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Thinkmoney (Pty) Ltd t/a Data Inc. Technologies

(“Data Inc.”)

Data Protection and Privacy Policy

We at Data Inc. take your privacy seriously and are committed to protecting your Personal Information. We place a high premium on the privacy of every person or organisation with whom we interact and therefore acknowledge the need for Personal Information to be handled with a reasonable standard of care.

This Data Protection and Privacy Policy (“Policy”) relates to our Processing of your Personal Information when you interact with us, access our Websites and/or use our Service. It explains how we undertake to Process Personal Information in a manner which promotes the constitutional right to privacy, while retaining accountability and managing Data Subject participation.

With our headquarters in Johannesburg, South Africa, we are a customer acquisition business, operating specifically in, but not limited to, the telecommunications and financial services sectors.

We are committed to complying with the Applicable Laws in the multiple jurisdictions in which we, and you, operate. We have therefore drafted this Policy in accordance with the provisions of POPIA, which governs Data protection in South Africa, and in consideration of the following international Applicable Laws:

(collectively referred to as “International Data Protection Laws”).

By engaging with us, electronically or physically, you Consent to the Processing and transfer of your Personal Information as set out in this Policy.

If you have any questions or concerns about our Processing of your Personal Information, please contact us via the contact details provided in this Policy.

Definitions

The headnotes to the clauses of this Policy are for reference purposes only and shall in no way govern or affect the interpretation of, nor modify nor amplify these terms nor any clause hereof.

Unless the context dictates otherwise, the words and expressions set forth below shall bear the following meanings and cognate expressions shall bear corresponding meanings:

  1. “Affiliate(s)” means any other business which provides lead generation services in South Africa and which Data Inc. may appoint from time to time in order deliver the Services to its Customer(s);
  2. “Anonymisation” means the process of turning Personal Information into anonymous information so that a Data Subject is not (or is no longer) identifiable;
  3. “Applicable Laws” means any laws applicable to Personal Data and Personal Information with particular emphasis on POPIA and the International Data Protection Laws. Applicable Laws includes any statute, regulation, notice, policy, directive, ruling or subordinate legislation; the common law; any binding court order, judgement or ruling; any applicable industry code, policy or standard enforceable by law; or any applicable direction, policy or order that is given by any regulator, competent authority or organ of state or statutory industry body;
  4. “Child” means any natural person under the age of 18 (eighteen) years (including the plural “Children”);
  5. “Competent Person” means anyone who is legally competent to consent to any action or decision being taken by any matter concerning a Child, for example a parent or legal guardian;
  6. “Consent” means any voluntary, specific and informed expression of will, in terms of which permission is given for the Processing of Personal Information as contemplated in Applicable Laws;
  7. “Controller” means Data Inc., in circumstances where it Processes Personal Data (as defined in Article 4 of the GDPR);
  8. “Cookies” are a small amount of Data generated by a website and saved by your web browser. Its purpose is to remember information about you. If Data Subjects elect not to receive Cookies, they may be able to view some, but not all, of the content on our Website;
  9. “Customer(s)” means any natural person(s), or where applicable juristic person(s), who have either concluded an agreement with Data Inc. in terms of which such Customer procures the Services provided by Data Inc. (whether for themselves or their own customers/clients/members), or a Data Subject and/or third party whose Personal Information/Personal Data, Data Inc. may Processes from time to time;
  10. “Campaign Site(s)” means any digital or online interface and/or Website(s) developed and deployed by Data Inc., which Data Inc. makes available to its Customer(s), Data Subjects and/or any Third Party and which facilitates the engagement between Data Inc. and its Customer(s), or any other Data Subject or Third Party on matters pertaining to the Services provided by Data Inc. to its Customer(s) from time to time, or by Data Inc’s Customer(s) to their own customers or any Data Subject or Third Party with whom they seek to engage from time to time;
  11. “Data” means Personal Information, Usage Data, Cookies and/or Location Data;
  12. “Data Inc.” means Thinkmoney (Pty) Ltd t/a Data Inc. Technologies (Registration Number: 2004/029728/07), which is a private company registered in terms of the Company Laws of South Africa and is the provider of lead generation and advertising services;
  13. “Data Protection Authority” means the relevant regulatory authoritative bodies in the respective jurisdictions established in terms of Applicable Laws;
  14. “Data Subject” means Data Inc.’s Customer(s) or any third Party in respect of whom Data Inc. Processes Personal Information/Personal Data (also referred to as “you” or “your”);
  15. “GDPR” means the General Data Protection Regulation, which is a European law that governs all collection and processing of personal data from individuals inside the European Union;
  16. “Location Data” means the information about the physical location of a Data Subject’s device. Depending on the Data Subject’s location, the Personal Information or Personal Data will be processed in accordance with Applicable Laws;
  17. “Marketing Channel(s)” means a wide range of media channels to be used to communicate with consumers, including but not limited to SMS, telecommunication, email, websites, Google (including but not limited to Google Search and Google Display) and social media platforms (including but not limited to Facebook, Instagram, LinkedIn, X, YouTube, etc.);
  18. “Offering/s” refer to the products or services provided by Data Inc. including those provided by any of our Affiliates;
  19. “Operator” means a person or entity who Processes Personal Information/Data for a Responsible Party;
  20. “PAIA” means the Promotion of Access to Information Act, Act 2 of 2000;
  21. “Personal Data” (as defined in Article 4 of the GDPR) means any information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly;
  22. “Personal Information” shall have the same meaning as is given in section 1 of POPIA;
  23. “Policy” means this Data Protection and Privacy Policy;
  24. “POPIA” means the Protection of Personal Information Act, Act No 4 of 2013, and the regulations thereto, as amended or replaced from time to time;
  25. “Processing” means any operation or activity or any set of operations, whether or not by automatic means, concerning Personal Information/Personal Data, including:
    1. the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use;
    2. dissemination by means of transmission, distribution or making available in any other form by electronic communications or other means; or
    3. merging, linking, blocking, degradation, erasure or destruction.
    4. for the purposes of this definition, “Process” has a corresponding meaning;
  26. “Pseudonymisation” means the Processing of Personal Information in such a manner that the Personal Information can no longer be attributed to a specific person without the use of additional information;
  27. “Regulator” means the Information Regulator established in terms of POPIA;
  28. “Responsible Party” means a public or private body or any other person which alone or in conjunction with others, determines the purpose of and means for Processing Personal Information. For purposes of this Policy, Data Inc. is the responsible party as defined in Section 1 of POPIA;
  29. “Services” means the various lead generation- and marketing services provided by Data Inc. to its Customer(s), the particulars of which services are clearly set forth on Data Inc.’s Websites from time to time;
  30. “Service Provider/s” means any independent juristic or natural person contracted by Data Inc. to facilitate our Offerings, improve our Website and add value to an existing Offerings or provide additional Offerings to you;
  31. “Subsidiary/ies” means any entity which is wholly owned by Thinkmoney Proprietary Limited;
  32. “Third-Party” means any Thinkmoney, Affiliate(s), Customer(s), employees, independent contractor, agent, consultant, user of Data Inc’s Services, Website, Campaign Site(s) or any other digital application interface deployed by Data Inc. from time to time pursuant to administering its business;
  33. “Usage Data” is data collected automatically, either generated by the use of an Offering, or our Websites (for example, the duration of a Website page visit), as more fully described below;
  34. “Website/s” means our Websites sourced at https://datainc.tech/ and any of our Affiliate or Subsidiary company websites.

Purpose and Application

  1. The purpose of this Policy is not only to inform Data Subjects about how Data Inc. Processes their Personal Information/Personal Data, but also to establish a standard by which Data Inc. and its employees and representatives shall comply with in as far as the Processing of Personal Information/Personal Data is concerned.
  2. Data Inc., in its capacity as a Responsible Party and/or Operator and/or Controller shall strive to observe and comply with its obligations under POPIA and the GDPR (as may be applicable and to the extent necessary) when it Processes Personal Information/Personal Data from or in respect of any Data Subject.

