Us, through your online application and from external providers, such as registeredCreditBureaus.

How we use your personal information

We are a responsible lender and want to ensure that your use of our lending products, as well as the electronic service offered, runs as successfully as possible. It is necessary for us to find out your exact needs and then use your personal information to determine whether you can repay the loan/pay the required instalments in terms of the provisions of the National Credit Act of 2005, and for us to provide you with relevant information which may be of use to you. The following are the reasons why we collect and process your personal information:

to identify you, and the accuracy and completeness of the information you provide to us;
in order for us to process your instructions or requests;
in order for us to ensure that you meet our lending criteria, we are required by law to collect and analyse your personal information and combine all the information that we have about you to compile acreditprofile of you in order for us to grant you a loan or another service we may offer, and to meet your specific needs. In order to do so, we conduct automated processing of your personal information. The decision generated from such automated processing is permitted as it will be taken in connection with the execution of a request for by you for our services and i) to ensure your request has been met, or ii) appropriate measures have been taken to protect your legitimate interests in using the automated decision making process which utilisesfinancial documentation providedby you to assess your ability to comply with your obligations for which services you have applied;
to supply to financial institutions or payment distribution agencies for purposes of payment processing;
once we have collected your personal information, we may send you promotional material or details (including via direct marketing – see below) which we think may be of interest to you. If we are aware of any products or services provided by third parties which could be of use to you, we may inform the third party to contact you directly. You can unsubscribe from receiving our promotional material at any time and we will no longer market to you thereafter.

We may also use your personal information:

for statistical, research and historical analysis;
to develop and improve our products;
to assess lending risks;
to carry out regulatory checks
to assess insurance risks, and where applicable, arrange, underwrite and administer insurance and handle claims;
to update your and our records;
to institute collection and legal proceedings where necessary;
to identify which of our products, or our partners’ products might interest you;
to identify andprevent fraud, money laundering and other criminal activities; to carry out regulatory checks,
for keeping you informed about yourloanor other service/s we provide to you, and for market research in terms of the products and services which we offer on behalf of third parties.

In addition, we utilise your personal information for the other purposes set out in this Privacy Policy.

Direct marketing

When you click on the box “Iaccept website terms of use and privacy policy” in the online application registration process, you expressly provide your voluntary, specific and informed consent to receive direct marketing fromFASTAor another subsidiary of Knickle (whose contact details are set out at the end of this Privacy Policy) advertising FASTA or another subsidiary of Knickle’s products and services by means of electronic communication, which could include automatic calling machines, facsimile, email, sms or email.

You have the option at any time to opt out of any mailing list maintained byFASTAby clicking on the unsubscribe link at the bottom of our emails, alternatively you may make direct contact with us to remove you from our mailing list.

If at any time you wish to stop receiving communications from a third party, you will need to follow the instructions about unsubscribing provided at that time by the third party. Please note that we only partner with trusted companies who will respect your right to unsubscribe from any such marketing communications, but we will not be responsible for managing that process or any disputes.

Additional data collection

In addition to the personal information you submit, we may collect information about your computer including, where available, your Internet Protocol (IP) address, your device’s operating system and browser type. We use this system administration for fraud detection as well as aggregate this information to our advertising partners which allow us to have a better understanding of our customer requirements and/or preferences by using cookies to track users as theytravelfrom website to website recording what commercial advertisements they view and select while browsing.

This is statistical data about browsing actions and patterns and does not specifically identify you or any other 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 you when you return to our 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 the 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.

We want to provide you with the best possible service, so calls to us may be recorded and/or monitored for quality checks and staff training. Recordings may also be used to help us combat fraud.

“PIN”

When you use theFASTA Website and the services providedby us, 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 card, password and/or PIN.

Disclosure of your personal information

We may share your personal information with third parties involved in the process of providing the services you request, such as other lenders, registered credit bureaus, customer service providers, collection agencies as well as theSouth African Creditand Risk Reporting Association (SACCRA).

