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ClearScore Privacy Policy

Effective from: 23/12/2024 20 min read

ClearScore Proprietary Limited respects your privacy and protecting your information is paramount. Please read this Privacy Policy carefully before using our website or registering to use our services in order to understand our views and practices regarding your personal data and how we will treat it. This Privacy Policy sets out the basis on which any personal data will be processed by us.

By visiting our website you are accepting and consenting to the practices described in this Privacy Policy. For the purpose of this Privacy Policy “applicable data protection law” means any laws in your jurisdiction in relation to data protection and privacy and in South Africa, includes the Protection of Personal Information Act 4 of 2013 (“POPIA”), including its regulations and the Promotion of Access to Information Act 2 of 2000 (“PAIA”), including its regulations.

The data controller or responsible party is Clear Score Proprietary Limited of Central Office Park No. 4, 257 Jean Avenue, Centurion, Gauteng, 0157, South Africa. References in this Privacy Policy and on our website to “we” , “our” or “us” are references to ClearScore Proprietary Limited. References to “you” and “your” means each natural or juristic person who uses our website or the associated services.

For the avoidance of doubt, we will at all times collect, maintain, use and retain your information in accordance with applicable law, including the National Credit Act, 2005 (“NCA”) and POPIA.

We may collect and process the following data about you:

Information you give us. You may give us information about you when you register for our service or by communicating with us by phone, email or otherwise. This includes information you provide when you subscribe to our services, participate in discussion boards or other social media functions on our website, provide us with feedback, participate in surveys, and when you report a problem with our website.

The information you give us may include your:

  • first name & last name;
  • physical address;
  • email address;
  • phone number;
  • date of birth;
  • ID number;
  • employment status;
  • marital status;
  • gender;
  • salary information;
  • financial and/or affordability information, such as your income and expenditure, your assets, credit products or credit position and any payments you make or receive;
  • credit card, loan or bank account information;
  • financial goals, such as an amount you'd like to borrow;
  • identification documentation details (such as your passport, driving license and or National ID details);
  • if you subscribe to Protect Plus, personal information relating to your use of the benefits or claims for costs or expenses; and
  • certain types of special category data, such as health data (for example, we may collect information on smoking behaviours).

Unless otherwise indicated, providing this information is mandatory in order for us to provide our services to you and should you fail to provide the information, we may not be able to provide the services you have requested.

Information we collect from credit bureaus on your behalf. If you register to use our services, we will obtain your credit score and credit report (and any other information contained in your credit report) from one or more credit bureaus on your behalf.

Information we collect about you. Each time you visit our website we may automatically collect the following information: (a) technical information, including the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; (b) information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

Information we collect from our Cybercheck Partners on your behalf. All our registered customers benefit from our ClearScore Protect service, upon email verification. To provide you with this service, we share the email address connected with your ClearScore account, your national ID number and/or passport (if provided) with our Cybercheck Partners (see more here), who use this information to identify whether any of your information may have been compromised. The Cybercheck Partners will not use the information you’ve shared for any other purpose (including marketing) and will only keep it for the time necessary to conduct the check after which it will be deleted.

If you verify your email and activate the ClearScore Protect service to include dark web monitoring (as further described in our Terms), we may also receive the following information about you from the Cybercheck Partner such as:

  • Name
  • Addresses
  • Social profiles
  • Email addresses
  • National ID number
  • Driving license details
  • Passport details
  • Phone numbers
  • Usernames
  • Date of birth
  • Education and professional history

If you subscribe to our Protect Plus service, we will also receive your personal data from CyberScout Ventures Limited ("CyberScout"), one of our Cybercheck Partners for Protect Plus, so you can obtain the benefit of the cover offered under your subscription.

Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, service providers, advertising networks, analytics providers, search information providers, credit bureaus) and may receive information about you from them, such as if you’ve taken out a credit product with one of our business partners.

Cookies

We and our service providers collect information about your use of our website from cookies. For information about our use of cookies and how to decline them please read our Cookies Notice.

