Introduction

This privacy notice provides a high-level overview of how we use and share personal information across DCB.

In this Privacy Notice, any reference to DCB includes the entity listed below:

• Data Consumer Bureau (Pty) Ltd with registration number 2022/601499/07.

High level Overview

DCB strives to protect privacy as we collect, use, process, disclose, transfer and retain personal information.

If your personal information is used unlawfully or infringes on your privacy, you have the right to object.

Contact details

Contact us about personal information issues on:

Telephone: 010 447 8108
Email: info@consumerbureau.co.za

How we use personal information

DCB limits the use and disclosure of personal information to the terms of the National Credit Act 34 of 2005 (“NCA”), the Protection of Personal Information Act 4 of 2013 (“POPIA”) and / or any other applicable laws and regulations.

Unless we have your consent or the law permits us, we do not sell, rent or lease your personal information to others. We will not use or share your personal information in ways unrelated to the circumstances described below.

Unless permitted, we do not use any personal information concerning religious or philosophical beliefs, race or ethnic origin, trade union membership, political persuasion, health, sex life or biometric data.

Products and services

Many of our products and services rely on personal information. For example:

Credit reporting: DCB compiles consumer credit information in credit reports from applications to, for example, credit providers or services providers for credit or services.

Direct marketing: When you visit the DCB Site, DCB may invite you to sign up for information, promotional offers and / or marketing.
You can sign up for our news by ticking the opt-in box, "I want to receive news and information on products to help me manage my debt better."

If you consent, DCB will access, use, process and analyse your personal information, your consumer credit information, Internet activity and marketing data to provide personalised offers from DCB and our trusted partners.

Digital marketing: To provide relevant products and services to consumers, we enable business partners to use our data and technology to create, deploy and measure targeted digital advertising programs.

Advertising: DCB may use domestic or overseas third-party advertising companies to serve ads on DCB Site or on other sites which we use for advertising. We may also use third-party analytical tools to personalise advertisements and enhance the visitor experience.

Market research: Participation in market research activities is optional. When you opt-in, we use your information to improve the experience of our products and services. Third parties assisting with market research can keep non-personal aggregated data for our research purposes.

Business products: DCB may use personal information to promote and market relevant products, services and special offers from us and our affiliates.

Customer service: DCB may use personal information to identify customers, process transactions and provide quality service.

Recruitment: DCB uses personal information when we receive an employment application.

Business operations

DCB may use personal information for our internal operations, such as:

• Names, contact details and other information from consumers who contact us to deal with their enquiries.
• Employee information (including employment and educational history, background checks and performance appraisals) to manage our relationship.
• CCTV cameras in public areas of our business premises for the safety of staff and visitors, and the security of our information and assets.
• Biometric information to manage access to our business premises, in order to ensure the safety of staff and visitors, and the security of our information and assets.
• Legal and regulatory purposes, such as responding to complaints or enquiries about how we have used personal information.
• In addition, we may aggregate anonymised data to provide advertising performance analytics to business partners.

Where do we get personal information

DCB gets personal information directly from its business partners, suppliers, clients, site visitors, and product and services customers signing up for any of our products or services.

How long we keep personal information

DCB retains information to fulfil the purpose(s) of its provision, to comply with applicable laws, and for as long as your consent to such purpose(s) remains valid after termination of our relationship.

Our legal basis for handling personal information

Legitimate interests: The Protection of Personal Information Act (POPIA) allows personal information usage where necessary for legitimate purposes without undue adverse impact. We base most of our processing activities on the 'legitimate interests' condition.

Consent: DCB relies on consent to process personal information.

Contracts: If you sign up for one of our online services, DCB will use personal information to provide the services as set out in the Terms & Conditions. We also use this basis for processing some of our staff data.

Compliance: DCB only accesses, uses, and discloses personal information without consent in exceptional circumstances where necessary to:

• Comply with the law and/or a legal process
• Comply with requests for information from police or government authorities
• Protect and defend our rights or property (including the enforcement of agreements)
• Protect the public interest
• Act in urgent circumstances to protect the personal safety of our employees or members of the public
• Act on implied consent

We apply the above in terms of the NCA, POPIA, and other relevant national legislation.

Who we share personal information with

Our clients and resale partners:
We share personal information with our clients for the purposes described above. Our clients have privacy notices providing details on how they use the data we supply.

These clients typically operate in the following sectors:

• Financial services (including banks, loans, credit cards, mortgages, pensions, and investments and savings providers)
• Insurance
• Retail (including car sales/leasing and online retailers)
• Telecommunications
• Marketing agencies acting for other organisations
• Auto dealers
• Commercial
• Collections

If our clients appoint an intermediary to act on their behalf, they too will receive the data.

Service providers

Our clients may provide information to third parties that help us achieve the purposes described above. For example:

• Cloud-based services help host, manage and analyse our databases.
• Cloud-based technologies support our ordinary business operations.
• Printing companies to produce and send direct mail or other correspondence.
• Payment service providers to help with payments made by individuals.
• Market research companies to help us better understand our customers.
• A specialist sub-contractor operates our CCTV system.
• Services Providers that assist us with providing our services to you.

These service providers cannot use your information for their purposes or on behalf of other organisations unless you consent.

