Privacy Policy

Who we are

Tugela Connect Connect (Pty) Ltd (“Tugela Connect” , us, we) is a Private Company with limited liability with registration no. 2025 / 697899 / 07 . Tugela Connect is not a licensed financial institution, bank, insurer, or FSP. We assist members with onboarding and administrative processes but do not provide financial advice, handle transactions, or assume liability for third - party products.

The Purpose of this Policy

This Policy regulates the Processing of Personal Information / Personal Data by Tugela Connect and sets forth the requirements with which we undertake to comply when Processing Personal Information / Personal Data pursuant to undertaking our operations and fulfilling its contractual obligations in respect of Data Subjects and Third Parties in general. We know that you value your privacy, and therefore we will do our best to respect that. We will exercise care in dealing with your personal and confidential information submitted to us via our website or WhatsApp line and undertake to deal with it in a lawful manner. The personal information requested from you will be used to process your membership application and associated benefits. Your personal information will be processed and maintained in accordance with accepted information management norms to ensure privacy and confidentiality thereof, and that it is accurate and up to date. We will only disclose your personal information to Third - Party service providers when necessary to enhance the delivery of products and services to you as a Tugela Connect member. Should you wish to have access to your personal information records maintained by us, this information will be made available following receipt of such a request.

Definitions

Child means any natural person under the age of 18 (eighteen) years;

Competent Person means anyone who is legally competent to consent to any action or decision being taken by any matter concerning a juristic person or Child, for example a director, parent or legal guardian;

Data Subject means Tugela Connect members, potential members or any Third - Party in respect of whom we Processes Personal Information / Personal Data;

GDPR means the General Data Protection Regulation, which is a European law that governs all collection and processing of personal data from individuals inside the European Union;

Personal Data (as defined in Article 4 of the GDPR) means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly;

Personal Information shall have the same meaning as is given in section 1 of POPIA

Policy  means this Data Protection and Privacy Policy;

POPIA means the Protection of Personal Information Act, No 4 of 2013;

Processing means any operation or activity or any set of operations, whether or not by automatic means, concerning Personal Information/Personal Data, including: the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use; dissemination by means of transmission, distribution or making available in any other form by electronic communications or other means; or merging, linking, blocking, degradation, erasure or destruction. For the purposes of this definition, “Process” has a corresponding meaning;

Special Personal Information / Data means Personal Information/Personal Data concerning, amongst other aspects contemplated in terms of section 26 of Part B of POPIA, a Data Subject’ s, religious beliefs, race or ethnic origin, trade union membership, political persuasion, health or sex life, biometric data, or criminal behaviour

Third - Party means any employee, independent contractor, agent, consultant, broker, sub - contractor, Regulator(s), user of Tugela Connect’s websites or mobile application interfaces, or other representative of Tugela Connect;

Third - Party service providers means African Bank and , or any other service provider contracted by Tugela Connect to fulfil its obligations to members, subject to compliance with POPIA and this Policy

Website means the website(s) owned and operated by Tugela Connect.

Collecting and Processing of Personal Information / Personal Data

Whenever any Data Subject completes this membership application or, contacts Tugela Connect electronically or telephonically, or uses one of the products, services, facilities, tools or utilities offered by Tugela Connect through its Website, we will in effect be Processing the Data Subject’s Personal Information / Personal Data. We collect information either directly from the data subject, or through intermediaries. We do not process special personal information (such as religious beliefs, health data, or biometrics) unless you explicitly consent to such processing as it is required by law. It may happen from time - to - time that we have collected a Data Subject’s Personal Information / Personal Data from other sources. In the event that a Data Subject has shared their Personal Information / Personal Data with any third parties, we will not be responsible for any loss suffered by the Data Subject, their dependents, beneficiaries, spouse(s). We will Process Personal Information / Personal Data in order to facilitate and enhance the delivery of products and services to our members, as well as safeguard the Personal Information / Personal Data relating to any Data Subjects which it in fact holds . In such an instance, the Data Subject providing us with such Personal Information / Personal Data will confirm that they are a Competent Person and that they have authority to give the requisite consent to enable us to process such Personal Information / Personal Data.

Personal Information / Personal Data. We undertake to process any Personal Information / Personal Data in a manner which promotes the constitutional right to privacy, retains accountability and Data Subject participation. We may, from time - to - time, Process Personal Information / Personal Data by making use of automated means (without deploying any human intervention in the decision - making process) to make decisions about the Data Subject or their application

In this instance it is specifically recorded that the Data Subject may object to or query the outcomes of such a decision. Lawful Basis for Processing We process your personal information only where we have a lawful basis to do so, including: - To fulfil our contractual obligations to you as a member; - Where required by law (e.g., FICA compliance); - With your consent, which you may withdraw at any time; - For our legitimate business interests, provided these do not infringe upon your rights. Children’s Data We do not knowingly process data of children under 18 without verifiable parental consent or legal authorisation (e.g. court order). Storage and retention of Personal Information / Personal Data We will retain Personal Information / Data, in an electronic or hardcopy file format, with a Third - Party service provider appointed for this purpose Personal Information / Personal Data will only be retained by us for as long as necessary to fulfil the purposes for which that Personal Information / Personal Data was collected and/or as permitted in terms of Applicable Law. It is specifically recorded that any Data Subject has the right to object to the Processing of their Personal Information and we shall retain and store the Data Subject’s Personal Information / Personal Data for the purposes of dealing with such an objecti on or enquiry as soon and as swiftly as possible. We retain your personal information only as long as necessary, including: - For the duration of your membership; - As required by law (e.g., 5 years for FICA records); - To resolve disputes or enforce agreements. After this period, data is securely deleted or anonymised. Provision of Personal Information / Personal Data to Third - Party service providers We may disclose Personal Information / Personal Data to our Third - Party service providers where necessary and to achieve the purpose(s) for which the Personal Information / Personal Data was originally collected and processed . We will enter into written agreements with such Third - Party service providers to ensure that they comply with Applicable Laws

