Welcome to our privacy notice. We are Bettr (Pty) Ltd (registration number 2017/387049/07) and this is our plan of action when it comes to protecting your privacy. We respect your privacy rights and take the protection of personal information very seriously. The purpose of this notice is to describe the way that we collect, store, use, and protect data that can be associated with you or another specific natural or juristic person and can be used to identify you or that person (“personal information”).
This notice applies to you, if you are:
Personal information includes:
Common examples of the types of personal information which we may collect and process include your:
Sensitive personal information
Depending on the products or services that you require, we may also collect sensitive personal information including your:
You must accept all the terms of this notice when you order any of our products or order, register for, or use the website, application, customer support channels (including but not limited to WhatsApp, in-app chat, email, voice calls, bug reporting, etc.) or any of our services. If you do not agree with anything in this notice, then you may not order any of our products or order, register for, or use the website, application, customer support channels or any of our services.
You may not access our website, application, customer support channels or order our products or services if you are younger than 16 (sixteen) years old or do not have legal capacity to conclude legally binding contracts.
By accepting this notice, you are deemed to have read, understood, accepted, and agreed to be bound by all of its terms.
You may only send us your own personal information or the information of another data subject where you have their permission to do so. You must ensure that any permission or consent that you obtain from a data subject to process their data is in written form, using clear and easily understandable language.
We may change the terms of this notice at any time by updating this web page. We will notify you of any changes by placing a notice in a prominent place on the website or the application, or by sending you an email detailing the changes that we have made and indicating the date that they were last updated. If you do not agree with the changes, then you must stop using the website, the application, customer support channels and our products and services. If you continue to use the website, the application, customer support channels or our products or services following notification of a change to the terms, the updated terms will apply to you and you will be deemed to have accepted those updated terms.
Once you register on our website, application or customer support channels you will no longer be anonymous to us. You will provide us with certain personal information.
This personal information will include:
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 notice.
When you order any products or services from us, you will be asked to provide us with additional information on a voluntary basis (products information or services information).
We may place small text files called ‘cookies’ on your device when you visit our website, use our application or customer support channels. These files do not contain personal information, but they do contain a personal identifier allowing us to associate your personal information with a certain device. These files serve a number of useful purposes for you, including:
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 notice of the company that created it, and not by us.
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.
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, application, customer support channels or when you enter competitions, take advantage of promotions, respond to surveys, order certain additional products or services, or otherwise use the optional features and functionality of our website, application or customer support channels.
We may monitor and record any telephone calls between us, unless you specifically request us not to.
Purpose for collection
We may use or process any products information, 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:
We may use your information for the purposes described above and:
We will only process personal information where an appropriate legal justification for such processing exists, namely:
Entering into or performance of a contract
This includes all the processing that is required to enable us to onboard you for one or more of our products or services (e.g. verify your identity, assess whether you qualify for the product/service, enrolling you, verify the accuracy of your information against third party databases and public records from time to time, etc.) and to perform in terms of the obligations of contracts concluded with you for provision of our products or services and managing our relationship with you for the duration of the contract and as required after termination of the relationship.
Compliance with law
Banking and financial services are highly regulated which means that there are a number of laws, regulations and directives that require us to perform certain processing activities. We also continuously perform due diligence and assurance checks to verify accuracy and quality of data.
We process personal information in order to protect your legitimate interest and where it is necessary for pursuing the legitimate interest of the responsible party or a third party to whom the information is supplied. We process personal information based on this justification only where we believe that such processing is beneficial to you and is limited to such processing that is necessary to achieve the purpose. Where our own or a third party’s legitimate interest is used as the justification, we always consider the nature of the legitimate interest and whether there is a risk of harm or an unreasonable infringement of your right to privacy.
We will obtain your consent to collect personal information:
We perform the following processing activities based on your consent that you gave us in product or service agreements, unless you have withdrawn your consent at any time after giving consent.
Messages and updates
We may send administrative messages and email updates to you about the website, the application or customer support channels. In some cases, we may also send you primarily promotional messages. You can choose to opt-out of promotional messages. We will not send you promotional messages unless you have chosen to opt-into them. But, we may send you one message asking you to opt-into promotional messages without you having opted-into promotional messages.
While you are logged into the website or application, 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.
We may share your personal information with:
We may disclose your personal information as required by law or governmental audit.
We may disclose your personal information if required:
We will not sell personal information. No personal information will be disclosed to anyone except as provided in this Privacy Notice.
We may disclose aggregate statistics (information about the customer population in general terms) about the personal information to advertisers or business partners.
We may need to disclose personal information to our employees that require the personal information to do their jobs. These include our responsible management, human resources, accounting, audit, compliance, information technology, or other personnel. Any of our employees or personnel that handle your personal information will have signed non-disclosure and confidentiality agreements.
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.
We take the security of personal information very seriously and always do our best to comply with applicable data protection laws. Our hosting company will host our website in a secure server environment that uses a firewall and other advanced security measures to prevent interference or access from outside intruders. We authorise access to personal information only for those employees who require it to fulfil their job responsibilities. We implement disaster recover procedures where appropriate. Please refer to our Information Security Notice for further context.
We will try to keep the personal information we collect as accurate, complete and up to date as is necessary for the purposes defined in this notice. From time to time we may request you to update your personal information on the website. You are able to review or update any personal information that we hold on you by accessing the application, emailing us, or phoning us. Please note that in order to better protect you and safeguard your personal information, we take steps to verify your identity before granting you access to your account or making any corrections to your personal information. Throughout your interaction with us you retain the right to rectify personal information that is incorrect or inaccurate. This does not apply if we process your personal information in our capacity as an operator or processor on behalf of a responsible party or data controller.
We will only retain your personal information for as long as it is necessary to fulfil the purposes explicitly set out in this notice, unless:
During the period of retention, we will continue to abide by our non-disclosure obligations and will not share or sell your personal information.
We may retain your personal information in physical or electronic records at our discretion.
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. Personal information may be stored on servers located outside the country in which it was collected in a foreign country whose laws protecting personal information may not be as stringent as the laws in the country in which it was collected. You consent to us processing your personal information in a foreign country whose laws regarding processing of personal information may be less than what international best practice recommends.
You may choose to correct or update the personal information you have submitted to us, by clicking the relevant menu in the application or contacting us through our customer support channels.
You are entitled to a right to be forgotten. We will delete any personal information that you don’t want us to have, provided the data is no longer necessary for the purpose for which we collected it. If you do this, we will remove your personal information from our system, but we may still retain certain personal information as required or allowed by law, including, but not limited to:
If you are a data subject of one of our customers (who is the data controller), then you must submit your request to the relevant data controller who will then delete your personal information.
You may request that we restrict the use of your personal information. When we restrict your personal information we still have the right to store it but not use it. You can ask that we do this in writing. We will respond to the request within 30 days.
If you should wish to transfer your data from us to another data controller we will facilitate this transfer. We will pass on all of your personal information to the data controller.
If you are a data subject of one of our customers (who is the data controller), then you must submit your request for your personal information to the relevant data controller, who will then export your personal information as a Microsoft Excel or CSV file.
We will notify our customers of any confirmed data breaches that have occurred. We will notify the relevant supervisory authority and any affected data subjects of the data breach.
We are not responsible for, give no warranties, nor make any representations in respect of the privacy policies or practices of linked or any third-party websites.
If you have any questions or concerns arising from this Privacy Notice or the way in which we handle personal information, please contact us.