Glenstone Loans - Privacy Policy

PRIVACY NOTICE

BY ACCESSING AND USING THIS WEBSITE AND/OR BY INTERACTING WITH LULA LEND IN ANY CAPACITY WHATSOEVER, YOU CONSENT TO THE PROCESSING OF YOUR PERSONAL INFORMATION BY LULA LEND ON THE BASIS SET OUT IN THIS PRIVACY NOTICE. IF YOU DO NOT CONSENT, YOU MUST IMMEDIATELY STOP ACCESSING AND/OR USING THIS WEBSITE.

1. INTRODUCTION

In providing services to users of the Lula Lend website, Lula Lend collects, uses, processes and, in some circumstances, shares the personal information of users in and through this website.
Lula Lend respects the rights of users of the Lula Lend website whose personal information is collected, and used and/or processed by it, including their right to protection against the unlawful collection, retention, sharing and use of such personal information.
The purpose of this Privacy Notice is to provide You with information about the information processing activities of Lula Lend and the manner in which Your rights are protected.
This Privacy Notice shall serve as a blanket notification to You about Lula Lend’s processing activities and will apply in relation to each interaction between You and Lula Lend.
Lula Lend may amend the provisions of this Privacy Notice to comply with any changes in the law, and/or pursuant to any changes to its information processing activities or privacy practices. Such amendments will be published on the website and will become operable from the date of such publication.
This privacy policy, and the interpretation and enforcement thereof, will be governed by the laws of the Republic of South Africa.

2. DEFINITIONS AND INTERPRETATION

In this Privacy Notice, the following words bear the following meanings:
1. “consent’’ means any voluntary, specific and informed expression of will in terms of which permission is given by or on behalf of You of the website for the processing of Your personal information;
2. ‘‘direct marketing’’ means to approach a data subject, either in person or by mail or electronic communication, for the direct or indirect purpose of promoting or offering to supply any goods or services to the data subject;
3. “information officer’’ means the information officer appointed by Lula Lend in accordance with the POPI from time to time;
4. “juristic person” includes a body corporate, a partnership, an association, or a trust as defined in the Trust Property Control Act 57 of 1988;
5. “Lula Lend” means Lula Lend (Pty) Ltd, registration number 2014/156767/07;
6. ‘‘operator’’ means an outside third party who processes personal information for or on behalf of Lula Lend in terms of a contract or mandate;
7. “Person” means a natural person or a juristic person;
8. “personal information’’ means any information linked to You or information that can identify You, including but not limited to:
  1. information relating to Your gender, nationality, ethnic or social origin age, language;
  2. information relating to Your education or Your financial, criminal or employment history;
  3. Your identity or registration number, e-mail address, physical address, telephone number, location information or online identifier;
  4. all financial information about You;
  5. Your personal opinions, views or preferences;
  6. correspondence sent by You which is of a private or confidential nature;
  7. the views or opinions of others about You; and
  8. Your name if it appears with other personal information relating to You, or if the disclosure of Your name on its own would reveal further personal information about You, or any other personal information as defined and contemplated in POPI;
9. ‘’POPI’’ means the Protection of Personal Information Act 4 of 2013, including any regulations or codes of conduct promulgated under it;
10. ‘’PAIA’’ means the Promotion of Access to Information Act 2 of 2000;
11. ‘’process” or “processing’’ means, in relation to personal information, any operation or activity or any set of operations, whether or not by automatic means, including:
  1. the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use of that information;
  2. dissemination by means of transmission, distribution or making available in any other form; or
  3. merging, linking, as well as restriction, degradation, erasure or destruction of that information;
12. “User Agreement” means the user agreement that a person who registers with Lula Lend will conclude on the Lula Lend website;
13. ‘’the website’’ means the website or any part thereof which is accessible from www.lulalend.co.za;
14. ‘’You’’ means a visitor or user of this website, or any of the content or services associated with this website, and “Your” has a corresponding meaning.
Any reference in this Privacy Notice to:
1. the singular includes the plural and vice versa;
2. any one gender includes the other genders, as the case may be;
3. an act, regulation or other law is to the version of that law in force at the effective date of this notice and includes any amendment or re-enactment made to that law after the effective date of this notice.
4. When calculating any number of days for the purposes of this notice, the first day must be excluded and the last day of the relevant interval included, unless the last day is not a business day, then the last day will be the next succeeding business day.
5. The word "include" means "include without limitation". Use of the word ‘’include’’ or ‘’in particular’’ is for illustration or emphasis only and where followed by specific examples must not be interpreted as limiting the meaning of the general wording preceding it.
6. A requirement that any notice, request, demand or other communication made in terms of this Privacy Notice must be in writing will be met if it is in the form of a data message as defined in the Electronic Communications and Transactions Act, No. 25 of 2002, and is accessible in a manner usable for subsequent reference.