Lawful Basis for Processing

We process your personal information only where we have a lawful basis to do so, including:

  • To fulfil our contractual obligations to you as a member;

  • Where required by law (e.g., FICA compliance);

  • With your consent, which you may withdraw at any time;

  • For our legitimate business interests, provided these do not infringe upon your rights.

    • Children’s Data

    We do not knowingly process data of children under 18 without verifiable parental consent or legal authorisation (e.g. court order).

    Storage and retention of Personal Information / Personal Data

    We will retain Personal Information / Data, in an electronic or hardcopy file format, with a Third - Party service provider appointed for this purpose Personal Information / Personal Data will only be retained by us for as long as necessary to fulfil the purposes for which that Personal Information / Personal Data was collected and/or as permitted in terms of Applicable Law. It is specifically recorded that any Data Subject has the right to object to the Processing of their Personal Information and we shall retain and store the Data Subject’s Personal Information / Personal Data for the purposes of dealing with such an objecti on or enquiry as soon and as swiftly as possible.

    We retain your personal information only as long as necessary, including:

  • For the duration of your membership;

  • As required by law (e.g., 5 years for FICA records);

  • To resolve disputes or enforce agreements.

    • After this period, data is securely deleted or anonymised.

    Provision of Personal Information / Personal Data to Third - Party service providers

    We may disclose Personal Information / Personal Data to our Third - Party service providers where necessary and to achieve the purpose(s) for which the Personal Information / Personal Data was originally collected and processed . We will enter into written agreements with such Third - Party service providers to ensure that they comply with Applicable Laws pursuant to the Processing of Personal Information / Personal Data provided to them by us from time to time.

    Who we share your Data with

    If you request a password reset, your IP address will be included in the reset email.

    Transfer of Personal Information / Personal Data outside of South Africa

    We may, under certain circumstances, transfer Personal Information / Personal Data to a jurisdiction outside of the Republic of South Africa in order to achieve the purpose(s) for which the Personal Information/Data was collected and Processed, including f or Processing and storage by Third - Party service providers. We will obtain the Data Subject’s consent to transfer the Personal Information / Personal Data to such foreign jurisdiction unless consent is not required by Applicable Law. The Data Subject should also take note that, where the Personal Information / Personal Data is transferred to a foreign jurisdiction, the Processing of Personal Information / Personal Data in the foreign jurisdiction may be subject to the laws of that fore ign jurisdiction.

    If we transfer your data outside South Africa, we ensure:

  • The recipient country has adequate data protection laws; or

  • We use POPIA - approved safeguards.

    • Complaints to the Information Regulator

    In the event that any Data Subject or Third Party is of the view or belief that we have Processed their Personal Information / Personal Data in a manner or for a purpose which is contrary to the provisions of this Policy, the Data Subject is required to fi rst attempt to resolve the matter directly with us, failing which the Data Subject or Third Party shall have the right to lodge a complaint with the Information Regulator, under the provisions of POPIA.

    The Information Regulator (South Africa):

    JD House

    27 Stiemens Street Braamfontein,

    Johannesburg, 2001

    E - mail:

    enquiries@inforegulator.org.za

    complaints.IR@justice.gov.za  

    Your Rights

    You may: Access, correct, or delete your Personal Information / data; Object to processing or withdraw consent; Lodge complaints with the Information Regulator to address provided herein above.

    Cookies

    Cookies are used in the process of user recognition and allow our web server to recognise you when you visit the Website. The type of information gathered to enable recognition is non - personal. Your username and e - mail address will be saved using cookies so that you need not re - enter these details every time you visit the Website. No personal information is ever stored in a cookie. You may choose to prevent your browser from accepting any cookies, which will prevent your username and e - mail address from being saved.

    Embedded content from other Websites

    Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website. These websites may collect data about you, use cookies, embed additional third - party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

    Contacting us

    All comments, questions, concerns or complaints regarding personal information/data or this policy, should be forwarded to Tugela Connect’s designated information officer/s or deputy information officer/s, as follows:

    Information Officer: Moses Ramabulana Email: moses@TugelaConnect.co.za

    Deputy Information Officer: Thabang Lengane Email: thabang@TugelaConnect.co.za

    Changes to this Privacy Policy

    Tugela Connect reserves the right to amend this Privacy Policy at any time. All amendments to this Privacy Policy will become effective when the updated version is posted on the Website. Unless otherwise stated, the current version viewed on the Website shall supersede and replace all previous versions of this Privacy Policy