We may also share your personal information with third parties who provide services which could be of use to you, such asdebtrepair companies who offer consumers assistance where the consumer has been placed under debt review, and for which we receive a fee from the debt repair company.

We have trusted relationships with these carefully selected third parties who either perform services on our behalf, or offer services to you directly. All third parties and service providers are bound by contract to maintain the confidentiality and security of your personal information and are restricted in their use thereof as per this Privacy Policy.

Disclosing your data to third parties

We may disclose your personal information:

in the event we sell or buy any business or assets (in which case we may disclose your personal information to the prospective seller or buyer of such a business or assets)
if our business or substantially all of its assets are acquired by a third party (in which case personal information held about customers will be one of the transferred assets)
if we have a duty to disclose your personal information in order to comply with a legal request, or in order to enforce any of our terms and conditions
where we are in law allowed to do so
in relation to the implementation, administration and/or enforcement of any agreement entered into with us.

Right to request access to your personal information

You are entitled to request access to your personal information at a prescribed fee and to request that inaccurate, irrelevant, excessive, outdated, incomplete, misleading or unlawfully obtained information be corrected.

Which laws apply?

This Privacy Policy will be governed by and construed and interpreted in accordance with the laws ofSouth Africa. To the extent that a court has jurisdiction over any dispute which may arise out of or in connection with this Privacy Policy, you agree that the matter be heard in the High Court ofSouth Africa, Western Cape Division, alternatively a court of competent jurisdiction in South Africa.

Disclosure of your personal information without your consent

Notwithstanding the above, we will disclose your personal information without your consent:

if we are required to do so by law or a court order; to enforce legislation concerning the collection of revenue as defined in section 1 of the South African Revenue Service Act, 1997;
to avoid prejudice to the maintenance of the law by any public body, including the prevention, detection, investigation, prosecution and punishment of offences;
for the conduct of proceedings in any court or tribunal;
in the interests of national security;
if disclosure would not prejudice your legitimate interest or lawful purpose;
if it would not be reasonably practicable to obtain your consent;
the information will not be used in a form in which you would be identified;
the information will be used for historical, statistical or research purposes.

Security and confidentiality

We understand the value of your personal information and therefore will take all reasonable steps to protect your personal information from loss, misuse or unauthorised alteration. Your personal information is stored in databases that have built-in safeguards and firewalls to ensure the privacy and confidentiality of that information.

We recognise the need for appropriate protection and management of the personal information you share with us. We protect that information using Secure Socket Layer (SSL) encryption technology and by limiting employee access on a need-to-know basis. We store data in encrypted form on computers and control access via secure web pages. We employ firewalls and other security technologies to protect our servers from external attack.

Our security systems meet or exceed industry standards and we are constantly monitoring internet developments to ensure our systems evolve as required. We also test our systems regularly to make sure our security mechanisms are up to date.

We are subject to South African data protection laws including, but not limited to, those contained in the National Credit Act 2005 read with the National Credit Amendment Act 2014 (“NCA”), POPIA, CPA, the Electronic Communications and Transactions Act of 2002, and the Promotion of Access to Information Act of 2000, which we fully comply with.

Foreign parties

Because we work with some carefully selected partners outside ofSouth Africa, in order to offer you our services, we may also need to transfer your personal information abroad, to countries whose data protection laws are less strict than in South Africa. If and whenever this is the case, we will ensure the information is held securely to standards at least as good as those inSouth Africaand is only used for the purposes set out in this Privacy Policy.

Third party links

Our site may contain links to third party websites. If you follow a link to any of these websites, please note that these websites have their own terms and privacy policies and that we do not accept any responsibility or liability for them. By registering atFASTA you may receive follow-up contactand offers from third party companies as you have agreed to do by accepting this Privacy Policy and, while we only work with selected partners, we are not responsible for the services or representations of third parties.

