This policy ("Policy") further sets out the data protection principles and procedures of Ovajoyed (the “Organisation”). In particular, this Policy summarises how the Organisation processes personal information belonging to, amongst others, applicants for funding, portfolio companies, business contacts, partners, and contractors (“data subjects”).
The Organisation takes the privacy of personal information very seriously, and is committed to processing personal information in accordance with data protection legislation, including the Protection of Personal Information Act (No. 4 of 2013) ("POPI") and, where applicable, the General Data Protection Regulation (EU 2016/679) ("GDPR"), which includes the retained EU law version of GDPR as it forms part of the law of the United Kingdom, and any other data protection legislation and/or regulation applicable to the Organisation (collectively, the “Data Protection Laws").
This Policy is made available on the Organisation's website (https://www.ovajoyed.com/) and is otherwise available in hard copy, on request.
The Organisation's Information Officers' details are as set out below:
Information Officers: Lee Zuk
This Policy uses terminology defined in POPI (these terms appear in bold). Please see paragraph 23 of this Policy where this terminology is defined and for guidance in interpreting this Policy.
The procedures and principles set out in this Policy must be followed at all times by the Organisation's employees, agents, contractors, affiliates, and other parties working on behalf of the Organisation, including third-party operators processing personal information on the Organisation's behalf. No personal information must be processed for or on the Organisation's behalf unless processed in accordance with this Policy.
Information We Collect From Your Use of the Services
Financial information, such as business size and loan amount;
Identification Information, such as:
Name, email address and phone number;
Other Information You Provide, such as information that you voluntarily provide to us, including your survey responses; suggestions for improvements; referrals; or any other actions you perform on the Services.
We collect data from when you interact with our website or applications (eg location or device type) as well as through other third party sources. We use this data in order to make our products and services better for you and others. We also collect personal information from third parties, including credit bureaux, customers and your bank and any public information source to verify your identity, purchase order information, do a credit check, assess risk and prevent fraud. By using our website you agree to this usage.
Other sources, including:
Social media networks;
Online advertising companies;
Service providers who help us with third-party identity verification, credit confirmation and fraud detection;
Credit bureaus and financial institutions;
Mailing list providers; and
Publicly available sources (such as public records of criminal convictions and arrest records).
HOW WE USE YOUR INFORMATION
(i) Performing, Improving and Developing our Services - eg delivering support you request, developing new products and services; improving, maintaining, customising, and facilitating your use of our Services; processing any transactions or transfers, internal research, measuring, tracking, and analyzing for business optimisation; and assessing risk and other profile enhancers and pricing and risk sensitivities.
(ii) Communicating with You About our Services - eg getting your feedback about our Services; Providing information about and promoting our Services Or information to you about our products and services.
(iii) Protecting our Services and Maintaining a Trusted Environment - eg Conducting investigations, complying with and enforcing applicable laws, regulations, legal requirements and industry standards, and responding to lawful requests for information from the government or to valid legal process; Contacting you to resolve disputes, collect fees, and help you with our Services; Making sure you follow or applicable agreements or policies; Investigating, detecting, preventing, recovering from or reporting fraud, misrepresentations, security breaches or incidents, other potentially prohibited, malicious, or illegal activities, or to otherwise help protect your account, including to dispute chargebacks on your behalf; Protecting your, our, our customers’, or your customers’ rights or property, or the security or integrity of our Services; Verifying or maintaining the quality and safety of our Services; and Verifying your identity.
(iv) Advertising and Marketing - eg communicating with you about opportunities, products, services, contests, promotions, discounts, incentives, surveys, and rewards offered by us and select partners. If we send you marketing emails, each email will have instructions on how you can “opt out” of getting future marketing from us.
(v) Other Uses - For any other reason we may tell you about from time to time.
We may share the personal information with (inter alia) the following categories of service providers and third parties:
With service providers who help us provide, maintain, and improve our Services (e.g., vendors who help us with fraud prevention, identity verification, and fee collection services), as well as financial institutions, credit bureaus, partners and other entities that help us provide the Services;
With service providers that help us run our advertising campaigns, expert guidance and advice, special offers, or other events or activities;
With our clients and/ or partner;
With 3rd party credit and risk partner;
With criminal check partie;
With employees and/ or contractors who assist in our processes;
If we do or try to do a corporate merger, consolidation, or restructuring (including during due diligence and negotiation of these); the sale of substantially all of our stock and/or assets; the financing, acquisition, divestiture, or dissolution of all or a portion of our business; or other corporate change.
(vii) Safety and Compliance with Law
If we believe that disclosure is reasonably necessary (i) to comply with any applicable law, regulation, legal process or governmental request (e.g., from creditors, tax, or other legal or governmental enforcement); (ii) to establish, exercise or defend our legal rights; (iii) to enforce or comply with our General Terms or other applicable agreements or policies; (iv) to protect our or our customers’ rights or property, or the security or integrity of our Services; (v) for an investigation of suspected or actual illegal activity; or (vi) to protect us, users of our Services or the public from harm, fraud, or potentially prohibited or illegal activities.
