Privacy Policy

Effective date: 24 June 2025

At Prime Loans Technology (Pty) Ltd (2024/739416/07/ NCRCP20937) (“PrimeLoans”), we prioritize the safeguarding of your Personal information. This Privacy Policy outlines how we collect, use, and protect your Personal data when you engage with our Services and Platform at primeloans.co.za and any associated platforms (collectively referred to as “the Platform”) or provide your Personal information in other ways. Our commitment to respecting your privacy ensures adherence to the highest standards. 

PrimeLoans operates as a private limited liability company and registered credit provider, fully compliant with the laws of the Republic of South Africa. 

Please note that some terms used in this Privacy Policy may not be defined sequentially but are clarified within our Terms and Conditions of Use (“Terms”). 

We encourage you to review all the provisions in this Privacy Policy, along with related policies and guidelines, to understand your rights and obligations comprehensively. 

1. Important Information and Who We Are 

1.1 Purpose of this Privacy Policy 

1.1.1 This Privacy Policy provides detailed information on how we collect, handle, and safeguard your Personal Information during your interactions with us. It aligns with the requirements of POPI. 

1.1.2 We recommend reading this Privacy Policy alongside other privacy notices or processing guidelines we may provide at specific instances of Personal Information collection or processing. This document is intended to complement such notices, not replace them. 

1.1.3 PrimeLoans does not process the Personal Information of children or any Special Personal Information as defined in section 26 of POPI (including religious or philosophical beliefs, race, health data, biometric and criminal records). Providing such Special Personal Information constitutes a direct breach of this Privacy Policy and our Terms. 

1.2 Responsible Party and Operator 

1.2.1 PrimeLoans’ Role 

PrimeLoans serves as the “Responsible Party” in determining how your Personal Information is processed as defined in section 1 of POPI. In certain cases, we may act as an “Operator”, as defined in section 1 of POPI, processing Personal Information on behalf of a third party. Where we act as an Operator, we do so in compliance with section 20 and 21 of POPI.

1.2.2 Information Officer 

PrimeLoans has designated an “Information Officer” to address inquiries regarding this Privacy Policy. Should you have any questions or wish to exercise your legal rights, please contact our Information Officer using the details below. 

1.3 Our Contact Details 

1.3.1 Our full details are: 

• Full Name: Prime Loans Technology (Pty) Ltd 
• Information Officer: Nita Morgan 
• Email Address: [email protected] 
• Postal Address: Dock road Junction corner of Stanley and Dock road Waterfront Western Cape 8001 
• Telephone Number: +27 21 139 0909 

1.3.2 You may also file a complaint with the Information Regulator’s Office of South Africa, 27 Stiemens  Street, Braamfontein, 0001 (010 023 5200). Complaints may also be lodged using the prescribed Form 5, available on the Information Regulator’s website at www.inforegulator.org.za/complaints and submitted to [email protected]. However, we encourage you to allow us the opportunity to resolve your concerns before contacting the regulator. 

1.4. Changes to this Privacy Policy 

1.4.1 We aim to keep your Personal data accurate and current. Please notify us of any changes to your Personal information during your engagement with us. 

1.4.2 This Privacy Policy may be updated periodically without prior notice. Changes take effect upon publication on our Platform. Continued use of our Services indicates your acceptance of the updated Privacy Policy. We encourage regular review of this document to remain informed about any modifications. 

1.5 Third-Party Links on Platform 

Our Platform may contain links to third-party websites, plug-ins, or applications. Interacting with these links or connections may allow third parties to collect or share your Personal Information. PrimeLoans does not control third-party platforms and is not responsible for their privacy policies or practices. We advise you to review the privacy policies of any third-party platforms you engage with.

2. What We Collect About You 

2.1 Personal Information, as defined in POPI, refers to any information about an individual, including both natural persons and legal entities (i.e., people and companies), that allows for their identification. This does not include anonymous information, where identifying details have been removed.  

2.2 We collect, use, store, and process various types of Personal Information, which we categorise as follows: 

2.2.1. Identity Data: Includes your full name, identity number, and, for businesses, company name, address, and registration details;

2.2.2 Contact Data: Includes email addresses, physical or registered addresses, proof of address, and contact phone numbers;

2.2.3 Profile Data: Covers information in your customer profile, such as credit history, account statements, and payment records;

2.2.4 Employment Data: Includes employment status, employer details, and salary or wage information. 

2.2.5 Financial Data: May consist of copies of payslips, recent bank statements, bank account details (for debit order authorisation), and payment provider or card details processed on our behalf by third-party service providers. 

2.2.6 Transaction Data: Contains details of payments made to or received from you, contracts, contractual terms, fees, subscriptions, invoices, and services rendered or received. 