3. RESPONSIBLE PARTY

Lula Lend will be the party who will be collecting and processing Your personal information and as such is designated as the ‘’responsible party’’ for the purposes of this Notice.
Lula Lend’s contact details are as follows:
- Registered address: 12 Calais Road, Sea Point, Cape Town, 8005
- Telephone number: 082 714 4231
- Email address: support@lulalend.co.za
- Website address: www.lulalend.co.za
Lula Lend may instruct operators from time to time to undertake certain processing activities relating to You’s personal information.

4. WHAT PERSONAL INFORMATION IS COLLECTED

Lula Lend may collect the following personal information from You:
1. Initials, first name, surname or registered full name;
2. Identity or registration number and/or date of birth;
3. Physical and postal address;
4. Email address;
5. Telephone and cellphone numbers;
6. Gender, nationality, ethnic and social origin, age, language preference;
7. financial information about You;
8. Your personal opinions, views or preferences;
9. correspondence sent by You which is of a private or confidential nature;
10. the views or opinions of others about You;
11. Your credit information and history; and
12. any other personal information that may be provided by You to Lula Lend or obtained by Lula Lend or required by Lula Lend in relation to the provision of the services of Lula Lend to You.
The supply of personal information by You to Lula Lend is voluntary and not mandatory. However, if You refuse to supply any personal information, certain consequences may naturally flow from such a refusal, such as preventing Lula Lend from concluding or performing any contract with You, or preventing Lula Lend from complying with one or more of its obligations in law.

5. PURPOSE/S FOR COLLECTION AND PROCESSING OF PERSONAL INFORMATION

Lula Lend shall only collect Your personal information for a specific, explicitly defined and lawful purpose relating to a function or activity of Lula Lend’s business.
Such purposes may include the following:
1. to make the decision whether or not to enter into a contract with You or allow You to contract with other users of the Lula Lend website portal;
2. to perform any obligations under a contract with You;
3. to comply with a legal obligation;
4. to protect a legitimate interest of Your (unless You have specifically objected in writing to all or some of the processing activities on reasonable grounds);
5. to pursue its own legitimate interests or the legitimate interests of a third party who it is sharing the information with (unless You have specifically objected in writing to all or some of the processing activities on reasonable grounds);
6. to process personal information for credit reporting purposes;
7. to process personal information for direct marketing purposes (unless You have opted out of receiving any direct marketing material);
8. to present content to You in the most effective way for you and your viewing device and browser;
9. to customise and display content including, but not limited to products, articles, listings and advertisement to You in a way that Lula Lend feels may interest You or be most beneficial to You;
10. to send content including, but not limited to products, articles, listings and advertisement content to You via email or other electronic media, where You have consented to be contacted by Lula Lend with such content;
11. to enable You to voluntarily participate in interactive features on the website;
12. to notify You about changes to the website; and/or
Lula Lend will not sell Your personal information to any third party without the prior written consent of You.

