PEPKOR HOLDINGS LIMITED
REGISTRATION NUMBER 2017/221869/06
EXTERNAL PRIVACY STATEMENT
1. Introduction
1.1. For purposes of this Statement:
1.1.1. “Applicable Laws” means all laws and regulations that Pepkor is required to comply with;
1.1.2. “Customer”, “Supplier”, “Applicant” or “You” means any prospective, new or existing customer/supplier/vendor/applicant of Pepkor and its subsidiaries; and
1.1.3. “Pepkor”, “We” or “Us” means Pepkor Holdings Limited, its direct and indirect subsidiaries and business units (the Pepkor group of companies). To obtain more information on the Pepkor group of companies
please refer to our website, www.pepkor.co.za.
1.1.4. “Personal Information” means information relating to an identifiable, living, natural person, and where applicable, an identifiable, existing juristic person, including, but not limited to, the name, race, gender, marital
status, address and identifying number of a person, symbol, e-mail address, physical address, telephone number, location information, online identifier or any other particular assignment to the person.
1.2. This Statement sets out how your personal information will be used by Pepkor and applies to any information, including personal and special personal information, you give to Pepkor or which Pepkor may collect from
third parties.
1.3. It is important that you read this Statement carefully before submitting any personal
information to Pepkor.
1.4. By submitting any personal information to Pepkor you provide consent to the processing of your personal information as set out in this Statement.
1.5. The provisions of this Statement are
subject to mandatory, unalterable provisions of Applicable Laws;
1.6. Please do not submit any personal information to Pepkor if you do not agree to any of the provisions of this Statement. If you do not consent to the provisions of this Statement, or parts of the Statement, Pepkor may not
be able to provide its products and services to you.
2. How to contact us
If you have any comments or questions about this Statement please contact the Information Officer at io@pepkor.co.za
3. Amendment of this Statement
3.1. We may amend this Statement from time to time for any of the following reasons:
3.1.1. to provide for the introduction of new systems, methods of operation, services, products, property offerings or facilities;
3.1.2. to comply with changes to any legal or regulatory requirement;
3.1.3. to ensure that our Statement is clearer and more favourable to you;
3.1.4. to rectify any mistake that may be discovered from time to time; and/or
3.1.5. for any other reason that Pepkor, in its sole discretion, may deem reasonable or necessary.
3.2. Pepkor will take reasonable steps to notify you of such an amendment, including publication on our website. It is your responsibility to check the website often.
4. Privacy and indemnity
4.1. Pepkor takes your privacy and the protection of your personal information very seriously, and we will only use your personal information in accordance with this Statement and applicable data protection legislation. It is
important that you take all necessary and appropriate steps to protect your personal information yourself (for example, by ensuring that all passwords and access codes are kept secure).
4.2. We have implemented reasonable technical and operational measures to keep your personal information secure.
4.3. You hereby indemnify and hold Pepkor harmless from any loss, damages or injury that you may incur as a result of incorrect or incomplete personal information to Pepkor.
5. Personal information which we may collect about you
5.1. You, as the data subject, consent to the collection of the following personal information about you:
5.1.1. personal information that may include your name, address, contact details, date of birth, place of birth, identity number, passport number, bank details, details about your employment, tax number and financial
information;
5.1.2. records of correspondence or enquiries from you or anyone acting on your behalf;
5.1.3. details of transactions you carry out with us;
5.1.4. details of contracts, sales or leases you carry out with us;
5.1.5. sensitive or special categories of personal information, including biometric information, such as images, fingerprints and voiceprints.
5.1.6. consumer credit information at any credit bureau or third party, subject to clauses 9.1.16 to 9.1.18 below.
5.2. Where you provide us with the personal information of third parties you should take steps to inform the third party that you need to disclose their details to us, identifying us. In addition, you should not share their personal information with us, unless they have consented to you sharing such information with us and to us processing such
information in accordance with this Statement.
6. Personal information of children
6.1. We do not intend to collect and/or process any personal information of children, unless we make this clear. If you do provide any personal information to us of children then you warrant that this is done with the consent of
the child’s parent or legal guardian to use this information as set out in this Statement.
