ADMiT PRIVACY NOTICE

Version: August 2024

YOUR USE AND CONTINUED USE OF ADMIT AND OUR SERVICES INDICATES THAT YOU HAVE BOTH READ AND ACCEPT THIS PRIVACY NOTICE AND ALL TERMS AND CONDITIONS AND NOTICES INCORPORATED HEREUNDER BY REFERENCE (I.E THAT ALSO FORM PART OF THESE) (“T&Cs”), INCLUDING:

ADMiT Consumer Terms and Conditions of Service

ADMiT Client Standard Terms and Conditions

ADMiT General Terms of Use

1) DEFINITIONS

In these T&Cs, the following terms shall have the meaning indicated below.

ADMiT (Platform): includes this/any ADMiT website, platform and/or any related (and/or enhanced) mobi-sites, software applications, or any other ADMiT related portals specifically made available by Principa to You.

Applicable Law: means all laws and regulations that Principa is required to comply with.

Assessment: means the test/s (including psychometric test/s) (being a set of predetermined questions) provided to and taken by Consumers, through ADMiT, in order to generate a Consumer Score/Profile.

Authorised Providers: means a third-party Client who contracts with Principa to access the features and functionality of ADMiT including the ability to access Consumer Score for the purposes set out herein or any other legal purpose

Consumer / Customer: means an individual (with or without a credit risk rating) who is economically active within the applicable territory, who takes the Assessment and uses the Services.

Consumer Score/s: means the risk rating/s generated through ADMiT and assigned to a Consumer, included but not limited to through the completion of the Assessment.

Consumer Data: means all other information and data variables related to a Consumer, besides the Consumer Score, housed on ADMiT including information provided by the Consumer and/or from other sources.

Consumer Profile: means the Consumer information housed on ADMiT, consisting of the Consumer Score and Consumer Data.

Client / Lender: means a person and/or juristic person that registers on the Client Portal to use the Services.

Client Portal: means the portal available to all Principa clients to sign up and receive services (including the Services) from Principa.

Principa, Us, We, Our: means Principa (Pty) Ltd (Registration number: 1999/012713/07)) having its registered address at Corner of Century Way and Century Blvd, The Colosseum Building Office 1002 (MO6) Mezzanine Level, Century City, Cape Town, 7441, email: popia@principa.co.za, Telephone +27 21 680 6000.

Performance Data: means data related to the Consumer’s performance in terms of an agreement entered into between a Consumer and Client and provided by the Client to Principa as well as data relating to the uptake of the Assessments by Consumers.  

Personal Information: includes Personal Information and Special Personal Information, as defined under Applicable Law.

Services: means the provision of our products and/or services (including but not limited to the provision of ADMiT, access to ADMiT through the Customer Portal, rendering of the Assessment/s and Consumer Scores or Profiles (as applicable) or when you engage with us or any of our product and/or service offerings, including any instances where your Personal Information is submitted to us directly or through or by a third-party and any supporting or ancillary services.

“You” “Your” or “user”: means, any person who creates an account, uploads any information onto the ADMiT Platform/the Client Portal or uses our Services and includes but is not limited to both Clients and Consumers.

2) INTRODUCTION 

2.1) We are delighted that you have shown interest in Principa. We take the protection of your Personal Information seriously and want you to feel informed when you are engaging with us. 

2.2) This Privacy Notice sets out how we will handle your Personal Information that you give to us or which we collect from third parties. 

2.3) In delivering our products/ carrying out our Services, we will use your Personal Information in accordance with this Privacy Notice and Applicable law.

2.4) Our Services are only intended to be used by persons aged 18 years or over. If you are a parent or guardian and you are aware that your child(ren) has provided us with Personal Information, please contact us. When we become aware that we have collected Personal Information of or from  children without verification of parental consent, we will take steps to delete and/or remove that information from our servers.

3) HOW THIS PRIVACY NOTICE APPLIES TO YOU 

3.1) This Privacy Notice will apply whenever you submit Personal Information to Principa, which will include (but is not limited to) when you browse or use ADMiT or our Services. 

