Introduction

Dola Money (Pty) Ltd is a private company registered in the Republic of South Africa with registration No. 2013/171171/07, operating under the laws of South Africa. Dola Money is also a registered Credit Provider in terms of the National Credit Act No. 34 of 2005. (Registration number: NCRCP14262).

We respect your privacy and take the protection of personal information very seriously. The purpose of this policy is to describe the way that we collect, store, use, and protect information that can be associated with you, or another specific natural or juristic person, and that can be used to identify you or that person (personal information).

Our privacy policy applies to all current and former customers and may change from time to time. Please also read the loan terms and conditions that are emailed to you as part of the loan application process, which provide further details of how we collect, process, and use your personal information. The loan terms and conditions should be read together with this privacy policy.

This privacy policy complies with and facilitates the obligations required from the South African Protection of Personal Information Act, No. 4 of 2013 (“POPI”), as amended.

Data subjects covered by this policy

This policy applies to you if you are:

• a visitor to our website; or
• a customer who has requested the services that we provide.

Our data processing roles and information officer

Dola Money is the responsible party and as such we are responsible for your personal data in instances where we decide the processing operations concerning your personal data. We also operate as an operator of personal data on behalf of users/clients who make use of our website and services to process their data for their purposes.

For clarity, parties who provide us with their own data subjects’ data via the services/website for processing will remain the responsible party for their data, where we will operate exclusively as the operator for such data. Should we receive any engagements about our processing of such data, we will direct the relevant data subject to the client user to account for the processing as the data subject’s responsible party.

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us by using the details set out below.

• Full name of legal entity: Dola Money (Pty) Ltd.
• Contact person: Yolanda le Roux.
• Email address: customercare@dola.co.za.
• Postal address: Postnet Suite 010, Private Bag X2, Ruimsig, 1732.
• Telephone number: 011 568 2963 / 011 568 2964.

We acknowledge your right to make a complaint to the South African Regulator’s office, but we will appreciate the chance to deal with your concerns before you approach any such regulator. Please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We may change the terms of this policy at any time by updating this web page. If you do not agree with the changes, then you must stop using the website and our services. If you continue to use the website or services following a change to the terms, the changed terms will apply to you and you will be deemed to have accepted those updated terms.

We try to keep the personal information we collect as accurate, complete and up to date as is necessary for the purposes defined in this policy. From time to time, we may request you to update your personal information on the website.

You can review or update any personal information that we have on you by accessing your account online, emailing us, or phoning us. Please note that to better protect you and safeguard your personal information, we may verify your identity before granting you access to your account or making any corrections to your personal information.

Third-party links on website or otherwise

The website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements or terms. When you leave our website or engage with such third parties, we encourage you to read the privacy policy of every third party you engage with.

The personal information we process

Personal information means:

• information automatically collected when you visit our website;
• information collected on registration;
• information collected on submission; and
• optional information that you provide to us voluntarily.

but excludes:

• information that has been made anonymous so that it does not identify a specific person;
• permanently de-identified information that does not relate or cannot be traced back to you specifically;
• non-personal statistical information collected and compiled by us; and
• information that you have provided voluntarily in an open, public environment or forum including any blog, chat room, community, classifieds, or discussion board (because the information has been disclosed in a public forum, it is no longer confidential and does not constitute personal information subject to protection under this policy).

Examples

Common examples of the types of personal information which we may collect and process are:

• identifying information e.g. your name, date of birth, and an identification number.
• contact information e.g. your phone number and/or email address.
• address information e.g. your physical and/or postal address; or
• demographic information e.g. your gender and/or marital status.

Sensitive personal information

Depending on the services that you require, we may collect sensitive personal information such as your financial information (e.g. your bank account and/or statement details).

Lawful grounds for processing

We will only use your personal data as allowed by law and for legitimate reasons, which you hereby expressly understand and consent to.

Your personal data will generally be used in the following circumstances:

• where we have your express consent to do so;
• where we need to consult with you or perform on the services contract we are about to enter into or have entered into with you;
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and/or
• where we need to comply with a legal or regulatory obligation.

