Both Vodacom Payment Services (Pty) Ltd (“VPS”) and Old Mutual Finance (RF) (Pty) Ltd (“Old Mutual”) are committed to respecting the privacy of your personal information. To demonstrate their commitment, VPS and Old Mutual (“we”, “us”, “our”) have created this privacy supplement to communicate their intent to provide effective processes for the appropriate handling of such personal information and to comply with applicable legislation that governs the authentication, protection and disclosure of personal information
This privacy supplement explains how VPS and Old Mutual process your personal information for the personal loan hosted on https://vodalend-personal.vodacom.co.za/ (collectively the “Platform”) to potentially offer you a personal loan. You may access the Platform directly or via the Vodapay application. Importantly, this supplement is designed to provide additional contextual information to the information that is already provided by VPS and Old Mutual in their respective privacy notices/policies. For more information on the VPS privacy notice please click here. For more information on the Old Mutual Privacy Notice please click here.
This privacy supplement explains the information that is collected via the Platform and how it will be used by both VPS and Old Mutual. Should you access the Platform via the Vodapay application, please note that there is a specific privacy policy that applies to your use of the Vodapay application that is ascertainable via the “T&Cs and Privacy” tab in the “My Account” section of the application.
By providing personal information on the Platform, you hereby acknowledge the processing activities outlined both herein and within the respective privacy policies / notices mentioned above.
VPS and Old Mutual are joint responsible parties in terms of the Protection of Personal Information Act 4 of 2013 (“POPIA”).
Your opinion matters to us – if you have any questions about this privacy supplement, you can email VPS at: [email protected] or you can write to our privacy team at:
The Information Officer – Mr Ricardo Platt
Vodacom Payment Services (Pty) Ltd
Vodacom Corporate Park
082 Vodacom Boulevard
Midrand
1685
Alternatively, should you wish to contact Old Mutual for any reason relating to this Privacy Supplement and /or Old Mutual’s Privacy Notice, kindly email Old Mutual at: [email protected].
Information we collect about you
- VPS and Old Mutual will collect personal information when you input personal information on the Platform. The personal information collected will include any information necessary (including financial and / or creditworthiness information) or required by the applicable law in order for VPS and Old Mutual to provide you with a personal loan. The personal information in this regard includes, but is not limited to, information such as your name, surname, ID number, bank statements, salary / wage / income information, credit history and / or employment information.
- We will normally collect information from you directly, however, there are instances where we will also collect additional personal information from third-party information sources (for example your employer, your bank, a credit bureau or other credit providers) to assess your application for a person loan, monitor our credit risk, fulfil our obligations under the National Credit Act and /or to comply with the requirements under any related applicable law.
- VPS may also collect anonymous analytics information on how potential customers use the Platform in order to improve the Platform and troubleshoot. VPS uses a variety of analytics methods including what is commonly referred to as “Big data analytics”. Big data analytics are mathematically driven analysis techniques on large and varied data sets (that is why it is “big” data) to uncover hidden patterns and previously unrevealed trends.
- VPS uses data analytics to, for example:
- Conduct market research and to carry out research and statistical analysis, including to monitor how customers use our networks, products and services; and
- Frame our marketing campaigns and determine how we might personalise those.
VPS and Old Mutual processes your personal information for specific and limited purposes. These include:
- The disclosure of your personal information to our duly appointed service providers who are involved in the delivery of products and / or services to you.
- Processing bank account details to facilitate payment and repayment of approved loans.
- Processing of personal information to assess and handle any customer queries, to develop and improve our products, services, communication methods and the functionality of the Platform.
- Once you have inputted the requisite personal information on the Platform and acknowledged this privacy statement, VPS may contact you to keep you informed about new and existing products and services, competitions, prize draws and other promotions and VPS may use your personal information to run those competitions, prize draws, events and / or promotions, only to the extent that you have not, at any stage, objected to or opted out of receiving such marketing communications. VPS will provide you with an opportunity to Opt-Out of any further direct marketing activities at each instance you are contacted.
