1. INTRODUCTION
The right to privacy is an integral human right recognised and protected in the South African Constitution and in the Protection of Personal Information Act 4 of 2013 ("POPIA"). We regard the lawful and correct treatment of personal information as important to the achievement of MoreCorp’s objectives. MoreCorp refers to MoreCorp Proprietary Limited, including affiliates or members of the MoreCorp Group, our branches, business units, divisions, employees and volunteers, contractors, suppliers and other persons acting on behalf of MoreCorp (“we”, “us” or “our”). Through the provision of quality goods and services, MoreCorp is necessarily involved in the collection, use and disclosure of certain aspects of the personal information of clients, customers, employees and other stakeholders. We are committed to effectively managing this personal information in accordance with POPIA. This Privacy Policy describes how MoreCorp will use your personal information and under what circumstances your personal information will be disclosed.
2. PERSONAL INFORMATION MORECORP COLLECTS FROM YOU
At MoreCorp, we strive to collect only the personal information that we need. The personal information we collect depends on how you interact with us.
When you create a customer ID or register with us, apply for commercial credit, purchase and/or activate a product or service, connect to our services, contact us (including through social media), participate in an online survey, or otherwise interact with us, we may collect a variety of information, including:
• Account Information: Your customer ID and related account details, including email address, devices registered, account status, and age;
• Contact Information: Information such as your name, email address, physical address, phone number, or other contact information;
• Biometric information: Information such as your fingerprints and voice recordings;
• Payment Information: Information about your billing address and method of payment, such as bank details, credit, debit, or other payment card information;
• Transaction Information: Information about purchases of MoreCorp products and services or transactions facilitated by MoreCorp, including purchases on our various platforms;
• Usage Data: Data about your activity on and use of our offerings, such as app launches within our services, including browsing history, search history, and product interaction;
• Location Information: Precise location only to identify which golf course or location you are using to enjoy our product or service;
• Health Information: Information relating to your health status, including data related to your physical health or condition;
• Fitness Information: Details relating to your fitness and exercise information as our ongoing objectives to ensure we offer you a customised sporting experience at MoreCorp;
• Financial Information: Details including salary, income, assets information, travel history, education, profession, investment patterns, amongst other things, where collected, to identify our customer base; and
• Other Information: Details such as the content of your communications with MoreCorp, including interactions with customer support and contacts through social media channels.
You are not required to provide the personal information that we have requested. However, if you choose not to do so, in many cases we may not be able to provide you with our products or services or adequately respond to requests you may have.
3. LEGAL BASIS FOR AND PURPOSE OF THE USE OF PERSONAL INFORMATION
MoreCorp uses personal information to facilitate our service offerings, to process your transactions, to communicate with you, for security and fraud prevention, and to comply with applicable law. We may also use your personal information for other purposes with your consent.
MoreCorp uses your personal information only when we have a valid legal basis to do so. MoreCorp‘s processing of personal information is premised on one or a combination of some of the following grounds:
• Consent – we may (but usually do not) need your consent to use your personal information. You can withdraw your consent by contacting us;
• Performance of an agreement – we may need to collect and use your personal information to enter into an agreement with you such as to facilitate the purchase of a product or rendering of a service;
• Legitimate interest – we may use your personal information for our legitimate interests or those of third parties; and/or
• Compliance with law or regulation – we may use your personal information in order to comply with applicable law/regulation.
If you fail to provide certain information when requested, we may not be able to perform in terms of the agreement entered into with you, or we may be prevented from complying with our legal obligations.
We will only use your personal information for the purposes for which it was collected. Where necessary, we may use your personal information for another purpose only where that purpose is compatible with the original purpose for which your personal information was collected. Where MoreCorp needs to use your personal information for a purpose unrelated to the reason for its collection, we will notify you and will explain the legal basis which allows it to do so.
Please note that MoreCorp may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We use your personal information to:
• facilitate our service offerings: MoreCorp collects personal information necessary to facilitate our service offerings, which may include personal information collected to personalise or improve our offerings, for internal purposes such as auditing or data analysis, or for troubleshooting;
• process your transactions: MoreCorp must collect data such as your name, purchase, and payment information;
• communicate with you: to respond to communications, reach out to you about your transactions or account, market our products and services, provide other relevant information, or request information or feedback. From time to time, we may use your personal information to send important notices, such as communications about purchases and changes to our terms, conditions, and policies;
• comply with applicable law: for example, to satisfy tax or reporting obligations, or to comply with a lawful governmental request.
