1.1 “Applicable Legislation” – means all legislation applicable to Spring Loans, including POPIA, Income Tax Act 58 of 1962, Value Added Tax Act 89 of 1991, Labour Relations Act 66 of 1995, Basic Conditions of Employment Act 75 of 1997, Employment Equity Act 55 of 1998, Electronic Communications and Transactions Act 25 of 2002, Telecommunications Act 103 of 1996; Electronic Communications Act 36 of 2005, Consumer Protection Act 68 of 2008, National Credit Act 34 of 2005;
1.2 “Data Subject” – means the person to whom personal information relates as defined under POPIA;
1.3 Information Officer” – means the ‘responsible person’ as defined by POPIA and as detailed in Spring Loans’ PAIA Manual, and who is authorised to develop, implement, monitor and maintain a compliance framework on behalf of Spring Loans;
1.4 “Operator” – means a person who processes personal information for a Responsible Party in terms of a contract or mandate, without coming under the direct authority of that Party;
1.5 “PAIA Manual” –means the manual published by Spring Loans in terms of the Promotion of Access to Information Act, 2 of 2000, as amended;
1.6 “Personal Information” – shall mean, for purposes of this Privacy Policy and as defined under POPIA, information about an identifiable, natural person, and in so far as it is applicable, an identifiable, juristic person, including, but not limited to –
1.6.1 information relating to the race, gender, sex, pregnancy, marital status, national;
1.6.2 ethnic or social origin, colour, sexual orientation, age, physical or mental health;
1.6.3 well-being, disability, religion, conscience, belief, culture, language and birth of the person;
1.6.4 information relating to the education or the medical, criminal or employment history of the person or information relating to financial transactions in which the person has been involved;
1.6.5 any identifying number, symbol or other particular assigned to the person;
1.6.6 the address, fingerprints or blood type of the person;
1.6.7 the personal opinions, views or preferences of the person, except where they are about another individual or about a proposal for a grant, an award of a prize to be made to another individual;
1.6.8 correspondence sent by the person that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence;
1.6.9 the views or opinions of another individual about the person;
1.6.10 the views or opinions of another individual about a proposal for a grant, an award or a prize to be made to the person, but excluding the name of the other individual where it appears with the views or opinions of the other individual;
1.6.11 the name of the person where it appears with other personal information relating to the person or where the disclosure of the name itself would reveal information about the person; and
1.6.12 but excludes information about a natural person who has been dead, or a juristic person that has ceased to exist, for more than 20 years.
1.7 “Privacy Policy” – means this policy developed in terms of POPIA and Regulations thereto;
1.8 “Processing” – means any operation or activity or any set of operations, whether or not by automatic means, concerning personal information, including –
1.8.1 the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use;
1.8.2 dissemination by means of transmission, distribution or making available in any other form; or
1.8.3 merging, linking, as well as restriction, degradation, erasure or destruction of information;
1.9 “Purpose” – means Spring Loans’ purpose to processing of Personal Information as set out under Spring Loans’ PAIA Manual;
1.10 “Responsible Party” – means, for purposes of this Privacy Policy, all persons to whom this Privacy Policy applies, whom, whether alone or in conjunction with others determines the purpose and means of processing Personal Information; and
1.11 “Special Personal Information” – means information relating to a person’s (a) religious or philosophical beliefs, race or ethnic origin, trade union membership, political persuasion, health or sex life or biometric information of a data subject; or (b) criminal behaviour, as defined under POPIA.
2.1 Purpose
2.1.1 At Spring Loans (Pty) Ltd (registration number: 2025/631597/07, regulator registration number: NCRCP22612 (“Spring Loans”)), we place the highest importance on protecting your Personal Information as defined in the Protection of Personal Information Act, 4 of 2013 (“POPIA”) of the Republic of South Africa, as amended.
2.1.2 POPIA, and the regulations promulgated thereunder (“Regulations”), give effect to the right to privacy provided by section 14 of the Bill of Rights of the Constitution of the Republic of South Africa, 1996.