3.2) Your continued use of our Services indicates that you (which may include any representative acting on your behalf) have both read and consented to the terms of this Privacy Notice.

3.3) If you do not agree to any of the provisions of this Privacy Notice, then you should not submit any Personal Information to Principa. Further, we note that if you do not consent to this Privacy Notice, or any parts thereof, we may not be able to provide you with our Services.

3.4) Whilst we try to balance our legitimate business interests with your reasonable expectation to privacy and to take all reasonable measures to prevent unauthorised access to, or disclosure of your Personal Information, we cannot guarantee that your Personal Information will be 100% secure.

4) SCOPE OF OUR PROCESSING

4.1) What we Collect 

4.1.1) We may collect information that allows you to be identified, such as:

4.1.1.1) your name, age, sex, addresses, e-mail address, identity/registration number, passport number, bank details, financial information, electronic identifying data (including the internet address of your domain, cookies, online identifier, web forms, IP addresses, activity logs, unique device identifiers and geo-location data); 

4.1.1.2) Special Personal Information (which could include information relating to your Assessment);

4.1.1.3) records of correspondence or enquiries from you or anyone acting on your behalf;

4.1.1.4) details of transactions, contracts or Services you carry out with us (or our partners and affiliates);  and 

4.1.1.5) any other information that you give us- when you register for our Services, communicate with us by phone, email or otherwise. This includes information you provide when you use or subscribe to our Services, participate in discussion boards or other social media functions on ADMiT, provide us with feedback, participate in surveys, and when you report a problem with  ADMiT.

4.1.2) Details on the different type of information that we may collect from different parties is contained in Annexure A: Overview of Types of Information Collected.

4.1.3) Note: Where you are a party who provides us with the Personal Information of third-parties/data subjects, you are obliged to take steps to inform the data subject/third-party that you need to disclose their details to us, which includes identifying us. We will process their Personal Information in accordance with this Privacy Notice.

4.2) How we Collect 

4.2.1) You may provide Personal Information to us either directly or indirectly (through and agent or intermediary, Authorised Provider or supplier) or through registering for our Services or requesting further information about our Services, whether in writing, through our website, the ADMiT Platform or the Customer Portal (as applicable), over the telephone or any other means. 

4.2.2) We may also collect your Personal Information from your appointed agent, any regulator, or other third party that may hold such information. 

4.3) How we Use Personal Information

4.3.1) We may collect, use, transfer or process your Personal Information: 

4.3.1.1) to provide and perform our Services to you, to notify you of changes to our Services and to improve, monitor and/or evaluate the effectiveness of Principa, its Services or offerings; 

4.3.1.2) to onboard you as a Client which may include running our Client vetting procedures;

4.3.1.3) to respond to and comply with your instructions, complaints or requests and to manage your account or our relationship ;

4.3.1.4) to operate, develop and manage our ADMiT Platform/Customer Portal/other portals;

4.3.1.5) for security (including fraud and crime prevention/reporting), administrative, auditing, operational, marketing and legal or regulatory purposes (which will include complying with any law enforcement agency requests);

4.3.1.6) for operational, marketing, auditing, legal and record keeping requirements;

4.3.1.7) complying with Applicable Laws, including lawful requests for information received from local or foreign law enforcement, government and tax collection agencies; 

4.3.1.8) to third parties for reasons set out in this Notice or where it is lawful to do so (this may include but is not limited sharing information with credit bureaus and prospective buyers or sellers or our business or assets); 

4.3.1.9) to aggregate it on an anonymous basis with other data for data analytical and reporting purposes; 

4.3.1.10) in the case of Consumers, to render and undertake further analysis and profiling of your Consumer Score/Profile (and other related information) to provide such to Authorised Providers for them assess your risk profile and/or to be able to use the information to contact you and to provide you with/carry out different financial services and offerings; 

4.3.1.11) outside of the Republic of South Africa, in accordance with Applicable Law, including for but not limited to for cloud storage and payment purposes and the use/performance of our Services;

4.3.2) We may from time to time (and at any time) contact you for market research about services, products and offerings available from Principa or specific affiliates or subsidiaries which we believe may be of interest to you, by email, phone, text or other electronic means, unless you have unsubscribed from receiving such communications. You will be able to unsubscribe from receiving such communications in the communications themselves. Failing which you can directly reach out to us. 