6. COLLECTION DIRECTLY FROM USER

Lula Lend shall, as far as possible, always collect personal information about You directly from You, except in the following circumstances:
1. where personal information is collected from a public record, or from another source if the information has already been made public by You;
2. where You have given your written consent to Lula Lend to collect your information from another source;
3. where the collection of Your personal information from another source will not prejudice any of Your legitimate interests;
4. where the collection of personal information from another source is necessary to maintain Lula Lend’s legitimate interests or those of any third party it intends sharing the information with;
5. where the collection of personal information directly from You would prejudice the purpose for the collection;
6. where the collection of personal information directly from You is not reasonably practicable in the circumstances.
If Lula Lend collects personal information from a source other than You, it shall record in writing the details of that source, including the full names and contact details of that source where applicable.
You hereby consent to Lula Lend requesting and obtaining credit information pertaining to You from any reputable credit reporting agency or institution for the purpose of concluding any transaction offered by Lula Lend through its website portal.
Personal information may be collected from or supplied by You in any of the following ways:
1. during the process of registering as a user on this website;
2. provided by You as part of your profile pages on the website;
3. when subscribing to a service, entering into a competition or promotion, or participating in a survey offered on this website;
4. when posting a comment, review, reply or recommendation on this website;
5. when requesting further services or information from Lula Lend and/or other users of Lula Lend;
6. when contacting Lula Lend to report a problem with the website or for any other reason;
7. when completing any forms on the Lula Lend website.
You may visit the website without providing any personal information. However, the website’s servers may still collect technical information regarding the use of the website, which is aggregated for analytical purposes, technical maintenance and for improving the content offered on the website. Such information may include details of Your visit, information about Your computer, including IP (Internet Protocol) address, operating system and browser type, Your location, and usage information. Individuals users like You will not be identified from or by this information and Lula Lend is entitled to copy, distribute or otherwise use such information without limitation.

7. COOKIES

“Cookies” are small text files transferred by a webserver to Your hard drive and thereafter stored on their computer. The types of information a Cookie collects includes Your username, the date and time of your visits to the website, your browsing history and preferences.
Lula Lend may use Cookies on this website to:
1. distinguish one user from another on the website;
2. remember Your last session when You return to the website;
3. estimate the website's audience size and usage patterns;
4. store information about Your preferences, which allows Lula Lend to customize the website and content according to Your individual preferences; and
5. speed up searches on the website.
The provisions of this clause are only applicable to Cookies used by Lula Lend. In some instances, third-party service providers may use Cookies on the website. Lula Lend cannot and does not control or access Cookies used by third party service providers and takes no responsibility therefor.
You have the right and ability to either accept or decline the use of Cookies on your computer’s web browser, whether You are logged in as a user, or simply casually visiting the website. However, declining the use of Cookies may limit Your access to certain features on the website.

8. GENERAL CONDITIONS FOR PROCESSING PERSONAL INFORMATION

Lula Lend shall comply with all laws, contracts or regulations when it processes Your personal information.
Lula Lend shall not act unreasonably when processing Your personal information. This means that it will collect and process Your personal information in a way that You can reasonably expect and in a way that is fair.
Lula Lend shall respect Your right to privacy at all times. If there is another way in which it can achieve the same goal without posing any risk of harm to Your privacy rights, then it will choose that option.
Similarly, if Lula Lend needs to process personal information but there are less privacy-invasive methods of collecting, using and sharing that information, then it will use those methods.
Lula Lend shall ensure that the personal information that is collected and processed is and remains relevant to the identified purpose/s for such processing, and that such information is and remains adequate, but not excessive, for achieving the identified purpose/s.
If there are any alternative ways to achieve the identified purpose/s without processing personal information, Lula Lend shall not process that personal information.
Lula Lend shall ensure that the processing activities it chooses to apply are proportionate to achieving the identified purpose/s and that no less privacy invasive measures are available to achieve the same purpose/s.
Lula Lend shall ensure that, regardless of the stated purpose/s for processing personal information, the rights and interests of users such as You will not be unnecessarily prejudiced or infringed, unless it cannot be avoided, and then in such cases, it shall ensure that its own rights and/or interests justify such prejudice or infringement taking place.
Once Lula Lend has achieved the purpose for the collection of Your personal information, it will destroy or delete such information, unless You have directed otherwise in writing, or Lula Lend is required by law to retain the information for a longer period of time.
If Lula Lend no longer needs to process personal information to achieve the purpose originally specified, it will stop using that information.

