Privacy Policy

Evolution Group – Privacy and Personal Information Notice.

Who we are
1. We are a purpose-led organisation that recognises the unique challenges and opportunities people face in their lives. We share our expertise to create brighter futures, through the responsible provision of financial services and products. We drive financial wellness, and are a platform for growth, sustainability and improvement.
2. Incorporated in 2001, Evolution is built on a focused portfolio of businesses. These centre around providing responsible finance to individuals and customer-centric debt management solutions to businesses.
3. Our Portfolio of business consists of, amongst others,
  1. Evolution Finance
  2. Evolution Life
  3. DMC Debt Management
4. For the purposes of this notice. “We” or “Us” or “Our” shall include Evolution Credit Ltd and all its subsidiaries, affiliate and associate entities (“the Evolution Group”).
5. For the purposes of this notice. “you” or “your” shall include our customers, service providers, employees and/or applicants for employment.
6. Any product or service offered to a customer by any company in the group is referred to as a solution in this document.

Purpose of this notice
1. We have developed this privacy notice (notice) to enable you to understand how we collect, use and safeguard your personal information.
2. We collect personal information about you. This includes what you tell us about yourself, what we learn by having you making use of a solution or product or interacting with us in anyway, as well as the choices you make about the marketing you elect to receive. This notice also outlines your privacy rights and how the law protects you.
3. Where we process personal information for another party under a contract or a mandate, the other party’s privacy policy or notice will apply.
4. In this notice “process” means how we collect, use, store, make available, destroy, update, disclose, or otherwise deal with your personal information.
5. We may combine your personal information and use the combined personal information for any of the purposes stated in this notice.
6. VERY IMPORTANT: If you use any of our solutions and service channels (including both assisted and unassisted interactions), or by accepting any agreement, contract, mandate or annexure with us or by utilising any solutions offered by us, you agree that in order to:
  1. conclude and fulfil contractual terms or obligations to you; or
  2. comply with obligations imposed by law; or
  3. protect or pursue your or our customers’, or our, or a third party’s legitimate interests, including offering solutions that best meet customers’ needs;
  4. your personal information may be processed through centralised functions and systems across companies in the group and may be used for the purposes, in the manner, and with the appropriate controls as set out in this notice.
7. We may change this Privacy Notice at any time. The most updated version will be available on https://www.evolution.za.com/legal-and-compliance/
8. NOTE: this notice is subject to our Information Protection Policy – available at https://www.evolution.za.com/legal-and-compliance/

What is Personal Information
1. For the purpose of this notice personal information means any information or combination of information that belongs to and/or can be used to identify a natural or juristic person.
2. Personal information includes, but is not limited to, the following information:
  1. marital status (married, single, divorced); national origin; age; language; birth; education;
  2. financial history (e.g. income, expenses, obligations, lending, insurance);
  3. employment history and current employment status;
  4. gender or sex (for statistical purposes as required by the law);
  5. identifying number (e.g. an account number, identity number or passport number);
  6. Contact details;

Personal Information Collected
1. We collect and process personal information about your financial position and/or needs. If you are a customer the type of information will depend on the type of customer you are, e.g. credit and/or insurance, the need for which it is collected and will be processed for that and or a related purpose only. Examples of personal information we collect and process include, but is not limited to:
  1. Your Identity number, name, surname, address, postal code, marital status, and number of dependants;
  2. Description of your residence, business, employment, assets; financial information, banking details, etc.;
  3. Any other information required by us, our suppliers and our insurers to provide you with the goods and services which forms part of our business being financial services related to long term insurance, the provision of credit and debt collection.
  4. We are further obliged to process certain information as required in terms of Financial Sector laws, including, but not limited to, The Financial Intelligence Centre Act, The National Credit Act, The Financial Advisory and Intermediary Services Act.
2. We also collect and process personal information for marketing purposes to ensure that our products and services remain relevant to our customers and potential customers. Please let us know of you do not want to receive marketing material or calls.
3. If you object or refuse to provide us with your information, we may choose to end our relationship with you. Note however that we may still be entitled to process your information based on a legal requirement or contractual obligation.

