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, and 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, process your transactions, 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 behaviour 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
Email address privacy@morecorp.co.za
Telephone no 0115635000
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