EXTERNAL PRIVACY STATEMENT

  1. Introduction
    1. For purposes of this Statement:
      1. “Applicable Laws” means all laws, regulations that Pepkor is required to comply with;
      2. “Client” or “you” means any prospective, new or existing client of Pepkor and its subsidiaries; and
      3. “Pepkor” or “we” or “us” means Pepkor Holdings Limited, its direct and indirect subsidiaries and business units (the Pepkor group of companies). To obtain more information on the Pepkor group of companies please refer to https://www.pepkor.co.za/retail-segments/.
    2. This Statement sets out how your personal information will be used by Pepkor and applies to any information, including personal and special personal information, you give to Pepkor or which Pepkor may collect from third parties.
    3. It is important that you read this Statement carefully before submitting any personal information to Pepkor.
    4. By submitting any personal information to Pepkor you provide consent to the processing of your personal information as set out in this Statement.
    5. The provisions of this Statement are subject to mandatory, unalterable provisions of Applicable Laws;
    6. Please do not submit any personal information to Pepkor if you do not agree to any of the provisions of this Statement. If you do not consent to the provisions of this Statement, or parts of the Statement, Pepkor may not be able to provide its products and services to you.
  2. How to contact us
    If you have any comments or questions about this Statement please contact the Information Officer at [email protected].
  3. Amendment of this Statement
    1. We may amend this Statement from time to time for any of the following reasons:
      1. to provide for the introduction of new systems, methods of operation, services, products, property offerings or facilities;
      2. to comply with changes to any legal or regulatory requirement;
      3. to ensure that our Statement is clearer and more favourable to you;
      4. to rectify any mistake that may be discovered from time to time; and/or
      5. For any other reason which Pepkor, in its sole discretion, may deem reasonable or necessary.
    2. Pepkor will take reasonable steps to notify you of such an amendment, including publication on our website. It is your responsibility to check the website often.
  4. Privacy and indemnity
    1. Pepkor takes your privacy and the protection of your personal information very seriously, and we will only use your personal information in accordance with this Statement and applicable data protection legislation. It is important that you take all necessary and appropriate steps to protect your personal information yourself (for example, by ensuring that all passwords and access codes are kept secure).
    2. We have implemented reasonable technical and operational measures to keep your personal information secure.
    3. You hereby indemnify and hold Pepkor harmless from any loss, damages or injury that you may incur as a result of any unintentional disclosures of your personal information to unauthorised persons or the provision of incorrect or incomplete personal information to Pepkor.
  5. Information which we may collect about you
    1. You, as the data subject, consent to the collection of the following information about you:
      1. information that may include your name, address, contact details, date of birth, place of birth, identity number, passport number, bank details, details about your employment, tax number and financial information;
        Disclaimer:
        The contents of this document should only be used for and by Pepkor Holdings Limited (Pepkor) and may not be distributed
        unlawfully. Older versions are not deemed official. Only the latest version is acceptable.
        External Privacy Statement - Page 3 of 7
      2. records of correspondence or enquiries from you or anyone acting on your behalf;
      3. details of transactions you carry out with us;
      4. details of contracts, sales or leases you carry out with us;
      5. sensitive or special categories of personal information, including biometric information, such as images, fingerprints and voiceprints.
    2. Where you provide us with the personal information of third parties you should take steps to inform the third party that you need to disclose their details to us, identifying us. In addition, you should not share their personal information with us, unless they have consented to you sharing such information with us and to us processing such information in accordance with this Statement.
  6. How we collect information
    1. You may provide personal information to us either directly or indirectly (through an agent acting on your behalf, or an introducer), by completing an application form for our products and services or requesting further information about our products and services, whether in writing, through our website, over the telephone or any other means.
    2. We may also collect your personal information for lawful purposes from your appointed agent, any regulator, or other third party that may hold such information.
  7. Use of information collected
    1. We may use, transfer and disclose your personal information for the purposes of:
      1. providing you with the services, products or offerings you have requested, and notifying you about important changes to these services, products or offerings;
      2. managing your account or relationship and complying with your instructions or requests;
      3. detecting and preventing fraud and money laundering and/or in the interest of security and crime prevention;
      4. assessing and dealing with complaints and requests;
      5. operational, marketing, auditing, legal and record keeping requirements;
      6. verifying your identity or the identify of your beneficial owner;