9. DISCLOSURE AND SHARING OF PERSONAL INFORMATION

Lula Lend may, in the course of providing any content or services on this website, or for the purposes of concluding or performing any transaction with You, share certain personal information with third party operators who perform certain processing activities on behalf of Lula Lend.
The categories of third party operators with whom it is shared is set out below:
1. banks or other financial institutions where You maintain or have maintained bank accounts, loan accounts or other financial or investment accounts;
2. credit bureau service providers;
3. service providers who provide Lula Lend with legal assistance, accounting or auditing services, payroll services and/or other utilised to effectively operate the Lula Lend business;
4. delivery and courier service providers;
5. Payment Gateway Provider;
6. Bulk email delivery providers.
Lula Lend may also share aggregated information about You, and Your usage patterns. Lula Lend may also use such aggregated information to help advertisers target specific audiences. Such aggregated information will be de-identified and Your personal information will not be disclosed.
Other than as stated in clause 9.1 to 9.3, Lula Lend shall not share Your personal information with any third parties unless it has Your express consent to do so.

10. USER’S RIGHTS IN RELATION TO THE PROCESSING OF THEIR PERSONAL INFORMATION

You shall have the following rights in relation to the processing of Your personal information:
1. to access and correct any personal information held by Lula Lend about them;
2. to object to the processing of their information; and
3. to lodge a complaint with the Information Regulator.
You may make a request in terms of clause 10.1.1 by following the process for making such a request as set out in Lula Lend’s PAIA manual.

11. FURTHER PROCESSING

Lula Lend shall not process Your personal information for any purpose not previously specified except in the following circumstances:
1. where You have consented to such further processing;
2. where the further processing is necessary for the exercise of any contractual rights or the fulfillment of any obligations between Lula Lend and You;
3. where the further processing activities are linked to or compatible with the original purpose;
4. where the further processing is necessary for the prevention, detection, investigation, prosecution and punishment of an offence;
5. where the further processing is necessary to enforce any law;
6. where the further processing is necessary for the conduct of legal proceedings in any court or tribunal that have commenced or are reasonably contemplated;
7. where the further processing is necessary to prevent or mitigate a serious and imminent threat to the life or health of You or another individual;
8. where the further processing is necessary for historical, statistical or research purposes.
Lula Lend shall ensure that if it intends processing personal information for other purposes not previously specified, it shall notify You of such further purposes and the possible consequences of the intended further processing for You.

12. ACCURACY, CORRECTNESS AND COMPLETENESS OF PERSONAL INFORMATION

Lula Lend shall take reasonably practicable steps to ensure that the personal information kept by it about You is complete, accurate, not misleading and is updated when necessary.
However, if You are aware of any personal information in Lula Lend’s custody that is incorrect, inaccurate or which needs to be updated, You must make a written request to Lula Lend’s information officer at info@lulalend.co.za to update or correct the relevant information.
If You have contested the accuracy of any personal information being used by Lula Lend, it shall immediately stop using that information until its accuracy has been verified.
Lula Lend reserves its right to only adhere to a request from You in terms of clause 12.2 if the correction or updating of that information will result in the personal information being correct and accurate.
Where personal information that has been shared by Lula Lend with a third party is subsequently updated or corrected, Lula Lend shall ensure that all third parties, with whom that information was shared, receives the updated and/or corrected version of the information as soon as it has been updated and/or corrected.

13. SECURITY SAFEGUARDS

Lula Lend is committed to protecting the personal information in its custody against any loss of, damage to or unauthorised destruction of that information, and to prevent any unauthorised parties from accessing that information.
Lula Lend takes steps to continually identify and document any risks to the personal information it has in its possession or under its control and that appropriate security safeguards are in place against those risks.
Lula Lend shall ensure that in any contracts entered into with third party operators who process personal information on Lula Lend’s behalf, include the following obligations:
1. the operator shall not process any personal information without Lula Lend’s knowledge and authority;
2. the operator shall treat all personal information given to it as confidential and shall not disclose it to any unauthorised third parties;
3. the operator shall establish and maintain adequate security measures which are the same or offer similar protection over the personal information as that employed by Lula Lend;
4. the operator shall notify Lula Lend immediately where there are reasonable grounds to believe that any personal information has been leaked to or accessed by any unauthorised person;
5. if the operator is situated in another country, it must comply with the data protection laws in that country and be able to provide verification that it is so compliant;
6. if an operator is legally obliged to disclose any personal information processed by them on Lula Lend’s behalf to other parties, it must notify Lula Lend beforehand to enable Lula Lend and/or You to protect Your rights if necessary.
You must maintain the secrecy of any passwords used to gain access to this website and You should change such passwords regularly.
Lula Lend shall ensure that all personal information on its systems is properly backed-up and that back-up copies are stored separately from the live files.
As the internet is not a secure medium of communication, Lula Lend cannot guarantee the security of any information You input on its website or send to Lula Lend via the internet. Lula Lend is not, and will not be, responsible for any damages You or others may suffer as a result of the loss of confidentiality of any such information.

