PRIVACY POLICY

1.         INTRODUCTION

Royal Finance Group is a group of entities which are all  registered credit providers, whose primary business is providing micro finance to the general public.  For more information on the different entities, please  refer to the “Legal Entity Information” section which can be found on the 4th tab above.

 

Royal Finance Group is committed to sound business practices in compliance with all the relevant legislation, which for purposes of this Privacy Policy, includes the Protection of Personal Information Act 4 of 2013 (“POPIA”) read with the Consumer Protection Act 68 of 2008, The National Credit Act 34 of 2005 and the Constitution of the Republic of South Africa.

 

2.         PURPOSE, SCOPE & OBJECTIVES

2.1      The policy sets out the manner in which personal information of consumers, utilizing Royal Finance Group’s Website for purposes of applying for credit, is collected, managed, stored, used and protected by Royal Finance Group. 

 

2.2      The objectives are to:

2.2.1        process personal information responsibly and lawfully in terms of the provisions of POPIA;

2.2.2        provide a guideline as to the manner in which Royal Finance Group processes and protects personal information;

2.2.3        adopt good practices in terms of processing of personal information;

2.2.4        display the commitment of Royal Finance Group to uphold and respect information privacy.  

 

3.         DEFINITIONS

“consent” means any voluntary, specific and informed expression of will in terms of which permission is given for the processing of personal information.

“data subject” means the person to whom the personal information relates.

 

“personal information” means information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person, including, but not limited to-

• information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth of a person;

• information relating to the education or the medical, financial, criminal or employment history of the person

• any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier or other particular assignment to the person;

• the biometric information of the person;

• the personal opinions, views or preferences of the person;

• 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;

• the views or opinions of another individual about the person; and

• the name of the person if it appears with other personal information relating to the person or if the disclosure of the name itself would reveal information about the person.

 

“processing” means any operation or activity or any set of operations, whether or not by automatic means, concerning personal information, including-

• the collection, receipt, recording, organization, collation, storage, updating or modification, retrieval, alteration, consultation or use

• dissemination by means of transmission, distribution or making available in any other form; or

• merging, linking, as well as restriction, degradation, erasure or destruction of information.

 

“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.

 

4.         TYPE OF INFORMATION PROCESSED

Royal Finance Group may collect and process the following types of information during the credit application process and granting of credit:

• Biometric Fingerprint Information

• Bank statements

• Payslips

• Name and surname

• Household Expenses

• Identity number (including date of birth)

• Nationality

• Gender

• Marital status

• Home owner status

• Race

• Contact details, including email address, telephone numbers, physical address

• Name, surname, contact details and relationship of client’s next of kin

• Credit report

• Employment information

• Client payment reports

• Bank Account Details, including status and last deposit date

• Number of Dependents

 

5.         LAWFUL PROCESSING OF PERSONAL INFORMATION

The conditions for the lawful processing of personal information by any responsible party i.e. Royal Finance Group, as prescribed by the provisions of POPIA, are set out herein below.  Royal Finance Group undertakes to comply with these conditions when processing personal information:

 

5.1      Accountability

Royal Finance Group will ensure that the conditions set out hereunder are given effect to and complied with at the time of processing of personal information.  Royal Finance Group will remain accountable and takes responsibility for personal information in its possession and processed by it. 

 

5.2      Processing limitation

5.2.1        Royal Finance Group undertakes to process personal information:

• • lawfully; and

• • in a reasonable manner that does not infringe the privacy of the data subject.

 

5.2.2        Personal information will only be processed if, given the purpose for which it is processed, it is in a manner that is adequate, relevant and not excessive.

 

5.2.3        Personal information will only be processed if

• the data subject or a competent person, where the data subject is a child, consents thereto.  The responsible party bears the burden of proof for the data subject’s or competent person’s consent.  The consent may be withdrawn at any time, provided that the lawfulness of processing personal information prior such withdrawal will not be affected

• processing is necessary to carry out actions for the conclusion or performance of a contract to which the data subject is a party;

• processing protects a legitimate interest of the data subject;

• processing is necessary for the proper performance of a public law duty by a public body; or

• processing is necessary for pursuing the legitimate interests of the responsible party of a third party to whom the information is supplied.