2.2.7 Technical Data: Includes IP addresses, login data, browser details, time zone settings, cookies, operating system information, and other technical data about devices used to access our platform. 

2.2.8 Usage Data: Relates to how you interact with our services, platform features, surveys, and other offerings. 

2.2.9 Marketing and Communications Data: Encompasses preferences for receiving notifications and marketing from us and third parties, along with details on communication methods used.  

2.2.10 Support Data: Covers messages sent to us via email or through the platform, as well as records of telephone interactions. 

2.3 We may also collect and utilise “Aggregated Data”, such as statistical or demographic information, for various purposes. Although derived from Personal Information, Aggregated Data is not considered Personal under the law as it does not reveal individual identities. However, if combined with Personal Information, it will be treated as such in compliance with this Privacy Policy. 

2.4 If you are required by law or contract to provide Personal Information and fail to do so, we may be unable to deliver services or fulfil contractual obligations. In such cases, we may have to restrict platform access or terminate services, but we will notify you beforehand. 

3. How Is Your Personal Information Collected 

3.1 We collect Personal information through various methods: 

3.1.1 Direct Interactions: You may provide Personal information by: 

3.1.1.1 Completing a loan application form. 

3.1.1.2 Communicating with us via platform, phone, email, or other means. 

3.1.1.3 Using our services or platform. 

3.1.1.4 Entering into contracts with us. 

3.1.1.5 Providing services as an independent contractor. 

3.1.1.6 Requesting information or providing feedback. 

3.1.2 Automated Technologies: As you interact with our platform, we may automatically collect technical and usage data through cookies, server logs, and similar technologies. We may also receive technical data when you visit other platforms using our cookies. 

3.1.3 Third Parties: We may obtain Personal information from: 

3.1.3.1 Credit bureaus. 

3.1.3.2 Analytics providers. 

3.1.3.3 Financial institutions. 

3.1.3.4 Marketing platforms. 

3.1.3.5 Search information providers. 

4. How We Use Your Personal Information 

4.1 We use your Personal information only when legally permitted and for legitimate purposes, to which you expressly consent. Common uses include: 

4.1.1 With your explicit consent. 

4.1.2 To fulfill contractual obligations for services provided to or by you. 

4.1.3 Where necessary for legitimate business interests, provided they do not override your rights and interests. 

4.1.4 To comply with legal or regulatory obligations. 

5. Purposes for Which We Process Your Personal Information 

5.1 We have outlined below, in a structured table format, 

5.1.1 the purposes for processing your Personal information,

5.1.2 the types of data processed and

5.1.3 the lawful bases for such processing.

5.2 Depending on the context, we may process your information under multiple lawful grounds. 

5.3 Quality Control 

To ensure high service standards and transparency, all interactions with us, including telephone calls, may be recorded for quality control, staff training, and regulatory compliance purposes. You may request a copy of any recorded conversation by contacting us. 

5.4 Marketing Practices 

We aim to offer you choices regarding your Personal information usage, particularly for marketing and advertising purposes. You can opt out of receiving marketing communications by using the built-in prompts or contacting us directly. 

5.5 Third-Party Marketing 

We will never share your Personal information with external third parties for marketing purposes without obtaining your explicit opt-in consent. 

5.6 Change of Purpose 

5.6.1 Should we need to use your Personal Information for a purpose other than the one originally collected, we will inform you and outline the legal basis for such use. In certain, limited circumstances, we may process your Personal Information, without your specific consent, where legally permitted or required by law. In such circumstances, we will notify you in compliance with section 18 of POPI. 

5.6.2 Your Personal Information will only be used for purposes aligned with the reason it was initially collected unless we determine the need for a compatible purpose. For clarification, please contact us.  

6. Disclosures of Your Personal Information 

6.1 We may need to disclose your Personal information to the following parties for the purposes outlined in the table above: 

6.1.1 Internal Affiliates: As detailed in the Glossary, these include members within our organisation who assist in managing and delivering our services. 

6.1.2 External Partners: As defined in the Glossary, these third parties are engaged to support various aspects of our operations, such as service provision or compliance. 

6.1.3 Corporate Transactions: Third parties involved in any sale, transfer, or restructuring of our business or assets. In the event of such changes, your Personal Information may be handled as outlined in this Privacy Policy. 

6.2 We ensure that all third-party recipients of your Personal Information adhere to strict confidentiality and data security requirements, complying fully with applicable laws. Third-party service providers are prohibited from using your Personal Information for any purpose other than those specified by us and operate under our explicit instructions. 