- Processing of personal information to create unique personalised offers based on your provided application information on the Platform, which may or may not require the use of ‘footprintless’ credit checks which do not impact your credit record.
- VPS disclosing the personal information that you have provided on Platform to other duly appointed third party lenders and / or service providers to facilitate the potential provision of a related lending product and / or services where your application for a personal loan has been unsuccessful and / or rejected by Old Mutual.
- Disclosure of personal information to Vodacom (Pty) Ltd, Vodacom Insurance Company Limited and Vodacom Life Assurance Company Limited to facilitate the purchase of goods and / or services offered by such companies.
- Processing your personal information for the potential provision of both related and unrelated lending products / services that may be offered by VPS.
You can control your marketing permissions and the personal information we use to tailor these communications at any time. See 'To opt-out of marketing messages' within the 'Your rights' section of this privacy supplement.
We may also transfer and disclose your personal information to third parties who may process information on our behalf:
- To comply with a legal obligation;
- When we believe in good faith that applicable law requires it;
- At the request of governmental authorities conducting an investigation;
- To verify or enforce our “Terms and Conditions” or other applicable policies;
- To detect and protect against fraud, or any technical or security vulnerabilities;
- To respond to an emergency; or otherwise;
- To protect the rights, property, safety, or security of third parties, VPS and Old Mutual; and
- To enable VPS to potentially offer you alternative and / or additional products / services related to our suite of lending products and / or services.
- VPS and Old Mutual takes the security of your personal information very seriously. We take every effort to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure.
- Our measures include implementing technology, policies and processes aimed at protecting the confidentiality, integrity and availability of your personal information. We will update and refine these measures on an ongoing basis.
- Access to your personal information is only permitted among our employees and agents on a need-to-know basis and subject to strict contractual confidentiality obligations when processed by third parties.
We may not retain your personal information any longer than is necessary for achieving the purpose for which your personal information was collected or subsequently processed. We will keep the personal information for a period which enables us to handle or respond to any complaints, queries or concerns relating to the product and / or services offered via the Platform, unless:
- The retention of your personal information is required or authorised by law.
- We reasonably require your personal information for lawful purpose related to our function or activities.
- The retention of your personal information is required by a contract that we enter into with you.
VPS and Old Mutual may also retain your personal information for the following reasons:
- Your personal information may also be retained so that we can continue to improve your experience with us and to ensure that you potentially receive alternative and / or related products or services via the Platform.
- We will actively review the personal information we hold and delete it securely, or in some cases anonymise it when there is no longer a legal, business or consumer need for it to be retained.
We have specialised security teams who constantly review, improve, and ensure the implementation of appropriate, reasonable technical and organisational measures to protect your personal information from unauthorised access, accidental loss, disclosure, or destruction. We are required in terms of POPIA to notify you and the Information Regulator, if any of your personal information has been compromised.
Communications over the internet (such as emails) aren’t secure unless they’ve been encrypted. Your communications may go through a number of countries before being delivered, as this is the nature of the internet.
We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.
We’ll never ask for your secure personal or account information by an unsolicited means of communication. You’re responsible for keeping your personal and account information secure and not sharing it with others.
Our website may provide links to third-party websites. We cannot be responsible for the security and content of such third-party websites. You are therefore required to make sure you read that company’s privacy and cookies policies before using or putting your personal information on their site.
The same applies to any third-party websites or content you connect to using our products and services.
You may choose to disclose your information in certain ways such as social plug-ins (including those offered by Google, Facebook, Twitter and Pinterest) or using third-party services that allow you to post reviews or other information publicly, and a third party could use that information.
Social plug-ins and social applications are operated by the social network themselves and are subject to their own terms of use and privacy and cookies policies. You should make sure you’re familiar with these.
At VPS and Old Mutual, we are committed to processing personal information honestly, ethically, with integrity, and always consistent with applicable laws and our values. Below we set out details on how you can exercise your rights. Please note, under certain circumstances these rights may be limited if we still have lawful grounds to process your personal information. If you have a question or cannot find the answer, please contact the privacy team via the contact details provided above and /or in the respective privacy policy / notice mentioned above.
