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Privacy Notice

Privacy Notice

PRIVACY NOTICE

Who are we?

E Centive Proprietary Limited (“E Centive ” or “we” “us”) are a Responsible Party in terms of the Protection of Personal Information Act, 4 0f 2013 (POPIA) with respect to your Personal Information.  We process all such Personal Information in order to enable us to do business with you and to provide products and services to you as requested. In this notice, “you” means you as an individual with whom we are dealing whose Personal Information we may need to collect and process in order to provide the requested products and services, and for any of the purposes described below.

What Personal Information is collected?

Please note that in accordance with Section 18 of POPIA you are hereby expressly informed of the fact that when you interact with us (“E Centive Dealing”) you may need to provide us with the following Personal Information, including but not limited to:

2.1.1    Your full names (name and surname),

2.1.2    Registration numbers

2.1.3    Identity or passport numbers,

2.1.4    Financial information including bank account information,

2.1.5    Statutory Information

2.1.6    E-mail and physical addresses,

2.1.7    Postal address, contact information,

2.1.8    Information relating to your occupation

2.1.9    Agent ID or salesman code

2.1.10 Support ticket query and related information

2.1.11  Physical address

2.1.12   Biometrics

2.1.13   Unique Identifiers

2.1.7    Personal Information submitted by you forming part of onboarding/registration documentation from time to time.

 

 

 

What do we do with your Personal Information and why do we collect it?

We take the privacy of any data subjects with whom we engage very seriously and we only collect and process Personal Information for specific purposes which are connected to our legitimate business purposes, which we generally need in order to comply with our obligations towards you and also to comply with obligations which are imposed upon us in terms of applicable laws regulating us. The Personal Information you provide to E Centive pursuant to your E Centive Dealing is typically processed for the following purpose(s), which purposes are connected to our legitimate business purposes:

  • To provide or manage any information, products and/or services requested by you pursuant to your E Centive
  • To evaluate whether or not to offer, extend or modify any offering or services requested by, or provided to, you.
  • Using, processing, sharing/transferring or engaging in analytics of your Personal Information for (i) routine business purposes; or (ii) the purposes of new business or product development.
  • To establish your needs, requirements and preferences in relation to the products and/or services provided by E-Centive.
  • To identify your risk profile and make an election as to whether we wish to enter into a contractual relationship with you and if so, on what terms.
  • To allocate unique identifiers to you for the purpose of processing your Personal Information, securely storing, retaining, and recalling your Personal Information from time to time, regardless of whether you conclude an agreement with E-Centive.
  • For general administration purposes pertaining to your request/s and to reply to you when you contact us for support.
  • To improve the quality of our products and services.
  • To analyse your Personal Information collected for research and statistical purposes.
  • To transfer your Personal Information across the borders of South Africa to other jurisdictions should it be required in the legitimate pursuit of E-Centive’s business requirements.
  • To identify products and services which might be of interest to you, as well as to inform you of such products and/or services.
  • To investigate and attempt to resolve any queries, complaints or requests.
  • To verify that the personal information provided is true and accurate.
  • To, unless you expressly “opt out”, process your Personal Information as defined above for the purposes of direct marketing and advertising to you of products and services provided by E Centive in future.
  • To, for the purposes of enhancing the scope of products and services we can offer to you or the method of delivery, share or transfer all or any part of your Personal Information to a third party who is a potential business partner or actual provider/supplier of outsourced services to us.
  • To, at any time procure or share information relating to your credit worthiness and risk profile from or with any registered credit bureau or credit provider’s industry association or industry body, which includes information pertaining to your credit history, financial history, judgements, default history and sharing information for purposes of risk analysis, tracing and related purposes.

This notice applies to all data (including all Personal Information) past, present or future submitted by you to E Centive or which we otherwise obtain pursuant to undertaking our normal business activities. In supplementation of the above purposes, we are legally required to collect and process certain personal information for specific purposes, such as:

·         Implementation of the entire incentive program and any other services which we offer

·         to facilitate your registration for the incentive programs offered

·         to track your claims to incentives

·         to ensure that your incentive card is delivered to you

·         to ensure your incentives are paid

·         to verify details provided by the you

·         to verify claims

 

 

 

Who do we share your Personal Information with?

For us to maintain the high standards of product and service delivery you have come to appreciate, we are required to share your personal information with some of our suppliers, service providers and business partners (banks, original equipment manufacturers (OEMs), network operators, financial services providers, couriers and SMS service providers). We use service providers and suppliers who we trust, who we have agreements with and they have agreed to keep your personal information secure and confidential, and to only use it for purposes which we have agreed to. 

So that you are fully made aware, please note that we do use service providers in order to:

 

Administer the entire incentive program and any other services which we offer.

 

 

Where do we store your Personal Information?

All your personal information is stored securely by E Centive through:

Encryption of data at rest

Data stored at rest in the underlying storage is encrypted, as are its automated backups, read replicas, and snapshots. The industry standard AES-256 encryption algorithm is used to encrypt data.


Encryption of data in transit

Communication between the application and database is encrypted using SSL/TLS.


Network isolation and database specific firewall

Database instances are networked within a cloud based VPN, and only application servers are allowed access. For maintenance access directly on database instances our team uses a tunnel to the VPN, and all communication of this nature is also encrypted using SSL/TLS.

 

In storing your Personal Information, we may transmit or transfer Personal Information outside South Africa to a foreign country, as such, personal information may be stored on servers located outside of South Africa in foreign countries that have different data protection laws in place. We are comfortable that these foreign countries protect Personal Information to an extent that compares to the way in which we do, which is acceptable to us. If you are interested in who these suppliers are, you are welcome to ask us at any time, we will happily disclose this information to you upon request.

What are your Rights?

It is important that you know what your rights are with regards to our processing of your personal information, and we want to make this clear to you also. Although we take steps to safeguard your personal information, process it lawfully and only share it with suppliers and service providers we trust, you have the following rights:

  • You can ask us at any time what personal information of yours we hold – we do not have any hidden agenda here.
  • You can ask us what personal information of yours is, or was, shared with any of our suppliers, service providers, or any third party for that matter – we will happily tell you.
  • You can ask us to update your personal information or even delete any information which is no longer accurate – we want to make sure your information is accurate and complete, but we need your help.
  • You can object to our processing of your personal information – we don’t want to process your information if you don’t want us to, but just bear in mind it may influence our ability to fulfil our obligations towards you.
  • You are more than welcome to lodge a complaint with the information regulator if you feel that we are not complying with POPIA – please do try and speak to us first, but this is a remedy available to you and we want you to know about it.

The contact details of the Information Regulator are:

The Information Regulator (South Africa)

JD House 27 Stiemens Street Braamfontein Johannesburg, 2001

PO Box 31533

Braamfontein, Johannesburg, 2107

E-mail: inforeg@justice.gov.za

 

With that said, we have (and continue to) implement reasonable security measures and protocols to protect the personal information we hold. These measures are to protect any personal information we hold from being disclosed without authorisation, from loss, damage, destruction or unauthorised access. As you will appreciate nothing is 100% secure in this day and age and therefore, we ask that if you suspect that either you, or we, have had an information security breach, please notify us immediately so that we can take action. You can do so by contacting our Information Officer whose information is set out below.  If you need to speak with our Information Officer, feel free to contact him/her. Our Head of Operations is Bronwynn Futcher and any queries or even questions you may have regarding this privacy notice can be directed to him/her at 011 807 5345.