4.4) Disclosure of Personal Information

4.4.1) Your Personal Information may be disclosed with Principa’s affiliates, subsidiaries, employees, agents, sub-contractors, and selected third parties who process the information on our behalf. 

4.4.2) Under the ADMiT offering, we will share consumer information with various third party Authorised Providers in order for such providers to assess the consumer’s risk profile and/or support them with their decision-making and consumer related processes. For more details about our partners, please refer to our Consumer T&Cs and Annexure A hereto.

4.4.3) We may also disclose your Personal Information to third parties for the purposes of onboarding you as a Client, rendering our Services and for the reasons recorded in clause 4.3 above, including any third parties with whom our Services are carried out/provided in conjunction with and/or who are involved in the completion of our Services and who may need to have your Personal Information in order to fulfil your request or the Services (e.g. Third party payment  providers or cloud service providers).

4.4.4) Further, we have teamed up with certain key partners to offer you certain add-on services, such as our rewards programme and alternative transactional support services. In order to provide these services, we may share your Personal Information with them. 

4.4.5) Wherever these persons are located outside of the country (and your Personal Information may be transferred cross-border) we will adhere to Applicable Laws. 

4.5) Security

We take appropriate technical and organisational steps to ensure the security of your Personal Information including implementing policies and procedures around use of technology and devices, IT security, document retention and destruction and data breach procedures.

4.6) Retention

4.6.1) We will not retain your Personal Information for longer than is needed and/or permitted in compliance with Applicable Law. We determine retention periods in respect of information we hold based on:

4.6.1.1) Legal obligations relating to minimum periods to retain data/records;

4.6.1.2) The purposes for which we process the Personal Information and whether we can achieve those purposes through other means;

4.6.1.3) Whether the information is required for reporting and analysis purposes relating to our operations;

4.6.1.4) The amount, nature, and sensitivity of the Personal Information; and 

4.6.1.5) The potential risk of harm from unauthorised use or disclosure of Personal Information. 


5) ACCESS TO YOUR INFORMATION

5.1) You may request details of personal information which we hold about you under the Promotion of Access to Information Act, 2000 (“PAIA”). Fees to obtain a copy or a description of personal information held about you are prescribed in terms of PAIA. Confirmation of whether or not we hold personal information about you may be requested free of charge. If you would like to obtain a copy of your personal information held by Principa, please review our PAIA Manual.

6) YOUR RIGHTS

6.1) As a user/data subject, you have certain rights, including the right:

6.1.1) to access your Personal Information stored and processed by us. This may be done by emailing us at the address referred to in clause 7 below;

6.1.2) to correct/rectify Personal Information that we hold on your behalf, in instances where such Personal Information is incorrect or incomplete;

6.1.3) to erase Personal Information (also known as ‘the right to be forgotten’). In simple terms, this enables you to request the deletion or removal of your information where there is no compelling reason for us keep using it. This is not a general right to erase; there are exceptions. For example, we have the right to continue using your personal data if such use is necessary for compliance with our legal obligations or for the establishment, exercise or defence of legal claims;

6.1.4) to restrict/suspend processing of Personal Information to only that which is strictly necessary for us to perform our Services to you. Please note that this right is limited in certain situations: when we are processing your Personal Information that we collected from you with your consent you can only request restriction on the basis of: (a) inaccuracy of data; (b) where our processing is unlawful and you don’t want your Personal Information erased; (c) you need it for a legal claim; or (d) if we no longer need to use the data for the purposes for which we hold it. When processing is restricted, we can still store your information, but may not use it further;

6.1.5) to complain- if we breach any of the terms of this Privacy Notice, to complain to the requisite data protection authority in South Africa;

6.1.6) to withdraw your consent at any time, if the processing of the Personal Information is based on consent;

6.1.7) to object to processing of Personal Information if such processing is based on legitimate interests; and

6.1.8) to object to the processing of Personal Information for direct marketing purposes.

