Splendi Privacy Policy

Splendi is a product of XPERT DECISION SYSTEMS (PTY) LTD (“XDS”). XDS is a registered credit bureau who values the protection of consumer privacy. Please read this Privacy and Cookie Policy carefully before using our website or registering to use our services in order to understand our views and practices regarding your personal data and how we will treat it. This Privacy Policy sets out the basis on which any personal data will be processed by us.

References in this Privacy Policy and on our website to “we”, “our” or “us” are references to Splendi and or XDS. References to “you” and “your” means each natural or legal person who uses our website or the associated services.

This Privacy Policy is incorporated into and is subject to Splendi’s Terms and Conditions as reflected on www.splendi.co.za.

By visiting our website, you are accepting and consenting to the practices described in this Privacy Policy. For the purpose of this Privacy Policy “applicable data protection law” means any laws in your jurisdiction in relation to data protection and privacy.

We specifically comply with the National Credit Act, 2005 (No.34 of 2005) (“NCA”) ,the Protection of Personal Information Act, 2013 (No. 4 of 2013) (“POPIA”) and the principles outlined in Sections 50 and 51 of the Electronic Communications and Transactions Act, 2002 (No.25 of 2002) which govern your right to having your personal information kept private.

For the purpose of this Privacy Policy, “Consumer Credit Information” means consumer credit information as defined in Section 70 of the NCA; and “Personal Information” means personal information as defined in Section 1 of the POPIA. You will be asked to provide your Personal Information when registering, accessing or using any Services (as defined under the Terms and Conditions). In this regard, we may collect a variety of information, including your:

  • Full name;
  • Contact numbers;
  • Email address;
  • SA ID number and/or Date of Birth;
  • Non-RSA ID number and/or Date of Birth;
  • Address details;
  • Marital status;
  • Family relationships; and or
  • Answers to security questions relating to your Consumer Credit Information on your Splendi Account.

Internet Information

The information we collect for our digital marketing business is segregated from Consumer Credit Information. Marketing data may include information on consumers, households, and businesses as well as non-personal aggregated information and advertising program performance data. Marketing data may include information about you, such as demographics, life events, public records, or firmographics.

Use and Disclosure of Personal Information

Splendi uses and discloses personal information to include only what is permitted and prescribed in terms of the NCA, POPIA or any other applicable laws or in instances where consumers have consented to such collection, use and disclosure.

Confidentiality of your Personal Information is important to us. Unless we have your consent or permitted use under the national laws, we disclose your Personal Information to others. We will not use or share your Personal Information in ways unrelated to the circumstances described in this Privacy Policy.

Specifically, we use and disclose information in the following circumstances:

(a) Information you give to us (or we collect from credit bureaux) or other third parties on your behalf as part of our services which we will use to:

  • administer your account and relationship with us and, to communicate with you by telephone, mail, email, text (SMS) message, instant messaging or other electronic means;
  • verify your identity as part of our identity authentication process (we will use the credit card or bank account information only for the purposes of verifying your identity (and to prevent, detect and prosecute fraud and crime and comply with legal or regulatory requirements) and will not retain it);
  • provide you with the information, products and services that you request from us;
  • provide you with information about other products and services we offer that are similar to those that you have already purchased;
  • provide you with information about products or services we feel may interest you or be best for you, where you have consented to receive such information;
  • your data may be shared with product providers to validate if you are an existing customer (which may affect whether you can be accepted for one of their products) or for fraud prevention purposes. The product provider does not have permission to use these data for any other purpose including marketing.
  • notify you about changes to our services;
  • ensure that content from our website is presented in the most effective manner for you and your device;
  • aggregate it on an anonymous basis with other data for data analytical and reporting purposes; and
  • undertake analysis and profiling of your credit information (and any other data provided by you or on your behalf or which we collect on your behalf) in order to identify and inform you of credit products (including personal loans and credit cards) that we consider are likely to interest you or be suited to your credit circumstances, where you have consented to receive such information.