Because we are not responsible for any representations or information or warranties or content on any website of any third party (including websites linked to this website or websites facilitated by us), we do not exercise control over third parties’ privacy policies and you should refer to the privacy policy of any such third party to see how such party protects your privacy.

Age

To register with us you must be 18-years of age or older. Minors are strictly forbidden from using our services.

Changes to this Privacy Policy

We reserve the right, in our sole discretion to update, modify or amend (including without limitation, by the addition of new terms and conditions) this Privacy Policy from time to time with or without notice. You therefore agree to review the Privacy Policy whenever you visit the FASTA website for any such change. Save as expressly provided to the contrary herein, the amended version of the Privacy Policy shall supersede and replace all previous versions thereof.

Contact us

FASTA (Pty) Ltd, a subsidiary of Knickle Holdings (Pty) Ltd

Address: Spaces, Dock Road Junction, Cnr Stanley & Dock Road, V&A Waterfront,Cape Town, 8001.

If you have any comments, questions or concerns arising from this Privacy Policy or our collection, processing and storing of your personal information, please contact us by sending an email to: support@fasta.co.za / info@fasta.co.za

Information Regulator

Should we be unable to address your concerns, or should you have a complaint about the collection, processing or storage of your personal information, you may contact the Information Regulator by sending an email to: inforeg@justice.gov.za.

Automatic Bank Statement Collection

TRUID PROPRIETARY LIMITED (Registration Number: 2015/361504/07) TERMS OF USE DATA PROTECTION & PRIVACY POLICY