2.1.3 POPIA and Regulations require the “Responsible Person” (as defined below) to develop, implement, monitor and maintain a compliance framework.
2.1.4 We have accordingly developed this Privacy Policy to comply with the aforesaid requirements and to further demonstrate commitment to the spirit of POPIA in respecting the rights of Data Subjects to have their Personal Information protected as set out in POPIA.
2.1.5 This Privacy Policy explains in detail how Spring Loans (“we”, “us” or “our”) collects, uses, stores, and protects your Personal Information whenever you interact with our services or digital platforms..
2.1.6 The terms “Data Subject”, “user”, “you” and “your” are used interchangeably in this Privacy Policy to refer to all persons who access our website at www.springloans.co.za, our mobile application “Spring Loans”, or any related online platforms and communication channels (collectively referred to as “the Platform”) and / or request our services as a credit provider and / or engage with us for any reason whatsoever.
2.1.7 You have the right to make a complaint at any time to the South African data regulator’s office (“Information Regulator”). We would, however, appreciate the chance to deal with your concerns before you approach any such regulator, so please contact us in the first instance.
2.1.8 Please note that certain terms used in this Privacy Policy may correspond to definitions provided in our Terms and Conditions of Use (“Terms”). This Privacy Policy is accordingly read in conjunction with Spring Loans’ Terms, and should be considered together to fully understand how we manage your personal data and to be aware of your rights and obligations when using our Platform.
2.2 Responsible Party and Operator
2.2.1 Spring Loans’ Role
2.2.1.1 Spring Loans acts as the Responsible Party, determining the purposes and means of processing your Personal Information, as defined under Section 1 of POPIA.
2.2.1.2 In certain cases, we may also act as an Operator, processing Personal Information on behalf of another party. When we do so, we ensure strict compliance with the obligations set out in Sections 20 and 21 of POPIA.
2.3 Information Officer
2.3.1 Spring Loans has appointed an Information Officer responsible for overseeing compliance with this Privacy Policy and handling any queries regarding the protection of your Personal Information.
2.3.2 If you have any questions or wish to exercise your legal rights under POPIA, please contact our Information Officer using the details provided below.
2.4 Contact Details
2.4.1 Our full contact details are as follows:
Full Name: Spring Loans (Pty) Ltd
Information Officer: Gereldien Yvette Tamboer
Email Address: ceo@springloans.co.za
Postal Address: 2nd Floor Tower B Northlands Cnr Shopping Centre, Northriding, Gauteng 2169, South Africa
Telephone Number: +27100850420
2.5 Changes to this Privacy Policy
2.5.1 We are committed to maintaining the accuracy and currency of your Personal Information. Please promptly inform us of any changes to your details during your relationship with Spring Loans to ensure that our records remain accurate.
2.5.2 This Privacy Policy may be reviewed and updated from time to time at our discretion. Any modifications will become effective immediately upon publication on our official Platform.
2.6 Third-Party Links on the Platform
2.6.1 Our Platform may include links, plug-ins, or applications that direct you to third-party websites or services. When you click on or engage with these links, third parties may collect, use, or share your Personal Information independently of Spring Loans.
2.6.2 Spring Loans is not responsible for, and does not control, third-party websites or applications that may be linked to our Platform or applications and bears no responsibility for their content, policies, or practices.
2.6.3 We strongly recommend that you carefully review the Privacy Policy and Terms of Use of any external websites or services you choose to visit before providing any Personal Information.
3.1 Should you decide to register with or function as a user on our Platform, engage with us and / or use any services offered by us, you hereby expressly consent to, and opt-in to, Spring Loans collecting, collating, processing, and using the following Personal Information when you use the Platform and / or services:
3.1.1 Identity Data: your full name, national identity number, and, where applicable, your company name, registration number, and business address.
3.1.2 Contact Data: your contact information such as email address, physical and postal addresses, proof of residence, and telephone or mobile numbers.