7. Suppliers and vendors
7.1. In the course of our business agreement, we may collect personal information about you as a data subject to ensure that the business agreement and matters relating to the agreement can be fulfilled.
7.2. We may also do due diligence on you to ensure that you meet the requirements set out in our procurement procedures.
7.3. If you provide any personal information of other persons to us, such as employees or your directors, you warrant that you are authorised to share their personal information with us for purposes set out in the Statement.
8. How we collect personal information
8.1. You may provide personal information to us either directly or indirectly (through an agent acting on your behalf, or an introducer), by completing an application form for our products and services or requesting further
information about our products and services, whether in writing, through our website, over the telephone or any other means.
8.2. We may also collect your personal information for lawful purposes from your appointed agent, any regulatory authority, or other third party that may hold such information.
8.3. In order to ensure that the content of our websites remains up-to-date, user-friendly and comprehensive, we employ web analytics tools, the predominant one being Google Analytics, which is a web-analysis tool from
Google Inc. This service uses cookies that track your preferences during your visits to our websites and allows us to simplify navigation and make our website more user-friendly. The information that is used during this
process (which includes your IP Address) is de-identified and makes personal identification impossible.
8.4. We might make use of first-party and third-party cookies, as well as web beacons and similar technologies to deliver measurement services and targeted advertising to visitors. No personal information is shared with any
third party outside of Pepkor and its subsidiaries when providing these targeted services.
9. Use of personal information collected
9.1. We may use, transfer and disclose your personal information for the purposes of:
9.1.1. providing you with the services, products or offerings you have requested, and notifying you about important changes to these services, products or offerings;
9.1.2. managing your account or relationship and complying with your instructions or requests;
9.1.3. detecting and preventing fraud and money laundering and/or in the interest of security and crime prevention;
9.1.4. assessing and dealing with complaints and requests; 9.1.5. operational, marketing, auditing, legal and record-keeping requirements;
9.1.6. verifying your identity or the identity of your beneficial owner;
9.1.7. transferring or processing of your personal information outside of the country your personal information was collected for processing by such countries that may not offer the same level of data protection, including
for cloud storage purposes and the use of any of our websites;
9.1.8. complying with Applicable Laws, including lawful requests for information received from local or foreign law enforcement, government and tax collection agencies;
9.1.9. recording and/or monitoring your telephone calls and electronic communications to/with Pepkor in order to accurately carry out your instructions and requests, to use as evidence and in the interests of crime
prevention;
9.1.10. conducting market research and providing you with information about Pepkor’s products or services from time to time via email, telephone, SMS, WhatsApp or other electronic and/or non-electronic means;
9.1.11. where you have unsubscribed from certain direct marketing communications, ensuring that we do not send such direct marketing to you again;
9.1.12. disclosing your personal information to third parties for reasons set out in this Statement or where it is not unlawful to do so;
9.1.13. monitoring, keeping record of and having access to all forms of correspondence or communications received by or sent from Pepkor or any of its employees, agents or contractors, including monitoring, recording
and using as evidence all telephone communications between you and Pepkor;
9.1.14. improving or evaluating the effectiveness of Pepkor’s business or products, services or offerings;
9.1.15. prevention and control of any disease;
9.1.16. to provide you with tailor-made offerings, we will use your information for data analysis which may include the use of AI technologies;
9.1.17. determining whether you meet the criteria for inclusion in certain direct marketing campaigns of Pepkor products and/or services, where applicable;
9.1.18. to deliver tailored advertising (including via social media);
9.1.19. conducting an affordability assessment in the event that you applied for credit;
9.1.20. pre-vetting Customers or Suppliers before we deal with them;
9.1.21. sharing your unique identifiers (such as your telephone number or identity number) with third parties, including other entities in the Pepkor Group to do data matching for purposes of enriching (improving) our or
their personal information, direct marketing, marketing analysis pre-vetting of Customers and Suppliers and other matters that may be in our legitimate or the legitimate interests of third parties; and
9.1.22. tracing you and collecting from you any outstanding debt due in terms of a credit agreement entered into with Pepkor.