Purpose for processing/Uses made of the information

We use information held about you in the following ways:

Information you give to us (or we collect from credit bureaus) or other third parties on your behalf as part of our services. We will use this information to:

  • administer your account and relationship with us and to, communicate with you by telephone, mail, email, text (SMS) message, instant messaging (such as WhatsApp) or other electronic means;
  • verify your identity as part of our identity authentication process (we will use the credit card or bank account information only for the purposes of verifying your identity (and to prevent, detect and prosecute fraud and crime and comply with legal or regulatory requirements) and will not retain it);
  • provide you with the information, products and services that you request from us, including if you subscribed to Protect Plus;
  • provide you with information about other products and services we offer that are similar to those that you have already purchased;
  • provide you with information about products or services we feel may interest you or be best for you, where you have consented to receive such information;
  • your data may be shared with product providers to validate if you are an existing customer (which may affect whether you can be accepted for one of their products) or for fraud prevention purposes. The product provider does not have permission to use these data for any other purpose including marketing;
  • notify you about changes to our services;
  • ensure that content from our website is presented in the most effective manner for you and your device;
  • aggregate it on an anonymous basis with other data for data analytical and reporting purposes; and
  • undertake analysis and profiling of your credit information (and any other data provided by you or on your behalf or which we collect on your behalf) in order to identify and inform you of credit products (including personal loans and credit cards) that we consider are likely to interest you or be suited to your credit circumstances, where you have consented to receive such information.

Information we collect about you. We will use this information:

  • to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to build up a picture of your interests so that you don’t miss information relevant to you when you visit our website;
  • to improve the service we offer you and to try and ensure that you get the best from our website, ensuring that content is presented in the most effective manner for you and for the devices you use to access it;
  • to allow you to participate in interactive features of our service, when you choose to do so;
  • as part of our efforts to keep our website safe and secure;
  • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
  • to make suggestions and recommendations to you and other users of our website about products or services that may interest you or them, subject to having received your consent where necessary.

Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above. We may monitor or record telephone conversations or other communications between you and us. We will use these recordings or transcripts of them to check your instructions to us, analyse, assess and improve our services to customers, for training and quality purposes and for the purposes of investigating any complaint you may make, or as evidence in any dispute or anticipated disputes between you and us.

Disclosure of your data to others may be necessary to ensure the smooth provision to you of our service. Information about you is collected when you register for, or use, our services and such data disclosed to the other entities as described below.

ClearScore Proprietary Limited forms part of a global organisation with offices in various jurisdictions. In appropriate circumstances, we may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries. In appropriate circumstances, we may also send personal information to be processed by third party service providers and suppliers located in other jurisdictions, such as the EU, UK or US. These third parties are subject to contractual confidentiality and security obligations and third parties may only process personal information on our behalf in accordance with our instructions and for the limited purposes agreed between us. Accordingly, your personal information may be transferred outside of South Africa and it may be processed by authorised individuals from any location. Wherever your data is processed outside of South Africa, we will ensure that appropriate mechanisms and contractual arrangements are in place to protect your data. You expressly agree to such transfers.

We may share your information with selected third parties, including:

(a) credit bureaus, to obtain your credit score and credit report and to provide our services to you (please see “Credit Bureaus" below for more detail);

(b) fraud prevention agencies, to prevent crime and trace those responsible (please see “Fraud Prevention Agencies” below for more detail);

(c) product providers, such as our business partners, which includes South African banks and registered credit providers, comparison sites or aggregators who offer you credit cards, loans, car finance, mortgages, insurance, pensions, investments and other related products, to:

  • assess if you are an existing customer and for fraud prevention purposes;
  • conduct analysis to provide you with better products and services in the future, and for segmentation purposes;
  • identify and inform you of credit products (for example, personal loans and credit cards) that are likely to be suited to your credit circumstances through targeted advertising;
  • perform the terms of their contract with you;
  • pre-fill an application form with the product provider; and
  • assess your probability of being accepted for a product based on the information you’ve provided us, so we can indicate to you as part of our services whether or not you are likely to be accepted for a product, including any loans or card products, when you search for credit offers on our website or apps;
  • assess whether you are eligible for pre-approved offers, including for any loans or cards, based on the information shared against product provider criteria. Pre-approval is dependent on the accuracy of your information and any changes made to this information directly with the product provider can lead to a change in this pre-approved status, and you would still need to apply with the product provider who may run a hard search and verify your information before making any offer;
  • for analysis and profiling of your credit information (and any other data provided by you or on your behalf) to identify and inform you of credit products that are likely to be suited to your credit circumstances through targeted advertising.

