Privacy Policy

Privacy Policy – 05.18v0.2

1. Introduction

We respect your privacy and take it very seriously. We are Ctrl Financial Intermediaries (Pty) Ltd (Registration number 2017/191425/07) and this is our plan of action for the protection of your personal information. It describes how we collect, use, disclose, and store your personal information.

2. Application

This policy applies to you when you visit our website, use our application, or order our services as a customer.

3. Personal information

3.1. Scope. Your personal information includes information we collect:

- automatically when you visit our website or use our application

- accept on registration or submission

- get through an order

- or you provide voluntarily

- but excludes anonymous, de-identified, statistical, and public information

3.2. Insurance information. As a financial intermediary, we need to collect a large amount of personal information to allow various insurers to provide you with accurate pricing (quotations) inside our application (insurance information). We use this same personal information to ensure that you do not have to enter the same information twice and therefore avoid the time-consuming process of getting new quotes.

3.3. Your obligations You:

- may only send us your own personal information or someone else’s personal information if you have their permission to do so

- and warrant that that information is true and accurate to the best of your knowledge

4. Acceptance and changes

4.1. Acceptance. You may not order any of our services if you do not accept this policy or any changes to it.

4.2. Changes. We may change this policy at any time and will notify you of the changes on our website, through our application, or by email. The changed policy applies to you if you continue using our website, our application, or our services following the notification. We have posted a version number at the bottom of this page to make sure that you know when we’ve made a change to any wording on it.

5. Collection

5.1. Automatically through website. When you visit our website, we automatically collect your Internet usage information, including your IP address, browser details, and usage information, which we may use to display our website correctly, track your activities on it, or for other necessary purposes.

5.2. Automatically through application. When you use our application, we automatically collect your application usage information through analytics software and other technologies, which we use to optimise our offering to you.

5.3. On registration or submission. We may ask you to provide us with certain identifying information when you register on or otherwise submit information through our website or application for the first time.

5.4. Through an order. We ask you to provide us certain services information when you order our services.

5.5. Voluntarily. We may ask you to provide us certain optional information on a voluntary basis.

5.6. Consent to collection. We will get your consent to collect your personal information when required by applicable law when you provide us with it.

5.7. Purpose for collection. We may process your information that you provide to us for the purposes that you indicated when you agreed to provide it to us. Processing includes gathering your personal information, disclosing it, and combining it with other personal information.

6. Use

6.1. Processing. We may process your personal information to fulfil our obligations to you.

6.2. Cookies. We may place small text files on your device when you visit our website that allow us to provide you with a personalised experience by associating your personal information with your device. They let us remember your preferences, allow third parties to provide services to you, and otherwise serve useful purposes for you. Your internet browser generally accepts them automatically, but you can often change this setting or delete them manually. However, we won’t be able to provide you with access to certain aspects of our website where cookies are necessary if you do so. We have no access to or control over any cookies that our business partners use on our website and they have their own privacy polices that govern them.

6.3. Messages. We may use your identifying information to send you administrative and update messages about our website or application.

6.4. Promotional messages. We may also sometimes send you promotional messages, but you may choose to opt-out of them.

6.5. Targeted content. We may use your personal information to provide you with targeted content through our website or application in a completely automated process.

7. Disclosure

7.1. Credit check You give us consent by using our application to do the following in order for you to obtain an insurance quotation:

- access to your credit information held by one or more of the registered credit bureaus

- and to verify and share policy and insurance claim information with insurers and other institutions or for a third party service provider to do so on our behalf.

7.2. Sharing. We may share your personal information with third parties for the purposes of fulfilling our obligations to you, including with:

- other companies or divisions within our group;

- our contractors who help provide part of our services, including those that help us understand your personal information; or

- third parties as required by applicable law.

7.3. Honour this policy. We will require anyone that we share your personal information with to honour this policy whenever possible in terms of applicable law.

7.4. Mandatory disclosure. We may disclose personal information to third parties if required for legal reasons, such as:

- to regulators as law or governmental audit requires

- law enforcement as subpoena or court order requires

- or third parties as applicable law requires

7.5. Marketing purposes. We may disclose aggregate statistical information that we have derived from your and other people’s personal information to our advertisers or business partners.

7.6. Personnel. We may need to disclose personal information to our personnel to do their jobs, but will not do so unnecessarily.

7.7. Change of ownership. We may assign our rights to the personal information we process to our new owners if our ownership changes for any reason.

8. Storage

8.1. Insurance information. FAIS requires us to store all information relating to your insurance, including the advice we have offered and the information upon which someone generated a quote for a period of five years. We store this information securely.

8.2. Access and deletion. You may ask us to:

- provide you with the personal information that we hold on you

- or delete it, provided that we do not need it to fulfil our obligations to you or applicable law does not require us to keep it

We will take all reasonable steps to verify your identity before doing so. We may charge a fee to recoup our costs associated with this request if there is a cost to us associated with it and provided that applicable law allows us to do so. Please contact us with your name and any other information needed to identify you correctly if you want access to information or want us to correct, update or delete it.

8.3. Accuracy. We will do our best to keep your personal information that we collect accurate, complete, and up to date.

8.4. Participation. We may ask you to update your personal information from time to time, but will take steps to verify your identity to prevent unauthorised access when doing so.

8.5. Retention. We will only keep your personal information for as long as is necessary to fulfil our obligations to you, unless you have given us permission to keep it longer or we are otherwise legally allowed to do so.

8.6. Transfer. We may transfer your personal information outside of the country in which it was collected to a foreign country. You consent to us processing your personal information in a foreign country with less stringent data protection laws than the country in which it was collected.

9. General

9.1. Updating or removing. You may update or remove your personal information through our website or application or by contacting us.

9.2. Limitation. We are not responsible for anyone else’s privacy policies or practices.

9.3. Enquiries. Please contact us if you have any questions about this privacy policy or how we handle your personal information.