Collecting & Processing of Personal Information / Personal Data

  1. Whenever you engage with Data Inc., whether it be physically or electronically, or through the use of our Services, facilities, Website you may be required to provide your Personal Information. In some instances, especially when you interact with our Websites, we may automatically collect your Location Data, Usage Data and Cookies. We will, in effect, be Processing your Data and will do so in terms of this Policy.
  2. It may be from time to time that Data Inc. has collected your Personal Information/Personal Data from other sources such as our Service Providers, social media networks and blogs (where the posting of your Personal Information may make it public information) and business associates, and in such instances, we will inform you by virtue of the updates in this Policy. In the event that you have shared your Personal Information/Personal Data with any third parties, Data Inc. will not be responsible for any loss suffered by the Data Subject, their dependents, beneficiaries, customers, members or employees (as the case may be).
  3. When a Data Subject provides Data Inc. with the Personal Information of any other Third Party, Data Inc. will process the Personal Information/Personal Data of such Third Party in line with this Policy, as well as the terms and conditions to which this Policy relates.
  4. We may Process the following types of Personal Information from time to time, including but not limited to:
    1. full names;
    2. identity numbers;
    3. registration numbers;
    4. financial details;
    5. statutory information;
    6. physical and postal address particulars;
    7. telephone numbers; and/or
    8. email addresses.
  5. When collecting Personal Information from you, we will comply with the notification requirements as set out in Applicable Laws, including the requirements set forth in Section 18 of POPIA.
  6. Data Inc. will Process Personal Information/Personal Data in order to facilitate and enhance the delivery of our Services to our Customers, foster a legally compliant workplace environment, as well as safeguard the Personal Information/Personal Data relating to any Data Subjects which it in fact holds. In such an instance, the Data Subject providing Data Inc. with such Personal Information/Personal Data will confirm that they are a Competent Person and that they have authority to give the requisite Consent to enable Data Inc. to Process such Personal Information/Personal Data.
  7. You may not always be required to provide the Personal Information that we have requested. However, if you choose not to provide certain information, you may not be able to take advantage of some of our Services and fully utilize our Websites.
  8. We Process Personal Information primarily to optimise the delivery of our Services and Websites, administer our business operations, ensure a legally compliant workplace environment and safeguard your Personal Information in our custody.
  9. Data Inc. undertakes to process any Personal Information/Personal Data in a manner which promotes the constitutional right to privacy, retains accountability and Data Subject participation. In supplementation of the above, Data Inc. will process Personal Information/Personal Data for the following purposes:
    1. To provide Services to Data Subjects, and to manage any information requested by Data Subjects in general;
    2. To establish a Data Subject’s needs, wants and preferences in relation to the Services provided by Data Inc. and our Affiliates or Subsidiaries;
    3. To help Data Inc. identify Data Subjects when they engage with Data Inc. for the first time or after an extended period of time from the last interaction;
    4. To facilitate the delivery of the Services and/or third party services to Customers and/or Data Subjects in general;
    5. To allocate to Customers unique identifiers for the purpose of securely storing, retaining and recalling such Customers Personal Information/Personal Data from time to time;
    6. To maintain records of Data Subjects and specifically Customer records;
    7. To maintain Third Party records;
    8. For recruitment purposes;
    9. For employment purposes;
    10. For apprenticeship purposes;
    11. For general administration purposes;
    12. For legal and/or contractual purposes;
    13. For health and safety purposes;
    14. To monitor access, secure and manage any facilities owned or operated by Data Inc. regardless of location in South Africa;
    15. To transact with third parties;
    16. To improve the quality of Data Inc.’s Services;
    17. To transfer Personal Information/Personal Data to any other Thinkmoney Company so as to enable the relevant company to market its products and/or services to Data Inc.’s Customer(s) or any other third party, as well as to render specific services to Data Inc. itself which would in turn enable Data Inc. to render its Services to its Customer(s);
    18. To transfer Personal Information/Personal Data to any Affiliate(s) so as to enable Data Inc. and its Customer(s) to make use of the services provided by the relevant Affiliate(s) and in turn enable the delivery of the Services and/or third-party services;
    19. To analyse the Personal Information/Personal Data collected for research and statistical purposes;
    20. To transfer Personal Information/Personal Data across the borders of South Africa to other jurisdiction(s);
    21. To carry out analysis and Data Subject and/or third party profiling;
    22. To transmit marketing material to any third party in respect of any third-party services via any Marketing Channel, including the Campaign Site(s);
    23. To identify other products and services which might be of interest to our Customers and Data Subjects in general, as well as to inform them of any third-party services.
  10. Data Inc. will not Process the Personal Information/Personal Data of a Data Subject for any purpose other than for the purposes set forth in this Policy, unless Data Inc. is permitted or required to do so in terms of Applicable Laws or otherwise by law.
  11. Data Inc. may from time to time Process Personal Information/Personal Data by making use of automated means (without deploying any human intervention in the decision-making process) to make decisions about the Data Subject or their application. In this instance it is specifically recorded that the Data Subject may object to or query the outcomes of such a decision.

