By accessing and using this website , the user consents to the procession of their personal infomration by Surestart Online Financial Services (Pty) Ltd on the basis set out in this Privacy notice. If the user does not consent , the user must immediately stop accessing and /or using this website 

1. Introduction

1.1 Surestart Online Financial Services (Pty) Ltd collects, uses and, in some circumstances, shares the personal information of Users in and through this              website.

1.2 Surestart Online Financial Services (Pty) Ltd respects the rights of Users whose personal information is collected and used by it, including their right to          protection against the unlawful collection, retention, sharing and use of such personal information.

1.3 The purpose of this Privacy Policy is to provide Users with information about the information processing activities of Surestart Online Financial Services          (Pty) Ltd and the manner in which their rights are protected.

1.4 This Privacy Policy shall serve as a blanket notification to Users about Surestart Online Financial Services (Pty) Ltd processing activities which will                remain valid for as long as one has an active account with Surestart Online Financial Services (Pty) Ltd. Users will not be notified separately on each              occasion that Surestart Online Financial Services (Pty) Ltd processes the same personal information in the same way over the period.

1.5 Surestart Online Financial Services (Pty) Ltd may amend the provisions of this Privacy Policy to comply with any changes in the law, and/or pursuant to          any changes to its information processing activities or privacy practices. Such amendments will be published on the website and will become operable            from the date of such publication.

1.6 This privacy policy, and the interpretation and enforcement thereof, will be governed by the laws of the Republic of South Africa. 

1.7 The provisions of this Privacy Policy must, as far as possible, be incorporated into the agreement between Surestart Online Financial Services (Pty) Ltd        and Users.

2. Definitions and Interpretation

2.1 In this Privacy Policy, the following words bear the following meanings:

- "application "means the Surestart Online Financial Services (Pty) Ltd

- "consent"means any voluntary , specific and infomration expression of will in terms of which permission is given by or on behalf of a User for the                      processing of their personal information ; 

- "direct marketing"means to approach a data subject , either  in person or by mail or electronic communication, for the direct or indirect purpose of                    promoting or offering to supply any goods or services to the data subject;

- "operator" means an outside third party who processes personal information for or on behalf of Surestart Online Financial Services (Pty) Ltd in terms of a      contract or mandate;

- "personal information" means any information linked to a User or information that can identify a User, including but not limited to: 

"POPI" means the Protection of Personal Information Act, including any regulations or codes of conduct promulgated under it;

"PROATIA" means the Promotion of Access to Information Act 2 of 2000;

"Process of Processing "means , in relation to personal information, any operation or activity or any set of operations, whether or not by automatic means, including:

The collection,receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use of that information;

"User" means a visitor or user of this website, or any of the content or services associated with this website or the application; and

"The Website "means the website or any part thereof which is accessible from www.TBC

Any reference in this Privacy Policy to :

When calculating any number of days for the purposes of this Policy, the first day must be excluded and the last day of the relevant interval included, unless the last day is not a business day, then the last day will be the next succeeding business day. 

The word "include" means "include without limitation". Use of the word ‘’include’’ or ‘’in particular’’ is for illustration or emphasis only and where followed by specific examples must not be interpreted as limiting the meaning of the general wording preceding it. 

A requirement that any Policy, request, demand or other communication made in terms of this Privacy Policy must be in writing will be met if it is in the form of a data message as defined in the Electronic Communications and Transactions Act, No. 25 of 2002, and is accessible in a manner usable for subsequent reference.

3. Responsible Party

3.1 Surestart Online Financial Services (Pty) Ltd will be the party who will be collecting and processing a User’s personal information and as such is                    designated as the ‘’responsible party’’ for the purposes of this Policy. 

3.2 Surestart Online Financial Services (Pty) Ltd contact details are as follows:

3.3 Email address: info@surestart.co.za, and 

3.4 Telephone number : +27 87 550 9060 

3.5 Surestart Online Financial Services (Pty) Ltd may instruct third party operators from time to time to undertake certain processing activities relating to the        User’s personal information.

