POPIA defines personal information as “information which relates to an identifiable, living, natural person, and where it applies, an identifiable, existing juristic person”. This includes, but is not limited to, your name, gender, address, contact details, identity number, and medical or health information.
How we collect information:
We collect personal information about you and any other person whose details you provide to us under the relevant laws, either:
Directly from you when you complete a product or service application form; electronically or telephonically. Indirectly from you when you interact with us electronically via our website, apps, or social media channels, which may include the collection of metadata.
Employers and other contracted entities to do with medical schemes and group insurance policies and where relevant, from third-party sources, such as other entities within the 1.618 Group. Financial intermediaries that are representatives of 1.618 or have intermediary agreements with public databases, data aggregators, other financial institutions, credit bureaus, and fraud prevention agencies.
We will also collect your information where you have only partially completed and/or abandoned any information which you applied to our website and/or other online forms. Given that we already consider you a customer at this stage, we may use this information to contact you in order to remind you to complete outstanding information.
Where we require personal information in order to provide you with our products and services, your failure to provide us with the information will cause 1.618 unable to provide you with our products and services. Where such services include financial advice, the appropriateness of the advice may be compromised if you do not provide complete and accurate information. You are responsible for informing 1.618 if your information changes.
What information we collect
Your relationship with 1.618 determines the exact nature of the personal information 1.618 processes, and the purpose for which such personal information is collected and used. However, most times, if we are handling your personal information as part of our role as a financial service, the personal information we may process includes the following:
Information about you - such as your name, identity number, age, gender, date of birth, nationality, occupation, lifestyle, current status of health, medical history.
Contact information - sometimes, for example, we may receive your email address, address, phone number, and postal address. Online information - for example, cookies, and IP address, if you use our websites, apps and/or social media channels.
Financial information - we may process information related to payments you make or receive in an insurance policy or claim. We may process information regarding your income, expenses, assets, liabilities, investments, retirement, and other financial provisions in providing financial advice and intermediary services.
Contractual information - for example, details about the policies you hold and with whom you hold them.
In order for us to provide clients with the financial products and services they have requested and to notify them of important changes to such products and services, we need to collect, use and disclose the personal information of clients, their representatives, controlling persons of entities, business contacts, staff of clients and service providers.
To the extent permissible under applicable laws, 1.618 may use your information:
For the detection and prevention of unlawful activity, fraud, money-laundering and loss, including as part of party due diligence required under applicable laws and in terms of 1.618 policies:
Occasionally, 1.618 may share aggregated information with its stakeholders and business partners in a manner that does not identify the persons to whom the information applies. However, 1.618 will not disclose your personal information to third parties unless there is valid processing ground as set out in section 11 of POPIA.
Security of personal information
1.618 has implemented appropriate technical and organisational information security measures (including, but not limited to, using encryption for transmission of credit card numbers) to keep your information secure, accurate, current, and complete. However, we cannot guarantee the security of any information you transmit to us online and you do so at your own risk. Where third parties are required to process your personal information in relation to the purposes set out on this notice and for other lawful requirements, we ensure they are contractually bound to apply the security practices. Your personal information will be held and used for as long as permitted for legal, regulatory, fraud prevention, and legitimate business purposes.
Collection of information by third parties
Owners or information system administrators of third-party websites that have links to the 1.618 website may collect personal information about you when you use these links. 1.618 does not control the collection or use of personal information by third parties and this privacy statement does not apply to third parties. 1.618 does not accept any responsibility or liability for third-party policies or your use of a third-party application, service, or platform. 1.618 also uses certain social networking services such as Facebook, LinkedIn, and Twitter to communicate with the public and 1.618 clients. When you communicate with 1.618 via these services, that social networking service may collect your personal information for its own purposes. These services may track your use of our digital channels on those pages where the links are displayed. If you are logged into those services while using our digital channels, their tracking will be associated with your profile. These services have their own privacy policies which are independent of 1.618’s privacy policies and practices.
1.618 will not sell, rent, or trade your personal information to any third party. 1.618 will share information about you with financial advisers that are 1.618 representatives or have intermediary agreements with 1.618. 1.618 may also share information within the 1.618 Group where it is in 1.618’s legitimate interest to do so.
Right of access to information
The Promotion of Access to Information Act (PAIA) coupled with POPIA offers an individual the right to access information held by a public or private body in certain instances. This right can be exercised under the 1.618 PAIA manual.
Correction of your information
Under POPIA, you have a right to correct any of your personal information held by 1.618. This right should be exercised under the procedure outlined in the 1.618 PAIA manual.
Objection to processing of your information
Under POPIA, you may object to our processing of your personal information on reasonable grounds relating to your particular situation, unless legislation provides for such processing.
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