Product providers may further share your data with other parties, including credit bureaus in accordance with their own privacy policies. That information may be returned to ClearScore for delivering these services. This process is essential for credit risk assessment, aligning of scorecards, and other related services.

(d) Advertising Partners such as: advertisers, advertising networks and social media platforms (including TikTok, Meta, Facebook, Amazon, and Google/YouTube), including insight analytic and business reporting services. The limited personal information about you that we share with Advertising Partners includes your name, date of birth, IP address and location. Such personal information is hashed before being sent on to Advertising Partners and in other instances is de-identified in order to further protect your personal information. We may provide Advertising Partners with your personal information to:

  • deliver ClearScore advertisements on third party websites that may be tailored to your individual interests. As a result, you may see certain “interest-based advertising” or “targeted advertising” on other websites or online services based on information relating to your access to and use of our website, our Services and other websites, including by:

  • excluding you from seeing targeted adverts if you have opted out of ClearScore marketing

  • creating audiences for our advertisements to social media network users who may be similar to you based on the data that the social media network holds about you

  • including you in audiences to receive marketing when you’re on a social media network

  • track metrics on our behalf or in connection with our Services in order for us to determine whether our adverts are effective in reaching our intended audience (for example, by telling them how many women or men have clicked on an advert), to understand the performance of our advertising campaigns, to see trends about the general use of our services, to create relevant advertisements and to analyse traffic to our website and Services. These measurement and analytic services enable us to improve, optimise and personalise our advertisement campaigns;
  • analyse our website, run contests, special offers, or other events or activities on our behalf.

Advertising Partners may also use and match personal information about you that they have independently collected using device data collection tools or other similar tracking technologies operated by third parties and in accordance with their privacy policy and practices, including through the use of cookies, or from personal information voluntarily shared by you on other websites or platforms.

You can opt out of the above mentioned data sharing with Advertising Partners at any time in your ClearScore account settings, as well as following the opt-out processes on your device, or managing your ad preferences on third party websites, platforms or applications.

(e) analytics and search engine providers that assist us in the improvement and optimisation of our website;

(f) external affiliate network partners that place advertisements on our app or website. When you click on a sponsored link on our website or app, we share a unique ClearScore URL or “hyperlink,” with the relevant external affiliate network partner. In doing so, we will not share any personal identifiers or information about you. Our external affiliate network partner may match that hyperlink with information you have shared on that external affiliate network partner’s website, including connecting our hyperlink with you in order to calculate a potential commission to ClearScore in line with their own privacy policies and practices. You can opt out of this data sharing at any time in your ClearScore account settings.

(g) our Cybercheck Partners to to obtain details of any recorded cybersecurity incidents affecting your nominated email account, passport or national ID, to provide you with our ClearScore Protect service; and

(h) if you are subscribed to Protect Plus, our Cybercheck Partners, to deliver the Protect Plus service to you and so you can obtain the benefit of the subscription and make claims for costs or expenses.

We may also disclose your personal information to third parties if:

(a) we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets. In such instances, we will ensure that we remain compliant with the relevant conditions of lawful processing set out in POPIA in so far as the processing of your personal information by such third parties is concerned;

(b) ClearScore Proprietary Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets. In such instances, we will ensure that we remain compliant with the relevant conditions of lawful processing set out in POPIA in so far as the transfer and processing of your personal information by such third parties is concerned; and

(c) we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and other agreements; or to protect the rights, property, or safety of ClearScore Proprietary Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

The legal basis for us processing your personal information. The legal basis upon which we base our processing of your personal information as described above will typically be one of the following: (a) your consent; (b) performance of a contract with you; (c) pursuing our legitimate interests; or (d) compliance with our legal obligations.

Credit Bureaus and fraud prevention agencies

If you register to use our services we will obtain on your behalf, in accordance with our Terms, copies of your credit report and credit score from designated credit bureaus. In order to provide these services to you, we will share your information with such credit bureaus.