4. What Personal Information Is collected

4.1 Surestart Online Financial Services (Pty) Ltd may collect the following personal information from the User

4.2 The supply of personal information by the User to Surestart Online Financial Services (Pty) Ltd is voluntary and not mandatory. However, if the User              refuses to supply any personal  information, certain consequences may naturally flow from such a refusal, such as preventing Surestart Online Financial        Services (Pty) Ltd from concluding or performing any contract with  the User, or preventing Surestart Online Financial Services (Pty) Ltd from complying        with one or more of its obligations in law.

4.2 Surestart Online Financial Services (Pty) Ltd is required in terms of laws regulating the provision of financial advice to collect certain personal                          information about a User.

5. Purpose/s for Collection and Processing of Personal Information

5.1 Surestart Online Financial Services (Pty) Ltd is required in terms of laws regulating the provision of financial advice to collect certain personal                           information about a User.

5.2 Surestart Online Financial Services (Pty) Ltd shall only collect a User’s personal information for a specific, explicitly defined and lawful purpose relating          to a function or activity of Surestart‘s business. 

- Such purposes may include the following :

5.3 Surestart Online Financial Services (Pty) Ltd intends to process a User’s personal information for any other purpose not listed in clause 5.2 or which is          otherwise not automatically permitted by law, it shall ensure that it obtains the User’s written consent to do so.

5.3 Surestart Online Financial Services (Pty) Ltd will not sell a User’s personal information to any third party without the prior written consent of the User.

6. Collection directly from User

6.1 Surestart Online Financial Services (Pty) Ltd shall, as far as possible, always collect personal information about a User directly from the User, except in          the following circumstances:

6.2 Surestart Online Financial Services (Pty) Ltd collects personal information from a source other than the User, it shall record in writing the details of that          source, including the full names and contact details of that source where applicable.

6.3 The User hereby consents to Surestart Online Financial Services (Pty) Ltd requesting and obtaining credit information pertaining to the User from any            reputable credit reporting agency or institution for the purpose of concluding any transaction for the sale of goods or services to the User on this website.

6.4 Personal information may be collected from or supplied by the User in any of the following ways: during the process of registering as a member on this           website or the application 

6.5 Personal information may be collected from or supplied by the User in any of the following ways:

6.6 The User may visit the website without providing any personal information. However, the website’s servers may still collect technical information                      regarding the use of the website, which is aggregated for analytical purposes, technical maintenance and for improving the content offered on the                  website. Such information may include details of the User’s visit, information about the User’s computer, including IP (Internet Protocol) address,                    operating system and browser type, the User’s location, and usage information. An individual User will not be identified from or by this information and            Surestart Online Financial Services (Pty) Ltd is entitled to copy , distribute or otherwise use such information without limitation.

7. Cookies

7.1 “Cookies” are small text files transferred by a webserver to a User’s hard drive and thereafter stored on their computer.  The types of information a                   Cookie collects includes a User’s username, the date and time of their visits to the website, their browsing history and preferences.

7.2 “Surestart Online Financial Services (Pty) Ltdmay use Cookies on this website to:

7.3  Distinguish one User from another on the website;

7.4 Remember the User’s last session when they return to the website;

7.5 Estimate the website's audience size and usage patterns; 

7.6 Store information about the User’s preferences, which allows Surestart Online Financial Services (Pty) Ltd to customize the website and content                    according to the Users individual preferences; and

7.7 Speed up searches on the website.

7.8  The provisions of this clause are only applicable to Cookies used by Surestart Online Financial Services (Pty) Ltd. In some instances, third-party service         providers may use Cookies on the website. Surestart Online Financial Services (Pty) Ltd cannot and does not control or access Cookies used by third           party service providers and takes no responsibility therefore

7.9 The User has the right and ability to either accept or decline the use of Cookies on their computer’s web browser, whether they are logged in as a                   member, or simply casually visiting the website. However, declining the use of Cookies may limit a User’s access to certain features on the website. 