PREAMBLE
1. The truID website:http://www.truid.co.zaand the truID mobile phone or tablet application (collectively the “truID System”) are owned and operated by truID Proprietary Limited (also referred to herein as “We”, “Our” or any related expression).
2. Please take the time to read and understand these terms and conditions of use together with our data protection and privacy policy (collectively the “Terms”) because by accepting these Terms and by Using the truID System, by whatever means or device, you consent to be bound by these Terms.
3. TheseTerms describe the services that We offer and provideto You through Your access and Use of the truID System, the manner in which the truID System is provided to You and set out our obligations to You and provide important information on how We collect, transmit, process and store Your Personal Information.
4. These Terms also place various obligations on You as a User of the truID System. By accepting these Terms you hereby grant truID the express consents required under the applicable laws to enable the truID System to be accessed and Used for its intended purposes.
5. If you do not consent to be bound by all of the provisions of these Terms, you may not use the truID System.
INTERPRETATION AND DEFINITIONS
1. In these Terms and Conditions, capitalised words will have the meanings assigned to them herein below and cognate words and phrases will have corresponding meanings: –
  1. “Data Subject” – means data subject as defined in POPIA, being the Person to whom Personal Information relates;
  2. “Equipment” – means the hardware, operating software and communication lines used for connecting to any local area network or wide area network which is used to operate, run, access or otherwise Use the truID System;
  3. “Operator” – means an operator as defined in POPIA, being a Person who processes Personal Information for a Responsible Party in terms of a contract or mandate, without coming under the direct authority of that Responsible Party;
  4. ‘‘Person’’ – means a natural person or a juristic person;
  5. “Personal Information” – means personal information as defined in POPIA being, information relating to an identifiable, living, natural Person, and where it is applicable, an identifiable, existing juristic Person, including, but not limited to— (a) information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth of the Person; (b) information relating to the education or the medical, financial, criminal or employment history of the Person; (c) any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier or other particular assignment to the Person; (d) the biometric information of the Person; (e) the personal opinions, views or preferences of the Person; (f) correspondence sent by the Person that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence; (g) the views or opinions of another individual about the Person; and (h) the name of the Person if it appears with other Personal Information relating to the Person or if the disclosure of the name itself would reveal information about the Person;
  6. “POPIA” – means the Protection of Personal Information Act No. 4 of 2013;
  7. “Process” – means to process as defined in POPIA which for the avoidance of doubt means any operation or activity or any set of operations, whether or not by automatic means, concerning Personal Information, including— (a) the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use; (b) dissemination by means of transmission, distribution or making available in any other form; or (c) merging, linking, as well as restriction, degradation, erasure or destruction of information;
  8. “Processing Party” – means Processor of the Personal Information of the Data Subject, being for the purposes of this Privacy Policy, the Client as the Responsible Party thereof or truID as the Operator thereof as the case may be;
  9. “Responsible Party” – means a responsible party defined in POPIA, as being a public or private body or any other Person which, alone or in conjunction with others, determines the purpose of and means for processing Personal Information;
  10. “Use/Using/Used” – means all use of the truID System by You, of whatever nature including to access, utilise, load, execute, employ, store or display on, download data to, submit data from, or any application of the truID System. Use is deemed to occur where any one or more of such processes occur on the Equipment or any other device that initiates, activates or is activated by such processes. The manner in which the truID System may be used by You is defined specifically in these Terms and Conditions;
THE TRUID SYSTEM
1. The truID System can be Used by You to easily and immediately access, extract, process and share certain Personal Information of Yours including Your financial information with Your appointed third party service provider (“Your Service Provider”) and other authorised service providers, such ascreditbureaus, who assist Your Service Provider and/or truID to provide their/Our services to You (Authorised Third Party Service Providers”) in a manner that ensures data privacy and authenticity for You and Your Service Provider. .
2. The privacy of Your Personal Information is assured by the truID System authenticating You with Your bank using Your online banking credentials which are entered by You and not stored by truID or shared with any other parties.
3. The authenticity of YourPersonal Information is confirmed by retrieving Your financialinformation directly from Your bank and sharing it directly with Your Service Provider and Authorised Third Party Service Providers automatically, electronically and without the intervention of any other parties.
4. By You consenting to these Terms, truID hereby agrees to provide You with access to and Use of the truID System, subject to and in accordance with the provisions of these Terms.
ACCESS TO THE TRUID SYSTEM
1. Access to and Use of the truID System:
  1. in order to Use the truID System You will be required to access the truID System via the truID web app on the appropriate Equipment;
  2. once You have accessed the truID System You will access Your online banking portal through the truID System and retrieve Your Personal Information using Your online banking login credentials. You hereby consent to truID processing such notices, pop-ups and communications required by the banksonline banking portal to provideyou with access to your online banking services. This processing by truID is automated by the truID System. You will then Use the truID System to share your Personal Information with Your Service Provider and their Authorised Third Party Service Providers. As soon as Your Personal Information is collected by the truID System it is encrypted and thereafter will only be transmitted and stored in encrypted form;