With your consent. For example:
At your direction or as described at the time you agree to share; or
When you authorize a third party application or website to access your information.
Data subjects have the right to have their personal information processed in accordance with the conditions for the lawful processing of personal information as referred to in Chapter 3 of POPI. The Organisation is committed to upholding the rights of data subjects, which rights include: The right to be notified; the right of access; the right to rectification; the right to correction, destruction or erasure; the right to object to or restrict processing; the right to data portability; rights with respect to automated decision-making and profiling; the right to complain to the Regulator; and the right to institute civil proceedings in relation to its personal information.
DATA SUBJECT ACCESS
Data subjects may, at any time, request an Information Officer to supply details as to the personal information which the Organisation holds about that data subject, what the Organisation is doing with that personal information, and why.
The Organisation does not charge a fee for the handling of normal requests. However, the Organisation reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.
RECTIFICATION OF PERSONAL INFORMATION
Data subjects have the right to require the Organisation to rectify any of their personal information that is inaccurate or incomplete. The Organisation shall comply with such requests timeously.
In the event that any affected personal information has been disclosed to third parties, those parties shall be informed of any rectification that must be made to that personal information.
COOKIES AND OTHER SIMILAR TECHNOLOGIES
Personal information may be used to improve our services. Eg - to save the usage data of our website visitors, and provide a customer specific content and IP addresses for analytical purposes and system usage improvements and usability. Your browser can alert you when cookies are placed on your device, and how you can stop or disable them via your browser settings. Please note, however, that without cookies all of the features of our online services may not work properly. If you use a mobile device, you can manage how your device and browser share certain device data by changing the privacy and security settings on your mobile device.
THIRD-PARTY ANALYTICS SERVICES
We may use third-party analytics service providers to help us with our online services, such as Google Analytics, Facebook etc. We may disclose your information (including IP address) to these analytics providers, and other service providers who use the information to help us figure out how you and others use our online services.
ONLINE TRACKING AND INTEREST-BASED ADVERTISING
You may see certain adverts on other websites because we use third-party services to advertise our services to you. We use these services to target our adverts to you and others based on your demographics, interests, and context. These third party ad services track your online activities over time and across multiple websites by collecting your information through automated technologies, including third-party cookies, web server logs, and web beacons. The information our ad services may collect on our behalf includes data about your visits to websites and the actions you take on those websites. This data collection takes place both on our online services, and on third-party websites that serve our adverts to you. This process also helps us figure out if our adverts to you are effective.
HOW LONG WE KEEP YOUR INFORMATION
We generally keep your information as long as reasonably necessary to provide you the Services and is re-used and stored by us for a reasonable period and in order for the completion of any of our related services, including any marketing and advertising of products by ourselves. AFter such time we store anonymised versions of your data to optimise and improve our services and in order that we are consistent with applicable law or as we believe is reasonably necessary to comply with applicable law, regulation, legal process, or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce our General Terms or other applicable agreements or policies, or to take any other actions consistent with applicable law and for future products and/or services that we believe may be of assistance to you.
TRANSFERRING PERSONAL DATA ACROSS BORDERS
The Organisation may, from time to time, transfer personal information to countries outside of the country in which the personal information was collected, but only where one of the following principles applies:
the third party who is the recipient of the information is subject to a law, binding corporate rules or binding agreement which provide an adequate level of protection that:
effectively upholds principles for reasonable processing of the information that are substantially similar to the conditions for the lawful processing of personal information relating to a data subject who is a natural person and, where applicable, a juristic person; and
includes provisions, that are substantially similar to this section, relating to the further transfer of personal information from the recipient to third parties who are in a foreign country;
the data subject consents to the transfer;
the transfer is necessary for the performance of a contract between the data subject and the responsible party, or for the implementation of pre-contractual measures taken in response to the data subject’s request;
the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the data subject between the responsible party and a third party; or
the transfer is for the benefit of the data subject, and: it is not reasonably practicable to obtain the consent of the data subject to that transfer; if it were reasonably practicable to obtain such consent, the data subject would be likely to give it.
You can opt out of receiving promotional messages from us by following the instructions in those messages, by informing the caller that you would not like to receive future promotional calls, or by unsubscribing on the provided links. You may only opt out of text messages from us by replying STOP. Opting out of receiving communications may impact your use of the Services. If you decide to opt out, we may still send you non-promotional communications messages about your account or our ongoing business relations.
Children’s Personal Information
Our Services are general audience services not directed at children under the age of 18. If we learn that any information we collect has been provided by a child under the age of 18, we will promptly delete that information.
We take reasonable measures, including administrative, technical, and physical safeguards, to protect your information from loss, theft, and misuse, and unauthorized access, disclosure, alteration, and destruction. Nevertheless, the internet is not a 100% secure environment, and we cannot guarantee absolute security of the transmission or storage of your information. We hold information about you both at our own premises and with the assistance of third-party service providers such as google.
STORAGE AND PROCESSING
We may, and we may use third-party service providers to process and store your information in the United Kingdom and South Africa. By using our website you consent to the transfer of your data for the purposes of our services.
You can contact our privacy team with any questions or concerns at the address below.