8. General Conditions for Processing Personal Information

8.1 Surestart Online Financial Services (Pty) Ltd shall comply with all laws, contracts or regulations when it processes a User’s personal information.

8.2 Surestart Online Financial Services (Pty) Ltd shall not act unreasonably when processing a User’s personal information. This means that it will collect            and process a User’s personal information in a way that the User can reasonably expect and in a way that is fair.

8.3 Surestart Online Financial Services (Pty) Ltdshall respect the User’s right to privacy at all times. If there is another way in which it can achieve the same        goal without posing any risk of harm to the privacy rights of the User, then it will choose that option.

8.4 Similarly, if Surestart Online Financial Services (Pty) Ltdneeds to process personal information but there are less privacy-invasive methods of collecting,         using and sharing that information, then it will use those methods.

8.5 Surestart Online Financial Services (Pty) Ltd shall ensure that the personal information that is collected and processed is and remains relevant to the              identified purpose/s for such processing, and that such information is and remains adequate, but not excessive, for achieving the identified purpose/s.

8.6 If there are any alternative ways to achieve the identified purpose/s without processing personal information, Surestart Online Financial Services (Pty)            Ltd shall not process that personal information.

8.7 Surestart Online Financial Services (Pty) Ltd shall ensure that the processing activities it chooses to apply are proportionate to achieving the identified            purpose/s and that no less privacy invasive measures are available to achieve the same purpose/s.

8.8 Surestart Online Financial Services (Pty) Ltdshall ensure that, regardless of the stated purpose/s for processing personal information, the rights and              interests of Users will not be unnecessarily prejudiced or infringed, unless it cannot be avoided, and then in such cases, it shall ensure that its own rights        and/or interests justify such prejudice or infringement taking place.

Once Surestart Online Financial Services (Pty) Ltd has achieved the purpose for the collection of the User’s personal information, it will destroy or delete such information, unless the User has directed otherwise in writing, or Surestart Online Financial Services (Pty) Ltd is required by law to retain the information for a longer period of time.

If Surestart Online Financial Services (Pty) Ltd no longer needs to process personal information to achieve the purpose originally specified, it will stop using that information.

9. Disclosure and Sharing of Personal Information

9.1 Surestart Online Financial Services (Pty) Ltd may, in the course of providing any content or services on this website, or for the purposes of concluding or        performing any sale or other transaction with a User, share certain personal information with third party operators who perform certain processing                  activities on behalf of Surestart Online Financial Services (Pty) Ltd.  

9.2 The information shared and the categories of third party operators with whom it is shared will always be notified to you prior to being shared.  

9.3 Surestart Online Financial Services (Pty) Ltd may also share aggregated information about Users of this website and their usage patterns. Surestart               Online Financial Services (Pty) Ltd may also use such aggregated information to help advertisers target specific audiences. Such aggregated                           information  will be de-identified and the User’s personal information will not be disclosed.

9.4 Other than as stated in clause 9.1 and 9.3, Surestart Online Financial Services (Pty) Ltd shall not share a User’s personal information with any third                parties unless it has the User’s express consent to do so.

10. User's Rights in Relation to the Processing of their Personal Information

10.1 Users shall have the following rights in relation to the processing of their personal information:

10.2  Users may make a request in terms of clause 10.1 by following the process for making such a request as set out in Surestart Online Financial                          Services (Pty) Ltd PROATIA manual.

11. Further Processing

11.1 Surestart Online Financial Servies (Pty) Ltd shall not process a User’s personal information for any purpose not previously specified except in the                  following circumstances:

Surestart Online Financial Servies (Pty) Ltd shall ensure that if it intends processing personal information for other purposes not previously specified, it shall notify the User of such further purposes and the possible consequences of the intended further processing for the User.

12. Accuracy, Correctness and Completeness of Personal Information

12.1 Surestart Online Financial Servies (Pty) Ltd shall take reasonably practicable steps to ensure that the personal information kept by it about Users is                complete, accurate, not misleading and is updated when necessary.

