1. Introduction and Scope

1.1 Ownisha For You Financial Services (Pty) Ltd, 2017/225708/07, an authorised financial services provider (FSP number 53572) under the Financial Advisory and Intermediary Services Act, 37 of 2002 (“Ownisha”, “we”, “us” or “our”), with its registered office at 132 Fox street, 1^st floor Mathomo House, Johannesburg, 2001, is the responsible party (as defined in POPIA) in respect of your personal information.

1.2 We are committed to protecting your privacy and to processing your personal information lawfully, reasonably and in a manner that is relevant to our business as a financial services provider, in accordance with the Protection of Personal Information Act, 4 of 2013 (“POPIA”).

1.3 We have appointed an Information Officer who is responsible for our compliance with POPIA. You may contact our Information Officer at Naledi@ownisha.com with any questions about this Privacy Policy or the way we handle your personal information.

1.4 This Privacy Policy applies to all users of the Website, our clients, prospective clients and any other person whose personal information we process in the course of providing financial services. It must be read together with our Website Terms of Use and any other agreement you may have with us. Where there is a conflict, the specific agreement between you and Ownisha will take precedence over this Privacy Policy.

1.5 This Privacy Policy does not apply to the processing of personal information by third parties, including on websites linked to or from the Website.

2. What is Personal Information?

2.1 “Personal Information” means information relating to an identifiable, living natural person, and where applicable, an identifiable, existing juristic person (such as a company or trust), including but not limited to:

• Identity information: your name, surname, date of birth, gender, identity or passport number, marital status and copies of your identity documents;
• Contact information: your postal and physical address, email address and telephone numbers;
• Financial information: your bank account details, income information, tax reference number, credit and affordability information, and information relating to the financial products or services you hold with us or apply for;
• Product and policy information: details of the financial products, policies or services you hold, apply for or enquire about, including claims history;
• Technical and usage information: your IP address, browser type, device information, login data and information about how you use the Website;
• Marketing preferences: your choices regarding direct marketing communications from us.

2.2 In limited circumstances, and only where necessary and permitted by law, we may process special personal information about you (such as health information relevant to certain insurance products, or information relating to criminal behaviour as part of our regulatory screening obligations). Special personal information will only be processed with your consent, or where another ground for lawful processing under POPIA applies.

3. What Does “Processing” Mean, and How Will Ownisha Process Your Personal Information?

3.1 “Processing” means any activity concerning your personal information, whether or not by automated means, including collecting, receiving, recording, organising, storing, updating, retrieving, using, distributing, merging, restricting, degrading or deleting it.

3.2 Ownisha will process your personal information:

• only for the specific, lawful purposes described in this Privacy Policy or otherwise disclosed to you at the time of collection;
• using appropriate technical and organisational security measures to protect it against loss, unauthorised access, or unlawful processing;
• by way of both manual (hard copy) and electronic means, including through our internal systems, client relationship and policy administration systems, and, where applicable, service providers who process personal information on our behalf under written agreements;
• in a manner that is adequate, relevant and not excessive in relation to the purpose for which it is collected; and
• only for as long as is necessary to fulfil the purpose for which it was collected, or as required by law.

4. What Will Ownisha Use Your Personal Information For?

We may use your personal information to:

• provide you with intermediary services, and assess the suitability of products for your needs;
• process applications for, and administer, financial products and services, including premium collection and claims handling;
• verify your identity and carry out the customer due diligence and screening required under the Financial Intelligence Centre Act, 38 of 2001 (FICA) and other applicable laws;
• communicate with you about your policies, products, transactions and any changes affecting them;
• comply with our regulatory reporting and record-keeping obligations to bodies such as the Financial Sector Conduct Authority (FSCA), the South African Reserve Bank (SARB) and the Financial Intelligence Centre;
• send you direct marketing communications, where you have consented to this (see clause 6 below);
• maintain, secure and improve the Website and your experience of it;
• detect, investigate and prevent fraud, security incidents or breaches of our terms; and
• exercise or defend our legal rights or comply with any other lawful obligation.

We will obtain your consent before using your personal information for any purpose materially different from those set out above.

5. Sharing of Your Personal Information

5.1 Ownisha will not sell or rent your personal information to third parties. We may, however, share your personal information where it is reasonably necessary to provide you with the products or services you have requested, or where we are legally required or permitted to do so, including with:

• product suppliers, insurers, reinsurers and underwriters with whom you hold or apply for a product;
• our service providers and agents (such as IT hosting providers, auditors and administrators) who process personal information on our behalf under written confidentiality and data protection agreements;
• regulators and government bodies, including the FSCA, SARB, the Information Regulator and the Financial Intelligence Centre, where required by law;
• professional advisers, such as our auditors and legal advisers; and
• any party to whom we are required to disclose information pursuant to a court order, subpoena or other legal process.

5.2 Other than as set out above, the only information we will ever disclose to third parties is aggregated or de-identified information that does not identify you personally.

6. Direct Marketing

6.1 We will only send you direct marketing communications by electronic means (such as email or SMS) if you have opted in to receive these, or if you are an existing client of Ownisha and the communication relates to similar products or services, as permitted under section 69 of POPIA.

6.2 You may opt out of receiving direct marketing communications from us at any time, free of charge, by using the “unsubscribe” function in any marketing communication, or by contacting us at info@ownisha.com.

6.3 Opting out of direct marketing will not affect our ability to send you essential communications relating to products or services you already hold with us.

7. Your Consent to the Processing of Your Personal Information

8. Your Rights

Subject to POPIA, you have the right to:

• request access to the personal information we hold about you;
• request that we correct or update any personal information that is inaccurate, incomplete or out of date;
• request that we delete personal information that we no longer have a lawful basis to retain;
• object to the processing of your personal information in certain circumstances, including for direct marketing purposes;
• request that we restrict the processing of your personal information in certain circumstances;
• withdraw any consent you have previously given us, at any time; and
• lodge a complaint with the Information Regulator if you believe we have processed your personal information unlawfully (see clause 11 below).

To exercise any of these rights, please contact our Information Officer using the details in clause 10 below. We may need to verify your identity before responding to your request, and we will respond within the timeframes required by POPIA.

9. Security and Retention of Your Personal Information

9.1 We implement appropriate technical and organisational measures, consistent with industry standards, to protect your personal information against loss, unauthorised access, alteration or disclosure.

9.2 We will retain your personal information only for as long as necessary to fulfil the purposes described in this Privacy Policy, or as required by applicable law (including our FICA, FAIS and other regulatory record-keeping obligations), after which it will be securely deleted or de-identified.

10. Changes to this Privacy Policy and Contact Information

10.1 Ownisha reserves the right to amend this Privacy Policy from time to time, at its sole discretion. Any changes will be published on the Website, and where appropriate, we will take reasonable steps to notify you of material changes.

10.2 Should you have any queries about this Privacy Policy, believe that any information we hold about you is incorrect, or wish to exercise any of your rights under clause 8, please contact our Information Officer:

11. Contact Details of the Information Regulator

11.1 If you are not satisfied with how Ownisha has responded to your concerns, or believe that your rights in respect of your personal information have been infringed, you may lodge a complaint with the Information Regulator of South Africa:

• Physical address: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191
• Complaints email: POPIAComplaints@inforegulator.org.za
• General enquiries: enquiries@inforegulator.org.za
• Website: www.inforegulator.org.za

11.2 If you are located outside South Africa, you may also be entitled to lodge a complaint with the relevant data protection authority in your own country.