      7. transferring or processing your personal information outside of the Republic of South Africa to such countries that may not offer the same level of data protection as the Republic of South Africa, including for cloud storage purposes and the use of any of our websites;
      8. complying with Applicable Laws, including lawful requests for information received from local or foreign law enforcement, government and tax collection agencies;
      9. recording and/or monitoring your telephone calls and electronic communications to/with Pepkor in order to accurately carry out your instructions and requests, to use as evidence and in the interests of crime prevention;
      10. conducting market research and providing you with information about Pepkor’s products or services from time to time via email, telephone or other means (for example, events);
      11. where you have unsubscribed from certain direct marketing communications, ensuring that we do not sent such direct marketing to you again;
      12. disclosing your personal information to third parties for reasons set out in this Statement or where it is not unlawful to do so;
      13. monitoring, keeping record of and having access to all forms of correspondence or communications received by or sent from Pepkor or any of its employees, agents or contractors, including monitoring, recording and using as evidence all telephone communications between you and Pepkor;
      14. improving or evaluating the effectiveness of Pepkor’s business or products, services or offerings; and
      15. prevention and control of any disease.
    2. We may from time to time (and at any time) contact you about services, products and offerings available from Pepkor or specific 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 can unsubscribe from receiving such communications by clicking here.
  8. Disclosure of your information
    1. Your personal information may be shared with the Pepkor group of companies, our agents and sub-contractors, and selected third parties who process the information on our behalf.
    2. We may also disclose your personal information to third parties in the following circumstances:
      1. to any of the other Pepkor group of companies subsidiaries, business partners or other third parties to –
        1. assess and monitor any of your applications for Pepkor’s products or services;
        2. determine which products and services may be of interest to you and/or to send you information about such products and services, unless you object or choose not to receive such communications [NOTE: Subject to the direct marketing provisions of POPIA.];
        3. have a better understanding of the your circumstances and needs to provide and improve Pepkor’s products and services;
        4. to any relevant person and/or entity for purposes of prevention, detection and reporting of fraud and criminal activities, the identification of the proceeds of unlawful activities and the combating of crime;
      2. to any regulator or supervisory authority, including those in foreign jurisdictions, if Pepkor in required to do so in terms of Applicable Laws;
        1. to a prospective buyer or seller of any of our businesses or assets;
        2. to any person if we are under a duty to disclose or share your personal information in order to comply with any Applicable Laws, or to protect the rights, property or safety of Pepkor, other clients or other third parties; and/or
        3. to your agent or any other person acting on your behalf, an or an introducer.
    3. We may transfer your information to another of Pepkor’s entities, an agent, sub-contractor or third party who carries on business in another country, including one which may not have data privacy laws similar to those of the Republic. If this happens, we will ensure that anyone to whom we pass your information agrees to treat your information with the same level of protection as if we were dealing with it.
    4. If you do not wish us to disclose this information to third parties, please contact us at the contact details set out above. We may, however, not be able to provide products or services to you if such disclosure is necessary.
  9. Retention of your information
    We may retain your personal information indefinitely, unless you object, in which case we will only retain it if we are permitted or required to do so in terms of Applicable Laws. However, as a general rule, we will retain your information in accordance with retention periods set out in Applicable Laws, unless we need to retain it for longer for a lawful purpose. (For example, for the purposes of complaints handling, legal processes and proceedings.)
  10. Access to, correction and deletion of your personal information
    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 Pepkor, please review our PAIA Manual located at https://pepkor.co.za/wp-content/uploads/2019/05/PAIA-Manual_Final.pdf.
    2. You may request the correction of personal information Pepkor holds about you. Please ensure that the information we hold about you is complete, accurate and up to date. If you fail to keep your information updated, or if your information is incorrect, Pepkor may limit the products and services offered to you or elect not to open the account.
    3. You have a right in certain circumstances to request the destruction or deletion of and, where applicable, to obtain restriction on the processing of personal information held about you. If you wish to exercise this right, please contact us using the contact details set out above.
    4. You have a right to object on reasonable grounds to the processing of your personal information where the processing is carried out in order to protect our legitimate interests or your legitimate interests, unless the law provides for such processing.
  11. Complaints
    1. Should you believe that Pepkor has utilised your personal information contrary to Applicable Laws, you undertake to first attempt to resolve any concerns with Pepkor:

      Name of Private Body: Pepkor Holdings Limited
      Designated Information Officer: The Information Officer
      Email address of Information Officer: [email protected]
      Postal address: PO Box 6100, Parow East, 7501
      Street address: 36 Stellenberg Road, Parow Industria, 7493
      Phone number: +27 21 929 4800

    2. If you are not satisfied with such process, you may have the right to lodge a complaint with the Information Regulator, using the contact details listed below:
      Tel: 012 406 4818
      Fax: 086 500 3351
      Email: [email protected]

Disclaimer:
The contents of this document should only be used for and by Pepkor Holdings Limited (Pepkor) and may not be distributed unlawfully. Older versions are not deemed official. Only the latest version is acceptable.



DIGITAL CHANNEL PRIVACY POLICY

This DIGITAL CHANNEL PRIVACY policy describes how we process information we collect and/or receive from you.

  1. INFORMATION WE COLLECT AND RECEIVE
    We collect and receive information about you in the following ways:
    1. Information you give us
      This includes any information that you provide to us directly:
      1. when you sign-up to utilise our services (Websites, Applications etc.);
      2. by filling in forms on our websites, or those provided to you;
      3. when you enter a competition, promotion, donations or complete a survey;
      4. by posting comments or content on our social media pages; or
      5. when you contact us or we contact you and you provide information directly to us.
    2. What personal information we collect
      When you register to use our services, you could be required to provide us with the following information, your -
      1. name and surname;
      2. contact number and email address;
      3. physical address;
      4. identity or passport number; and
      5. date of birth.
      6. When you opt to “Create a Company Account”:Documents relating to the company, Company Registration, Proxy/Company Resolution documentation, Company Administrator contact details and the Legal address
    3. Information we collect or receive when you use our website or social media platforms
      We collect information when you use websites or social media platforms by using cookies, web beacons and other technologies. Depending on how you access and use websites, we may receive:
      1. Log information;
      2. Information we infer about you based on your interaction with products and services;
      3. Device information (for example the type of device you're using, how you access platforms, your browser or operating system and your Internet Protocol ("IP") address);
      4. Location information.
    4. Information from third-party sources
      We may receive additional information about you that is publicly or commercially available and combine that with the information we have collected or received about you in other ways.
  2. HOW WE USE THE INFORMATION WE COLLECT AND RECEIVE
    We use the information we collect and receive for the following general purposes:
    1. to provide you with information, products or services you request from us;
    2. in order to refer you to an appropriate third-party service provider;
    3. to communicate with you;
    4. to provide you with support; and
    5. to provide effective advertising (for example to provide you with news, special offers and general information about other goods, services and events which we offer, that are similar to those that you have already hired or enquired about).
  3. HOW WE SHARE THE INFORMATION WE COLLECT AND RECEIVE
    1. We don’t sell your personal information to third parties for their marketing purposes.
    2. We may share information with:
      1. our affiliates, in other words, other companies in our group;
      2. we may disclose your personal information to a limited number of our employees and third party service providers (other than those who we refer you to), who we assist you to interact with;
      3. our business partners. We may share non-personally identifiable information with select business partners;
      4. other parties in response to legal process or when necessary to conduct or protect our legal rights;
      5. companies that provide services to us. Companies that provide services to us or act on our behalf may have access to information about you. These companies are limited in their ability to use information they receive in the course of providing services to us or you; and
      6. third-parties where you provide consent. In some cases, third-parties (often advertisers) may wish to attain information about you in order to promote their products to you, or for whatever other reason. We may share information with third-parties where you provide consent in the form of an explicit opt-in. Before we ask you to opt-in, we will endeavour to provide you with a clear description of what data would be shared with the third-party. Remember that once you have opted in to allow us to send your information to the third-party, we cannot control what they do with your data; therefore, be sure to investigate their privacy policies before providing permission for us to share your information.
  4. YOUR RIGHTS
    1. You have the right to ask us not to contact you for marketing purposes. You can exercise this right at any time by using any of the various "opt-out" options that we will always provide to you when we communicate with you. We won’t send you marketing messages if you tell us not to but we will still need to send you service-related messages.
    2. Our websites use cookies. If you wish to reject our cookies, you can configure your browser to do so.
    3. We want to make sure that any data we hold about you is up to date. So, if you think your personal information is inaccurate, you can ask us to correct or remove it.
  5. RETENTION OF DATA
    We will retain your personal information only for as long as is necessary for the purposes set out in this privacy policy or to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.
  6. OUR COMMITMENT TO SECURITY
    The security of your data is important to us. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. However, we do employ a number of safeguards intended to mitigate the risk of unauthorized access or disclosure of your information. We will do our best to protect your personal information and we will use up to date technology that will help us to do this. We will at all times comply with our obligation under applicable law.
  7. TRANSFER OF DATA
    1. We are based in and operate from South Africa. Your information, including personal information, may be transferred to and maintained on servers located outside of your country of residence, where the data privacy laws, regulations and standards, may not be equivalent to the laws in your country of residence.
    2. We might transfer your personal information to places outside of South Africa and store it there, where our suppliers might process it. If that happens, your personal information will only be transferred to and stored in a country that has equivalent, or better, data protection legislation than South Africa or with a service provider which is subject to an agreement requiring it to comply with data protection requirements equivalent or better than those applicable in South Africa.
    3. Your use of our website, followed by your submission of information to us, represents your consent to such transfer.
    4. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
  8. LINKS TO OTHER WEBSITES
    Our website or social media platforms may contain links to and from websites, mobile applications or services of third parties, advertisers or affiliates. Please note that we are not responsible for the privacy practices of such other parties and advise you to read the privacy statements of each website you visit which collects personal information.
  9. CHANGES TO THIS PRIVACY POLICY
    We may update this privacy policy from time to time. Any changes that we may make to our privacy policy will be posted on our website and will be effective from the date of posting.
  10. ACCESS TO YOUR PERSONAL INFORMATION
    1. You may at any time request:
      1. confirmation that we hold your personal information;
      2. access to your personal information;
      3. the identities or categories of third parties to whom we have disclosed your personal information; or
      4. that we correct or delete any personal information that is incomplete, misleading, inaccurate, excessive or out of date.
    2. Requests may be made in writing to [email protected]

Disclaimer:
The contents of this document should only be used for and by THE COMPANY and may not be distributed unlawfully. Older versions are not deemed official. Only the latest version is acceptable.