PRIVACY POLICY | The Sun Exchange

PRIVACY POLICY

The Sun Exchange (Pty) Ltd and its affiliates (hereinafter, “the Company”, “we”, “us” or “our”) are committed to protecting and respecting your privacy. In addition, we are subject to the Personal Information Protection Bill of Aug 2009.

This Privacy Policy (together with our Terms and Services) governs our collection, processing and use of your Personal Information.

“Personal Information” is information which identifies you personally or by which your identity can reasonably be ascertained. This may include your name, address, e-mail address, and other contact details.

The purpose of this Privacy Policy is to inform you of:

1. the kinds of Personal Information which we may collect about you and how it may be used;

2. our use of information regarding IP Addresses and our use of cookies;

3. how your Personal Information may be disclosed to third parties;

4. your ability to access, correct, update and delete your Personal Information; and

5. the security measures we have in place to prevent the loss, misuse, or alteration of Personal Information under our control.

Gathering and Use of Personal Information

We may collect your Personal Information if you use the Site, open an Account to use the Platform or perform any Transactions on the Platform. We may also collect Personal Information about you from recordings of telephone conversations between us and you (or your representatives) and from publicly available registers.

Some of the Personal Information we collect is required by us to meet our legal and regulatory obligations (eg, information required to verify your identity). Otherwise, the Personal Information we collect is required in order for us to provide our services efficiently and effectively.

The types of Personal Information which we collect may include: your name; your photographic identification; your address; your phone number; your e-mail address; your banking details including account numbers; your date of birth; and information about your Transactions.

We may use your Personal Information for the following purposes:

1. to allow you to open and operate an Account;

2. to enable you to complete Transactions on the Platform;

3. to correspond with you in relation to your Account and your Transactions;

4. to analyze use of our Site and the services we provide;

5. as required for legal and regulatory purposes, including for dispute resolution purposes;

6. to provide you with information about products, services and promotions that may be of interest to you, from ourselves and third parties;

7. for market research e.g. surveying our Users’ needs and opinions on issues, such as our performance etc.

You should note that you are not obliged to give your Personal Information to the Company, but if you choose not to do so, we may not be able to provide our services, or your access to our services may be limited.

IP Addresses

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.

Cookies

We may use a browser feature known as a “cookie”, which assigns a unique identification to your computer. Cookies are typically stored on your computer’s hard drive. Information collected from cookies is used by us to evaluate the effectiveness of our Site, analyse trends, and administer the Platform. The information collected from cookies allows us to determine such things as which parts of our Site are most visited and difficulties our visitors may experience in accessing our Site. With this knowledge, we can improve the quality of your experience on the Platform by recognising and delivering more of the most desired features and information, as well as by resolving access difficulties. We also use cookies and/or a technology known as web bugs or clear gifs, which are typically stored in emails to help us confirm your receipt of, and response to, our emails and to provide you with a more personalised experience when using our Site. We may use third party service provider(s), to assist us in better understanding the use of our Site. Our service provider(s) may place cookies on the hard drive of your computer and may receive information that we select that will educate us on such things as how visitors navigate around our site, what products are browsed, and general Transaction information. Our service provider(s) analyses this information and provides us with aggregate reports. The information and analysis provided by our service provider(s) will be used to assist us in better understanding our visitors’ interests in our Site and how to better serve those interests. The information collected by our service provider(s) may be linked to and combined with information that we collect about you while you are using the Site. Our service providers are contractually restricted from using information they receive from our Site other than to assist us. By using our Site you are agreeing that we may use cookies for the purposes set out above.

Disclosure of Personal Information

We use the Personal Information for the purposes indicated at the time you provide us with such information, and/or otherwise for the purposes set out in this Privacy Policy and/or as otherwise permitted by law. We may make available the Personal Information that you provide to us to our affiliates, agents, representatives, service providers and contractors for these purposes. We may share Users’ Personal Information with financial institutions or insurance companies as required for the purposes of the Company’s dealings with those institutions, and with other companies in the case of a merger, divestiture, or other corporate re-organization. If you request it in writing, we may share your Personal Information with your nominated advisers. Except where disclosure of your Personal Information is required by law or requested by you, we will generally require any third party which receives or has access to Personal Information to protect such Personal Information and to use it only to carry out the services they are performing for you or for us, unless otherwise required or permitted by law. We will ensure that any such third party is aware of our obligations under this Privacy Policy and we will take reasonable steps to ensure that contracts we enter with such third parties binds them to terms no less protective of any Personal Information disclosed to them than the obligations we undertake to you under this Privacy Policy or which are imposed on us under applicable data protection laws.

Access and Changing of Personal Information

You have the right to access the Personal Information we hold about you, and to require the correction, updating and blocking of inaccurate and/or incorrect data by sending an email to us. We will usually respond to your request within 14 days. You may also request the deletion or destruction of your Personal Information, your Account details or your Transaction details by sending an email to us. The Company will act on your request only when it is not inconsistent with its legal and regulatory obligations and compliance procedures. Upon your written request, we will inform you of the use and general disclosure of your Personal Information. Depending on the nature of your request, there may be a minimal charge for accessing your Personal Information.

Security

We take reasonable steps to protect your Personal Information from misuse, loss, unauthorised access, modification or disclosure, including implementing appropriate security measures. The security measures in place will, from time to time, be reviewed in line with legal and technical developments. However, we give no guarantee that such misuse, loss, unauthorised access, modification or disclosure will not occur

Retention of Personal Information

We will hold your Personal Information only for as long as it is necessary for us to do so, having regard to the purposes described in this Privacy Policy and our own legal and regulatory requirements. In general, Personal Information relating to your Account for at least a period of five years after your Account is closed. Similarly, we usually retain information about Transactions on your Account for a period of five years from the date of the Transaction. Personal Information which is collected for other purposes will be discarded inn accordance with our policies in place from time to time.

Links

There may be links from our Site to other sites and resources provided by third parties. This Privacy Policy applies only to our Site. Accessing those third party sites or sources requires you to leave our Site. We do not control those third party sites or any of the content contained therein and you agree that we are in no way responsible or liable for any of those third party sites, including, without limitation, their content, policies, failures, promotions, products, services or actions and/or any damages, losses, failures or problems caused by, related to or arising from those sites. We encourage you to review all policies, rules, terms and regulations, including the privacy policies, of each site that you visit.

Changes

Our policies, content, information, promotions, disclosures, disclaimers and features may be revised, modified, updated, and/or supplemented at any time and without prior notice at the sole and absolute discretion of the Company. If we change this Privacy Policy, we will take steps to notify all Users by a notice on our website and will post the amended Privacy Policy on the website.

Contact Us

If you have any questions, comments, or concerns regarding our Privacy Policy and/or practices as it or they relate to the Platform, please contact us. If you have a complaint about how your Personal Information has been used, please contact us in the first instance. If we cannot resolve your complaint to your satisfaction, you may complain to the Protection Regulator who may investigate your complaint further.