(b) Information we collect about you which we will use to:

  • administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • build up a picture of your interests so that you don’t miss information relevant to you when you visit our website;
  • improve the service we offer you and to try and ensure that you get the best from our website, ensuring that content is presented in the most effective manner for you and for the devices you use to access it;
  • allow you to participate in interactive features of our service, when you choose to do so;
  • keep our website safe and secure;
  • measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
  • make suggestions and recommendations to you and other users of our website about products or services that may interest you or them, subject to having received your consent where necessary.

(c) Information we receive from other sources that we may combine such information with information you give to us and which we may use for the purposes set out above.

(d) monitor or record telephone conversations or other communications between you and us which we will use to check your instructions to us, analyse, assess and improve our services to you, for training and quality purposes and for the purposes of investigating any complaint you may make, or as evidence in any dispute or anticipated disputes between you and us.

Consumer Information included in your credit report

Our credit report may include the following information:

  • identifying information, such as first name, surname, ID number, physical and postal address, contact numbers, marital status, spouse details, and current employer and occupation;
  • account history or payment profile information a 24 month record of all your accounts with credit or service providers and a history of how you pay these accounts on a monthly basis;
  • enquiries which includes a list of credit or service providers authorized by yourself or permitted in terms of the NCA to receive your credit report;
  • public records such as judgments, administration orders, sequestrations, and rehabilitation;
  • default data as recorded on your credit profile when you fail to make the payment of money owed and which default data is submitted by the credit or service providers to us; and
  • any other information that is permitted to be included under the NCA.

Our consumer business

With your consent, we may use your Personal Information to promote and market additional products and services. If you provide your consent, we may share your Personal Information, e.g. name and email address, with one or more third parties in order to administer the programme and present such information to you. If you do not register your ID Number or Passport Number, we will not collect any Personal Information on you while you visit the Site. In connection with the email registration program, our third party email processor may use action tags (also known as single pixel gif or web beacons) to collect completely anonymous information concerning your use of the Site. Such a third party administrator is not authorized to use any such information for any other purpose. If you decide to register for emails, you may opt-out from receiving such communications, at any time as specified above.

In the majority of instances, Splendi is not capable of being provided with direct consent by consumers. Such consent is directly provided by consumers to Splendi’s data suppliers. Splendi however takes all reasonable measures to ensure that all data suppliers are contractually bound to ensure that all legally required consents are obtained prior to accessing any Consumer Credit Information contained in our credit reports.

Digital marketing business

Through Splendi’s digital marketing services, we enable our business partners to communicate with consumers in a digital environment. In an effort to provide relevant products and services to consumers, these businesses use our data and technology to create, deploy, and measure targeted advertising programs digitally. We collect information as outlined below and use it for permitted marketing uses. In addition, we may aggregate and depersonalize data for analytical purposes, to provide reporting to our business partners, and for measuring advertising performance. As a part of enabling digital marketing services, we may use service providers.

Compliance with laws and regulations

We may only access, use and/or disclose your Personal Information without your consent in exceptional circumstances. These include circumstances where we believe such action is necessary to:

  • comply with the law or legal process served on us;
  • comply with requests for information from police or government authorities;
  • protect and defend our rights or property (including the enforcement of our agreements);
  • protect the public interest;
  • act in urgent circumstances to protect the personal safety of our employees or members of the public;
  • where applicable, with your implied consent; and
  • to the extent permitted or required in terms of the NCA, POPIA and other relevant national legislation.

Market research

Your participation in market research activities is optional. Should you choose to participate, we may use information you provide to improve your experience with our products and services. We may engage third parties to assist us with our market research efforts who may retain non-personal aggregated information. However, all Personal Information you provide will only be used for our research purposes.

Retention of your information

We retain your Personal Information for as long as reasonably necessary to fulfil the purpose(s) for which it was collected and to comply with applicable laws and your consent to such purpose(s) remains valid after termination of our relationship with you.
Furthermore, we retain your Consumer Credit Information in our credit information database in accordance with the data retention periods prescribed by the NCA.