3.1.3 Profile Data: details within your customer profile, including credit history, account or loan information, transactional records, and repayment history.
3.1.4 Employment Data: employment-related details such as employer name, occupation, job title, and income or remuneration information.
3.1.5 Financial Data: documentation and information used to verify or process your financial activity, such as payslips, bank statements, banking details for debit order authorisation, and card or payment information handled securely by authorised third-party payment service providers.
3.1.6 Transaction Data: records of payments made to or received from you, contracts entered into, subscription details, service usage, applicable fees, and related financial documentation such as invoices or receipts.
3.1.7 Technical Data: technical information about your access to our Platform, including IP address, login credentials, browser type and version, operating system, time zone, device type, and cookie or tracking data.
3.1.8 Usage Data: information on how you use and interact with our Platform, services, mobile applications, online tools, and participation in surveys or promotional activities.
3.1.9 Marketing and Communications Data: preferences for receiving communications and marketing materials from Spring Loans or third parties, along with your preferred method of contact.
3.1.10 Support Data: any correspondence you send to us, including emails, online chat messages, or telephone call logs, as well as notes or summaries made during customer support interactions.
3.2 In addition to the above, we may also collect and analyse Aggregated Data, such as statistical or demographic information, to improve our services and business performance. While Aggregated Data may be derived from your Personal Information, it does not directly identify you and is therefore not considered Personal Information under POPIA. However, if such data is combined with identifiable information, it will be treated as Personal Information under this Privacy Policy.
3.3 In some cases, we are legally or contractually required to collect specific Personal Information from you. If you fail to provide this information when requested, Spring Loans may be unable to deliver certain products or services or fulfil our contractual obligations. If this occurs, we will notify you beforehand and explain the implications prior to restricting or terminating your access to our services.
3.4 You warrant that the Personal Information disclosed to Spring Loans is directly from you as a user of the Platform or in connection with our services, and all such Personal Information is lawfully yours to provide. You also warrant that any Personal Information provided to us from a third-party Responsible Party, was obtained from you lawfully and provided to us with your express consent to the relevant Responsible Party to do so.
3.5 You may choose to provide additional Personal Information to us, in which event you agree to provide accurate and current information, and, generally, not to impersonate or misrepresent any person or entity or falsely state or otherwise misrepresent your affiliation with anyone or anything.
4.1 Spring Loans collects Personal Information through a combination of direct interactions, automated technologies, and information obtained from third parties. The method and extent of collection depend on how you engage with our services and Platform.
4.2 Direct Interactions
You may choose to provide Personal Information to us directly through various channels, including (but not limited to):
4.2.1 Completing and submitting a loan or credit application form.
4.2.2 Communicating with us via our Platform, telephone, email, live chat, or other communication methods.
4.2.3 Registering or transacting through our online or mobile services.
4.2.4 Entering into agreements or contractual arrangements with Spring Loans.
4.2.5 Providing goods or services to us as an independent contractor, consultant, or service provider.
4.2.6 Requesting product or service information, support, or providing feedback about our offerings.
4.3 Automated Technologies
4.3.1 When you use or interact with our Platform, we may automatically collect certain Technical and Usage Data. This includes data collected through:
4.3.1.1 Cookies,
4.3.1.2 Server logs, and
4.3.1.3 Similar tracking technologies used to enhance security, improve performance, and personalise your experience.
4.3.2 We may also receive limited technical information about your browsing behaviour from third-party analytics or advertising partners when you visit websites or applications that use our cookies or integrated technologies.
4.4 Third-Party Sources
We may collect your Personal Information lawfully from trusted third-party or publicly available sources, where permitted by POPIA and other Applicable Legislation:
4.4.1 Credit bureaus and verification agencies, for assessing creditworthiness and identity verification.
4.4.2 Analytics service providers, which assist us in understanding Platform usage and user behaviour trends.
4.4.3 Financial institutions and payment service providers, for processing payments, disbursements, or debit orders.
4.4.4 Marketing or lead generation partners, who lawfully share information about individuals interested in financial products.
