Privacy and Cookie Policy

ClearScore Proprietary Limited respects your privacy and protecting your information is paramount. Please read this Privacy and Cookie 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.

The data controller 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 legal 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 the National Credit Act, 2005 (“NCA”).

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 name, address, email address, phone number or date of birth, financial information relating to your assets, credit products or credit position and any payments you make or receive, and credit card, loan or bank account information.

Information we collect from credit bureaux on your behalf. If you register to use our services, we will obtain your credit score and credit report from one or more credit bureaux 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 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 bureaux) and may receive information about you from them.

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 Policy.

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 bureaux] or other third parties on your behalf as part of our services. We will use this information to:

(a) administer your account and relationship with us and to, communicate with you by telephone, mail, email, text (SMS) message, instant messaging or other electronic means;

(b) 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);

(c) provide you with the information, products and services that you request from us;

(d) provide you with information about other products and services we offer that are similar to those that you have already purchased;

(e) 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;

(g) 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.

(h) notify you about changes to our services;

(i) ensure that content from our website is presented in the most effective manner for you and your device;

(j) aggregate it on an anonymous basis with other data for data analytical and reporting purposes; and

(k) 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:

(a) to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

(b) to build up a picture of your interests so that you don’t miss information relevant to you when you visit our website;

(c) 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;

(d) to allow you to participate in interactive features of our service, when you choose to do so;

(e) as part of our efforts to keep our website safe and secure;

(f) to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;

(g) 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.

Who your data can be disclosed Disclosure of your data to others may be necessary to ensure the smooth provision to you of the products, services and information you request. Your data may be disclosed to the other entities as described below.

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

We may share your information with selected third parties including:

(a)credit bureaux, to obtain your credit score and credit report and to provide our services to you (please see “Credit Bureaux” 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)Business partners, suppliers and sub-contractors for the performance of any contract we enter into with you;

(d)Service providers we use (such as comparison sites and aggregators) 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 (for example, personal loans and credit cards) that are likely to be suited to your credit circumstances through targeted advertising;

(e)Advertisers and advertising networks that require the data (in an aggregated format whereby individuals cannot be individually identified), to select and serve relevant adverts to you and others and to make sure their adverts reach their intended audience (for example, by telling them how many women or men have clicked on an advert); and (f)Analytics and search engine providers that assist us in the improvement and optimisation of our website.

We may 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;

(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; 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.

Credit Bureaux

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 bureaux. In order to provide these services to you, we will share your information with such credit bureaux.

Credit bureaux collect and maintain information about consumers’ and businesses’ credit behaviour. 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 bureaux 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 bureaux 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: (i) Checking details on applications for loans or other credit and credit-related or other facilities; (ii) Managing loan, credit and credit-related accounts or facilities; (iii) Recovering debt; (iv) Checking details on proposals and claims for all types of insurance; (v) 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.

Direct marketing and how you can change your preference

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 or SMS or mail.

If you would like us to stop sending direct marketing to you, we offer simple ways to do this. Whenever you receive direct marketing you will be told how to unsubscribe.

If you consented to receive marketing communications when you registered for our website or services, you can tell us that you do not wish to receive any more by logging into your ClearScore account and going into the “My Account” section. At the bottom of the page, you can click on “Change” under “Change what emails you receive from us” to easily switch off all marketing emails.

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. We will keep an archived record of your personal data for a period of up to 7 years after termination (unless a longer period is prescribed by law) for the purposes of responding to legal disputes and legal or regulatory enquiries or investigations only, but will not use this data for any other purpose.

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. Please check these policies before you submit any personal data to these websites.

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 request a copy of 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.

Any access request may be subject to a fee prescribed by the applicable data protection law in order to meet our costs in providing you with details of the information we hold about you. If a fee is payable, you may request an estimate of the fee before requesting a copy of your personal information. We may require you to pay a deposit for all or part of the fee.

The request must be in writing and must contain the following:

(a)your name and postal address

(b) a telephone number where you can be reached.

(c) a photocopy of your passport or driving licence;

(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.

Please send your request to:

Data Protection Manager Clear Score Proprietary Limited Central Office Park No. 4, 257 Jean Avenue, Centurion, Gauteng, 0157, South Africa10.Changes to our privacy policy

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 help.za@clearscore.co.za.

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

Clear Score uses cookies for a variety of purposes, including ensuring that our website functions as expected, remembering your preferences and gathering data on the users of our website and our services.

By using our website (through any device) you agree that this Cookies Policy, together with our Privacy Policy and Terms, applies to that use.

We are committed to protecting you and any information (anonymous or otherwise) that we collect about you online. This section tells you about how and why we use cookies, and how this allows us to improve our service.