4. YOUR RIGHTS
Where appropriate, MoreCorp will ensure that its clients and customers are made aware of their rights as data subjects. You have the right to have your personal information processed in accordance with the conditions for the lawful processing of personal information, including the right:
• to be notified that personal information about you is being collected, or when your personal information has been accessed or acquired by an unauthorised person;
• to establish whether MoreCorp holds personal information relating to you and to request access to such personal information;
• to request, where necessary, the correction, destruction or deletion of your personal information;
• to object, on reasonable grounds, relating to your particular situation to the processing of your personal information, where MoreCorp is processing your information on the basis of its legitimate interest;
• to institute civil proceedings regarding the alleged interference with the protection of your personal information; and
• to submit a complaint to the Information Regulator regarding MoreCorp’s non-compliance with applicable laws. The contact details for the Information Regulator are as follows:
Address: JD House
27 Stiemens Street
Braamfontein
Johannesburg
2001
Email: complaints.IR@justice.gov.za
Where any of your rights under POPIA have been infringed upon, you can also submit a complaint to MoreCorp’s Information Officer in writing. Where so required, the Information Officer will provide you with a "POPIA Complaint Form". For more information about your rights including your right to access details of the personal information relating to you and a copy of that information, please contact the Information Officer ’s at privacy@morecorp.co.za
5. SHARING OF YOUR PERSONAL INFORMATION
MoreCorp may share your personal information with other companies or entities (third parties) with which we have a business relationship, in order to provide the service you have requested. The third parties with whom MoreCorp shares your personal information will not use such personal information beyond that which is necessary to deliver your requested service. MoreCorp requires that all third parties to use appropriate security measures to protect your personal information.
MoreCorp will disclose your personal information to certain authorities or third parties (such as law enforcement agencies in South Africa), where such an obligation is imposed on MoreCorp by law. We may also disclose and otherwise process your personal information in accordance with applicable law to defend MoreCorp’s legitimate interests, for example, in civil or criminal legal proceedings.
6. PROTECTION OF PERSONAL INFORMATION AT MORECORP
We use administrative, technical, and physical safeguards to protect your personal information, taking into account the nature of the personal information and the processing, and the threats posed. We are constantly working to improve on these safeguards to help keep your personal information secure.
6.1 Children and Personal Information
MoreCorp understands the importance of safeguarding the personal information of children, which we consider to be individuals under the age of 18. That is why MoreCorp has implemented additional processes and protections to help keep children's personal information safe.
To access certain MoreCorp services, such services may be obtained through a parent or guardian only. If we learn that a child's personal information was collected without appropriate authorisation, it will be deleted as soon as possible.
6.2 Cookies and Other Technologies
MoreCorp’s websites, online services, interactive applications, email messages, and advertisements may use “cookies” and other technologies such as pixel tags and web beacons. These technologies help us to better understand user behavior including for security and fraud prevention purposes, tell us which parts of our websites people have visited, and facilitate and measure the effectiveness of advertisements and web searches.
· Communications Cookies: used to enable network traffic to and from MoreCorp’s systems, including by helping us detect any errors.
· Strictly Necessary Cookies: These cookies are set as required to provide a specific feature or service that you have accessed or requested. For example, they allow us to display our websites in the proper format and language, to authenticate and verify your transactions.
· Other Cookies: These cookies are used to understand how visitors interact with our websites and online services, including by helping us to assess the effectiveness of advertisements and web searches. MoreCorp also uses these cookies to remember choices you make while browsing, so we can provide you with a customised experience.
If you prefer that MoreCorp not use cookies, we provide you with the means to disable their use. However, certain features of the MoreCorp website may not be available if cookies are disabled.
7. UPDATING YOUR PERSONAL INFORMATION
While we take reasonable steps to keep the personal information in our possession accurate and up to date, you may assist this process by informing MoreCorp as and when your personal information is changed or updated. It is your responsibility to provide us with your correct details as well as to update your personal information where appropriate.
Should you wish to know what personal information we hold about you or you would like us to stop processing your personal information for the purpose of sending promotional materials or direct marketing, you may, as appropriate and in accordance with applicable law, exercise such rights by contacting us through the contact points referred to below. Should you request MoreCorp to delete or stop processing your personal information, we may also then not be able to continue to provide the services to you.
8. RETENTION PERIODS
MoreCorp retains personal information only for so long as necessary to fulfil the purposes for which it was collected, including as described in this Privacy Policy, or as required by law. We will retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Policy. When assessing retention periods, we first carefully examine whether it is necessary to retain the personal information collected and, if retention is required, work to retain the personal information for the shortest possible period permissible under law.
9. CONTACT US
Our contact information is set out below should you have any questions or concerns about this Privacy Policy:
Head of Legal Risk and Compliance
MoreCorp (Pty) Ltd
Address: 12 Stirrup Lane, Woodmead Office Park, Woodmead Ext 14, Sandton
E-mail address: privacy@morecorp.co.za
Telephone no: 0115635000