It is important to note that we do not control the information on your credit report and we cannot amend it if it is incorrect or inaccurate. In these situations, we will assist you as much as possible in raising a dispute with the appropriate credit bureaus.

Credit bureaus collect and maintain information about consumers and businesses credit behavior. This includes Electoral Roll, fraud prevention, and credit information (including details of previous applications and the conduct of your bank accounts) and public information such as judgments, and bankruptcies.

Credit bureaus may form a link between any previous or subsequent names that you use in the records they hold about you.

The information that organisations provide to credit bureaus about you, your financial associates and your business (if you have one) may be provided to other organisations and used by them and us to:

(a)help make decisions, for example when:

  • checking details on applications for loans or other credit and credit-related or other facilities;
  • managing loan, credit and credit-related accounts or facilities;
  • recovering debt;
  • checking details on proposals and claims for all types of insurance;
  • checking details of job applicants and employees;

(b) detect and prevent crime, fraud and money laundering;

(c) check your credit history;

(d) verify your identity if you, or someone financially linked with you, applies for a loan or services;

(e) trace your whereabouts; and

(f) undertake research, statistical analysis and systems testing. Fraud Prevention Agencies.

We have processes and systems that protect our customers and ourselves against fraud and other crime. Customer information can be used to prevent crime and trace those responsible. We will share your personal information with fraud prevention agencies. If false or inaccurate information is provided and fraud is identified, details of this fraud will be passed to these agencies. Law enforcement agencies may access and use this information. Other organisations may also access and use this information to prevent fraud and money laundering, for example when: (a) checking details on applications for credit and credit related or other facilities; (b) managing credit and credit related accounts or facilities; (c) recovering debt; (d) checking details on proposals and claims for all types of insurance; and (e) checking details of job applicants and employees.

We and other organisations may access and use from other countries the information recorded by fraud prevention agencies.

Cybercheck Partners

We have partnered with web monitoring services to provide you with our ClearScore Protect service, which helps you to identify whether or not information associated with your email account , passport or national ID has been compromised online. To provide this service, we share your email address (the one we use to send you service emails regarding our services) with our Cybercheck Partners on a monthly basis, alongside your national ID number and/or passport, if you have chosen to provide this. These providers will then check their databases to identify whether there are any recorded instances of your account details having been compromised. Your email address, national ID number and/or passport (if relevant) are processed solely on our instructions and will not be used by our partners for any other purpose, including marketing. We will notify you of the results of the dark web monitoring in the manner set out in our Terms. For more details about our ClearScore Protect service, please refer to our Terms here).

We will not use the results of these dark web monitoring checks conducted on your behalf for any other purpose.

We have partnered with CyberScout, to provide you with certain benefits if you subscribe to Protect Plus. We will share your personal data, including your contact details and full name with CyberScout so that you can obtain the benefit of the cover offered under Protect Plus.

We offer you the opportunity to receive information from us. We will normally send direct marketing by email if we have your email address, but may choose to contact you via other methods such as telephone, SMS, instant messaging (such as WhatsApp), mail or push notifications via your mobile phone.

You may receive the following types of communications from us:

  • Product recommendations. We’ll get in touch with personalised, timely product recommendations that can help you improve your financial situation. Product can include personal loans and credit cards. You can unsubscribe from these whenever you like.
  • Content communications. We’ll send you content such as tips, research, features and news, coaching programmes on how to keep on top of your money and other related content. You can unsubscribe from these at any time and we will never spam your inbox.
  • Core communications. We will send you your credit report every month, alerts whenever there is a change to your credit report, security alerts pertaining to your ClearScore account, reports detailing the findings of our ClearScore Protect service, significant changes which may impact our service and other such related content. These communications are an intrinsic part of owning a ClearScore account and cannot be opted-out of.

By accepting this Privacy Policy or continuing to use the ClearScore service, you hereby provide your consent to receiving the marketing communications detailed above.

If you would like us to stop sending direct marketing to you, we offer simple ways to do this. Whenever you receive direct marketing emails from us, you will be given the chance to unsubscribe. You can also change your marketing preferences via your ClearScore account settings at any time.