 

5.2.4        Personal information will be collected directly from the data subject, unless:

• the information is contained in or derived from a public record or has deliberately been made public by the data subject;

• the data subject is a competent person, where the data subject is a child, has consented to the collection of the information from another source;

• collection of the information from another source would not prejudice a legitimate interest of the data subject;

• collection of the information from another source is necessary;

• to avoid prejudice to the maintenance of the law by any public body;

• to comply with an obligation imposed by law or to enforce legislation;

• for the conduct of proceedings, in any court or tribunal, that have commenced or are reasonably contemplated;

• in the interest of national security; or

• to maintain the legitimate interests of the responsible party or of a third party to whom the information is supplied;

• compliance would prejudice a lawful purpose of the collection; or

• compliance is not reasonably practicable in the circumstances of the particular case.

 

 

5.3      Purpose specification

5.3.1        Royal Finance Group will collect the personal information for the following and related purposes:

• Application for credit

• Conducting an Affordability Assessment

• Obtaining a credit bureau report

• Fraud check

• Pre-agreement statement & quotation & credit agreements

• Debt collection

• Marketing if consent was obtained

• Compliance with legislation

 

5.3.2        Once personal information, processed and stored by Royal Finance Group, has reached its expiry date or becomes in any way redundant, Royal Finance Group will destroy or delete the record of personal information in a manner that prevents its reconstruction in an intelligible form.

 

5.3.3        Royal Finance Group will restrict the processing of personal information if:

• the accuracy is contested by the data subject, for a period to enable the verifying of the personal information;

• the personal information is no longer needed for the purpose for which it was collected and processed, but maintained for purposes of proof;

• the processing is unlawful and the data subject opposes its destruction, but requests the restriction of its use instead; o

• data subject requests the transmission of personal data into another automated processing system.

 

5.4      Further processing limitation

Any further processing of personal information carried out by Royal Finance Group will be done in accordance or compatible with the purpose for which it was initially collected.

 

5.5      Information quality

Royal Finance Group will take reasonably practicable steps to ensure that the personal information is complete, accurate, not misleading and updated where necessary.

 

5.6      Openness

5.6.1        Royal Finance Group will maintain the documentation of all processing operations under its responsibility.

 

5.6.2        When personal information is collected, Royal Finance Group will take reasonably practicable steps to make the data subject aware of:

• the information being collected or the source from which the information is collected;

• the name and address of the responsible party;

• the purpose for which the information is being collected;

• whether or not the supply of the information by that data subject is voluntary or mandatory;

• the consequences of failure to provide the information;

• any particular law authorizing or requiring the collection of the information;

• the fact that, where applicable, the responsible party intends to transfer the information to a third country or international organization and the level of protection afforded of the information by that third country or international organization;

• any further relevant information.

 

 

 

5.7      Security safeguards

5.7.1        Royal Finance Group undertakes to secure the integrity and confidentiality of personal information in its possession or under its control.  This is done by taking appropriate, reasonable technical and organisation measures to prevent loss of, damage to or unauthorised destruction of personal information; and unlawful access to or processing of personal information.

 

5.7.2        The following safeguards has been put in place by Royal Finance to secure the integrity and confidentiality of personal information:

• Physical access security to the building like a locked premises with safety bars.  Premises is linked to a security company. 

• Password protection on Loan Management systems

• Password protection on all computer logins

• Anti-virus programs on all computers, which are tested and updated monthly

• Firewalls

• External hard drive for backup purposes

 

5.7.3        Where there are reasonable grounds to believe that the personal information of a data subject has been accessed or acquired by any unauthorised person, Royal Finance Group will notify, as soon as possible after the discovery of the compromise:

• the Information Regulator; and

• the data subject, unless the identity of such data subject cannot be established.

