1. PROTECTING YOUR PERSONAL INFORMATION

Nyaradzo takes your right to privacy and access to information seriously. This is as per the principles of the Protection of Personal Information Act, 4 of 2013 and Promotion of Access  to Information Act, 2 of 2000, and in general consideration of any other laws that regulate the  rights to privacy and access to information. In this Privacy Statement, any reference to  “Nyaradzo’’ or “we” refers to one or more of the entities, or affiliates of Nyaradzo Financial  Services operating in South Africa. Protecting the privacy, confidentiality and security of your personal information is very  important to us as it is critical for us to maintain your trust and act in the right way to meet your needs. To this end , we have therefore implemented policies and procedures to ensure that your personal information is protected.

This Privacy Notice describes how Nyaradzo collects, uses, discloses, retains and protects your personal information, in accordance with the Protection of Personal Information Act, 4 of 2013 (POPIA) and other relevant laws. POPIA defines personal information as information which relates to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person”. This includes, but is not limited to, your name, sex, gender, address, contact details, identity number and medical or health information.

2. THE PERSONAL INFORMATION WE COLLECT ABOUT YOU

▪ Nyaradzo may collect, acquire, receive, record, organise, collate, store, update, change, retrieve, read, process, analyse, use and share your Personal Information in the manner as set out in this Privacy Statement. When we perform one or more of these actions, we are “Processing” your Personal Information.

▪ “Personal Information” refers to private information about an identifiable natural or juristic person. Personal Information does not include information that does not identify a person (including in instances where that information has been anonymised). The Personal Information that we collect about you may differ on the basis of the products and services that you receive from Nyaradzo.

▪ We may process various types of Personal Information as follows:

• Identity Information, which includes information concerning your name, username or similar identifier, marital status, title, date of birth, gender, race and legal status, as well as copies of your identity documents, photographs, identity number, registration number and your qualifications;

• Contact Information, which includes your billing addresses, delivery addresses, e-mail addresses and telephone numbers, as well as company secretarial information that has been disclosed in relation to you;

• Financial Information, which includes bank account and payment card details, insurance information, financial statements and VAT registration numbers and credit ratings;
• Transaction Information, which includes details about payments made to or received from you and company information, which may consist of financial activity and regulatory disclosures;
• Technical Information, which includes your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Website;

• Profile Information, which includes your username and password, purchases or orders made by you, your interests, preference and feedback;
• Usage Information, which includes information as to your access to and use of the Website, products and services; and
• Marketing and Communications Information, which includes your preferences in respect of receiving marketing information from us and our third parties, and your communication preferences.

3. HOW WE COLLECT INFORMATION

▪ We collect personal information about you and any other person whose details you provide to us in accordance with the relevant laws through:

• Directly from you when you complete a product or service application form, electronically, telephonically or by way of a hard copy;
• Indirectly from you when you interact with us electronically by way of our website, apps, or social media channels
• We will collect your information where you have only partially completed and/or abandoned any information which you began to apply to our website and/or other online forms. Given that we already consider you a customer at this stage, we may use this information to contact you in order to remind you  to complete outstanding information
• Nyaradzo receives Personal Information about you from various third parties and public sources, including: third-party sources, such as other entities within the Nyaradzo Group, intermediaries that are representatives of Nyaradzo entities or have intermediary agreements with third party service providers our information technology suppliers

4. HOW WE USE YOUR PERSONAL INFORMATION

We process your personal information in order to meet compliance and regulatory obligations which include compliance with anti-money laundering legislation. Such processing includes verifying your identity or the identity of your beneficiaries including beneficial owners and/or controlling persons of juristic customers. Nyaradzo is also required by various laws to maintain a record of our dealings with customers. Collected Personal Information is used for maintaining and improving customer experience and facilitate the sale of our products.

Within the confines of the law , Nyaradzo may use Personal Information to :

▪ Provide you with our financial products and services, and maintaining our relationship with you;

▪ Provide you with financial advice and intermediary services as necessary;

▪ Conclude and administer your application,

▪ Execute a transaction or policy update in accordance with your request;

▪ Assess, check, and process claims;

▪ Meet our contractual obligations with you or take steps necessary for the conclusion of a contract with you;

▪ Comply with legislative and regulatory requirements, including codes of conduct and  requirements of regulators (including the Companies and Intellectual Property Commission [“CIPC“] , the Financial Sector Conduct Authority and Prudential Authority);

▪ Carry out investigations to detect and prevent unlawful activity, fraud, moneylaundering and loss, including as part of party due diligence required under applicable laws and in terms of Nyaradzo policies