7) COMPLAINTS

7.1) If, you wish to raise a complaint regarding the processing of your Personal Information then please first reach out to Principa’s designated Information Officer at: popia@principa.com

7.2) However, if you are still unsatisfied with how we have handled your Personal Information, you can lodge your complaint with the Information Regulator or authority in the applicable and relevant country. We are happy to share further information or guidance in this regard should you need it. 

7.3) The South African Information Regulator’s contact details are set out below.

The Information Regulator

Contact Details: Tel: 012 406 4818

Fax: 086 500 3351 

POPIAComplaints@inforegulator.org.za

PAIAComplaints@inforegulator.org.za

8) INDEMNITY AND LIABILITY  

8.1) Without derogating from any other limitations of liability or indemnifications agreed to between us, in agreeing to the provisions of this Privacy Notice, you hereby unconditionally agree to indemnify us against any liability that may result from the processing of your Personal Information, including any loss, damage or injury arising from any inaccurate or incomplete Personal Information provided to us by the you and/or any third party and/or any unintentional disclosure of your Personal Information to any unauthorised persons. 

8.2) Further while we use every effort to update the information on the ADMiT Platform/Customer Portal regularly, we accept no liability if any information is incorrect or inaccurate information.

9) MARKETING 

9.1) We offer you the opportunity to receive information from us. We will normally send direct marketing by email if we have your email address, but may choose to contact you via other methods such as telephone, SMS, mail or push notifications via your mobile phone.

9.2) You may receive the following types of communications from us:

9.2.1) Service offerings  - we will inform you about our Services, any rewards offerings or other current special offers from time to time. You can unsubscribe from these whenever you like.

9.2.2) Content communications - we will send you content such as tips, research, features and news, coaching programmes on how to keep on top of your risk rating and other related content. You can unsubscribe from these at any time and we will never spam your inbox. 

9.2.3) Core communications - we will send you your Consumer Score , security alerts, any details on significant changes which may impact our Service and other such related content. These communications are an intrinsic part of owning an ADMiT account and cannot be opted-out of.

9.3) By accepting this Privacy Policy or continuing to use our Service, you hereby provide your consent to receiving the marketing communications detailed above.

9.4) If you would like us to stop sending direct marketing to you, we offer simple ways to do this. Whenever you receive direct marketing emails from us, you will be given the chance to unsubscribe.

9.5) Please note, however that if you do opt out we may not be able to provide you with all of our Services.

10) LOG FILES 

10.1) When you visit Principa’s ADMiT Platform even if you do not register an account, we may collect information, such as your IP address, the name of your ISP (Internet Service Provider), your browser, the website from which you visit us, the pages on our ADMiT Platform that you visit and in what sequence, the date and length of your visit, and other information concerning your computer's operating system, language settings, and broad demographic information. This information is aggregated and anonymous data and does not identify you specifically. However, you acknowledge that this data may be able to be used to identify you if it is aggregated with other Personal Information that you supply to us. This information is not shared with third parties and is used only within Principa on a need-to-know basis. Any individually identifiable information related to this data will never be used in any way different to that stated above, without your explicit permission.

11) COOKIES 

11.1) We use cookies. A cookie is a small piece of information stored on your computer, smart phone or device by the web browser for record-keeping purposes. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our Services. 

11.2) You can view and edit certain cookies by looking in the cookies’ directory of your browser installation. Permanent cookies are not required for ADMiT to work but may enhance your browsing experience. Likewise, if you do not accept cookies, you may not be able to use some portions of our Services.

11.3) The following types of cookies are used as part of ADMiT:

11.3.1) "Session cookies": which are used to maintain a so-called 'session state' and only last for the duration of your use of ADMiT . A session cookie expires when you close your browser, or if you have not visited the server for a certain period of time. Session cookies are required for ADMiT  to function optimally but are not used in any way to identify you personally;

11.3.2) "Permanent cookies": these cookies permanently store a unique code on your computer or smart device in order to be able to identify you as an individual user. No Personal Information is stored in permanent cookies; and 

11.3.3) “Security Cookies”: these cookies are used for security related purposes. 