6.3 As a registered credit provider, we also share your Personal Information with authorised credit bureaux for credit evaluation purposes. We utilise the services of credit bureaux such as Experian (https://www.experian.com/), which operate in accordance with the regulations of the National Credit Regulator. 

7. Cookies 

7.1 Our Platform uses “cookies” to collect information about your interactions with our site automatically. Cookies are small data files stored on your device that help us improve user experience, track usage, and deliver targeted content or advertisements. 

7.2 The data collected through cookies is aggregated and not used to personally identify you. If you prefer not to have cookies enabled, you can modify your browser settings to disable them. However, this may limit your ability to access certain features or functionalities of our Platform. By continuing to use our Platform without disabling cookies, you consent to our use of cookies in accordance with this Privacy Policy. 

8. International Transfers 

8.1 Your Personal information may be processed or stored outside South Africa for purposes such as cloud hosting or collaboration with international service providers. 

8.2 To ensure your Personal Information remains protected during international transfers, we implement the following safeguards:

8.2.1 We only transfer Personal Information to jurisdictions with privacy laws that meet or exceed the standards established in South Africa;

8.2.1 Where applicable, we utilise contracts or clauses designed to enforce strict security and compliance measures during cross-border data transfers; 

8.3 If you require additional details about international transfers of your Personal information, please contact us. 

9. Data Security 

9.1 We prioritise the security of your Personal Information by implementing robust measures to prevent unauthorised access, accidental loss, or misuse. These include: 

9.1.1 restricting access to your Personal Information to employees, agents, and contractors with a legitimate operational need; 

9.1.2 ensuring all individuals or entities processing your Personal Information on our behalf comply with confidentiality obligations; and

9.1.3 maintaining comprehensive procedures to detect, respond to, and mitigate information breaches. Where required, we will promptly inform you and the Information Regulator of any breaches. 

9.2 Our commitment to data security is ongoing, and we continuously evaluate and enhance our protective measures to safeguard your Personal Information. 

10. Data Retention 

10.1 We will retain your Personal Information only for as long as necessary to achieve the purposes for which it was collected and/or as required by applicable law. Such laws include, but are not limited to –

10.1.1 records of credit applications, agreements, and enforcement actions, retained for a minimum of three years from the termination of the credit agreement in accordance with section 170 of the National Credit Act 34 of 2005, as amended and regulations 55 and 56 of the regulations promulgated under the National Credit Act;

10.1.2 records of financial transactions and client identification retained, for at least five years following the conclusion of a transaction or termination of the relationship, in terms of section 22 of the Financial Intelligence Centre Act 38 of 2001, as amended;

10.1.3 company records including accounting and communications logs, retained for a minimum of seven years as required by section 24 of the Companies Act 71 of 2008, as amended; and

10.1.4 tax records, including payroll, invoices, and supporting financial documentation, retained for a minimum of five years as required by section 29(3)(a) of the Tax Administration Act 28 of 2011, as amended, and read with the Income Tax Act 56 of 1962, as amended.

10.2 To determine the appropriate retention period for your Personal information, we consider: the nature, scope, and sensitivity of the Personal Information;

10.2.1 the nature, scope, and sensitivity of the Personal Information;

10.2.2 the potential risks associated with unauthorised access or disclosure; 

10.2.3 the purposes for which the information is processed and whether those purposes can be achieved through alternative means; and

10.2.4 any applicable South African legal requirements. 

10.3 In the absence of any prescribed retention period, we will retain Personal Information only for so long as necessary for operational, legal, or reporting purposes. Once the retention period expires, or the ,Personal Information will be securely deleted or de-identified in accordance with section 14 of POPI. De-identified information, which cannot be traced back to you, may be retained and used indefinitely for research or statistical analysis without further notice to you. 

11. Your Legal Rights 

11.1 You have rights in relation to your Personal Information where we are the relevant Responsible Party over such Personal Information. Please contact us to find out more about, or to manifest, these rights: 

11.1.1 request access to your Personal information; 

11.1.2 request correction of your Personal information; 

11.1.3 request erasure of your Personal information; 

11.1.4 object to the processing of your Personal information; 

11.1.5 request a restriction of processing your Personal information; and

11.1.6 request transfer of your Personal information. 

11.1.7 Right to withdraw consent. This withdrawal will not affect the right of PrimeLoans to process your Personal Information where it has a legal requirement to do so, or where a competent authority with the necessary jurisdiction has directed it to process or disclose such Personal Information

11.2 Important Notices 

11.2.1 Fees: Accessing your data or exercising your rights is free of charge. However, we reserve the right to charge a reasonable fee if a request is unfounded, repetitive, or excessive. 