4.4.5 Search and information providers, which help confirm identity, business registration details, or contact information.
5.1 Spring Loans uses your Personal Information only when there is a lawful and legitimate basis for doing so, and primarily for purposes to which you have expressly consented or that are necessary for our business operations.
5.2 All processing of Personal Information is conducted strictly in compliance with POPIA, the National Credit Act (“NCA”), and any other applicable South African legislation. The most common circumstances under which we use your Personal Information include:
5.2.1 When you have provided your explicit consent for a specific purpose.
5.2.2 To fulfil contractual obligations arising from agreements we have entered into with you or with third parties acting on your behalf.
5.2.3 Where the processing is necessary for our legitimate business interests, provided such interests do not override your fundamental rights and freedoms.
5.2.4 Where it is required to comply with a legal, regulatory, or statutory obligation under South African law or other applicable legislation.
6.1 Spring Loans processes Personal Information strictly for lawful purposes and in accordance with the principles of POPIA. The nature and scope of processing depend on your relationship with us and the services you use.
6.2 Below is a summary of the key purposes for which we may process your Personal Information, along with the lawful bases that justify such processing:
6.2.1 We process your Identity, Contact, and Financial Data to verify your identity and ensure compliance with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations.
6.2.2 Your Financial, Employment, and Profile Data may be processed to conduct affordability assessments and creditworthiness checks before entering into a credit agreement. Such processing is based on your consent and our statutory obligations.
6.2.3 We use Identity, Contact, and Transaction Data to prepare, conclude, and manage contractual agreements entered into between you and Spring Loans, ensuring proper performance of our contractual duties.
6.2.4 Financial and Transaction Data may be processed to facilitate disbursements, repayments, debit order instructions, and other financial transactions related to your account. This is necessary to execute our contract with you and to support legitimate business operations.
6.2.5 We process Profile, Identity, and Contact Data to maintain accurate customer records, manage your account, and ensure seamless delivery of services. This processing is necessary for both contractual performance and legitimate business purposes.
6.2.6 Your Contact and Communication Preference Data are used to communicate essential service updates, policy changes, or notifications related to your account or obligations under Applicable Legislation.
6.2.7 Support Data and Contact Data may be used to provide customer assistance, respond to queries, or resolve service-related issues, based on legitimate business interests.
6.2.8 We process Identity, Financial, and Transaction Data to meet legal and regulatory requirements such as those under FICA, AML, and NCR compliance frameworks.
6.2.9 Technical, Usage, and Aggregated Data are processed to analyse system performance, detect and prevent fraud, improve user experience, and optimise our Platform and internal operations.
6.2.10 With your explicit consent, we may process your Marketing and Communication Data to provide you with personalised product updates, promotional offers, and educational materials relevant to your financial interests. You can withdraw consent anytime by contacting us or using the unsubscribe link.
6.2.11 Finally, Financial and Transaction Data may be processed for audit, tax, and reporting purposes, where required by law.
6.3 Quality Control
6.3.1 To maintain consistent service quality and ensure compliance with regulatory and operational standards, Spring Loans may record or monitor all interactions with you, including telephone conversations, online chats, or other communication channels.
6.3.2 Such recordings may be used for staff training, service improvement, verification of information, and legal or compliance purposes.
6.3.3 If you wish to access a copy of any recorded communication, you may submit a request to our Information Officer using the contact details provided in Section 1.3 of this Privacy Policy.
6.4 Marketing Practices
6.4.1 We are committed to giving you full control over how your Personal Information is used for marketing and promotional purposes. You may choose whether to receive marketing materials or promotional messages from Spring Loans.
6.4.2 If you decide that you no longer wish to receive such communications, you can easily opt out at any time by following the unsubscribe instructions included in our messages or by contacting us directly through the provided support channels.
6.5 Third-Party Marketing
6.5.1 Spring Loans (Pty) Ltd will never sell, rent, or share your Personal Information with third parties for their independent marketing purposes without obtaining your prior explicit opt-in consent.