Personal Information / Personal Data for Direct Marketing Purposes

  1. Data Inc. acknowledges that it may only use Personal Information/Personal Data to contact Data Subjects for purposes of direct marketing where Data Inc. has complied with the provisions of POPIA and GDPR (where applicable) and when it is generally permissible to do so in terms of Applicable Laws.
  2. Where this is lawfully permitted Data Inc. will ensure that a reasonable opportunity is given to all Data Subjects to object (opt-out) to the use of their Personal Information/Personal Data for Data Inc.'s marketing purposes when collecting the Personal Information/Personal Data and on the occasion of each communication to the Data Subject for purposes of direct marketing. Once you have opted out, it would take approximately 6 weeks for the opt out to be actioned within Data Inc.
  3. You may opt out of receiving promotional emails from us by following the instructions in those emails. If you opt out, we may still send you non-promotional emails, such as emails about the Offerings you have taken up.

Cookies

  1. Our Websites use Cookies to keep track of your visits and activity on the Websites.
  2. For information related to the use of Cookies, please see our Cookie Policy available on all our respective Websites.

Usage Data

  1. We may also Process Usage Data that your browser sends whenever you visit or engage with our Websites or when you access our Services by or through any device.
  2. This Usage Data may include information such as your device Internet Protocol (“IP”) address, browser type, browser version, the websites that you visit, the pages of other websites and the uniform resource locator (“URL”) of such pages, the time and date of your visit to those pages, the time spent on those pages, unique device identifiers, URL data for market segmentation purposes and other diagnostic data. It may also include information in terms of the type of device you use, your device unique ID and your device operating system.

Location Data

  1. With your permission, by enabling your location services, we may Process your Location Data in order to provide features, add value or improve or customise our Services.
  2. You can enable or disable your location services when you use any of our Websites, at any time, by way of your device settings.

Security of Your Personal Information

  1. We take all reasonable and appropriate steps to protect your Personal Information against loss, misuse, unauthorised access, disclosure, alteration and/or destruction.
  2. We use appropriate technical and organisational measures to protect your Personal Information. These measures include, but are not limited to, physical access controls and strict confidentiality measures, encryption, internet firewalls, intrusion detection and network monitoring depending on the nature of the information and the scope of Processing.
  3. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. Please remember that no method of transmission over our Websites or electronic storage is absolutely secure.