Rights related to automated decision-making
VPS and Old Mutual may process your personal information using automated means. An automated decision is a decision that is made solely by automatic means, where no humans are involved in the decision-making process related to your personal information. Automated processing on the Platform is conducted to ensure we provide our products and services in a responsible manner i.e. so as to ensure you are not overly indebted.
Right to correct personal information
If you become aware that any of the information we keep about you is incorrect or outdated, you can contact the VPS privacy team at [email protected]
Right to access personal information
You have the right to request a record or description of personal information that we hold about you. This includes the right to request VPS or Old Mutual to confirm, free of charge, whether or not it holds any personal information about you; as well as information about the categories of third parties who have, or have had, access to your personal information. To make this request please contact the VPS privacy team at [email protected]
Right to object to use of personal information
You have the right, in certain circumstances, to object to VPS / Old Mutual processing your personal information. In order for us to provide you with products and services, we are required to process your personal information which is necessary for the conclusion or performance of a contract and to give effect to your signing up to the Platform and as such the provision of your personal information is mandatory.
Under certain circumstances, you have the right to object to certain types of processing, including processing for direct marketing (i.e., receiving emails or SMS from us notifying you or being contacted with varying potential opportunities). If you no longer want to receive marketing messages from us, you can choose to opt out at any time.
Notwithstanding the fact that VPS will ensure you are provided with an opportunity to opt out of any future direct marketing communications at each instance you are provided with same, if you no longer want to receive marketing messages from VPS, you can choose to opt-out at any time.
There are various other ways to opt out:
- Navigate to the notification settings in the Vodapay application
- Contact VPS’ customer services team at 082 135 or [email protected].
- Click the link at the end of a marketing email, text or picture message to unsubscribe from that channel
- Change your communication preferences by dialling *135*181#
- Tell the customer care agent if you receive a marketing call
- Disable push notification messages, including marketing messages, at any time in our apps by changing the notification settings on your device or by uninstalling the app
- Contact our customer care team for guidance
If you’re opted out of marketing, you may still receive service-related messages.
Please note: You may still receive marketing messages for up to 7 (seven) days after opting out while we update our records.
How to lodge a complaint
If you want to contact us about any of your rights or should you believe that we have used your personal information contrary to applicable law, you undertake to first attempt to resolve any concerns with our Customer Services team at 082 135 or [email protected]. We will do our best to help but if you are still unhappy, you can contact the Privacy Office at [email protected]. If you are not satisfied with such process, you have the right to lodge a complaint with the Information Regulator at: The Information Regulator (South Africa)
JD House
27 Stiemens Street
Braamfontein
Johannesburg
2001
Email: [email protected]
Right to restrict use of your personal information
If you feel that the personal information we hold on you is inaccurate, or you believe we shouldn’t be processing your personal information, please contact our Customer Services team at 082 135 or [email protected]. In certain circumstances, for example where you contest the accuracy of your information, or where VPS / Old Mutual no longer requires your information for achieving its purpose but must maintain it for purposes of proof, you have the right to ask us to restrict processing.
Right to deletion
VPS and Old Mutual strives to only process and retain your personal information for as long as we need to. In certain circumstances, for example, where you indicate that your personal information is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or obtained unlawfully, you have the right to request that we erase your personal information that we hold. If you feel that we are retaining your personal information longer than we need, it is worth first checking that your contract with us has been terminated, which you can do with Customer Services. If your contract with us has been terminated, we may still have lawful grounds to process your personal information.
How do we keep this privacy supplement up to date?
- We will update this privacy supplement when necessary to reflect customer feedback and changes in our products and services.
- We will update this privacy supplement when necessary to reflect customer feedback and changes in our products and services. If the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy supplement changes). We will also keep prior versions of this privacy supplement in an archive for your review.
- We will not reduce your rights under this privacy supplement.