9.1.23. To manage your potential employment as an Applicant or post-employment relationship with us.
9.2. We may from time to time (and at any time) contact you about services, products and offerings available from Pepkor or specific subsidiaries which we believe may be of interest to you, by email, telephone, SMS,
WhatsApp or other electronic and/or non-electronic means, unless you have unsubscribed from receiving such communications. You can unsubscribe from receiving such communications.
10. Disclosure of your personal information
10.1. Your personal information may be shared with the Pepkor group of companies, our agents and sub-contractors, and selected third parties who process the information on our behalf.
10.2. We may also disclose your personal information to third parties in the following circumstances:
10.2.1. to any of the other Pepkor group of companies subsidiaries, business partners or other third parties to – 10.2.1.1. assess and monitor any of your applications for Pepkor’s products or services;
10.2.1.2. determine which products and services may be of interest to you and/or send you information about such products and services, unless you object or choose not to receive such communications;
10.2.1.3. have a better understanding of your circumstances and needs to provide and improve Pepkor’s products and services;
10.2.1.4. to any relevant person and/or entity for purposes of prevention, detection and reporting of fraud and criminal activities, the identification of the proceeds of unlawful activities and the combating of crime;
10.2.2. to any regulator or supervisory authority, including those in foreign jurisdictions, if Pepkor is required to do so in terms of Applicable Laws;
10.2.3. to a prospective buyer or seller of any of our businesses or assets;
10.2.4. to any person if we are under a duty to disclose or share your personal information in order to comply with any Applicable Laws, or to protect the rights, property or safety of Pepkor, other Customers or other third
parties; and/or
10.2.5. to your agent, or any other person acting on your behalf, and/or an introducer.
10.3. We may transfer your personal information to another of Pepkor’s entities, an agent, sub-contractor or third party who carries on business in another country, including one which may not have data privacy laws similar to
those of the applicable jurisdictions. If this happens, we will ensure that anyone to whom we pass your personal information agrees to treat your personal information with the same level of protection as if we were dealing
with it.
10.4. If you do not wish us to disclose this information to third parties, please contact us at the contact details set out above. We may, however, not be able to provide products or services to you if you do not agree with such
disclosure.
11. Retention of your personal information
We may retain your personal information indefinitely, unless you object, in which case we will only retain it if we are permitted or required to do so in terms of Applicable Laws. However, as a general rule, we will retain your personal information in accordance with retention periods set out in Applicable Laws, unless we need to retain it for longer for a lawful purpose. (For example, for the purposes of complaints handling, legal processes and proceedings.)
12. Access to, correction and deletion of your personal information
12.1. You may request details of personal information which we hold about you under the applicable legislation in your jurisdiction. Please refer to the Annexures section for more information on how to exercise your rights as
a data subject.
12.2. For South Africa, you may opt out of direct marketing communications free of charge by contacting our call centre: (+27) 860 900 100. For any other jurisdictions, you may opt out of direct marketing communications free
of charge by emailing us: io@pepkor.co.za.
13. Complaints
13.1. Should you believe that Pepkor has utilised your personal information contrary to Applicable Laws, you undertake to first attempt to resolve any concerns with Pepkor:
Name of Private Body: Pepkor Holdings Limited
Authorised Information Officer: The Information Officer
Email address of Information Officer: io@pepkor.co.za
Postal address: PO Box 6100, Parow East, 7501 Street address: 36 Stellenberg Road, Parow Industria
Phone number: (+27) 860 900 100
13.2. If you are not satisfied with such a process, you may have the right to lodge a complaint with the relevant regulatory authority in your jurisdiction. For South Africa, refer to the
contact detail(s) listed below:
POPIAComplaints@inforegulator.org.za
ANNEXURES
ANNEXURE A - PAIA MANUAL
To exercise your rights as a data subject in South Africa under the Promotion of Access to Information Act and the Protection of Personal Information Act, refer to the Pepkor PAIA Manual.
Disclaimer:
The contents of this document should only be used for and by Pepkor Holdings Limited (Pepkor) and may not be distributed unlawfully. Older versions are not deemed official. Only the latest version is acceptable.
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