We, Truzo Ltd. (UK Registered) and Truzo (Pty) Ltd, (collectively referred to as “Truzo”/ “we”/” our”) understand that your privacy is important to you. We are committed to taking steps to protect your privacy when you use our website, application (app) and/or platform (collectively referred to as “platform”) and implementing business practices that comply with all relevant legislation, including the Protection of Personal Information Act 4 of 2013 (“POPI”) and General Data Protection Regulation (“GDPR”) (EU) 2016/679.
We will not use your personal information for any other purpose than that set out in this Policy and will endeavour to protect your personal information that is in our possession from unauthorised alteration, loss, disclosure or access.
What Is Personal Information
For purposes of this Policy, “personal information/data” is any information relating to a living, identifiable individual (natural person) and existing juristic person (business entity), either in electronic or hard copy format, that may include, but is not limited to the following:
- Full names and surname, registered name, email addresses, phone numbers, gender, age of a person, photograph, nationality, title;
- Information relating to the education/qualification of a person, nature/industry of business; and/or
- Any identifying number, symbol, e-mail address, physical address, bank account number, telephone, number, location information, registration number, online identifier etc.
When And How Do We Collect Personal Information?
We may collect or obtain personal information about you –
- Directly from you when you visit as a guest or use the Truzo site as an existing user;
- During our relationship with you as a registered user;
- When you make your personal information public;
- When you visit and/or interact with our various social media platforms;
- When you register to receive our newsletters or other communication;
- When you interact with any third-party content or advertising on our website
- When you apply for a position with Truzo;
- When attending a Truzo hosted or sponsored event or webinar; and
- You contact us with any other enquiry, complaints or notice.
INFORMATION THAT YOU PROVIDE
When registering on our platform, you may be asked to enter your name, email address, phone number, as well as, a password, as appropriate.
For the safety of all Truzo Users, as well as, to enable us to comply with our local and international regulatory requirements, we may request the following personal information in addition to the basic subscription information mentioned above:
- As an individual user in your private capacity – identity/passport number, date of birth, nationality, employment details, as well as, bank account information. If necessary, we may also ask you to provide us with additional information and/or verification documents (as the case may be);
- As a business entity, with authorised representative(s) – registration number, registered and/or trading name, nature of business / industry, details of owners and controllers (such as directors, partners, trustees, beneficiaries, members, shareholders, beneficial owners, authorised signatories etc.) If necessary, we may also ask you to provide us with additional information and/or verification documents of the business entity or any party related thereto (as the case may be).
By accessing the Truzo platform and completing the registration section, you provide consent for a Truzo representative to contact you. The contact method used by the Truzo representative will be based on the contact information you provided during registration (whether through completed or interrupted registration).
INFORMATION THAT WE AUTOMATICALLY COLLECT
We automatically collect data about you and your device including, but not limited to:
- Internet Protocol;
- IP address;
- Browser type;
- Access times and duration of your use of our platform;
- Searches conducted on our platform;
- Your use of our website and any actions taken on our platform;
- Device’s operating system;
- Type of device used; and
- Any information stored in cookies that we have set on your device.
INFORMATION COLLECTED FROM COOKIES
Cookies are small data files that a site or its service provider transfers to your device’s hard drive through your web browser (if you allow), that enables the site’s or service provider’s systems to recognise your browser and capture and remember certain information. Cookies help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services.
Purpose And Legal Basis For Processing Information
The information you provide, or we collect is used in order to:
- Primarily provide you with escrow payment services, enabling you to make and receive payments securely and in compliance with applicable regulations;
- Respond to your queries and comments timely;
- Send communications, updates and marketing material about the company;
- Personalise your user experience;
- Allow us to deliver the type of content you are most interested in;
- Send communications about updates to Terms and Conditions, Privacy Policies and other legal notices;
- Administer this website and help us improve and operate our website, services and marketing material;
- Provide you with requested material and/or information;
- Provide reports to third parties (such reports are aggregated and do not contain any information which may identify you as an individual);
- Send confirmation and technical notices, security alerts, administrative messages, feedback communications; and
- To fulfil our legal, regulatory, or risk management obligations – to comply with our legal obligations (performing customer due diligence/”know your customer”, anti-money laundering, anti-bribery, sanctions or reputational risk screening, identifying conflicts of interests) – for the prevention of fraud and/or other relevant background checks as may be required by applicable law and regulation and best practice at any given time (if false or inaccurate information is provided and fraud is identified or suspected, details may be passed to fraud prevention agencies and may be recorded by us or by them) and to enforce our legal rights, to comply with our legal or regulatory reporting obligations and/or to protect the rights of third parties.