 

5.7.4        Royal Finance Group will notify the data subject in writing of the unauthorized access to or acquiring of its personal information and provide sufficient information to the data subject in order to take protective measures against the potential consequences of the compromise.

 

5.8      Data subject participation

Any queries or concerns regarding this Privacy Policy, your information held, corrections or deletion of personal information or updating personal information, please contact us on mariette@royalfinance.co.za

 

6.         COLLECTION OF INFORMATION

Royal Finance Group collects personal information in the following manners:

• Credit Applications  

• Credit bureaus

• Voluntary disclosure by data subject

•   Website

• Telephonically

• Email

 

ONLINE CREDIT POLICY

This policy governs the online credit application process for Royal Finance Group.  Royal Finance Group is a group of entities which are all  registered credit providers, whose primary business is providing micro finance to the general public of South Africa.  For more information on the different entities, please refer to the “Legal Entity Information” tab above.

After completing the application form together with your personal and bank account information, the system will send an email with all of your details to the branch where you are registered with or the branch of your choosing in the application form.

By continuing with the online credit application, you confirm that you have read and understood the Terms & Conditions of the Website Use (available on 1^st tab above)  and you consent to Royal Finance Group collecting your personal information and processing same in accordance with its Privacy Policy (available on 2^nd tab above) for purposes of granting credit.

CREDIT RECORD CONSENT

You also agree and consent to the following:

I (the applicant with information as supplied during the application process) agree to the branch of my choosing with legal entity information as on the 4^th tab above.

Receiving, compiling and retaining any confidential credit information about me for purposes of (i) assisting you to

·      perform your statutory assessment of my creditworthiness, (ii) deciding whether to grant credit to me and (iii)

·      monitoring my credit profile, should you grant me credit;

·      Filing my consumer credit information with any other credit provider and a registered credit bureau, including Compuscan Holdings (Pty) Ltd, Experian Limited, TransUnion ITC and the National Loans Register;

·      Sharing my consumer credit information with any tracing agent or collection company in the event of me defaulting in my credit repayment obligations to you

I further hereby consent to a Credit Bureau:

·      Providing you with a credit report which you may rely on (i) to assess my creditworthiness and (ii) to base your decision whether to grant credit to me;

·      Accepting the filing of my consumer credit information from any credit provider;

·      Issuing a report to any person who requires it for a lawful purpose.

My Agreement to these terms and conditions signifies my consent as aforesaid and my agreement to hold you and any credit bureau and other credit provider to whom you may provide my consumer credit information in terms of my aforesaid consent harmless against any and all liability, loss, claim, demand, cost, fees and expenses arising out of or from or in connection with my aforesaid consent.

INFORMATION NEEDED FOR APPLICATION PROCESS

In order for the branch to process your application you will be required to provide the following (either via the website application process or through telephonic contact with a loan officer during the process):

• Your South African ID number, full names, surname, personal phone numbers, HR telephone number, and your employee number at HR Department (if applicable)
• A photo of yourself
• Upload copies of your ID, salary slip, three latest bank statements and proof of residence
• Banking Details
• Your Feza card details (if you already have one)
• Employment details
• Address, marital status and number of dependants
• Details of your next of kin
• Details of loan that you are applying for (loan amount, repayment frequency, loan term)

 

IMMEDITAE DECLINE REASONS

Your credit application will be declined immediately if the following appear on your credit report:

• Under Administration
• Insolvent
• More than three judgments noted against your name
• Debt Review Application / Under Debt Counselling
• High Risk

Your credit application will be declined immediately if the following appear on your Bank Statement:

• Inactive or Closed Status
• Last Deposit Date more than a month ago

You will also be immediately declined should you be

• A Non-SA Citizen
• Self Employed
• Employment details are seen as a too big a risk in current economic environment.

 In the event that your application is immediately declined for one of these reasons, we will contact you on the telephone number used for the application to let you know that you do not qualify for the loan.

