We value you and respect your right to privacy; the success of our business depends upon our ability to maintain your trust. This policy applies to all Personal Information that the Truworths Group may process about any person visiting our online platforms and website, our customers, potential customers or prospects, or any person whose personal information we collect because of a relationship with our customer (for example a reference or beneficiary's information received from a customer).
All references to “Truworths” or the “the Truworths Group” hereafter in this Policy will mean Truworths International Limited and all other members of the Truworths group registered in Africa,
The Personal Information under our control will not be distributed, sold or shared with third parties other than for purposes specified in this policy. We will never sell your Personal Information for marketing purposes.
Please note that this policy applies in addition to any provisions specified in your customer agreement with us ‐ whether you are a credit-, layby- or loyalty customer. If there is any discrepancy between the customer terms and this policy, the provisions of this policy will apply.
We may amend this policy from time to time and the most updated version will apply at the time of processing.
Where we refer to “Personal Information”, it means “personal information” as defined in the Protection of Personal Information Act, 4 of 2013 (“POPI”). Personal Information includes any information about a person that can be used to identify a person directly or indirectly. It includes information like a name, an identification number, location information, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.
Information which is anonymous (i.e. which does not relate to any individual or from which no individual can be identified) does not fall within the ambit of Personal Information for the purposes of this Policy.
What Personal Information is collected:
We collect various information fields, depending on the reason why we need the information. These include, amongst others, personal details, such as your name, surname, identity number, IP address, email address telephone number, employment history, financial information, cookies, views/preferences you may express and/or non-personal browsing habits and click patterns.
How Personal Information is collected:
- Directly from you:
- when you register online or participate in a survey, competition or any form of promotion;
- when you apply to become or become a customer by opening an account with us, entering into an agreement for insurance cover or entering into a layby agreement;
- when you become a member of TRULOYALTY or IDREAM; and/or
- in any other circumstances where you provide any information to us, whether voluntary or mandatory.
- In certain instances, we collect Personal Information from third parties. We will only collect Personal Information this way for our legitimate business purposes, where such information is publicly available or where such collection is otherwise permitted under POPI. Examples include information collected from credit bureaus, fraud agencies, banks, friends or family.
Purpose for processing of Personal Information
We generally process Personal Information for the following purposes:
- Your application for an agreement with us, which may include various checks like credit, fraud, identity, banking details, etc.
- Managing your agreement with us, including, tracing, collections, ongoing credit and fraud vetting, and managing benefits you may be entitled to in terms of an agreement;
- in order to make your retail experience more effortless and to communicate with you about our products, services (including credit services), competitions and promotions, including to take all reasonable steps to consider whether you may qualify for any products or services we offer in addition to your existing agreement with us.
We may also use your Personal Information for any other legitimate business purposes relating to our services and/or business activities, such as:
- responding to queries you post on our website or email to us;
- providing you with or offering you our goods or services (including certain products or services provided by third parties);
- risk and analytic purposes;
- improving our website design and efficiency by analysing certain information collected, including cookies and other related information;
- complying with any regulatory or other obligations, including without limitation our reporting obligations as a registered credit provider;
- sale of debt or any portion of our business; and/or
- crime and fraud prevention
Truworths owns and retains all rights to non-personal statistical information collected and compiled by Truworths.
When you become a customer and/or register on our website, you will be added to our mailing list where you may choose to receive emails or SMS messages and telephone calls from us regarding our business, products, services, competitions, and promotions.
You can unsubscribe from our mailing list at any time which will result in us no longer marketing to you. We include a link in every direct marketing communication allowing you to unsubscribe from specific marketing communication and you can email us to ask us to remove you from all our mailing lists.
If you unsubscribe from all our mailing lists, we may still contact you in other non-direct marketing instances, such as in the course of providing you with services or to collect amounts owing to us.
Sharing Personal Information:
We will only share your Personal Information for purposes of providing goods and services to you or any other legitimate business purpose relating to our business activities, including but not limited to, the protection of our or your rights, complaints, marketing, or enforcing any agreement between us and complying with regulatory and legislative obligations.
