CUSTOMER PRIVACY NOTICE

This Notice explains how we obtain, use and disclose your personal information, as is required by the Protection of Personal Information Act (“PPI”).

TFS is committed to protecting your privacy and to ensure that your personal information is collected and used properly, lawfully and transparently.

This Notice sets out:

  1. Who we are
  2. What information we collect
  3. Our aim to provide ongoing financial, legal and associated services
  4. To whom we disclose your information
  5. How we safeguard your information
  6. Your rights to access and correction of information
  7. Notice relating to Children
  8. Definition Personal Information
  9. Changes to this Notice
  10. How to contact us
  1. WHO WE ARE
    1. In this Notice,
      1. “TFS”, “TFS Group” or “we” refers to one or more of TFS Holding (Pty) Ltd, any of our subsidiaries, employees, officers and affiliates (hereinafter “TFS”).
      2. Financial services refers to [__________________]
      3. Legal services refers to the provision of legal advice on a wide range of estate planning, business structuring and commercial legal drafting; and
      4. Associated services refers to
        1. [_____________________]
    2. [SHORT DESCRIPTION]
  2. THE INFORMATION WE COLLECT
    1. We collect and process your personal information mainly to provide you with access to our services and products, to help us improve our offerings to you and for certain other purposes explained below.
    2. The type of information we collect will depend on the purpose for which it is collected and used. We will only collect information that we need for that purpose.
    3. We collect information directly from you where you provide us with your personal details, for example when you purchase a product or services from us or when you submit enquiries to us or contact us. Where possible, we will inform you what information you are required to provide to us and what information is optional.
    4. We also collect information about you from other sources as explained below.
    5. With your consent, we may also supplement the information that you provide to us with information we receive from other companies in the TFS Group in order to offer you a more consistent and personalized experience in your interactions with TFS.
    6. Website usage information is collected using “cookies” which allows us to collect standard internet visitor usage information.
    7. HOW WE USE YOUR INFORMATION
      1. We will use your personal information only for the purposes for which it was collected or agreed with you, for example:
      2. To provide our products or services to you, to carry out the transaction you requested and to maintain our relationship;
      3. To conduct credit reference searches or verification;
      4. To confirm and verify your identity or to verify that you are an authorised user for security purposes;
      5. For operational purposes, and where applicable, credit scoring and assessment and credit management;
      6. For the detection and prevention of fraud, crime, money laundering or other malpractice;
      7. For debt tracing or debt recovery;
      8. To conduct market or customer satisfaction research or for statistical analysis;
      9. For audit and record keeping purposes;
      10. Legal advisory purposes;
      11. In connection with legal proceedings.
    8. We will also use your personal information to comply with legal and regulatory requirements or industry codes to which we subscribe or which apply to us, or when it is otherwise allowed by law (for example to protect Old Mutual's interests).
  3. ONGOING SERVICES
    1. Given our aim to provide you with ongoing financial, legal and associated services, we would like to use your information to keep you informed about other financial products and services which may be of particular interest to you.
    2. You may also give and withdraw consent and tell us what your communication preferences are by clicking here to log into _______________ or by contacting us at the numbers/addresses provided below.
  4. DISCLOSURE OF INFORMATION
    1. We may disclose your personal information to our service providers who are involved in the delivery of products or services to you. We have agreements in place to ensure that they comply with these privacy terms.
    2. We may share your personal information with, and obtain information about you from:
      1. Third parties for the purposes listed above, for example credit reference and fraud prevention agencies, law enforcement agencies;
      2. The South African Revenue Service when required;
      3. Other companies in the TFS Group when we believe it will enhance the services and products we can offer to you, but only where you have not objected to such sharing;
      4. Other third parties from whom you have chosen to receive marketing information.
    3. We may also disclose your information:
      1. Where we have a duty or a right to disclose in terms of law or industry codes;
      2. Where we believe it is necessary to protect our rights.
  5. INFORMATION SECURITY
    1. TFS has implemented generally accepted standards of technology and operational security in order to protect personally identifiable information from loss, misuse, alteration or destruction. All TFS employees follow a network-wide security policy. Only authorised TFS personnel are provided access to personally identifiable information and these employees have agreed to ensure confidentiality of this information. TFS's policy is to use secure socket layer technology for the protection of credit card information submitted through web forms. This policy is also required for any fulfilment agents of the TFS Group.
    2. We are legally obliged to provide adequate protection for the personal information we hold and to stop unauthorised access and use of personal information. We will, on an ongoing basis, continue to review our security controls and related processes to ensure that your personal information is secure.
    3. Our security policies and procedures cover:
      1. Physical security;
      2. Computer and network security;
      3. Access to personal information;
      4. Secure communications;
      5. Security in contracting out activities or functions;
      6. Retention and disposal of information;
      7. Acceptable usage of personal information;
      8. Governance and regulatory issues;
      9. Monitoring access and usage of private information;
      10. Investigating and reacting to security incidents.
    4. When we contract with third parties, we impose appropriate security, privacy and confidentiality obligations on them to ensure that personal information that we remain responsible for, is kept secure.
    5. We may need to transfer your personal information to another country for processing or storage. We will ensure that anyone to whom we pass your personal information agrees to treat your information with the same level of protection as we are obliged to.
  6. YOUR RIGHTS:
    1. ACCESS TO INFORMATION
      1. You have the right to request a copy of the personal information we hold about you. To do this, simply click here to log into _____________ to review your personal information or contact us at the numbers/addresses listed below and specify what information you would like. We will take all reasonable steps to confirm your identity before providing details of your personal information.
      2. Please note that any such access request may be subject to a payment of a legally allowable fee.
    2. CORRECTION OF YOUR INFORMATION
      1. You have the right to ask us to update, correct or delete your personal information. You may do this by clicking here to log into ____________ to review and change your personal information or by contacting us at the numbers/addresses provided below.
      2. We will take all reasonable steps to confirm your identity before making changes to personal information we may hold about you.
      3. We would appreciate it if you would keep your personal information accurate. Please update your information by logging onto _________ whenever your details change.
  7. CHILDREN
    TFS understands the importance of protecting children's privacy especially in an online environment. The TFS sites covered by this privacy statement are not intentionally designed for or directed at children 18 years of age or younger. It is TFS' policy never to knowingly collect or maintain information about anyone under the age of 18.
  8. PERSONAL INFORMATION
    Personal Information means information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person, including, but not limited to—
    1. information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth of the person;
    2. information relating to the education or the medical, financial, criminal or employment history of the person;
    3. any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier or other particular assignment to the person;
    4. the biometric information of the person;
    5. the personal opinions, views or preferences of the person;
    6. correspondence sent by the person that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence;
    7. the views or opinions of another individual about the person; and
    8. the name of the person if it appears with other personal information relating to the person or if the disclosure of the name itself would reveal information about the person;
  9. CHANGES TO THIS NOTICE
    1. Please note that we may amend this Notice from time to time. Please check this website periodically to inform yourself of any changes.
  10. HOW TO CONTACT US
    If you have questions about this Notice or believe we have not adhered to it, or need further information about our privacy practices or wish to give or withdraw consent, exercise preferences or access or correct your personal information, please contact us at the following numbers/addresses: