Real People Group – Privacy and Personal Information Notice.
  1. Who we are
    1. We are a purpose-led organisation that recognises the unique challenges and opportunities people face in their lives. We share our expertise to create brighter futures, through the responsible provision of financial services and products. We drive financial wellness, and are a platform for growth, sustainability and improvement.
    2. Incorporated in 2001, Real People is built on a focused portfolio of businesses. These centre around providing responsible finance to individuals and customer-centric debt management solutions to businesses.
    3. Our Portfolio of business consists of, amongst others,
      1. Real People Home Improvement Finance
      2. Real People Life
      3. DMC Debt Management
    4. For the purposes of this notice. “We” or “Us” or “Our” shall include Real People Investment Holdings Ltd and all its subsidiaries, affiliate and associate entities (“the Real People Group”).
    5. Any product or service offered to a customer by any company in the group is referred to as a solution in this document.

  2. Purpose of this notice
    1. Protecting customers’ personal information is important to us. To do so, we follow general principles in accordance with applicable privacy laws.
    2. We have developed this privacy notice (notice) to enable our customers to understand how we collect, use and safeguard their personal information.
    3. We collect personal information about our customers. This includes what customers tell us about themselves, what we learn by having a customer or when a customer makes use of a solution, as well as the choices customers make about the marketing they elect to receive. This notice also outlines customers’ privacy rights and how the law protects customers.
    4. Where we process personal information for another party under a contract or a mandate, the other party’s privacy policy or notice will apply.
    5. In this notice “process” means how we collect, use, stores, makes available, destroys, updates, discloses, or otherwise deals with customers’ personal information.
    6. We may combine customers’ personal information and use the combined personal information for any of the purposes stated in this notice.
    7. VERY IMPORTANT: If customers use our solutions and service channels (including both assisted and unassisted interactions), or by accepting any agreement, contract, mandate or annexure with the group or by utilising any solutions offered by us, customers agree that in order to:
      1. conclude and fulfil contractual terms or obligations to a customer;
      2. comply with obligations imposed by law; or
      3. to protect or pursue customers’, the group’s, or a third party’s legitimate interests, including offering solutions that best meet customers’ needs;
      4. customers’ personal information may be processed through centralised functions and systems across companies in the group and may be used for the purposes, in the manner, and with the appropriate controls as set out in this notice.
    8. We may change this notice from time to time if required by law or its business practices. Where the change is material, we will notify customers and will allow a reasonable period for customers to raise any objections before the change is made. Please note that we may not be able to continue a relationship with a customer or provide customers with certain solutions if they do not agree to the changes.
    9. NOTE: this notice is subject to our Information Protection Policy – available here

  3. What is Personal Information
    1. For the purpose of this notice personal information means any information or combination of information that belongs to and/or can be used to identify a natural or juristic person.
    2. Personal information includes, but is not limited to, the following information about a customer:
      1. marital status (married, single, divorced); national origin; age; language; birth; education;
      2. financial history (e.g. income, expenses, obligations, lending, insurance);
      3. employment history and current employment status;
      4. gender or sex (for statistical purposes as required by the law);
      5. identifying number (e.g. an account number, identity number or passport number);
      6. Contact details;

  4. Personal Information Collected
    1. We collect and process personal information about consumers’ financial position and/or needs. The type of information will depend on the type of customer, e.g. credit and/or insurance, the need for which it is collected and will be processed for that and or a related purpose only.
    2. Whenever possible, we will inform the customer as to the information required and the information deemed optional. Examples of personal information we collect and process include, but is not limited to:
      1. The Customer’s Identity number, name, surname, address, postal code, marital status, and number of dependants;
      2. Description of the customer’s residence, business, employment, assets; financial information, banking details, etc.;
      3. Any other information required by us, our suppliers and our insurers to provide customers with the goods and services which forms part of our business being financial services related to long term insurance, the provision of credit and debt collection.
      4. We are further obliged to process certain information as required in terms of Financial Sector laws, including, but not limited to, The Financial Intelligence Centre Act, The National Credit Act, The Financial Advisory and Intermediary Services Act.
    3. We also collect and process personal information for marketing purposes to ensure that our products and services remain relevant to our customers and potential customers.

  5. When, and from where, we obtain personal information about customers
    1. We collect information about customers:
      1. directly from customers;
      2. based on customers’ use of solutions or service channels (such as our websites and applications, including both assisted and unassisted customer interactions) as applicable;
      3. based on how customers engage or interact with us, such as on social media, and through emails, letters, telephone calls and surveys;
      4. based on a customer’s relationship with us;
      5. from technology, such as a customer’s access and use including both assisted and unassisted interactions (e.g. on our websites) to access and engage with our platform;
      6. customers’ engagement with advertising, marketing and public messaging; and
      7. from third parties that we interact with for the purposes of conducting our business (such as partners, service providers, list providers, credit bureaux, regulators and government departments).
    2. We collect and process customer personal information at the start of, and for the duration of their relationship with us. We may also process customers’ personal information when their relationship with us has ended.
    3. The third parties (which may include parties we engage with as independent responsible parties, joint responsible parties or operators) from whom we may collect customers’ personal information include, but are not limited to, the following:
      1. members of the group, any connected companies, subsidiary companies, its associates, cessionaries, delegates, assignees, affiliates or successors in title and/or appointed third parties (such as its authorised agents, partners, contractors and suppliers) for any of the purposes identified in this notice;
      2. the customer’s spouse, dependants, partners, employer, joint applicant or account holder and other similar sources;
      3. attorneys, tracing agents, debt collectors and other persons that assist with the enforcement of agreements;
      4. payment processing services providers, merchants, banks and other persons that assist with the processing of customers’ payment instructions;
      5. Insurers, brokers, other financial institutions or other organisations that assist with insurance and assurance underwriting, the providing of insurance and assurance policies and products, the assessment of insurance and assurance claims, and other related purposes;
      6. law enforcement and fraud prevention agencies, and other persons tasked with the prevention and prosecution of crime;
      7. regulatory authorities, industry ombudsmen, government departments, and local and international tax authorities;
      8. credit bureaux;
      9. qualification information providers;
      10. trustees, executors or curators appointed by a court of law;
      11. our service providers, agents and subcontractors, such as couriers and other persons we use to offer and provide solutions to customers;
      12. courts of law or tribunals;
      13. marketing list providers;

  6. The Use of Personal Information
    1. The Personal Information will be used for the purpose for which it was collected or obtained.
    2. The purpose for which we use personal information may include the following;
      1. Providing products or services to customers and conclude transactions as requested;
      2. Assessing and processing claims and or queries;
      3. Conducting credit reference and affordability assessments;
      4. Confirming, verifying and updating customer details;
      5. Enforcing our legal rights;
      6. Debt collection and credit management;
      7. For the detection and prevention of fraud, crime, money laundering or other malpractices;
      8. Conducting market or customer satisfaction research;
      9. For audit and record-keeping purposes;
      10. In connection with legal proceedings;
      11. Providing services to customers, to render the services requested and to maintain and constantly improve the relationship;
      12. Providing communication in respect of our business and regulatory matters that may affect customers; and
      13. In connection with and to comply with legal and regulatory requirements or when it is otherwise allowed by law
    3. We will only process personal information if one or more of the following conditions are met;
      1. Where the customer consents to the processing;
      2. Where the processing is necessary to enable us to perform our duties or enforce our legal rights;
      3. Processing complies with an obligation imposed by law;
      4. Processing protects a legitimate interest of the customer, it is in the customer’s best interest to
        1. have a full and proper assessment performed to provide them with an applicable, beneficial and affordable product or service; or
        2. assist customers with debt to meet their financial obligations, and support our customers on their journey to become financially independent; or
        3. assist customers in obtaining appropriate long term insurance products and cover.
      5. Processing is necessary for pursuing our legitimate interests or those of a third party to whom information is supplied — in order to provide customers with products and or services both we and any of our product suppliers require certain personal information from the customers to make an expert decision on the unique and specific product and or service required.

  7. Disclosure of Personal Information
    1. We may disclose a customer’s personal information to any of our group companies or subsidiaries, joint venture companies and or approved product- or third-party service providers whose services or products customers elect to use, subject to agreements being in place to ensure that compliance with confidentiality and privacy conditions.
    2. We may also share customer personal information with, and obtain information about customers from third parties for the purposes listed above.
    3. We may also disclose a customer’s information where it has a duty or a right to disclose in terms of applicable legislation, the law, or where it may be deemed necessary in order to protect our rights.

  8. Centralised Processing
    1. We aim to create efficiencies in the way it processes information across the group. Customers’ personal information will therefore be processed through centralised group functions and systems, which includes the housing of their personal information in a centralised group data warehouse.
    2. This centralised processing is structured to ensure efficient processing that benefits both the customer and the group. Such benefits include, but are not limited to:
      1. improved information management, integrity and information security;
      2. the leveraging of centralised crime and fraud prevention tools;
      3. better knowledge of a customer’s financial service needs so that appropriate solutions can be advertised and marketed to the customer;
      4. a reduction in information management costs; and
      5. streamlined transfers of personal information for customers with solutions across different businesses or companies within the group.
    3. In order to:
      1. conclude and fulfil contractual terms or obligations to a customer; or
      2. comply with obligations imposed by law; or
      3. to protect or pursue customers’, the group’s, or a third party’s legitimate interests, including offering solutions that best meet customers’ needs;
      4. customers’ personal information may be processed through centralised functions and systems across companies in the group and may be used for the purposes and/or related purposes, in the manner, and with the appropriate controls as set out in this notice and our Information Protection Policy

  9. Customers’ Duties And Rights Regarding The Personal Information We Have About Them
    1. Customers must provide us with proof of identity when enforcing the rights below.
    2. Customers must inform us when their personal information changes, as soon as possible after the change.
    3. Customers warrant that when they provide us with personal information of their spouse, dependants or any other person, they have permission from them to share their personal information with us. We will process the personal information of the customer’s spouse, dependent or any other person which the customer has shared with it as stated in this notice.
    4. Customers have the following rights;
      1. Right of access to and request to rectify information
      2. Right to object to processing
      3. Right to lodge a complaint to the Information Regulator
    5. In order to exercise the rights in 9.4 customers are advised to follow the process as set out in our Promotion of Access to Information Manual – available here