Storage and Retention of Personal Information / Personal Data

  1. Data Inc. will retain Personal Information/Data it has Processed, in an electronic or hardcopy file format, with a third party Service Provider appointed for this purpose. Personal Information/Personal Data will only be retained by Data Inc. for as long as necessary to fulfil the purposes for which that Personal Information/Personal Data was collected and/or as permitted in terms of Applicable Law.
  2. Data Inc. will not retain your Data for longer than necessary.
  3. The retention time will depend on:
    1. purpose for which the information was collected or subsequently processed;
    2. any legal obligations we have in terms of Applicable Laws;
    3. the nature of any contracts we have in place with you; or
    4. the existence of your Consent.
  4. It is specifically recorded that any Data Subject has the right to object to the Processing of their Personal Information and Data Inc. shall retain and store the Data Subject’s Personal Information/Personal Data for the purposes of dealing with such an objection or enquiry as soon and as swiftly as possible.
  5. We will use Pseudonymisation to retain your Usage Data for internal analysis purposes. We generally retain your Usage Data for a shorter period, except when it is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain it for longer time periods.

Failure to Provide Personal Information

  1. Where Data Inc. is required to collect Personal Information/Personal Data from a Data Subject by law or in order to fulfil a legitimate business purpose of Data Inc. and the Data Subject fails to provide such Personal Information/Personal Data, Data Inc. may, on notice to the Data Subject, decline to render Services without any liability to Data Inc.

Securing Personal Information / Personal Data

  1. Data Inc. has implemented appropriate, reasonable, physical, organisational, contractual and technological security measures to secure the integrity and confidentiality of Personal Information/Personal Data, including measures to protect against the loss or theft, unauthorised access, disclosure, copying, use or modification of Personal Information/Personal Data in compliance with Applicable Laws.
  2. In further compliance with Applicable Laws, Data Inc. will take steps to notify the relevant regulator(s) and/or any affected Data Subjects in the event of a security breach and will provide such notification as soon as reasonably possible after becoming aware of any such breach.
  3. Notwithstanding any other provisions of this Policy, it should be acknowledged that the transmission of Personal Information/Personal Data, whether it be physically in person, via the internet or any other digital data transferring technology, is not completely secure. Whilst Data Inc. has taken all appropriate, reasonable measures contemplated in clause 11.1 above to secure the integrity and confidentiality of the Personal Information/Personal Data it Processes, in order to guard against the loss of, damage to or unauthorized destruction of Personal Information/Personal Data and unlawful access to or processing of Personal Information/Personal Data, Data Inc. in no way guarantees that its security system is 100% secure or error-free. Therefore, Data Inc. does not guarantee the security or accuracy of the information (whether it be Personal Information/Personal Data or not) which it collects from any Data Subject.
  4. Any transmission of Personal Information/Personal Data will be solely at the own risk of Data Subject. Once Data Inc. has received the Personal Information/Personal Data, it will deploy and use strict procedures and security features to try to prevent unauthorised access to it. As indicated above, Data Inc. reiterates that it restricts access to Personal Information/Personal Data to third parties who have a legitimate operational reason for having access to such Personal Information/Personal Data. Data Inc. also maintains electronic and procedural safeguards that comply with the Applicable Laws to protect your Personal Information from any unauthorized access.
  5. Data Inc. shall not be held responsible and by accepting the terms and conditions to which this Policy relates, any Data Subject agrees to indemnify and hold Data Inc. harmless for any security breaches which may potentially expose the Personal Information/Personal Data in Data Inc.’s possession to unauthorized access and or the unlawful processing of such Personal Information/Personal Data by any third party.

Provision of Personal Information / Personal Data to Third Parties

  1. Data Inc. may disclose Personal Information/Personal Data to third parties where necessary and to achieve the purpose(s) for which the Personal Information/Personal Data was originally collected and Processed.
  2. Data Inc. will enter into written agreements with such third parties, to ensure that they comply with Applicable Laws pursuant to the Processing of Personal Information/Personal Data provided to it by Data Inc. from time to time.