11.2.2 Verification: To protect your privacy, we may request specific details to confirm your identity before processing any request. Additional information may also be sought to expedite our response. 

11.2.3 Response Time: We strive to respond to all valid requests within one month. Complex requests or multiple concurrent requests may require additional time, in which case we will inform you of the delay. 

11.2.4 Means of Contact: To exercise your legal rights listed above, please send your request to our Information Officer at [email protected]. 

11.2.5 Account Cancellation: Information on cancellation (deletion) of your Personal Account can be found at this link https://primeloans.co.za/account-cancellation/. 

11.3 If you are not a South African citizen, please note that our information processing complies with South African privacy protection laws. Should foreign legislation be applicable to your use of our services or platform, including the processing of your Personal Information, kindly contact us to discuss your rights under that jurisdiction. 

12. Glossary 

12.1 Lawful Basis: 

12.1.1 Legitimate Interest: Refers to our need to manage our organisation effectively, ensuring a secure, high-quality user experience while balancing any potential impact on your rights. We will not process your Personal Information based on legitimate interests if it is overridden by your rights or if we lack your consent.  

12.1.2 Performance of Contract: Relates to processing necessary to fulfill a contractual agreement or to prepare for entering into one with you. 

12.1.3 Legal/Regulatory Obligation: Involves processing required to meet legal or regulatory requirements. 

12.1.4 Express Consent: Represents your explicit agreement to Personal Information processing, as confirmed by your active acceptance of this Privacy Policy. 

12.2 Third Parties: 

12.2.1 Internal Affiliates: Entities within the PrimeLoans group involved in joint operations or responsible party activities. 

12.2.2 External Partners:  

12.2.2.1 Authorized Service Providers: External providers contracted to perform services linked to your use of our platform. 

12.2.2.2 Governmental Authorities: South African or other national governments and/or their respective authorities pursuant to our adherence with anti-corruption and crime-fighting legislation; and/or 

12.2.2.3 Professional Advisers: Consultants, lawyers, auditors, or insurers who provide advisory or operational support. 

12.3 Your Legal Rights: You are entitled to exercise certain rights concerning your Personal Information, which we manage as the Responsible Party. Below is an overview of your rights: 

12.3.1 Access Your Personal Information: You may request a copy of the Personal Information we hold about you, enabling you to confirm its accuracy and ensure it is being processed lawfully. y. 

12.3.2 Rectify Your Data: You have the right to request corrections to incomplete or inaccurate Personal Information we hold about you. Verification of the accuracy of any new information you provide may be required before updates are made. . 

12.3.3 Request Erasure: You may ask us to delete or remove your Personal information under the following circumstances: 

12.3.3.1 It is no longer necessary for the purposes it was collected; 

12.3.3.2 You successfully object to its processing (see below); 

12.3.3.3 It has been processed unlawfully; or 

12.3.3.4 We are legally required to erase it. 

Please note that certain legal or regulatory obligations may prevent us from complying with your request to delete specific information. If applicable, we will inform you of the reasons for this at the time of your request. 

12.3.4 Object to Processing: 
You may object to the processing of your Personal information when: 

12.3.4.1 The processing is based on legitimate interests, and you believe it impacts your fundamental rights and freedoms; or 

12.3.4.2 The information is being used for direct marketing purposes. 

12.3.4.3 In some cases, we may demonstrate that our legitimate grounds for processing your information override your objection. 

12.3.5 Restrict Processing: 
You can request a temporary suspension of processing your Personal information in specific scenarios, such as: 

12.3.5.1 If you wish to verify the accuracy of the information; 

12.3.5.2 Where the processing is unlawful, and you prefer restriction over deletion; 

12.3.5.3 If the data is no longer required by us, but you need it to establish, exercise, or defend legal claims; or 

12.3.5.4 If you have objected to processing, and we are verifying whether overriding legitimate grounds exist.

12.3.6 Data Portability: You may request that we transfer your Personal Information to you or a third party of your choice in a structured, commonly used, and machine-readable format. This right applies only to automated Personal Information processing based on your consent or when the Personal Information was used to perform a contract. 

12.3.7 Withdraw Consent: You can withdraw your consent at any time where we rely on it to process your Personal Information. This will not affect the legality of processing conducted before your consent was withdrawn. Please note that withdrawing consent may limit our ability to provide certain features, services, or platform access. We will notify you of such consequences, if any, at the time of withdrawal.  

Important Notice on Consent 

While you retain the right to withdraw consent under POPI, other applicable South African legislation may require us to continue processing your Personal Information (as detailed hereinabove). This includes compliance with anti-corruption, crime prevention, and other legal obligations, which you explicitly acknowledge and agree to.