14. NOTIFICATION OF BREACH OF SECURITY

If personal information about You is inadvertently leaked or Lula Lend’s security has been unlawfully breached by any unauthorised party, Lula Lend shall immediately identify the relevant users who may be affected by the security breach, and shall contact them at their last known email address or contact details or by the quickest means possible.
Lula Lend shall provide sufficient information to You to allow You to take the necessary protective measures against the potential consequences of the compromise, or shall advise You of the steps to be taken by You and the possible consequences that may ensue from the breach for You.

15. DECISIONS BASED ON PERSONAL INFORMATION PROCESSED

If Lula Lend is required to make a decision about You using any personal information that has been obtained, it shall ensure that a record of such information and the decision made is kept for a reasonable period of time to give You an opportunity to request access to that record.
Lula Lend may allow You a reasonable opportunity to make representations before any decision is made solely on the basis of the personal information processed, if that decision will affect Your legal position, or will otherwise adversely affect You in some manner or form.
Lula Lend shall always ensure that the underlying logic behind any decision made pursuant to the automated processing of personal information is sound and that this underlying logic may be able to be communicated to You to enable You to make representations.
If Lula Lend has made a decision based on incorrect personal information, it shall immediately revisit that decision as soon as it receives notice or becomes aware of the error or inaccuracy of that information.

16. LINKED THIRD PARTY WEBSITES

This website may contain links or references to other websites, including those of advertisers (“third party websites“) which are not under Lula Lend’s control.
The provisions of this Privacy Notice are not applicable to third party websites and Lula Lend shall not be responsible for the information processing practices and/or privacy policies of those third party websites, or the cookies that those websites may use.

17. DIRECT MARKETING

You hereby consent to the processing of Your personal information for the purpose of direct marketing by means of electronic communications including automatic calling machines, facsimile machines, SMS’s or electronic mail.
Where You are a pre-existing customer of Lula Lend, Lula Lend shall be entitled, without Your consent, to sending electronic communications to You for the purpose of marketing similar products or services offered by Lula Lend.
You may object, free of charge, and without unnecessary formality, to the use of their details either when the information was first collected from You or when each subsequent electronic communication is sent to You by Lula Lend and/or its subsidiaries.
You can opt out of receiving further marketing communications by un-checking certain boxes on the forms used on the website to collect their personal information, or by contacting Lula Lend at support@lulalend.co.za.

18. CHILDREN’S PERSONAL INFORMATION
Lula Lend does not knowingly process any personal information relating to a person under the age of 18 years. If this website is being accessed by the parent or guardian of a child under the age of 18 years, and personal information pertaining to that child is being provided by the parent or guardian, then they hereby expressly consent to Lula Lend processing such information according to the further provisions of this Privacy Notice.