12.2 However, if a User is aware of any personal information in Surestart Online Financial Servies (Pty) Ltd custody that is incorrect, inaccurate or which                needs to be updated, the User must make a written request to Surestart’s information officer at info@surestart.co.za to update or correct the relevant              information.

12.3 If a User has contested the accuracy of any personal information being used by Surestart Online Financial Servies (Pty) Ltd, it shall immediately stop               using that information until its  accuracy has been verified.

Surestart Online Financial Servies (Pty) Ltd reserves its right to only adhere to a request from a User in terms of clause 12.2 if the correction or updating of that information will result in the personal information being correct and accurate.

Where personal information that has been shared by Surestart Online Financial Servies (Pty) Ltd with a third party is subsequently updated or corrected, Surestart Online Financial Servies (Pty) Ltdshall ensure that all third parties, with whom that information was shared, receives the updated and/or corrected version of the information as soon as it has been updated and/or corrected. 

13. Security Safeguards

13.1 Surestart Online Financial Servies (Pty) Ltd is committed to protecting the personal information in its custody against any loss of, damage to or                        unauthorised destruction of that information, and to prevent any unauthorised parties from accessing that information.

13.2 Surestart Online Financial Servies (Pty) Ltd takes steps to continually identify and document any risks to the personal information it has in its                          possession or under its control and that appropriate security safeguards are in place against those risks.

13.3 Surestart Online Financial Servies (Pty) Ltd shall ensure that in any contracts entered into with third party operators who process personal information            on Surestart Online Financial Servies (Pty) Ltd behalf, include the following obligations:

13.4 Users must maintain the secrecy of any passwords used to gain access to this website and should change such passwords regularly.

13.5 Surestart Online Financial Servies (Pty) Ltd shall ensure that all personal information on its systems is properly backed-up and that back-up copies are          stored separately from the live files.

14. Notification of Breach of Security

14.1 If personal information about a User is inadvertently leaked or Surestart Online Financial Servies (Pty) Ltd security has been unlawfully breached by              any unauthorised party, Surestart Online Financial Servies (Pty) Ltd shall immediately identify the relevant Users who may be affected by the security            breach, and shall contact them at their last known email address or contact details or by the quickest means possible.

14.2 Surestart Online Financial Servies (Pty) Ltd shall provide sufficient information to the User to allow him or her to take the necessary protective                         measures against the potential consequences of the compromise, or shall advise Users of the steps to be taken by them and the possible                               consequences that may ensue from the breach for them.

15. Decisions Based on Personal Information Processed

15.1 If Surestart Online Financial Servies (Pty) Ltd is required to make a decision about a User using any personal information that has been obtained, it                shall ensure that a record of such information and the decision made is kept for a reasonable period of time to give the User an opportunity to request            access to that record.

15.2 Surestart Online Financial Servies (Pty) Ltd shall allow a User a reasonable opportunity to make representations before any decision is made solely on          the basis of the personal information processed, if that decision will affect the legal position of the User, or will otherwise adversely affect them in some          manner or form.

15.3 Surestart Online Financial Servies (Pty) Ltd shall always ensure that the underlying logic behind any decision made pursuant to the automated                         processing of personal information is  sound and that this underlying logic can be communicated to the User to enable them to make representations.

15.4 If Surestart Online Financial Servies (Pty) Ltd has made a decisions based on incorrect personal information, it shall immediately revisit that decision              as soon as it receive Policy or  becomes aware of the error or inaccuracy of that information.

16. Linked Third Party Websites

16.1 This website may contain links or references to other websites, including those of advertisers (“third party websites“) which are not under                              Surestart Online Financial Servies (Pty) Ltd control.

16.2 The provisions of this Privacy Policy are not applicable to third party websites and Surestart Online Financial Servies (Pty) Ltd shall not responsible for          the information processing practices and/or privacy policies of those third party websites, or the cookies that those websites may use.

17. Direct Marketing

17.1 The User hereby consents to the processing of their personal information for the purpose of direct marketing by means of electronic communications               including automatic calling machines, facsimile machines, SMS’s or electronic mail.