▪ Share with our auditors and for record-keeping purposes

▪ Maintain the security of our digital channels and systems

▪ Communicate with you and retain a record of our communications with you and your communications with us

5. SHARING YOUR INFORMATION

▪ Nyaradzo may share your Personal Information under the following circumstances:

• With our agents, intermediaries, advisers, service providers and suppliers that have agreed to be bound by this Privacy Statement or similar terms, which offer the same level protection as this Privacy Statement
• Other third parties in relation to the purposes set out under the previous section (How we use your information);
• Other insurers, public bodies and law enforcement (either directly or through shared databases) for fraud detection and prevention;
• To enable us to enforce or apply any other contract between you and us;
• To mitigate any actual or reasonably perceived risk to us, our customers, employees, contractors, agents or any other third party;
• With government agencies and other regulatory, if required to do so by law or if we reasonably believe that such action is necessary comply with the law or with any legal process for example, as requested by the Prudential Authority of Financial Sector Conduct Authority

▪ Nyaradzo WILL NOT sell, rent, or trade your personal information to any third party.

6. SECURITY AND RETENTION OF INFORMATION

▪ Nyaradzo strives to protect the integrity and confidentiality of your personal information.

▪ We have implemented appropriate technical and organisational information security measures including, a robust cybersecurity system , to keep your information secure, accurate, current, and complete. Despite implementation of these measures, we cannot guarantee that your Personal Information is 100% secure. Transmission of any information to us online is done at your own risk.

▪ Your Personal Information is stored on our servers or those of our service providers and in hard copy format where provided as such at our offices

▪ We create a back-up of your information for operational and safety purposes.

▪ We regularly update our information collection, storage and processing practices, including physical security measures in order to ensure that we are up to date with industry best practice

▪ Nyaradzo will hold your personal information for as long as permitted for legal, regulatory, fraud prevention and legitimate business purposes.

▪ For purposes of determining the appropriate retention period for Personal Information, Nyaradzo considers, among other things, the nature and sensitivity of the Personal Information, the potential risks or harm that may result from its unauthorised use or disclosure, the purposes for which we process it and whether those purposes may be achieved through other means. We will always comply with applicable legal, regulatory, tax, accounting or other requirements as they pertain to the retention of Personal Information.

7. RIGHT OF ACCESS TO AND CORRECTION OF PERSONAL INFORMATION

▪ You may ask Nyaradzo to give you a description of your personal information that we hold and/or ask us to correct or update your personal information.

▪ The Promotion of Access to Information Act (PAIA) together with POPIA offer an individual the right to access information held by a public or private body in certain instances. You may exercise this right as per Nyaradzo’s PAIA manual which is accessible under the ‘Documents’ repository on this site.

▪ POPIA, gives you the right to correct any of your personal information which

Nyaradzo holds. This right can be exercised in accordance with the procedure outlined in the PAIA manual

▪ Should Nyaradzo choose to charge a fee for attending to any of the above requests, the law allows us as detailed in the PAIA manual

8. MARKETING

▪ Direct marketing as defined in the Consumer Protection Act and POPIA, means to approach a person, either in person or by mail or electronic communication, for the direct or indirect purpose of:

• Promoting or offering to supply, in the ordinary course of business, any goods or services to that person;

• Requesting the person to make a donation of any kind, for any reason.

▪Nyaradzo may send you information on news, trends, services, events and promotions for our own similar products and or services . Should you wish not to be contacted, you have the right to opt out of receiving such marketing at any time at [info@nyaradzo.co.za] Please note Nyaradzo may continue to send you communication that is not marketing related but relevant to your policy.

9. CHANGES TO THIS PRIVACY STATEMENT

▪ Nyaradzo may change or update this Privacy Notice. The latest version of this notice  will be published on our website for you to view. The latest version will replace all earlier versions, unless otherwise specified. Please check the website regularly to ensure that you are aware of the latest version of this Privacy Notice.

10. THE INFORMATION REGULATOR

▪ The Information Regulator has made available the Guide on how to use the Promotion of Access to Information Act 2 of 2000 Guide) on their website. The Guide will assist data subjects to access their personal information in terms of section 23 of POPIA.

▪ Should we fail to resolve your request/query, you have the right to complain to the Information Regulator, whose contact details are:

The Information Regulator

JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001

P.O. Box 31533, Braamfontein, Johannesburg, 2017

Complaints email : complaints.IR@justice.gov.za

General enquiries email: inforeg@justice.gov.za