1) Privacy Statement
Our Privacy Notice governs the way the FirstRand Group (‘us’; ‘we’ or ‘our’), treat your personal information collected electronically when you use our website, apply online for certain products and services, contact us electronically or register for one of the services offered on the website. We respect your privacy and treat your personal information as confidential. Our Privacy Notice explains how we use, collect, share and store your personal information. You may access our full Privacy Notice here.
The FirstRand Group is a group of entities, some of which operate in other countries. MotoVantage is a subsidiary of FirstRand Bank Limited. A simplified group structure highlighting some of the group’s major subsidiaries and businesses is shown in our Privacy Notice. The FirstRand Group follows a multi-branding approach and some of the major brands in the Group are shown below.
2) We respect your privacy and personal information
We respect your privacy and your personal information and for this reason, we take all reasonable measures, in accordance with our Privacy Notice, to protect your personal information and to keep it confidential, even when you are no longer our customer.
We also voluntarily subscribe to the principles, outlined in Section 51 of the Electronic Communications and Transactions Act 2002 ('ECT Act'), which govern your right to having your personal information kept private.
We briefly outline these principles below:
- We will only collect, disclose, collate, process and store your personal information with your express written permission unless legally required to do so, and will only use such information for the lawful purpose for which it is required.
- We will disclose in writing, the specific purpose for which we collect, disclose, collate, process and store your personal information. We will also keep a record of that personal information and the specific purpose for which we collect it.
- We will not collect, disclose, collate, process or store your personal information for any other purpose, other than that which we disclosed to you, unless you give us your express written permission to do so, or unless we are permitted to do so by law.
3) Some general rules we apply to keep your trust
- Different interactions with us will need different levels of personal information disclosure. If you are unsure or uncomfortable with the reason why personal information is needed, feel free to obtain clarity before disclosing that personal information.
- Our Privacy Notice will indicate the purposes for which your personal information is collected, used and shared.
- We will always process your personal information legally and in a manner either allowed or required by law. If needed, we will ask for your consent.
4) Who does our Privacy Notice apply to
Our Privacy Notice is applicable to individuals and entities and applies to the processing of personal information or special personal information.
What do these words mean in terms of our law?
- Personal information is information that can be used to identify you, like your name, surname and identity number.
- Special personal information is sensitive personal information that can be used to identify you and receives some extra protection in law, for example your health or race.
- A juristic person is a company or an entity that has a separate legal personality from you.
5) When will we process your personal information
We will only process your personal information if it relates to our business activity AND
- You or your guardian/parent consented; or
- The law permits/requires; or
- To protect your legitimate interests, ours or another person’s.
6) When will we process your special personal information
The grounds are the same as those for processing of personal information and could also include:
- For statistical or research purposes
- When it is needed to identify you
- To determine insurance risk
- To create, use or protect a right in law
7) When and where do we obtain personal and special personal information
- Your use of our solution-like products and services or channels (app and website)
- Your interactions or engagements with us (telephone, letters, e-mail and social media)
- Information you have shared on public platforms
- Third parties (partners, rewards programme partners, marketing list providers and dealers)
- Other members of the FirstRand Group, its associates, affiliates, appointed partners and agents
8) Third parties from whom we can obtain your personal and special information OR whose personal and special personal information we can obtain from you
- Your spouse (where the solution, like a product, is jointly used), employer or dependants
- People whom you permit to have your personal and special personal information for example, dealers
- Attorneys, debt collectors, tracing agents and other people who assist in enforcing agreements
- Persons who enable payments
- Insurance brokers and other financial institutions
- Courts or Tribunals
9) Reasons we need to process your personal and special personal information
In order to:
- Provide you with products, goods and/or services
- Market products, goods and/or services to you
- Respond to your queries or complaints
- Comply with regulatory and risk requirements
10) How we use your personal and special personal information for Marketing
To inform you about beneficial products and services. You may request that we stop marketing to you at any time.
11) When will we use your personal and special personal information to make automated decisions about you
We may make automated decisions where the law allows. This means that we use personal and special personal information to reach an answer without human involvement. This decision may affect you and you may query it. For example, approving or declining of a credit application.
12) When, how and with whom we share your personal and special personal information
12.1) Generally we will only share your personal and special personal information if
- You consented
- The law allows
- To fulfil our contract with you
- It is needed to protect your rights or interests, ours or another person’s
12.2) Who we share your personal and special personal information with
If we share your personal and special personal information, the receiver of the personal or special personal information has a duty to keep it confidential and secure. We will share your personal and special personal information with:
- Other members of the FirstRand Group, its associates, affiliates, appointed third parties such as sub-contractors, suppliers, service providers and agents
- Payment processing card information and service providers, merchants, banks and other providers
- Regulatory bodies, for example the National Credit Regulator
13) When and how we obtain and share personal and special personal information with Credit Bureaux
We may access your credit bureau information where permissible in law including, for example, considering your credit application or verifying your details.
14) When will we transfer your personal and special personal information to another country
- If the law allows
- To fulfil or create a contract
- You give us an instruction that requires the transfer of your personal and special personal information
- You have consented to the transfer of your personal and special personal information
- If it is unreasonable or not practical to obtain your consent, but the transfer is in your interests.
We will always use safe personal information or special personal information transfer and storage practices.
15) Your duties, rights and security
You have a duty to:
- Inform us when your personal and special personal information changes
- Safeguard your personal and special personal information
You have the right to:
- Access records of your personal and special personal information held by us
- Request correction of your personal and special personal information
- Withdraw consent
- Object to the use of your personal and special personal information
- Have your personal and special personal information deleted in certain circumstances
- File a complaint with the Information Regulator
- Personal and special personal information must be secure and protected by us
If you need more information on fulfilling your rights of access to your information you can access our Promotion of Access to Information Act manual here.
16) How long do we keep your personal and special personal information
- For the duration of your contract(s) with us
- As required by law
- As required by a valid business
17) How we process personal and special personal information about persons related to a juristic person
We do not only process the personal and special person information of a juristic person but also the personal and special personal information of person(s) related to that juristic person. Our Privacy Notice and the processing practises will also apply to these person(s).
18) Our Cookie Notice
By using our website or applications you agree that cookies may be forwarded from the relevant website or application to your computer or device. You can access the full Cookie notice here
The Promotion of Access to Information Act, No 2 of 2000 and the Promotion of Information Amendment
Act 54 of 2002 (“PAIA”) give effect to the constitutional right of access to any information in records held by
public or private bodies that is required for the exercise or protection of any rights. PAIA provides an outline of
the types of records and the personal information held by MotoVantage and sets out the procedure to request
access to personal information, the requirements which such request must meet as well as the grounds for
refusal or partial refusal of such request. In addition, it explains how to access, or object to, personal information
held by the MotoVantage, or request correction of the personal information, in terms of Section 23 and 24 of the
Protection of Personal Information Act 4 of 2013 (“POPIA”).
PAIA gives effect to the constitutional right of access to personal information held by private sector or public
bodies, if the record or personal information is required for the exercise or protection of any rights.
PAIA and POPIA recognise that the right to access to information cannot be unlimited and should be subject to
justifiable limitations, including, but not limited to:
- limitations aimed at the reasonable protection of privacy;
- commercial confidentiality; and
- effective, efficient and good governance;
and in a manner which balances that right with any other rights, including such rights contained in the Bill of
Rights in the Constitution and the Protection of Personal Information Act 4 of 2013 (“POPIA”).