6.5.2 Where we collaborate with trusted third-party partners to deliver joint marketing initiatives, we will ensure full compliance with POPIA and will only share limited, necessary information as permitted by law and subject to your consent.
6.6 Change of Purpose
6.6.1 If, in the future, we intend to process your Personal Information for a purpose different from that for which it was originally collected, we will notify you in advance and explain the legal basis for such use.
6.6.2 In limited circumstances, we may process your Personal Information without prior consent where required or authorised by law, in accordance with Section 18 of POPIA.
6.6.3 We will only use your Personal Information for purposes that are compatible with the original reason for its collection, unless we have a lawful justification to use it for another related purpose.
6.6.4 If you would like clarification on how your data is being used or whether a particular purpose is compatible, please contact our Information Officer.
7.1 In the course of conducting our business and providing services, Spring Loans may need to share your Personal Information with specific categories of recipients for the purposes outlined in this Privacy Policy. These disclosures are always subject to strict confidentiality and lawful processing requirements.
7.2 Internal Affiliates
7.2.1 This includes members, employees, and authorised representatives within the Spring Loans organisation who require access to your Personal Information in order to perform their official duties, manage internal operations, or deliver services to you.
7.3 External Partners
7.3.1 We may share limited Personal Information with approved third-party service providers who assist us in various operational, administrative, and compliance-related activities — such as data hosting, payment processing, auditing, IT support, marketing (where consented), or credit verification. These partners act strictly under our instruction and are contractually bound to maintain the confidentiality and integrity of your data.
7.4 Corporate Transactions
7.4.1 In the event that Spring Loans undergoes a merger, acquisition, restructuring, or sale of business assets, your Personal Information may be transferred to the relevant third party as part of the transaction. In such cases, we ensure that the handling of your data remains consistent with this Privacy Policy and applicable data-protection laws.
7.5 All external recipients of Personal Information are required to comply fully with POPIA and maintain appropriate technical and organisational safeguards. They are expressly prohibited from using your Personal Information for any purpose other than those expressly authorised by Spring Loans.
7.6 Spring Loans shares limited and necessary Personal Information with authorised and regulated credit bureaux such as Experian South Africa, strictly in accordance with SECTION 70 OF THE NATIONAL CREDIT ACT AND RELATED REGULATIONS.
8.1 Our Platform uses essential and analytical cookies to ensure functionality, security, and performance. Non-essential cookies will only be used with your consent.
8.2 The data collected through cookies is generally aggregated and does not, by itself, personally identify you. If you prefer not to allow cookies, you may adjust your browser settings to block or delete them. However, disabling cookies may affect certain features or functionality of the Platform.
8.3 By continuing to use the Spring Loans Platform without disabling cookies, you consent to the use of cookies in accordance with this Privacy Policy.
9.1 Your Personal Information may, from time to time, be transferred or stored outside the Republic of South Africa. This may occur where Spring Loans utilises international cloud-based systems, secure hosting environments, or collaborates with foreign service providers to support operational efficiency and data security.
9.2 To ensure your Personal Information remains adequately protected during such transfers, we implement the following safeguards:
9.2.1 We transfer Personal Information only to countries or territories that offer data-protection standards equivalent to or exceeding those required under South African law.
9.2.2 Where necessary, we enter into binding contractual clauses or data-transfer agreements that impose strict confidentiality, integrity, and security obligations consistent with POPIA.
9.2.3 f you would like further information about how and where your Personal Information may be transferred internationally, or to obtain a copy of relevant safeguards, please contact our Information Officer at the address provided in this Privacy Policy.