We use an automated decision making system to make automated decisions based on the personal information we have about you. This helps us to make sure our decisions are quick and fair, based on what we know.

Identity verification. We use an automated decision making system to verify the details you provide against those held by third party providers. If you do not pass the check using the automated system, we cannot provide our services to you without being able to verify your identity.

Tailored products and services. We may use your information to predict the probability that you may be accepted for a product, or to determine the best order or manner in which to display products to you.

Tailored communications. We want to make sure we’re only sending you emails and marketing communications that are relevant to you, and so we will use your personal information to determine which content you may be more interested in receiving.

You have the right not to be subject to a decision based solely on automated processing, including profiling. We understand that not everyone is comfortable with decisions being left entirely up to machines. If you have any questions about automated decision making, please contact us via privacy@clearscore.co.za.

All information you provide us with is stored on our secure servers.

The transmission of information via the internet may not always be completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access, loss or damage.

How long we keep your information will depend on the purpose for which we use it. We will only retain your information for as long as is necessary for those purposes.

Please note that if you withdraw consent to the processing of your personal data, access to our website and the associated services will be suspended or terminated. If you opt to delete your ClearScore account, we will permanently erase or fully anonymise your personal information.

Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.

Some business partners may also contact you through a phone call for the purpose of assisting you with an application if you have visited their website and have abandoned or not submitted an application,

You can exercise specific rights with regards to the data we hold about you, such as:

  • you may at any time request us to confirm whether we hold information about you. We will respond to such a request at no charge;

  • you may also request a copy of the record containing any personal data about you held by us, and details of any third parties who have or have had access to your information. We will respond within a reasonable time. In certain circumstances, we may or must refuse your request, in accordance with the provisions of PAIA. A request to be provided with a copy of the record, or a description about the personal information held by us, may be subject to a fee prescribed by the applicable data protection law to account for the related costs associated with granting you access to the information concerned. If a fee is payable, you may request an estimate of the fee before requesting a copy of your personal information/ record within our possession. We may require you to pay a deposit for all or part of the fee;

  • in certain circumstances, you have the right to request us to correct or delete personal information we keep about you which is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully. Please note that we can only amend data that is under our control, and we cannot amend or correct information in your credit report;

  • you also have a right to request that we destroy or delete a record of personal information about you that we are no longer authorised to retain. Please note that we are not obliged to accede to your request to correct or delete information. In circumstances where we do not accede to your request we will take reasonable steps to attach a copy of your request to the information concerned;

  • you have the right to be notified that information about you is being collected and, in the event of unauthorised access, to be notified of such unauthorised access; and

  • in certain circumstances, you have the right to object to the processing of your personal information. This would be the case where we process your information on the basis that it protects your legitimate interests, or where the processing is necessary for our legitimate interests or those of a third party to whom the information is supplied.

Wherever possible, we will provide you with tools to exercise these rights by yourself. However, you can also address your requests to privacy@clearscore.co.za or to our Information Officer at Clear Score Proprietary Limited Central Office Park No. 4, 257 Jean Avenue, Centurion, Gauteng, 0157, South Africa.

In order to fulfil your requests under this section, we may require some details such as: (a)your name, email address and postal address (b) a telephone number where you can be reached. (c) a photocopy of your passport, national ID or driving licence (for proof of identity); (d) your signature and the date of the request; (e) signed authority from the individual whose data is required if you are applying on their behalf.

If you are not satisfied with our response to any complaints you raise with us or you believe that our processing of your information does not comply with the applicable data protection laws, we suggest you contact our Information Officer. Please address your message to privacy@clearscore.co.za.

However, you can also lodge a complaint to the Information Regulator, at: Email: complaints.IR@justice.gov.za / Tel: +27-10-023-5200 / +27-82-764-4173

Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Policy.

Questions, comments and requests regarding this Privacy Policy should be addressed to privacy@clearscore.co.za.

If you require any further guidance on updating the details we hold about you, please contact us: privacy@clearscore.co.za.

You may also address any complaint or objection to our Information Officer at Clear Score Proprietary Limited Central Office Park No. 4, 257 Jean Avenue, Centurion, Gauteng, 0157, South Africa or via privacy@clearscore.co.za .