AFFORDABILITY CHECK

Should your application not be declined as above, we will take the following information into consideration to perform an Affordability Check in line with the Affordability Guidelines provided by the National Credit Regulator:

• Loan amount required, number of instalments, first next salary date and first instalment date.
• Gross salary
• Monthly Living Expenses
• Existing debt obligations – will be cross referenced with the information appearing on your credit report

Based on the information provided above, the Royal Finance branch where you have applied will perform an affordability calculation and one of three eventualities can occur:

1. You do not qualify for the loan amount requested, but you are pre-approved for a lesser amount or the loan amount requested over a longer repayment period – we will then contact you on the telephone number used for the application to ask if you will be interested in the lesser amount or longer payment period. If you accept, we will start with the steps required to conclude the loan.
2. You are pre-approved for the loan amount and repayment period requested – we will contact you on the telephone number used for the application and we will start with the steps required to conclude the loan.
3. Your credit application will be declined if it appears from the calculation that you cannot afford the loan in accordance with the Affordability Assessment Regulations and any Affordability guidelines that may be issued by the National Credit Regulator.  We will contact you on the telephone number used for the application to let you know that you do not qualify for the loan.

PROCESSING OF APPLICATION

On receipt of the documents and further information, your application will be processed by the Royal Finance Group’s branch of your choice.  The branch will process the credit application in accordance with its own internal criteria and approve and pay out the loan to you at the branch or electronically, whatever the best suited for the situation.

IMPORATANT NOTE :   Any pre-approved loan can be refused by the branch at any stage as a result of a poor affordability assessment and failure to meet the branch’s criteria.

 

LEGAL ENTITY INFORMATION
The 12 oulets of the Royal Finance Group trading as Royal Finance are:

BRANCH NAME	REGISTERED BUSINESS NAME	NCR NUMBER
BLOEMFONTEIN	TFS8 (Pty) Ltd	NCRCP971
HENNENMAN	Bashasha Financial Services CC	NCRCP1250
KIMBERLEY1	J.L Financial Services CC	NCRCP1526
KIMBERLEY2	J.L Financial Services CC	NCRCP1526
KLERKSDORP	TFS8 (Pty) Ltd	NCRCP971
KROONSTAD1	TFS8 (Pty) Ltd	NCRCP971
KROONSTAD2	TFS8 (Pty) Ltd	NCRCP971
MIDDELBURG	Step by Step Financial Service (Pty) Ltd	NCRCP5655
ORKNEY	TFS8 (Pty) Ltd	NCRCP971
WELKOM	Lourick Financial Services (Pty) Ltd	NCRCP10384

Other entities forming part of the Royal Finance Group, but not trading as Royal Finance are Gemsbok Financial Services CC (Upington, Kakamas and Kathu) and Avok Financial Services CC (Worcester and Rawsonville).  

Language Policy  

Royal Finance’s business language is English, and all customers will be provided with documentation, per standard, in the English language.

 

PRE-AGREEMENT STATEMENT AND QUOTATION

 

Royal Finance’s Pre-agreement statement and quotation will be translated and will be made available on request, as supplemental, in Tswana, Sotho, Zulu, Afrikaans, Xhosa, or Ndebele.  Customers will in all cases be provided with English documentation, together with the requested supplemental document.

 

CREDIT AGREEMENT

 

The credit agreement will be available in English for final signature.  A translated version of the document will be made available on request by the customer for perusal of all information in Tswana, Sotho, Zulu, Afrikaans, Xhosa, or Ndebele. 

 

ENFORCEMENT NOTICES

 

Enforcement notices will be available in English as the official legislative document with either the Tswana, Sotho, Zulu, Afrikaans, Xhosa, or Ndebele translations on the back of the enforcement notice.  These will then be submitted to the legal process.

 

BRANCH STAFF ASSISTANCE

 

In each of Royal Finance’s branches, the staff effectively communicate in English.  We have diverse staff throughout the country and have staff that can communicate in Tswana, Sotho, Zulu, Afrikaans, Xhosa, or Ndebele.  If there isn’t someone in the branch that are able to speak a required language, we have the capability to arrange for a telephonic translator in Tswana, Sotho, Zulu, Afrikaans, Xhosa, or Ndebele.