Privacy Policy – Mandela House

Mandela House

Standard Website Privacy & Cookies Policy

The Protection of Personal Information Act, 2013 (“POPI”) came into complete commencement on 1 July 2021, in this regard we have a number of obligations and duties in terms of POPI that we must comply with. The protection of your personal information is a high priority for us, and we have taken steps to ensure that your personal information is protected and remains private.

In addition to this document serving as our privacy policy, this document will also serve as our data subject notification as contemplated in section 18 of POPI. In this regard, this document will inform you of what personal information we collect, why we collect it, how we use it and what safety measures are in place to protect it.

Where we refer to “process”, it means how we collect, use, store, make available, destroy, update, disclose, or otherwise deal with your personal information. As a general rule we will only process your personal information if this is required to deliver or offer a service, provide a product or carry out a transaction.

We may combine your personal information and use the combined personal information for any of the purposes stated in this Privacy Policy.

In this document any reference to “we” or “us” or “our” is reference to Mandela House and its subsidiaries.

If you use our services, goods and/or products, you agree that we may process your personal information as explained under this Privacy Policy.

We may change this Privacy Policy from time to time if the law or our business practices requires it.

The version of the Privacy Policy displayed on our website at the time of your interaction with us will be applicable.

What is personal information?

Personal information refers to any information that identifies you or specifically relates to you. Personal information includes, but is not limited to, the following information about you:

Age	Financial history	Personal views
Belief	Gender	Physical address
Birth	Identity number	Physical health
Biometric	Language	Pregnancy
Colour	Location information	Race
Conscience	Marital Status	Religion
Correspondence	Mental Health	Sex
Criminal history	Medical History	Sexual orientation
Culture	Name	Social origin
Disability	National Origin	Symbol
Education	Online identifier	Telephone number
E-mail address	Other particular assignment	Well being
Employment history	Personal opinions

Is the supply of the personal information voluntary or mandatory?

The supply of certain personal information is mandatory, meaning we have to collect this personal information from you by law. If you do not supply this information, we cannot comply with our legal obligations. In this regard, if you do not supply this personal information, we cannot do business with you. We collect personal information as is required by the following legislation:

Basic Conditions of Employment Act, No 75 of 1997

Continuing Education and Training Act (previously known as Further Education and Training Colleges Act) 16 of 2006

Compensation for Occupational Injuries and Diseases Act, No. 130 of 1993

Credit Agreement Act, No. 75 of 1980

The Criminal Procedure Act, No. 51 of 1977

Debt Collectors Act, No. 114 of 1998

Employment Equity Act, No. 55 of 1998

Financial Intelligence Centre Act, No. 38 of 2001

Higher Education Act 101 of 1997

Income Tax Act 58 of 1962

Labour Relations Act, No 66 of 1995

National Credit Act, No. 34 of 2005

NQF Act No 67 of 2008

Pension Funds Act, No. 24 of 1956

Skills Development Act 97 of 1998

Unemployment Insurance Act, No. 63 of 2001

Financial Advisory and Intermediary Service Act, No. 37 of 2002

Occupational Health and Safety Act No. 85 of 1993

Prevention of Organised Crime Act No. 121 of 1998

In other instances, the supply of personal information is voluntary, which means there is no law imposed on us to collect this personal information. Even though there is no law that imposes the collection of the personal information, we require the personal information to deliver the products and/or services to you. In this regard, if you do not supply the personal information, we cannot do business with you.

When will we process your personal information?

We will only process your personal information for lawful purposes relating to our business if the following applies:

if you have consented thereto.
if a person legally authorised by you, the law, or a court, has consented thereto.
if it is necessary to conclude or perform under a contract, we have with you.
if the law requires or permits it.
if it is required to protect or pursue your, our or a third party’s legitimate interest.

What is special personal information?

Special personal information is personal information about the following:

Biometric information	Philosophical beliefs	Sex life
Criminal behaviour	Political persuasion	Trade union membership
Ethnic origin	Race
Health	Religious beliefs

When will we process your special personal information?

We may process your special personal information in the following circumstances:

if you have consented to the processing.
if the information is being used for any Human resource or payroll requirement.
if the processing is needed to create, use, or protect a right or obligation in law.

if the processing is for statistical or research purposes and all legal conditions are met.
if the special personal information was made public by you.
if the processing is required by law.
if racial information is processed, and the processing is required to identify you; and / or if health information is processed, and the processing is to determine your insurance risk, or to comply with an insurance policy or to enforce an insurance right or obligation.

When and from where we obtain personal information about you?

We may collect personal information about you from the following sources:

We may collect personal information directly from you.

If the law requires us to do so, we will ask for your consent before collecting personal courts of law or tribunals.

Reasons we need to process your personal information.

We will process your personal information for the following reasons:

to provide you with products, goods, and services
to market our products, goods, and services to you.
to respond to your enquiries and complaints.

to process or consider or assess insurance or assurance claims.
to provide insurance and assurance policies and products and related services.
to enable you to take part in customer loyalty reward programmes, to determine your qualification for participation, earning of reward points, determining your rewards level, monitoring your buying behaviour with our rewards partners to allocate the correct points or inform you of appropriate products, goods, and services you may be interested in or to inform our reward partners about your purchasing behaviour.
to enable you to take part in and make use of value-added products and services.

to assess our lending and insurance risks; and / or
for any other related purposes.

When how and with whom we share your personal information?

In general, we will only share your personal information if any one or more of the following apply:

if you have consented to this.

if it is necessary to conclude or perform under a contract, we have with you;
if the law requires it; and / or
if it’s necessary to protect or pursue your, our or a third party’s legitimate interest.

How we secure your personal information

We will take appropriate and reasonable technical and organisational steps to protect your personal information according to industry best practices. Our security measures (including physical, technological, and procedural safeguards) will be appropriate and reasonable. This includes the following:
keeping our systems secure (like monitoring access and usage);
storing our records securely.
controlling the access to our buildings, systems and/or records; and

safely destroying or deleting records.
Ensure compliance with best practice standards.

How long do we keep your personal information?

We will keep your personal information for as long as:

the law requires us to keep it.

a contract between you and us requires us to keep it.
you have consented for us keeping it.
we are required to keep it to achieve the purposes listed in this Privacy Policy.
we require it for statistical or research purposes.
a code of conduct requires us to keep it; and / or
we require it for our lawful business purposes.

Take note: We may keep your personal information even if you no longer have a relationship with us, for the historical data that may be required by your employer or employee.

You must inform us when your personal information changes.

Please contact our Information Officer to give effect to any of the below rights.

You have the right to request access to the personal information we have about you by contacting us. This includes requesting:

confirmation that we hold your personal information.
a copy or description of the record containing your personal information; and
the identity or categories of third parties who have had access to your personal information.

We will attend to requests for access to personal information within a reasonable time. You may be required to pay a reasonable fee to receive copies or descriptions of records, or information about third parties. We will inform you of the fee before attending to your request.

The contact details for the Information Regulator is as follows:

Email:	Complaints.IR@justice.gov.za
Postal Address:	P.O. Box 31533, Braamfontein, Johannesburg, 2017
Physical Address:	JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001.

How can you get in touch with us?

Enquiries

Enquires about this policy or our processing of your personal information in general, you can contact our Information Officer and/or Deputy Information Officer at the following details: https://www.mandelahouse.com/