Transfer of Personal Information / Personal Data Outside of South Africa

  1. Data Inc. may, under certain circumstances, transfer Personal Information/Personal Data to a jurisdiction outside of the Republic of South Africa in order to achieve the purpose(s) for which the Personal Information/Data was collected and Processed, including for Processing and storage by third-party Service Providers.
  2. Data Inc. will obtain the Data Subject's consent to transfer the Personal Information/Personal Data to such foreign jurisdiction unless consent is not required by Applicable Law.
  3. If you are located outside the Republic of South Africa and choose to provide information to us, please note that we may transfer your Data to the Republic of South Africa and Process it there.
  4. The Data Subject should also take note that, where the Personal Information/Personal Data is transferred to a foreign jurisdiction, the Processing of Personal Information/Personal Data in the foreign jurisdiction may be subject to the laws of that foreign jurisdiction. Your Consent to this Policy followed by your submission of such Data represents your Consent to such transfer.
  5. We will take reasonably necessary steps to ensure the secure treatment of your Data in accordance with this Policy. Your Data will not be transferred to an organization or country unless adequate data protection laws or controls are in place to safeguard your Data.

Access to Personal Information / Personal Data

  1. A Data Subject has the right to a copy of the Personal Information/Personal Data which is held by Data Inc. (subject to a few limited exemptions as provided for under Applicable Law).
  2. Data Inc. will provide the Data Subject with any such Personal Information/Personal Data to the extent required by Applicable Law and subject to and in accordance with the provisions of Data Inc.’s PAIA Manual (published in terms of section 51 of the Promotion of Access to Information Act, 2000 (“PAIA”), which PAIA Manual can be sourced on Data Inc.’s website at https://datainc.tech/
  3. The Data Subject can challenge the accuracy or completeness of his/her/its Personal Information/Personal Data in Data Inc.'s records at any time in accordance with the process set out in Data Inc.'s PAIA Manual.
  4. The prescribed fees to be paid for copies of the Data Subject's Personal Information/Personal Data are listed in Data Inc.'s PAIA Manual.

Keeping Personal Information / Personal Data Accurate

  1. Data Inc. will take reasonable steps to ensure that Personal Information/Personal Data that it Processes is kept updated where reasonably possible. For this purpose, Data Inc. has provided a function on its Website to enable Data Subjects to update their information.
  2. Data Inc. may not always expressly request the Data Subject to verify and update his/her/its Personal Information/Personal Data and expects that the Data Subject will notify Data Inc. from time to time in writing:
    1. of any updates or amendments required in respect of his/her/its Personal Information/Personal Data;
    2. where the Data Subject requires Data Inc. to delete his/her/its Personal Information/Personal Data; or
    3. where the Data Subject wishes to restrict the Processing of his/her/its Personal Information/Personal Data.

Affiliate and Affiliate Processing

  1. Our Affiliates and/or Subsidiaries may transfer your Personal Information among themselves to fulfil operational requirements and to assist us in complying with our obligations to you.
  2. All our Affiliates and/or Subsidiaries adopt and apply the principles set forth in this Policy in order to standardise, justify and ensure that any transfers of Personal Information between them adhere to the lawful Processing requirements set forth in Applicable Laws. This also guarantees compliance by ensuring that any potential additional handling of your Personal Information stays in line with the original reason it was collected by a specific Affiliate or Subsidiary.
  3. Affiliates only transfer Personal Information in the following circumstances:
    1. when you instruct us or our Affiliates and/or Subsidiaries to do so;
    2. with your Consent in circumstances where such Consent is required;
    3. to provide features, add value, or improve the quality and customise our Services and Websites;
    4. improve the quality of our Services and Websites;
    5. where the Personal Information has been de-identified, including through aggregation or Anonymisation;
    6. to provide assistance with marketing, billing, processing credit card payments, data analysis, fraud prevention, network and information security, technical support and customer service;
    7. when it is necessary for the fulfilment of our Services to you or prospective Customers;
    8. to comply with Applicable Laws or to respond to lawful requests and legal process;
    9. to protect any Data Subject’s vital interests, but only where we believe it is necessary; and
    10. in connection with or during negotiation of any business transfer, merger, financing, acquisition, or dissolution transaction or proceeding involving the sale, transfer, divestiture or disclosure of all or a portion of our business or assets to another company.
  4. From time to time, we may engage in joint sales or product promotions with certain third parties and/or our Affiliates or Subsidiaries.
  5. If you have specifically expressed an interest in, or purchased, a jointly offered product, promotion or service, we may share relevant Personal Information with those third parties or Affiliates or Subsidiaries. Where you have given Consent to do so, these third parties, Affiliates or Subsidiaries may send you marketing communications about their own products and services.
  6. Please be aware that we do not control third parties or Affiliates who are not contracted to Process Personal Information for and on our behalf. These third parties and Affiliates are responsible for managing their own use of the Personal Information collected in these circumstances. We recommend that you carefully consider any applicable privacy policies of the relevant third parties, Service Provider or Affiliate to find out more about their handling of your Personal Information.