17.2 Where a User is a pre-existing customer ofSurestart Online Financial Servies (Pty) Ltd, Surestart Online Financial Servies (Pty) Ltd shall be entitled,              without the User’s consent, to sending electronic communications to the User for the purpose of marketing similar products or services offered by                    Surestart Online Financial Servies (Pty) Ltd.

17.3 The User may object, free of charge, and without unnecessary formality, to the use of their details either when the information was first collected from            them or when each subsequent electronic communication is sent to them by Surestart Online Financial Servies (Pty) Ltd.

17.4 The User can opt out of receiving further marketing communications by un-checking certain boxes on the forms used on the website to collect their                 personal information, or by contacting Surestart Online Financial Servies (Pty) Ltd at: info@surestart.co.za.

18. Children’s Personal Information

Surestart Online Financial Servies (Pty) Ltd shall not process any personal information relating to a person under the age of 18 years unless it has obtained consent from that person’s parent or legal guardian. If this website is being accessed by the parent or guardian of a child under the age of 18 years, and personal information pertaining to that child is being provided by the parent or guardian, then they hereby expressly consent to Surestart Online Financial Servies (Pty) Ltd processing such information according to the further provisions of this Privacy Policy. 

19. Cross Border Transfers of Personal Information

19.1 Surestart Online Financial Servies (Pty) Ltd may transfer personal information to another country in the following circumstances:

19.2 If Surestart Online Financial Servies (Pty) Ltd is required to transfer personal information from South Africa to a third party in a foreign country, it shall            ensure that the third party is subject to a law, binding code of conduct or contract which effectively upholds principles for the reasonable processing of             personal information which are substantially similar to the data protection offered in the Republic of South Africa. 

20. Retention of Information

20.1 Surestart Online Financial Servies (Pty) Ltd will keep a record of any personal information collected for no longer than is necessary to achieve the                  specific purpose for which it collected such information in the first place unless:

20.2 The User has consented to their information being kept for a longer period.

Surestart Online Financial Servies (Pty) Ltd may, if it has de-identified personal information, kept such information for historical, statistical or research purposes. Surestart Online Financial Servies (Pty) Ltd shall ensure that appropriate safeguards are in place to prevent those records from being used for any other purposes, or against the information being re-identified.

21. Returning, Destroying or Deleting Personal Information

21.1 Where Surestart Online Financial Servies (Pty) Ltd is no longer authorised to retain a record of any personal information, it shall either:

22. Consent

22.1 The User hereby consents to the processing of their personal information in terms of the provisions of this Privacy Policy.

22.2 The User acknowledges and agrees that such consent has been given voluntarily after the User has read and understood the provisions of this Privacy          Policy, in particular, regarding the following:

Should a User wish to withdraw any consent previously given by the User, they must notify Surestart Online Financial Servies (Pty) Ltd information officer in writing.  

23. Lodging an Objection

A User may, on reasonable grounds, object to the processing of their personal information at any time after that processing has started.

If a User wishes to object to the processing of their personal information, they must send written Policy of their objection to Surestart Online Financial Servies (Pty) Ltd information officer, together with their reasons for doing so.

24. Choice of Law

This Privacy Policy shall be governed and interpreted in accordance with the laws of the Republic of South Africa  

25. Amendment of this Privacy Policy

Surestart Online Financial Servies (Pty) Ltd reserves the right to change, update, add, remove and/or amend any of the provisions of this Privacy                   Policy  from time to time. Such changes, updates, additions, removals or amendments will become effective from the date of their publication on this               website.

It is the User's obligation to periodically check the provisions of this Privacy Policy for any such changes, updates, additions, removals or amendments.

The User's continued use of this website following any changes, updates, additions, removals or amendments to this Privacy Policy will be considered Policy of the User's acceptance to abide by and be bound by this Privacy Policy, as amended.

Contact

For more information on your rights to Privacy over your information, or the information processing activities of Surestart Online Financial Servies (Pty) Ltd , please do not hesitate to contact us directly on: info@surestart.co.za

Date of last update: 24 August 2018