12) THIRD PARTY LINKS AND EXTERNAL TOOLS ON ADMIT

12.1) The Services available through ADMiT, may contain links to other third-party websites (including our affiliates, partners and Authorised Providers). We are not responsible and take no liability for the acts, content or privacy policies of these third-party websites and advise you to review the privacy policies of those parties.

12.2) We may also use third-party service providers to monitor and analyse user behaviour and the use of our Services, which may include but is not limited to: 

12.2.1) Google Analytics: which is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Services. This data is then shared with other Google services and Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out your activity on the website being made available to Google Analytics by installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout?hl=en. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

12.3) These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

13) AMENDMENT OF THIS PRIVACY NOTICE

13.1) We may amend this Privacy Notice and/ or any of the documents incorporated under it by reference from time to time. 

13.2) To the extent permitted by Applicable Law, any such amendment will come into effect and become part of any agreement you have with Principa when notice is given to you of the change by publication on our ADMiT Platform/Customer Portal and, where appropriate, notified to you by e-mail. It is your responsibility to check the ADMiT Platform/Customer Portal often. 

ANNEXURE A: OVERVIEW OF TYPES OF INFORMATION COLLECTED (AND POTENTIALLY SHARED)

(Please note that while we do our best to regularly update this Annexure, it must be regarded as an indicative but not exhaustive list)

Information we collect from Consumers 

If you choose to register on the ADMiT Platform, we will collect your full name, identity number, email address and telephone number in order to create an ADMiT account and to register you for our additional service offerings.  We may also run additional verification or vetting processes, which you will be notified of, in order to complete your registration. These could include verifying your identity, race and biometric information).

Once you have created an account, you can elect:

  • every 6 months (or such other period as specified by Principa) to complete an Assessment/s ; and/or 

  • at any time, to upload various data and other Personal Information 

This information will be used generate your Consumer Profile and/or your Consumer Score/s. 

We will collect:

  • all of the information rendered during and from the Assessment (which note may be a psychometric assessment); and 

  • will also create a Consumer Profile based on your Consumer Score/s and Consumer Data which may include OPTIONAL information, that you elect to provide: such as your gender, qualifications, your province, residential status, monthly income, marital status, date of birth, employment status, dependants and monthly savings. 

Where you have authorised an Authorised Provider to access your Consumer Profile, this information may be shared with the Authorised Providers for the purposes of assisting them in their decision making and consumer lifecycle processes.  We also may get Performance Data about you from Authorised Providers for the purpose of running general/aggregated analytics on the accuracy and functionality of the Assessments/Consumer Profiles.

Further we may:

  • collect any additional information that you upload onto the ADMiT Platform and Personal Information from the internet and social media sites about you and from other third party input tools; and

  • receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, service providers, advertising networks, analytics providers, search information providers, and may receive information about you from them.

If you contact our customer support team, we will use the information you provide to assist you with your query.

Information we collect from Clients

We collect names, company registration numbers and registration documents, contact details, names and identity numbers of directors/members, financial and tax information and key employee information and where applicable for credit purposes, financial statements.

We may conduct ‘know your customer’ or similar compliance screenings on you or your organisation, where we collect information such as your identification or passport documents and information, address, company incorporation documentation and share registers and tax information. We obtain this information either directly from you or from your employer, or the company you are shareholder or director of. In the context of conducting compliance screenings, we may also check the personal information provided to us against public information, including official sources (such as sanctions lists), media sources (such as news reports, journal articles), and additional government and official sources (such as court records, election results, company filings, official company websites and press releases).

In the exceptionally rare event of a compliance screening hit, we may potentially collect Special Personal Information such as information regarding proceedings relating to alleged criminal conduct, race, biometrics  and/or political affiliations.

Information we collect from you when you visit our ADMiT Platform/Website

Our websites uses automatic systems of data collection, such as cookies. Refer to the main body (above) of our Privacy Notice for further information in this regard.