Sharing Personal Information
We may share your information with the following parties or for the following reasons:
- Business partners, companies, service providers, employees or agents who are involved in delivering services to you on our behalf;
- Data Providers/Credit Bureaus assisting us in complying with our legal, regulatory, or risk management obligations – you agree that we may verify your personal information against any third party databases/credit bureaus or through other sources as deemed appropriate by Truzo;
- Law enforcement agencies, regulators, courts and other parties in order to comply with the law, legal processes or lawful requests e.g. a court order, warrant, etc.
- Other parties with your consent;
- Companies and affiliates who form part of the Envisionit Group of Companies, for example between Truzo (Pty) Ltd registered in South Africa and Truzo Ltd. registered in the United Kingdom; and/or
- To protect the rights and property of Truzo, our agents, customers, and others. This includes, but is not limited to, enforcing our agreements, policies and terms and conditions.
In the event of a reorganisation, restructuring, merger, bankruptcy, sale of the business, we may share your information with the third party involved in the transaction.
How Long Do We Keep Your Personal Data?
We will retain your personal data for as long as is necessary to fulfil the purpose for which this data was collected and any other permitted linked purpose. If your personal data is used for two purposes we will retain it until the purpose with the latest period expires; but we will stop using it for the purpose with a shorter period once that period expires. Our retention periods are also based on our business needs and good practice.
What Rights You Have In Relation To Your Personal Data
In terms of the applicable Privacy Laws, your rights include, but are not limited to the following:
- The right to be informed as to how your personal data will be used and if applicable, further processed (which includes the purpose of this Policy);
- The right to request access (right to access) to the personal information the group has;
- The right to inform us and correct any personal data that is inaccurate, irrelevant, excessive, out-of-date, incomplete, misleading or obtained without valid business justification (right to rectification);
- The right to have your personal data destroyed or deleted when we are no longer authorised to retain it or no other legal right exists to retain such data (right to erasure, also known as “the right to be forgotten”);
- The right to object to the processing of your personal data (right to restrict processing) if you believe we are not acting in accordance with this Policy;
- The right to opt-out of receiving marketing communications;
- The right to be informed of how and if any automated decisions regarding you have been made; and
- The right to data portability , which requires us to provide personal information to you or another controller in a commonly used, machine readable format, but only where the processing of that information is based on
- consent; or
- the performance of a contract to which you are a party.
- The right to file a complaint (right to complain) with Truzo or the regulator with jurisdiction (in South Africa customers can contact the Information Regulator) about an alleged contravention of the protection of their personal information. Truzo will address customer complaints as far as possible.
Cross Border Transfers Of Information
In the instance that personal information is transferred cross-border, we will take appropriate steps to ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights.
We implement appropriate technical and organisational security measures to protect your Personal Information that is in our possession against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, in accordance with applicable laws.
Where there are reasonable grounds to believe that your personal information that is in our possession, has been accessed or acquired by any unauthorised person, we will notify the relevant regulator and you, unless a public body responsible for detection, prevention or investigation of offences or the relevant regulator informs us that notifying you will impede a criminal investigation.
Although we will implement all reasonable measures to protect your personal information that is in our possession, we cannot guarantee the security of any information transmitted using the internet and we cannot be held liable for any loss of privacy that occurs during the course of such transmission.
You are responsible for keeping your personal and account information secure and not sharing it with others. We will never ask you for your personal or account information through unsolicited or unscrupulous means. Although we have implemented security measures to protect your information, you acknowledge that your information may be accessed by unauthorised parties through illegal, unlawful or malicious means.
Your personal information provided to us should be accurate, complete and up-to-date. Should your personal Information change, the onus is on the you to notify us of the change and provide us with the accurate data to enable us to perform our services to you.
We undertake to restrict the processing of personal information to data which is sufficient for the fulfilment of the primary purpose and applicable legitimate purpose for which it was collected.
Truzo (Pty) Ltd
2nd Floor One-on-Jameson Building,
1 Jameson Avenue, Melrose Estate,
Johannesburg, South Africa, 2196.
Tel: +27 11 486 0692
Email: email@example.com or firstname.lastname@example.org
Attention: Truzo Information Officer
C/o Founders Factory, Northcliffe House,
2 Derry Street,
London, United Kingdom
Tel: +44 7780 690 559
Information Regulator Details (South Africa)
Mr Mosalanyane Mosala
Chief Executive Officer
JD House, 27 Stiemens Street, Braamfontein,
P.O Box 31533, Braamfontein,
Complaints email: complaints.IR@justice.gov.za
General enquiries email: email@example.com
Tel: 010 023 5200