Children’s Privacy

  1. Our Offerings are not intended for use by Children.
  2. We do not knowingly collect personally identifiable information from Children.
  3. If you become aware that a Child has provided us with Personal Information, please contact us in accordance with clause 20 below.
  4. If we become aware that we have collected Personal Information from Children without parental Consent, we will take immediate steps to remove/delete such Personal Information.

PAIA Manual

  1. PAIA is the statutory law in South Africa governing access to information and enables people to gain access to information held by both public and private bodies.
  2. If you would like to review, amend or obtain a copy of your Personal Information held by us, please review our PAIA manual on how to submit a request. Our PAIA manual is located on our Websites.

Your Rights

  1. While you have rights concerning your Personal Information, it is important to note that there may be various considerations in determining how to address any requests you may have.
  2. Your rights include:
    1. Right of Access – you can ask us for a copy of the Personal Information we hold.
    2. Right to Know – you can ask us what Personal Information is or was shared with any of our Affiliates or Service Providers.
    3. Right to Change – you can ask us to update your Personal Information or delete any Personal Information that is no longer accurate or relevant.
    4. Right to Object – you can object to our Processing of your Personal Information.
    5. Right to Report – you can lodge a complaint with the relevant authorities should you feel aggrieved by the manner in which we have Processed your Personal Information. The information regarding the applicable relevant Data Protection Authority is set out in Clause 20 below.
  3. All comments, questions, concerns or complaints regarding Personal Information/Personal Data or this Policy, should be forwarded to Data Inc.’s Information Officer at the following email address informationofficer@datainc.tech.

Contact Us

If you wish to update your preferences by email or believe that Data Inc. or any of our Affiliates or Subsidiaries has utilised your Personal Information contrary to Applicable Laws, please first attempt to resolve any concerns directly with us:

Name of Private Body:
Thinkmoney Proprietary Limited t/a Data Inc.
Email address:
info@datainc.tech
Postal address:
Po Box 2289, Highlands North, Gauteng, 2037
Street address:
6 Benmore Road, Morningside, Sandton, 2196
Phone number:
011 301 3000

If you are not satisfied with the outcome of the above process, you have the right to lodge a complaint with the relevant Data Protection Authority, using the contact details listed below:

Name of Body:
Information Regulator South Africa
Phone number:
010 023 5200
Website:
https://inforegulator.org.za/
General enquiries:
enquiries@inforegulator.org.za
POPIA Complaints:
POPIAComplaints@inforegulator.org.za

Changes to This Policy

  1. We reserve the right to update or modify this Policy at our sole discretion, at any given time and without prior notice to you.
  2. This may be carried out to meet legislative or regulatory demands and evolving business requirements.
  3. Unless otherwise stated, the current version of this Policy shall supersede and replace any previous versions.
  4. This Policy was last updated on 01/10/2024.