10.1 Spring Loans applies industry-standard encryption, network isolation, and secure storage protocols to protect your Personal Information. We maintain comprehensive technical and organisational measures to prevent unauthorised access, accidental loss, misuse, alteration, or unlawful disclosure of your Personal Information. Our security measures include, but are not limited to:
10.1.1 restricting access to your Personal Information exclusively to authorised employees, agents, and contractors who require such access to perform legitimate business functions;
10.1.2 ensuring that all individuals or entities processing Personal Information on our behalf are contractually bound by confidentiality and data-protection obligations consistent with POPIA; and
10.1.3 maintaining and periodically testing internal procedures to identify, respond to, and mitigate information-security incidents or data breaches. Where required by law, we will promptly notify both the affected individuals and the Information Regulator of South Africa of any confirmed breach.
10.2 We will, accordingly:
10.2.1 reat your Personal Information as strictly confidential, save where we are entitled to share it as set out in this Privacy Policy;
10.2.2 take all reasonable measures to identify reasonably foreseeable risks to Personal Information in our possession or under our control;
10.2.3 take all reasonably appropriate technical, security and organisational measures to ensure that your Personal Information is kept secure and is protected against unauthorised or unlawful processing, accidental loss, destruction or damage, alteration, disclosure or access;
10.2.4 ensure that the measures taken to secure your Personal Information are effectively implemented and are subject to periodic review to ensure that they are functioning correctly and efficiently;
10.2.5 update security measures in response to new risks or to remedy previously deficient safeguards;
10.2.6 provide you with reasonable access to your Personal Information to view and/or update personal details;
10.2.7 promptly notify you if we become aware of any unauthorised use, disclosure or processing of your Personal Information;
10.2.8 provide you with reasonable evidence of our compliance with our obligations under this Privacy Policy on reasonable notice and request; and
10.2.9 upon your request, promptly correct, transfer, return or destroy any and all of your Personal Information in our possession or control, save for that which we are legally obliged or entitled to retain (acknowledging that some Platform and / or Service functionality might be lost if certain Personal Information is amended or destroyed).
10.3 t is the responsibility of our Information Officer to implement and oversee the security measures put in place by Spring Loans to protect against –
10.3.1 unauthorised access to Personal Information, necessitating the need for restricted access or access privileges within the Practice;
10.3.2 the loss and/ or damage of Personal Information through any means whatsoever;
10.3.3 the unauthorised archiving and destruction of Personal Information.
10.4 Whilst we will do all things reasonably necessary to protect your rights of privacy, we cannot guarantee or accept any liability whatsoever for unauthorised or unlawful disclosures of your Personal Information, whilst in our possession, made by third parties who are not subject to our control, unless such disclosure is as a result of our gross negligence or fraud.
10.5 If you disclose your Personal Information to a third party, such as an entity which operates a website linked to the Platform or anyone other than Spring Loans, Spring Loans shall not be liable for any loss or damage, howsoever arising, suffered by you as a result of the disclosure of such information to the third party, including another user. This is because we do not regulate or control how that third party uses your Personal Information. You should always ensure that you read the privacy policy of any third party.
10.6 We are committed to implementing the necessary measures to keep your data secure, where we have implemented current industry-setting standards to keep your data secure.
11.1 We will not retain your Personal Information longer than the period for which it was originally needed, unless we are required by law to do so, or you consent to us retaining such information for a longer period. In some circumstances, other Applicable Legislation require us to retain your data beyond your request for its deletion, or beyond your direct engagement with Spring Loans. As such, we may retain your Personal Information in adherence with compulsory instructions from other Applicable Legsilation, notwithstanding your application to have it deleted or amended.
11.2 The retention periods prescribed under key statutes include, but are not limited to:
11.2.1 National Credit Act, 34 of 2005 (as amended):
11.2.1.1 Records of credit applications, agreements, and enforcement actions must be retained for a minimum of three (3) years following termination of the credit agreement, as set out in Section 170 and Regulations 55–56.11.2.2 Financial Intelligence Centre Act, 38 of 2001 (as amended):
11.2.2.1 Records of financial transactions and client identification (FICA documentation) must be retained for at least five (5) years from the date of the transaction or the termination of the business relationship, whichever occurs later.
