PRIVACY POLICY

Effective Date: January 1, 2025

Last Updated: January 1, 2025

1. INTRODUCTION

FixSA (Pty) Ltd ("we," "us," or "our") is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, store, and share your personal information when you apply for a Discovery Bank account through our platform, in accordance with the Protection of Personal Information Act (POPIA) 4 of 2013.

FixSA is an authorized Financial Services Provider (FSP 18147) and acts as an intermediary between you and Discovery Bank Limited.

By submitting your application through our platform, you consent to the collection and processing of your personal information as described in this policy.

2. INFORMATION WE COLLECT

2.1 Personal Information

When you complete a bank account application, we collect the following information:

• Identity Information: Full name, surname, South African ID number
• Contact Information: Cell phone number, email address, physical address (street address, suburb, province, postal code)
• Financial Information: Current bank details, gross monthly salary
• Referral Information: Details about who referred you to our service
• Documents: Copies of your South African ID document and proof of residence

2.2 Technical Information

We may automatically collect:

• IP address and device information
• Browser type and version
• Pages visited and time spent on our platform
• Application completion progress

3. HOW WE USE YOUR INFORMATION

We use your personal information for the following purposes:

3.1 Primary Purposes

• To facilitate your bank account application with Discovery Bank
• To verify your identity and conduct FICA (Financial Intelligence Centre Act) compliance checks
• To communicate with you about your application status
• To provide customer support and respond to your inquiries
• To fulfill our legal and regulatory obligations as a financial services provider

3.2 Secondary Purposes (with your consent)

• To send you information about other financial products and services that may benefit you
• To improve our services and user experience
• To conduct market research and analytics

4. INFORMATION SHARING AND DISCLOSURE

4.1 Sharing with Discovery Bank

We share your complete application information, including personal details and uploaded documents, with Discovery Bank Limited for the purpose of processing your bank account application. Discovery Bank is a registered financial services provider and is bound by their own privacy policies and regulatory obligations.

4.2 Third-Party Service Providers

We may share your information with trusted third-party service providers who assist us in:

• Hosting and maintaining our platform (Google Apps Script, Google Drive)
• Data storage and backup services
• Identity verification services
• Communication services (email delivery)

All third-party providers are contractually obligated to maintain the confidentiality and security of your information.

4.3 Legal Requirements

We may disclose your information when required by law, including:

• Compliance with FICA and anti-money laundering regulations
• Response to court orders or legal processes
• Protection against fraud or illegal activities
• Cooperation with regulatory authorities (e.g., Financial Sector Conduct Authority)

4.4 Information We Do NOT Share

We will never sell, rent, or trade your personal information to third parties for marketing purposes without your explicit consent.

5. COMMISSION DISCLOSURE

As a financial services broker, FixSA receives commission from Discovery Bank for successful account applications. This commission does not affect the fees or services you receive from Discovery Bank. The commission structure is regulated by the Financial Sector Conduct Authority (FSCA).

6. DATA SECURITY

We implement appropriate technical and organizational measures to protect your personal information against:

• Unauthorized access or disclosure
• Accidental loss or destruction
• Unlawful processing
• Alteration or damage

Our security measures include:

• Encrypted data transmission (SSL/TLS)
• Secure document storage on Google Drive with restricted access
• Regular security audits and updates
• Access controls and authentication requirements
• Staff training on data protection

However, please note that no method of transmission over the internet is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

7. YOUR RIGHTS UNDER POPIA

Under the Protection of Personal Information Act, you have the right to:

7.1 Access

Request access to your personal information we hold and receive a copy of it.

7.2 Correction

Request correction of inaccurate, incomplete, or outdated information.

7.3 Deletion

Request deletion of your personal information, subject to legal retention requirements.

7.4 Objection

Object to the processing of your personal information for direct marketing purposes.

7.5 Restriction

Request restriction of processing in certain circumstances.

7.6 Data Portability

Request a copy of your information in a commonly used electronic format.

7.7 Withdrawal of Consent

Withdraw your consent to marketing communications at any time without affecting the processing of your application.

To exercise any of these rights, please contact us at support@fix-sa.co.za.

8. DATA RETENTION

We retain your personal information for as long as necessary to:

• Fulfill the purposes outlined in this policy
• Comply with legal and regulatory requirements (minimum 5 years as per FICA regulations)
• Resolve disputes and enforce agreements

After the retention period, your information will be securely deleted or anonymized.

9. COOKIES AND TRACKING

Our platform may use cookies and similar tracking technologies to:

• Remember your application progress (auto-save feature)
• Analyze platform usage and performance
• Improve user experience

You can control cookies through your browser settings. However, disabling cookies may affect the functionality of our auto-save feature.

10. CHILDREN'S PRIVACY

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from minors. If we become aware that we have collected information from a minor, we will delete it promptly.

11. CROSS-BORDER TRANSFERS

Your information may be stored on servers located outside South Africa (e.g., Google Cloud services). We ensure that any cross-border transfers comply with POPIA requirements and that adequate safeguards are in place.

12. UPDATES TO THIS POLICY

We may update this Privacy Policy from time to time to reflect:

• Changes in our practices
• Legal or regulatory requirements
• New features or services

We will notify you of significant changes by:

• Posting the updated policy on our website
• Updating the "Last Updated" date
• Sending an email notification (if we have your consent)

Your continued use of our services after changes indicates acceptance of the updated policy.

13. COMPLAINTS AND CONCERNS

If you have concerns about how we handle your personal information, you may:

14. CONTACT INFORMATION

Data Protection Officer:

FixSA (Pty) Ltd

Email: support@fix-sa.co.za

FSP Number: 18147

For questions, concerns, or to exercise your rights, please contact us at the above email address.