  3. Your Service Provider and their Authorised Third Party Service Providers will then, upon receipt of the Personal Information of Yours transmitted by the truID System, be able Process Your Personal Information and provide You with their services
  4. truID will not store your online banking log in credentials. It is Your responsibility to keep Youronline banking login credentials confidential and secureand to ensure that Your login credentials are not disclosed to any persons including any representatives of Your appointed third party service provider.
TERMS OF USE OF THE TRUID SYSTEM
1. You acknowledge and understand that through the Use of the truID System, the truID System will access certain Personal Information Yours. The truID System is only granted “read only” access. truID can only collect Your Personal Information;
2. You undertake that all Personal Information provided by You is accurate and current information, and that You are not impersonating or misrepresenting any person or entity or falsely stating or otherwise misrepresenting Your affiliation with anyone or anything;
3. Youunderstand that for purposes of Processingof your Personal Information, Your Service Provider shall at all times be the Responsible Party. truID shall, only in those instances where it is mandated to do so on Your Service Provider’s behalf, be the Operator for the Processing of your Personal Information. truID does not have control of how your Personal Information is Processed or used by Your Service Provider or their Authorised Third Party Service Providers;
4. You hereby expressly consent, subject to 6.a.vii, to your Personal Information being collected and stored by truID for historical, research and statistical purposes provided that Your Personal Information is collected and stored in an encrypted and de-identified or anonymized manner and will not be transmitted or published in an identifiable form;
5. Please be aware that the truID System is Used entirely at Your own risk. truID makes no representations and/or warranties of any kind to You whether express or implied. truID accepts no liability, to You to the extent permitted by law, for any damages, howsoever arising, whether direct, indirect, incidental, special or consequential loss from the access to or Use of the truID System.
6. truID accepts no liability, to You to the extent permitted by law, for any damages, howsoever arising, whether direct, indirect, incidental, special or consequential loss arising from a misuse of your Personal Information by Your Service Provider and/or their Authorised Third Party Service Providers nor for any actions, errors or omissions of or by Your Service Provider and/or their Authorised Third Party Service Providers which may be prejudicial to You. ;
DATA PROTECTION AND PRIVACY POLICY
1. truID is committed to the privacy of Your Personal Information. truID will only collect the minimum amount of Personal Information necessary for it or Your Service Provider or its/their Authorised Third Party Service Providers to provide its/their services to You. –
  1. truID uses a combination of technical, procedural and operational measures to keep Your Personal Information private, safe and secure. Please read more about our security.
  2. truID undertakes to You that it shall at all times use all appropriate measures to: –
    1. comply with the provisions of POPIA and any other privacy and data protection legislation applicable in all relevant jurisdictions governing the collection, storage, use and Processing of Personal Information;
    2. not Process Your Personal Information for any purpose other than as provided for in these Terms and ensure, in so far as is reasonably possible, that there is no breach of POPIA and/or any other applicable privacy and data protection laws;
    3. comply with any of Your specific instructions when Processing Your Personal information (to avoid doubt, the accessing, collecting, transmitting, storing and Processing of Your Personal Information constitutes such instructions);
    4. not disclose or otherwise make available Your Personal Information to any third party other than Your Service Provider and any Authorised Third Party Service Providers who require access to Your Personal Information strictly to enable Your Service Provider and/or truID to provide You with their/its services;
    5. ensure that the integrity and confidentiality of Your Personal Information in its possession or under its control is secure and remains confidential;
  3. immediately notify You of any infringements of POPIA or other applicable data protection legislation; and
  4. destroy or irretrievably delete (from all medium) Your Personal Information by agreement upon the receipt of a written request from You to destroy Your Personal Information.
2. Unless You have disabled “cookies” in Your internet browser, truID will store cookies (small text files containing a string of characters) on Your Equipment when You access the truID System. These cookies enable truID to recognise You as a returning user, track your usage behaviour, as well as store Your user preferences and other information. truID. Cookies also allow truID to provide custom, personalised content and information, monitor the effectiveness of Our marketing campaigns and monitor aggregate metrics such as total number of users that have accessed the truID System.
3. Upon written request received from You, truID will disclose the full details on the measures and protections taken by it to comply with POPIA and any other applicable privacy and data protection laws.
4. Notwithstanding the aforementioned, You recognize and agree that hosting data online involves risks of unauthorised disclosure or exposure and that, in Using the truID System, You assume such risks. truID gives no representation, warranty, or guarantee that Your Personal Information will not be exposed or disclosed through errors or the actions of third parties.
5. Please be aware that truID may change its privacy policy at any time. We will notify You of any lessening of Your rights or Our obligations regarding your Personal Information before such changes are made. The most current version of the Our privacy policy will govern Our use of Your Personal Information and will always be available athttp://www.truid.co.za.
QUERIES
1. If you have a query or dispute in respect of truID, please contact us via our Customer Support Portal on weekdays between 8am and 5pm. If the query or dispute relates to any information we have obtained from Your bank or other source on Your behalf, You acknowledge and understand that we may refer the query or dispute to them if we deem it appropriate.