Where required for our business operations, we may share your Personal Information with our service providers. We only share information with service providers after we enter into an agreement with the service provider to regulate the way in which the Personal Information will be used and secured.
Where the law or our contractual obligations require or allow us to do so, we may also share your Personal Information with third party service providers, agents, contractors, employees, law enforcement agencies, regulatory and government institutions or business affiliates. We will only share your Personal Information in these instances where it is necessary for us to do so and/or only to the extent that your Personal Information is needed for such third parties to perform their services or obligations.
Examples of third parties with whom we may share your Personal Information include credit bureaus, debt counsellors and payment distribution agents, vetting agencies, ombudsmen and debt collectors.
Sending Personal Information outside of South Africa:
We may transfer your information cross border for our legitimate business purposes, such as for cloud storage and for our billing practices or where our service provider processes the Personal Information cross border in terms of our contract with them. All information transfers will comply with POPI and all other applicable laws.
We will take all reasonable steps to ensure that your Personal Information is protected. We protect and manage Personal Information that we hold about you by using electronic and computer safeguards like firewalls, data encryption, as well as physical and electronic access control to our buildings. We only authorise access to Personal Information to those employees who require it to fulfil their designated responsibilities.
If in your engagement with us, you register any account with log-in details, it remains your responsibility to keep your information secure and not share it with anyone.
Right to object:
You may, on reasonable grounds, object to us processing your Personal Information, including to object to information being processed for direct marketing purposes. If you object, we will stop processing your Personal Information, except if POPI or any other applicable law allows its continued use.
Lodging a complaint:
If you believe we are processing your Personal Information unlawfully, please let us know first by emailing us at [email protected].
You may lodge a complaint to the Information Regulator (South Africa) with the following contact details:
Address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
Contact number: 010 023 5200.
Email: [email protected].
Children's Personal Information and special Personal Information:
We do not intentionally collect or use Personal Information of children (persons under the age of 18 years), unless with express consent of a parent or guardian or if POPI or any other applicable law otherwise allows or requires us to process such Personal Information.
Special Personal information including race, biometric behaviour and health will only be processed with your consent or if otherwise permitted under POPI.
Quality and access to your Personal Information:
We want to ensure that your Personal Information is accurate and up to date. You may ask us to correct any Personal Information that you think is inaccurate or request us to remove your information by following the process set out in our Proatia Manual, which is available on this website. You have the right to request us to provide you with Personal Information that we hold about you. You must contact us directly to do so or send an email to the address set out in our Proatia Manual, which is available on this website, and if our business operations and the law require and/or allow us to provide it to you, we will provide the record of your Personal Information within a reasonable time of receiving your request.
Retention of Information:
We will report a material security breach of Personal Information to the Information Regulator and to the individuals or companies involved. If you want to report any concerns about our privacy practices or if you suspect any breach regarding your Personal Information, kindly notify us by sending an email to [email protected]
You can easily erase cookies from your computer or mobile device using your browser. For instructions on how to handle and delete cookies please look under “Help” in your browser. You can choose to disable cookies, or to receive a notification each time a new cookie is sent to your computer or mobile device. Please note that if you choose to disable cookies, you will not be able to take advantage of all our features.
Our website may contain links to other sites that are not under our control. These will have their own policies regarding privacy, which you should review before visiting them. We cannot take responsibility for linked Websites and provide these links solely for the convenience and information of our visitors.
In addition to the above, our website uses Google Analytics for tracking, along with an AMP Client ID, for consistency in data collection when our website is used. How Google uses the data, and the information on opting out of analytics tracking can be found at the following link: https://policies.google.com/technologies/partner-sites
You can choose to opt out of the Google Analytics and Google Display Network Advertising by heading over to the Google Ad Preferences Manager at https://support.google.com.
We recommend that you review our policy from time to time as there may be occasional updates.