Where do we store and send personal information

We may make use of Service Providers situated outside of South Africa. We will not transfer personal information to a country lacking laws that provide an adequate level of information protection — unless we have an agreement with the recipient requiring measures that offer a similar level of protection as POPIA in South Africa.

How the personal information is used

We provide data and analytics that help our clients make decisions about lending and other matters, as their data, knowledge, processes, and practices play a significant role in those decisions.

For example, when we sell our services to credit or loan providers, we do not decide whether they should grant you credit or a loan — this is for the lender to decide.

Your rights concerning personal information

We outline your rights regarding the personal information we hold about you below:

• Access: You can access all information that we hold about you by contacting us through info@consumerbureau.co.za.
• Correction/Destruction/Deletion: If the information we hold about you is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or obtained unlawfully, you have a right to ask us to correct it or delete it.
• Objection to processing: You may object (on reasonable grounds) to processing your personal information unless legislation provides for such processing.
• Objection to direct marketing: You may object to us using your personal information for direct marketing, and if you do, we will stop.

Where to lodge a complaint

We strive to deliver the highest levels of customer service; however, if you are unsatisfied, kindly contact us:

Telephone: 010 447 8108
Email: info@consumerbureau.co.za

Personal Information

As alluded to hereinabove, DCB limits the use and disclosure of personal information to the terms of the National Credit Act 34 of 2005 (NCA), Protection of Personal Information Act 4 of 2013 (POPIA) and/or any other applicable laws and/or regulations.

Many of DCB’s products and services rely on personal information, which may include:

• Credit reporting: DCB compiles consumer credit information in credit reports from applications to, for example, credit providers or services providers for credit or services.
• Credit services: We may provide your information to organisations you deal with directly, such as credit risk assessors.
• Example: credit risk assessment If you apply for credit from one of our clients, they send us your data so we can find you in our databases and reply with information about your credit history. They use that information to assess your creditworthiness.
• Fraud detection services: We may provide personal information to organisations other than those you deal with directly.
• Example: fraud alerts If we receive numerous identity verification checks against an individual in a short space of time, this could indicate someone is attempting identity theft or another form of fraud. In this case, we provide real-time fraud alerts to clients subscribed to that service.

If you have provided your details to an organisation to confirm your identity, we may retain those details and link them to other details we hold about you. Then, if a fraudster tries to use your details to apply for credit with a different organisation, we can raise a potential fraud alert.

Sources for information

We may collect your personal information, or obtain information originating from the following sources:

• An organ of state, a court or judicial officer.
• Any person who supplies goods, services or utilities to consumers.
• A person providing long-term and short-term insurance.
• Entities involved in fraud investigation.
• Educational institutions.
• Debt collectors to whom a credit provider ceded or sold book debt.
• Other registered credit bureaus.

The information we need

To verify information, credit providers need to include:

• Your initials or full name and surname.
• Your South African identity number (if you have one) or your passport number and date of birth.

Note: Any further information requested by credit providers must be necessary and relevant to your application. No law forces you to give information, but a credit provider can't consider your credit application if you don't provide the information required.

How long we keep personal information

Simply put, we keep personal information for as long as necessary. More technically, we retain personal information to fulfil the purpose(s) of its provision, to comply with applicable laws, and for as long as your consent to such purpose(s) remains valid after termination of our relationship.

The Regulations to the NCA require we use various categories of information only for the maximum periods prescribed for credit scoring or credit assessment.

We keep specific data indefinitely to verify the integrity of the information we may need to process in the future. We store this information securely and don't use it for any other purpose.

Our legal basis for handling personal information

Required by the NCA: The Protection of Personal Information Act (POPIA) allows personal information usage where necessary for legitimate purposes without undue adverse impact. We base most of our processing activities on the requirements placed on us by the NCA.

Consent: In most instances, consumer consent to use personal information comes to DCB through our clients and data suppliers.

You need to agree on who can use your personal information and how. To do this, persons who have your information must notify you should they have your data and how they plan to use it.

DCB strives to ensure its clients and data suppliers honour their contractual obligation to get all legally required consents before accessing personal information in our credit reports.

Contracts: If you sign up for one of our online services, DCB will use your personal information to provide the services as set out in the Terms & Conditions. DCB will further use this basis for processing some of our staff data. Refer to the privacy notice on the relevant website for details.

Compliance: DCB only accesses, uses, and discloses personal information without consent in exceptional circumstances where necessary to:

• Comply with the law or a legal process served on us.
• Comply with requests for information from police or government authorities.
• Protect and defend our rights or property (including the enforcement of agreements).
• Protect the public interest.
• Act in urgent circumstances to protect the personal safety of our employees or members of the public.

Closing Remarks

At Data Consumer Bureau (Pty) Ltd, we are committed to safeguarding your privacy and ensuring that your personal information is handled with the utmost care and respect. We continuously strive to enhance our privacy practices to protect your data and provide you with transparent and trustworthy services.

We encourage you to regularly review our Privacy Policy, as we may update it to reflect changes in our services or in the law. Should you have any questions or concerns regarding your personal information, please do not hesitate to contact us.

Thank you for trusting Data Consumer Bureau with your personal information. We value your trust and are dedicated to keeping your data safe and secure.

Last Updated: August 2024