Privacy Notice

This privacy policy has been compiled to better serve those who are concerned with how their 'Personally Identifiable Information' (PII) is being used online. PII, as described in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website.

01

Introduction

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”).

02

Audience

This notice applies to you, if you are:

  • a visitor to our website;
  • a user of our App; or
  • engaging with us through a customer support channel.

03

Personal Information

Personal information includes:

  • certain information that we collect automatically when you visit our website, use our application or engage with our customer support channels;
  • certain information collected on registration (see below);
  • certain information collected on submission;
  • certain information collected to investigate and resolve customer support queries; and
  • optional information that you provide to us voluntarily (see below);

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 notice).

Common examples

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

  • identifying information – such as your name, date of birth, or identification number of any kind;
  • contact information – such as your phone number or email address;
  • address information – such as your physical or postal address; or
  • demographic information – such as your gender or marital status.

Sensitive personal information

Depending on the products or services that you require, we may also collect sensitive personal information including your:

  • financial information – such as your bank account details;
  • special personal information such as:
  • demographic information – such as your race or ethnicity; criminal information – such as information about your commission or alleged commission of any offence or about any related legal proceedings; or employment information – including your membership of a trade union.
  • personal information of children – under the age of 18 (eighteen).

04

Acceptance

Acceptance required

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.

Legal capacity

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.

Deemed acceptance

By accepting this notice, 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. 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.

05

Changes

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.

06

Collection

On registration

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:

  • your name and surname;
  • your identity number and document;
  • your email address;
  • your biometric identification information (such as selfie, video and audio recording);
  • your mobile number;
  • your residential address;
  • your profile photo, and
  • your username and passcode.

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.

On order

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).

From browser

We automatically receive and record internet usage information on our server logs from your browser (mobile or desktop), 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

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:

  • granting you access to age restricted content;
  • tailoring our website’s functionality to you personally by letting us remember your preferences;
  • improving how our website performs;
  • allowing third parties to provide services to our website; and
  • helping us deliver targeted advertising where appropriate in compliance with the applicable laws.

Your internet browser generally accepts cookies automatically, but you can often 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. Many websites use cookies and 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 notice 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, 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.

Recording calls

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:

  • products purposes – such as collecting orders for, supplying, and supporting our products;
  • services purposes – such as providing our services;
  • marketing purposes – such as pursuing lawful related marketing activities;
  • business purposes – such as internal audit, accounting, business planning, 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 information for the purposes described above and:

  • remember your information so that you will not have to re-enter it during your visit or the next time you access the website, the application or customer support channels;
  • 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, the application or customer support channels.

07

Lawful use

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.

Legitimate interest

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.

08

Consent

We will obtain your consent to collect personal information:

  • in accordance with applicable law;
  • when you provide us with any registration information or optional 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.

Targeted content

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.

09

Disclosure

Sharing

We may share your personal information with:

  • other divisions or companies within the group of companies to which we belong so as to provide joint content and services like registration, for transactions and customer support, to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about our products, services, and communications (they will only use this information to send you marketing communications if you have requested their products or services);
  • an affiliate, in which case we will seek to require the affiliates to honour this privacy notice;
  • companies and organisations that assist us with identity verification, background screening, due diligence, processing or otherwise fulfilling transactions that you have requested and fraud prevention services;
  • our products suppliers or service providers under contract who help supply certain products or help with parts of our business operations, including fraud prevention, bill collection, marketing, technology services (our contracts dictate that these products suppliers or service providers only use your information in connection with the products they supply or services they perform for us and not for their own benefit);
  • credit bureaus to report account information, as permitted by law;
  • banking partners as required by credit card association rules for inclusion on their list of terminated merchants (in the event that you utilise the services to receive payments and you meet their criteria);
  • third parties that we have contracted with to provide specific services tailored to the personal information that you have provided us; and
  • other third parties who provide us with relevant services where appropriate.

Regulators

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

Law enforcement

We may disclose your personal information if required:

  • 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 customers.

No selling

We will not sell personal information. No personal information will be disclosed to anyone except as provided in this Privacy Notice.

Marketing purposes

We may disclose aggregate statistics (information about the customer population in general terms) about the personal information to advertisers or business partners.

Employees

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.

10

Security

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.

11

Accurate and up to date

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.

12

Retention

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:

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

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.

13

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. 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.

14

Updating or removing

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:

  • where we can show legitimate grounds for processing your personal information that override your request; or
  • where we process your personal information in order to establish, exercise or defend legal claims.

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.

15

Restriction of processing

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.

16

Data portability

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.

17

Data breaches

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.

18

Limitation

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.

19

Enquiries

If you have any questions or concerns arising from this Privacy Notice or the way in which we handle personal information, please contact us.