Acceptance

Acceptance required

You must accept all the terms of this policy when you request our services. If there is any term or condition in this policy that you do not agree to, then you may not request our services.

Legal capacity

You may not access our website or request our services if you are younger than 18 years old or do not have the legal capacity to conclude legally binding contracts.

Deemed acceptance

By accepting this policy, you are deemed to have read, understood, accepted, and agreed to be bound by all of its terms.

Your obligations

You may only send us your own personal information, or the information of another data subject where you have their permission to do so.

Collection of your data

We have listed below the various methods for how we derive/collect personal data from you:

On registration

When you register on our website, you provide us with personal information which may include, but is not limited to:

• your name and surname;
• your nickname;
• your email address;
• your telephone number;
• your ID number; and
• your postal address or street address.

We will use this personal information to fulfil your account, provide additional services and information to you as we reasonably think appropriate, and for any other purposes set out in this policy.

On request

When you request our services, you may be asked to provide us with additional information on a voluntary basis (services information).

From browser

We automatically receive and record internet usage information on our server logs, such as your Internet Protocol address (IP address), browsing habits, click patterns, version of software installed, system type, screen resolutions, colour capabilities, plug-ins, language settings, cookie preferences, search engine keywords, JavaScript enablement, the content and pages that you access on the website, and the dates and times that you visit the website, paths taken, and time spent on sites and pages within the website (usage information). Please note that other websites visited before entering our website might place personal information within your URL during a visit to it, and we have no control over such websites. Accordingly, a subsequent website that collects URL information may log some personal information.

Cookies

Most websites use cookies. Cookies are small text files that are placed on your device when you visit a website, to:

• grant you access to age-restricted content;
• tailor the website’s functionality to you personally by remembering your preferences;
• improving how the website performs;
• allowing third parties to provide services to the website; and
• helping to deliver targeted advertising where appropriate in compliance with the applicable laws.

Cookies do not contain personal information, but a personal identifier may allow us to associate your personal information with a certain device. Your internet browser generally accepts cookies automatically, but you can change this setting to stop accepting them. You can also delete cookies manually. However, no longer accepting cookies or deleting them will prevent you from accessing certain aspects of our website where cookies are necessary. Most websites use cookies. You can find out more about them at www.allaboutcookies.org.

Third-party cookies

Some of our business partners use their own cookies or widgets on our website. We have no access to or control over them. Information collected by any of those cookies or widgets is governed by the privacy policy of the company that created it, and not by us.

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. Our web beacons do not collect, gather, monitor or share any of your personal information. We merely use them to compile anonymous information about our website.

Optional details

You may also provide additional information to us on a voluntary basis (optional information). This includes content or products that you decide to upload or download from our website or when you enter competitions, take advantage of promotions, respond to surveys, order certain services, or otherwise use the optional features and functionality of our website.

Recording calls

We may monitor and record any telephone call that you make to us.

Purposes for collecting your data

We may use or process any services information, or optional information that you provide to us for the purposes that you indicated when you agreed to provide it to us. Processing includes gathering your personal information, disclosing it, and combining it with other personal information. We generally collect and process your personal information for various purposes, including:

• services purposes, such as collecting requests for and providing our services;
• marketing purposes, such as pursuing lawful related marketing activities;
• business purposes, such as internal audit, accounting, business planning, and joint ventures, disposals of business, or other proposed and actual transactions; and
• legal purposes, such as handling claims, complying with regulations, or pursuing good governance.

We may use your usage information for the purposes described above and to:

• remember your information so that you will not have to re-enter it during your visit or the next time you access the website;
• monitor website usage metrics such as total number of visitors and pages accessed; and
• track your entries, submissions, and status in any promotions or other activities in connection with your usage of the website.

Use of your data

Our obligations

We may use your personal information to fulfil our obligations to you.

Messages and updates

We may send administrative messages and email updates to you about the website. In some cases, we may also send you primarily promotional messages. You can choose to opt-out of promotional messages.