Transfer of Personal Information Outside

Unless permitted under the law or your consent is obtained, Splendi will not transfer your Personal Information outside the Republic of South Africa.

Your rights and participation

Splendi aims to ensure that your Personal Information is accurately recorded. To be able to achieve this, we adhere to processes that help ensure and maintain data accuracy. We provide individuals with reasonable access to review and correct their Personal Information, as detailed in our Site.

When gathering your Consumer Credit Information Splendi works with our data suppliers to increase their awareness of the importance of providing only Consumer Credit Information that is accurate, complete, and up to date. Splendi however, cannot alter the information reported by such data suppliers, unless the information is determined to be wrong, incomplete or inaccurate. If you do not agree with the accuracy of information Splendi has on file, we have procedures in place to ensure that such information is verified, and where appropriate, amended or corrected. We however rely on you to bring any such information challenges to our attention.

Unless otherwise provided in any laws, you have the right to access, update, correct or object to processing your Personal Information. You may do this by emailing informationofficer@xds.co.za

When you contact us please let us know your name, address, any email address you have provided on the Site and a description of the circumstances under which you provided the data. We will make reasonable efforts to incorporate as soon as practicable the changes in Personal Information that we maintain.

Security of your information

Splendi takes security and the protection of Personal Information and Consumer Credit Information seriously. We maintain physical, technical and organizational safeguards to protect any data that we collect. We have adopted procedures to secure storage of Personal Information and are committed to working with our data suppliers to protect the security of Personal Information during any transfer to or from us. Moreover, we have also instituted a number of safeguards to identify and help prevent the fraudulent use of Consumer Credit information Furthermore, your Personal Information is only accessible to those Splendi employees, agents or contractors for business purposes and on a strictly need to know basis. For security purposes all of the Personal Information that we collect or obtain about you, including your credit report, is housed in secure environments that have controls in place to limit access to and secure the data maintained therein.

The Site, takes precautions to secure your Personal Information. If and when we ask you to provide your Personal Information, we will do so through a site that uses relevant industry standard authentication and authorization protocols as well as TLS (Transport Layer Security). TLS provides security for your information by encrypting it as it travels from your computer to our environments.

To protect your privacy and security, we will also take reasonable steps to verify your identity before granting access to or making alterations to data we maintain.

Children's privacy

We define children as individuals under the age of 18. The Site is not intended for the use of children and we do not intend to collect information about children through the Site. Splendi does not knowingly collect information from children under the age of 18 and our sites do not target children under 18. We encourage parents and guardians to take an active role in their children’s online activities and interests.

You must be at least 18 to access or use any products or services through the Site or become a subscriber of any subscription program entitled to subscription benefits. Specific to our direct marketing service, we define children as individuals age 18 or younger.

Children's privacy

We define children as individuals under the age of 18. The Site is not intended for the use of children and we do not intend to collect information about children through the Site. Splendi does not knowingly collect information from children under the age of 18 and our sites do not target children under 18. We encourage parents and guardians to take an active role in their children’s online activities and interests.

You must be at least 18 to access or use any products or services through the Site or become a subscriber of any subscription program entitled to subscription benefits. Specific to our direct marketing service, we define children as individuals age 18 or younger.

Third part sites

The Site may offer links to third party web sites including payment gateways for credit card payment. You should be aware that operators of linked web sites may also collect your Personal Information (including information generated through the use of cookies) when you link to their web sites.

Splendi is not responsible for how such parties collect, use or disclose your information and it is important for you to familiarize yourself with their privacy policies before providing them with your Personal Information.

Enforcement of this Privacy Policy

Our compliance with this Privacy Policy will be monitored on a regular basis. Splendi reserves the right to modify this Privacy Policy. The Privacy Policy posted at any time via the Site shall be deemed to be the Privacy Policy then in effect.

Data Subject Rights

You have the right to access your personal information, dispute incorrect information, and request for your profile to be deleted. For more information please visit XDS website.