11.2.3 Companies Act, 71 of 2008 (as amended):
11.2.3.1 Company records, including accounting, corporate, and communication logs, must be retained for a minimum of seven (7) years, in accordance with Section 24 of the Act.
11.2.4 Tax Administration Act, 28 of 2011, read with the Income Tax Act, 56 of 1962:
11.2.4.1 Tax-related records, including payroll information, invoices, and supporting financial documentation, must be retained for at least five (5) years, as required by Section 29(3)(a) of the TAA.
11.3 When determining how long to retain your Personal Information, Spring Loans considers:
11.3.1 the nature, volume, and sensitivity of the information;
11.3.2 the potential risks associated with unauthorised access, disclosure, or misuse;
11.3.3 the original purposes for which the data was collected and whether those purposes can be achieved through other means; and
11.3.4 all relevant legal, regulatory, and operational obligations under South African law.
11.4 In instances where no specific statutory retention period applies, Spring Loans will retain Personal Information only for as long as it remains necessary for legitimate business, legal, or reporting purposes. Once the retention period expires, such Personal Information will be securely deleted or irreversibly de-identified in accordance with Section 14 of POPIA.
11.5 De-identified data that cannot be linked back to any individual may be retained indefinitely and used for statistical, analytical, or research purposes, without further notice to you.
12 YOUR RIGHTS AND OBLIGATIONS
12.1 You are entitled to request access to any relevant Personal Information held by Spring Loans and where such access is necessary for you to exercise and / or protect any of the user’s rights. For any Personal Information held by any third-party Responsible Party, the user must approach that Responsible Party for the realisation of the user’s Personal Information rights with them, and not with Spring Loans.
12.2 Under POPIA, you have rights in relation to your Personal Information. Please contact us to find out more about, or manifest, these rights:
12.2.1 have your data Processed in a fair, lawful and transparent way;
12.2.2 be informed about how your Personal Information is being used, an example being this Privacy Policy;
12.2.3 access Personal Information we hold about you;
12.2.4 require us to correct any mistakes in your Personal Information;
12.2.5 require us to delete Personal Information concerning you in certain situations where there is no good reason for us to continue to Process it;
12.2.6 request that we transfer your Personal Information to you or another service provider in a simple, structured format;
12.2.7 object at any time to Processing of your Personal Information for direct marketing purposes;
12.2.8 object to automated decision making which produces legal effects concerning you or similarly significantly affects you;
12.2.9 object in certain other situations to our continued Processing of your Personal Information; and/or
12.2.10 otherwise restrict or temporarily stop our Processing of your Personal Information in certain circumstances.
12.3 You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
12.4 We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
12.5 We try to respond to all legitimate requests within one week. Occasionally it may take us longer than a week if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
12.6 Users with citizenships from jurisdictions other than of South Africa, please note that Spring Loans complies with all South African data protection laws when processing your Personal Information pursuant to the Services as we are a South African entity operating in the South African market. Should foreign law be applicable in any regard to your use of our services and / or the Platform in any way, including how we may process your personal information, please contact the Information Officer who will gladly engage you on its application and your rights.
12.7 Users acknowledge that any content provided by users on the Platform, including via a messaging system, enters an open, public forum, and is not confidential, where the author of which will be liable for that content, and not Spring Loans.
12.8 Users understand that there are risks involved in sharing Personal Information. By disclosing Personal Information such as the user’s name and email address, users acknowledge and understand that this information may be collected and used by an authorised third party to communicate with you.
12.9 By accepting this Privacy Policy, you have opted-in to receive emails from us, where your email address will be used to contact you from time to time and may also use it for security reasons to confirm your identity.
12.10 You have the right to opt-out of receiving email communication by following the directions posted on every email communication or by emailing the Information Officer and asking to not be contacted from then on.
12.11 If you wish to cancel (delete) your user account, you may do so by visiting the following page:🔗 https://springloans.co.za/account-cancellation/
12.12 If you are not a South African citizen or resident, please note that Spring Loans processes Personal Information in accordance with South African data-protection laws.