Targeted content

While you are logged into the website, we may display targeted adverts and other relevant information based on your personal information. In a completely automated process, computers process the personal information and match it to adverts or related information. We never share personal information with any advertiser, unless you specifically provide us with your consent to do so. Advertisers receive a record of the total number of impressions and clicks for each advert. They do not receive any personal information. If you click on an advert, we may send a referring URL to the advertiser’s website identifying that a customer is visiting from the website. We do not send personal information to advertisers with the referring URL. Once you are on the advertiser’s website however, the advertiser is able to collect your personal information.

Disclosure of your data to third parties

Sharing

By virtue of the services we provide, we have to share some limited personal data with external third parties to assist in providing you with the Dola Money Services. These contracted and secure third-parties are listed below, alongside the nature of the data transferred, as well as the reason for such transfer.

Name	Information	Reason
Experian	RSA ID Number	Credit assessment
	First Name
	Last Name
	Gender
	Date of birth
	Address
EasyDebit	RSA ID Number	Bank account verification Debit order collection
	First Name
	Last Name
	Bank Details

Regulators

We may disclose your personal information as required by law or governmental audit.

Law enforcement

We may disclose personal information to third parties if required for legal reasons.

• by a subpoena or court order;
• to comply with any law;
• to protect the safety of any individual or the general public; and
• to prevent violation of our customer relationship terms.

No selling

We will not sell personal information, and no personal information will be disclosed to anyone except as provided in this privacy policy.

Marketing purposes

We may disclose aggregate statistics (information about the customer population in general terms) to advertisers or business partners. No personal information will be provided to third party marketers to enable them to contact you.

Employees

We may need to disclose personal information to our employees that require the personal information to do their jobs e.g. management, human resources, accounting, audit, compliance, information technology and/or other personnel.

Change of ownership

If we undergo a change in ownership, or a merger with, acquisition by, or sale of assets to, another entity, we may assign our rights to the personal information we process to a successor, purchaser, or separate entity. We will disclose the transfer on the website. If you are concerned about your personal information migrating to a new owner, you may request us to delete your personal information.

Opting Out

You can at any time request us to cease or change your marketing preferences. Where you opt-out of receiving these marketing messages, this opt-out will not apply to other personal data which we process for another lawful basis.

Security

We take the security of personal information very seriously and do our best to comply with applicable data protection laws. Our website is hosted in a secure server environment that uses a firewall and advanced security measures to prevent interference or access from outside intruders.

Retention

We will only retain your personal information for as long as it is necessary to fulfil the purposes explicitly set out in this policy, unless:

• retention of the record is required or authorised by law; or
• you have consented to the retention of the record.

We may retain your personal information in physical or electronic records at our discretion. During the period of retention, we will continue to abide by our non-disclosure obligations and will not share or sell your personal information.

To determine the appropriate retention period for personal data, we consider: the amount, nature, and sensitivity of the personal data; the potential risk of harm from unauthorised use or disclosure of your personal data; the purposes for which we process your personal data; whether we can achieve those purposes through other means; and the applicable legal requirements.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Transfer to another country

We may transmit or transfer personal information outside of the country in which it was collected to a foreign country and process it in that country. Whenever we transfer your personal data out of the territory, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the Information Regulator’s Office of South Africa; and/or
• Where we use certain service providers, we may use specific contracts/clauses approved by the Information Regulator’s Office which give personal data the same protection it has in South Africa.

Your legal rights

In relation to our processing of your data, you have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected. (We may need to verify the accuracy of the new data you provide to us.)
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no valid reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure should there be legal reasons (which will be communicated to you) that are applicable at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground, on the basis that you view it as impacting on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. Note that in some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • if you want us to establish the data’s accuracy;
  • where our use of the data is unlawful, but you do not want us to erase it;
  • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform on a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain website access or services to you. We will advise you if this is the case at the time you withdraw your consent. (Please take note that regardless of your right to withdraw consent under POPI, other South African legislation applies and may require that we continue to process your data in order to comply with anti-corruption, crime-fighting and/or other national legislation, which you expressly understand and agree to.)

You will not have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data, or to exercise any of your other rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month, subject to the complexity of the request or number of requests you make.

Enquiries

If you have any questions or concerns arising from this privacy policy or how we handle personal information, please contact us at customercare@dola.co.za.