19. CROSS BORDER TRANSFERS OF PERSONAL INFORMATION

Subject to clause 19.2, Lula Lend does not intend sharing Your personal information with a third party in another country.
Lula Lend may transfer personal information to another country in the following circumstances, to which You consent:
1. the transfer is necessary for the performance of a contract that Lula Lend has with You or the performance of services offered by Lula Lend to You;
2. the transfer is necessary for the implementation of pre-contractual measures taken in response to Your request;
3. the transfer is necessary for the conclusion or performance of a contract with a third party which is for the benefit of or in the interest of You;
4. the transfer is otherwise for the benefit of You;
5. You have consented to the transfer of Your information; or
6. to store Your personal information electronically in a secure database, which shall be done by electronically transmitting Your personal information via a secure connection to, and storing Your personal information electronically in, a secure database hosted in an ISO27001 certified environment.
The service providers to which Lula Lend discloses Your personal information in terms of clause 19.2 and/or the User Agreement have the right to electronically transmit Your personal information via a secure connection to, and store Your personal information electronically in, a secure database hosted outside South Africa, provided they have security and privacy policies and procedures providing at least the same level of protection as Lula Lend does.

20. RETENTION OF INFORMATION

Lula Lend will keep a record of any personal information collected for no longer than is necessary to achieve the specific purpose for which it collected such information in the first place unless:
1. it is required by law to keep a record of such information for a longer period of time; or
2. it needs to keep a record of such information for another lawful purpose; or
3. it has a contractual obligation to keep a record of such information; or
4. You have consented to their information being kept for a longer period.
Lula Lend may, if it has de-identified personal information, kept such information for historical, statistical or research purposes. Lula Lend shall ensure that appropriate safeguards are in place to prevent those records from being used for any other purposes, or against the information being re-identified.

21. RETURNING, DESTROYING OR DELETING PERSONAL INFORMATION

Where Lula Lend is no longer authorised to retain a record of any personal information, it shall either:
1. ensure that the information is permanently destroyed or deleted as soon as reasonably practicable; or
2. return the information to You or transfer it to a third party, if requested by You in writing to do so.

22. USER FORUMS ON THE LULA LEND WEBSITE
If You post content to or comment on another user's posts on a user forum on Lula Lend’s website, your views will be available to all persons who can access the forum. If You publish any of Your personal information onto a forum, Lula Lend will not be responsible for how other people make use of or process that information. Lula Lend reserves the right not to publish or to remove any posts it considers inappropriate.

23. CHANGE OF CONTROL
If Lula Lend merges with, or is acquired by, any other business, You will be notified and any personal information that Lula Lend holds about You will become available to that other business, but only in terms of the detailed terms of use of this Privacy Policy.

24. CONSENT

You hereby consent to the processing of Your personal information in terms of the provisions of this Privacy Notice.
You acknowledge and agree that such consent has been given voluntarily after You have read and understood the provisions of this Privacy Notice, in particular, regarding the following:
1. the types of personal information to be processed;
2. the specific processing activities to be undertaken;
3. the specific purpose/s for such processing; and
4. the possible consequences for You that may arise from such processing.
Should You wish to withdraw any consent previously given by You, You must notify Lula Lend’s information officer in writing. You have the right to withdraw any consent at any time, demand that the processing of the personal data be terminated and the gathered personal data be deleted or closed and that the Lula Lend user account be closed, provided that You do not have any valid Loan Agreements or any open or failed Loan applications in Lula Lend (all such terms being as defined in the User Agreement).

25. LODGING AN OBJECTION

You may, on reasonable grounds, object to the processing of Your personal information at any time after that processing has started.
If You wishes to object to the processing of Your personal information, You must send written notice of Your objection to Lula Lend’s information officer, together with Your reasons for doing so.

26. CHOICE OF LAW
This Privacy Notice shall be governed and interpreted in accordance with the laws of the Republic of South Africa.

27. AMENDMENT OF THIS PRIVACY NOTICE

Lula Lend reserves the right to change, update, add, remove and/or amend any of the provisions of this Privacy Notice from time to time. Such changes, updates, additions, removals or amendments will become effective from the date of their publication on this website.
It is Your obligation to periodically check the provisions of this Privacy Notice for any such changes, updates, additions, removals or amendments.
Your continued use of this website following any changes, updates, additions, removals or amendments to this Privacy Notice will be considered notice of Your acceptance to abide by and be bound by this Privacy Notice, as amended.

CONTACT
For more information on your rights to privacy over your information, or the information processing activities of Lula Lend, please do not hesitate to contact us directly on support@lulalend.co.za or alternatively contact Lula Lend on 087 943 2381.
Date of last update: 17 March 2020

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