If you wish to use our website, but would like us not to set cookies in your browser, you can disable or remove the cookies. Details on how to do this are set out in section 5 below. Please note that disabling or removing the cookies we or our third party service providers set may impact the functionality and security of our website and our ability to provide our services to you. Please note that you will not be able to use our website or the associated services if you do not accept our use of cookies.

We reserve the right to make changes to our Cookies Policy. Any changes we may make to our Cookies 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 Cookies Policy. Your continued use of our website is taken as your agreement to any such changes.

Cookies are files containing small amounts of information which are downloaded to the device you use when you visit a website. Your web browser (such as Internet Explorer, Mozilla Firefox, Google Chrome or Safari) then sends these cookies back to our website [or application] on each subsequent visit. Cookies do not contain any information that personally identifies you.

We and our reputable third party service providers use the information we obtain about you through the use of cookies for the following purposes to:

(a) recognise your device(s) when you visit our website;

(b) remember if you’ve set any preferences on our website;

(c) temporarily store data as part of, for example, customer surveys;

(d) test new content and evaluate its effectiveness;

(e) remember if you’ve been informed of our Cookies Policy, Privacy Policy and other Terms;

(f) track you as you navigate our website (including tracking page usage and paths used by visitors through our website; and tracking use of our Internet banner advertisements and other links from our marketing partners’ websites to our website);

(g) improve our website’s usability;

(h) allow you to share pages with social networks such as LinkedIn, Facebook and Twitter / to support social media components, like Facebook or Twitter (where our website uses a plugin from these third party platforms);

(i) ensure you don’t miss information that is relevant to you (including targeting our website content, targeting our marketing campaigns and direct marketing emails, targeting our Internet banner advertisements on our website and on other websites);

(j) analyse use of our website (including for statistical analysis, sales and marketing research). To stop us setting these cookies you will need to set up your browser to reject all cookies (see further below).

We may also combine this web usage data with other information we have collected about you. We store this information so that we have a better and more specific understanding of the way users are using our website, and their preferences and interests, for the purposes set out above.

Cookies may be either “persistent” cookies or “session” cookies, depending on how long they are used.

Persistent cookies remain on your device after you have closed your browser, and allow a website to remember your actions and preferences. They are activated each time you visit the website where the cookie was generated. Sometimes persistent cookies are used by websites to provide targeted advertising based on the browsing history of the device. They are stored by the browser and remain valid until their set expiry date (unless deleted by the user before the expiry date).

Session cookies only last for the duration of your visit and are deleted when you close your browser. They facilitate tasks such as allowing a website to identify that a user of a particular device is navigating from page to page, supporting website security or basic functionality.

Many of the cookies we use are session cookies. For example, they help us to ensure the security of your session, and can also keep you signed in to your Clear Score account while you move between pages.

Whether a cookie is a first or third party cookie depends on which website the cookie comes from. First party cookies are those set by or on behalf of the website visited. All other cookies are third party cookies. We use both first party and third party cookies. You can read more about them below. Third party cookies: In some cases, some of these cookies are managed for us by third parties, but we don’t allow the third party to use the cookies for any purpose other than those listed above. Strictly necessary cookies

These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website such as your Clear Score account.

Performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Analytics cookies. In order to keep our products and services easy to use and up-to-date, we use web analytics services to help us understand how people use our website. For example we can see which parts of our services are most popular, identify when errors occur and test different versions of a page or feature to see which one works best. These web analytics services may be designed and operated by other companies on our behalf. They do this using small invisible images known as “web beacons” or “tracking pixels” that may be included in the digital products and services on our website. These are used for example to count the number of times something has been seen. These web beacons are anonymous and do not contain or collect any information that identifies you.

Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. We use retargeting and online behavioural advertising to market ClearScore which employs targeting cookies to deliver you more targeted advertising.

By using our website or apps, you agree that we can place the above types of cookies on your device.

Below is a full list of the cookies we use together with a description of what they are used for, and whether they are ‘first’ or ‘third’ party. Where a cookie is a third party cookie, please visit the providers’ website for more information.

In all modern browsers you may elect to reject cookies and/or enable do not track features, and we provide instructions on how to do this below. Please note however that by doing so parts of our website may no longer function as expected. For example, if you delete cookies any preferences they record will be lost. This includes for example where you have opted out from cookies, as this requires an opt-out cookie to be set.

If your concerns are based around third party cookies, then we recommend you just reject those cookies, rather than all cookies so that we can still provide you with the functionality you expect.

If you do wish to stop your browser from accepting cookies, see the following pages:

Mozilla Firefox: http://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Google Chrome: https://support.google.com/chrome/bin/answer.py?hl=en&answer=95647&p=cpn_cookies

Internet Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies

Safari: http://support.apple.com/kb/PH5042

If you have any questions about our cookies or this Cookies Policy, please contact us on help.za@clearscore.co.za