12.13 If any foreign privacy legislation applies to your use of our Platform or to the processing of your Personal Information, please contact us to discuss how your rights may be exercised under that jurisdiction.
13.1 We will disclose the user’s personally identifiable information if we reasonably believe that we are required to do so by law, regulation or other government authority or to protect the rights and property of Spring Loans, its affiliates or the public. Spring Loans may also co-operate with law enforcement in any official investigation and may disclose the user’s personally identifiable information to the relevant agency or authority in doing so.
13.2 Circumstances may arise where, whether for strategic or other business reasons, Spring Loans decides to sell, buy, merge or otherwise reorganise its business. Such a transaction may involve the disclosure of Personal Information to prospective or actual purchasers, or the receipt of it from sellers. It is Spring Loans’ practice to seek reasonable protection for information in these types of transactions and notify you prior to any disclosure of Personal Information. Such disclosure will also be subject to this Privacy Policy.
13.3 Spring Loans strives to keep the user’s Personal Information accurately recorded. Spring Loans provides a user with the reasonable ability to review and correct it or ask for anonymisation, blockage, transfer or deletion, as applicable. Please contact the Information Officer to engage us on such actions or requests.
13.4 We also collect, use and share aggregated data or de-identified data such as statistical or demographic data for any purpose. Such de-identified or aggregated data may be derived from your Personal Information but is not considered Personal Information in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific feature. However, if we combine or connect aggregated data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Privacy Policy.
14.1 We are continually improving our ways of work and our existing services and . We regularly review and, if appropriate, update our Privacy Policy from time to time, and as our services and use of personal data evolves. Because of these ongoing changes, changes in the law and the changing nature of technology, our data protection practices may also change from time to time. If and when our data protection practices change, we will update this Privacy Policy to describe our new practices.
14.2 If we want to make use of your Personal Information in a way that we have not previously identified, we will contact you to provide information about this and, if necessary, to ask for your consent.
14.3 If we do, we will notify you next time you visit our Website. We encourage you to check this Privacy Policy regularly.
14.4 We will update the version number and date of this document each time it is changed.
15.1 In the successful implementation of this Privacy Policy, the Information Officer must maintain a report regarding all steps taken in instances of non-compliance, as prescribed by both POPI and PAIA, which includes but is not limited to –
15.1.1 the general responsibility of the consent provided by Data Subjects;
15.1.2 reporting instances of loss, breach and/or unauthorized access of Personal Information to relevant authorities, and remedial action taken;
15.1.3 the destruction of personal information;15.1.4 the de-identification of personal information;
15.1.5 the implementation of specific security measures;
15.1.6 disciplinary action against employees violating this Privacy Policy;15.1.7 obtaining expert assistance, where required;
16 COMPLAINTS, OBJECTIONS, WITHDRAWALS, AMENDMENTS AND DELETIONS
16.1 Complaints
16.1.1 In any instance of actual or alleged violation of this Privacy Policy, any person may lodge a complaint with the Information Officer, or a designated Deputy. The complaint will be processed in line with the principles of natural justice, and apply this Privacy Policy, as well as the Applicable Legislation and related policies of Spring Loans, when doing so.
16.1.2 The Information Office may constitute a Committee to investigate the matter, and to make findings on the complaint, and recommend action by the relevant departments, units or structures of the Scheme.
16.2 Objections, Withdrawals, Amendments and Deletions
16.2.1 Any person can object to the processing of Personal Information held by Spring Loans, withdraw a consent to such processing, or request amendments and/or deletion of their Personal Information.
16.2.2 The forms to object, consent to marketing, change or request destruction of personal information must be on the forms attached to the Privacy Policy, as prescribed by the Regulations to the POPI Act published under GG number 42110 dated 14 December 2018, which forms shall be made available at www.springloans.co.za.
17.1 This Privacy Policy shall be reviewed every two years or more frequently as may be required and may be amended from time to time as may be required by law, for corrections of material errors, as the case may be.
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