When, and from where, we obtain personal information about customers
1. We have a duty to take all reasonably practicable steps to ensure your Personal Information is complete, accurate, not misleading and updated on a regular basis. To enable this, we will always try to obtain Personal Information from you directly. Where we are unable to do so, we will make use of verifiable independent third-party data sources.
2. We collect and process your personal information at the start of, and for the duration of your relationship with us. We may also process your personal information when your relationship with us has ended.
3. The third parties (which may include parties we engage with as independent responsible parties, joint responsible parties or operators) from whom we may collect personal information included, but are not limited to, the following:
  1. members of the group, any connected companies, subsidiary companies, its associates, cessionaries, delegates, assignees, affiliates or successors in title and/or appointed third parties (such as its authorised agents, partners, contractors and suppliers) for any of the purposes identified in this notice;
  2. spouses, dependants, partners, employer, joint applicant or account holder and other similar sources;
  3. attorneys, tracing agents, debt collectors and other persons that assist with the enforcement of agreements;
  4. payment processing services providers, merchants, banks and other persons that assist with the processing of customers’ payment instructions;
  5. insurers, brokers, other financial institutions or other organisations that assist with insurance and assurance underwriting, the providing of insurance and assurance policies and products, the assessment of insurance and assurance claims, and other related purposes;
  6. law enforcement and fraud prevention agencies, and other persons tasked with the prevention and prosecution of crime;
  7. regulatory authorities, industry ombudsmen, government departments, and local and international tax authorities;
  8. credit bureaux;
  9. qualification information providers;
  10. trustees, executors or curators appointed by a court of law;
  11. our service providers, agents and subcontractors, such as couriers and other persons we use to offer and provide solutions to customers;
  12. courts of law or tribunals;
  13. marketing list providers;

The Use of Personal Information
1. The Personal Information will be used for the purpose for which it was collected or obtained.
2. The purpose for which we use personal information may include the following;
  1. Providing products or services and to conclude transactions as requested;
  2. Assessing and processing claims and or queries;
  3. Conducting credit reference and affordability assessments;
  4. Confirming, verifying and updating information;
  5. Enforcing our legal rights;
  6. Debt collection and credit management;
  7. For the detection and prevention of fraud, crime, money laundering or other malpractices;
  8. Conducting market or customer satisfaction research;
  9. For audit and record-keeping purposes;
  10. In connection with legal proceedings;
  11. Providing services to you, to render the services requested and to maintain and constantly improve the relationship;
  12. Providing communication in respect of our business and regulatory matters that may affect you; and
  13. In connection with and to comply with legal and regulatory requirements or when it is otherwise allowed by law
3. We will only process personal information if one or more of the following conditions are met;
  1. With consent;
  2. Where the processing is necessary to enable us to perform our duties or enforce our legal rights;
  3. Where processing complies with an obligation imposed by law;
  4. Where processing protects a legitimate interest of the customer, it is in the customer’s best interest to
    1. have a full and proper assessment performed to provide them with an applicable, beneficial and affordable product or service; or
    2. assist customers with debt to meet their financial obligations, and support our customers on their journey to become financially independent; or
    3. assist customers in obtaining appropriate long term insurance products and cover.
  5. Processing is necessary for pursuing our legitimate interests or those of a third party to whom information is supplied — in order to provide customers with products and or services both we and any of our product suppliers require certain personal information from the customers to make an expert decision on the unique and specific product and or service required.

Disclosure of Personal Information
1. We may disclose your personal information to any of our group companies or subsidiaries, joint venture companies and or approved product- or third-party service providers whose services or products customers elect to use, subject to agreements being in place to ensure that compliance with confidentiality and privacy conditions.
2. We may also share your personal information with, and obtain information about you from third parties for the purposes listed above.
3. We may also disclose your information where we have a duty or a right to disclose in terms of applicable legislation, the law, or where it may be deemed necessary in order to protect our rights.
4. We may disclose personal information we collected to our shareholders, funders or third-party service providers, with whom we engage in business or whose services or products we elect to use.
5. We endeavour to enter into written agreements to ensure that other parties comply with our confidentiality and privacy requirements.

Cross Border Transfer of Information
1. We may disclose personal information we collected to our shareholders, funders or third-party service providers, with whom we engage in business or whose services or products we elect to use, including cloud services hosted in international jurisdictions.
2. We will ensure that any country, company or person that we pass your Personal Information to agrees to treat your information with the same level of protection as we are obliged to.

Centralised Processing
1. We aim to create efficiencies in the way it processes information across the group. Your personal information will therefore be processed through centralised group functions and systems, which includes the housing of your personal information in a centralised group data warehouse.
2. This centralised processing is structured to ensure efficient processing that benefits both you and the group. Such benefits include, but are not limited to:
  1. improved information management, integrity and information security;
  2. the leveraging of centralised crime and fraud prevention tools;
  3. better knowledge of a customer’s financial service needs so that appropriate solutions can be advertised and marketed to the customer;
  4. a reduction in information management costs; and
  5. streamlined transfers of personal information for customers with solutions across different businesses or companies within the group.
3. In order to:
  1. conclude and fulfil contractual terms or obligations to a customer; or
  2. comply with obligations imposed by law; or
  3. to protect or pursue customers’, the group’s, or a third party’s legitimate interests, including offering solutions that best meet customers’ needs;
  4. customers’ personal information may be processed through centralised functions and systems across companies in the group and may be used for the purposes and/or related purposes, in the manner, and with the appropriate controls as set out in this notice and our Information Protection Policy

Customers’ Duties And Rights Regarding The Personal Information We Have About Them
1. You must provide us with proof of identity when enforcing the rights below.
2. You must inform us when their personal information changes, as soon as possible after the change.
3. You confirm that, where you provide us with personal information of your spouse, dependants, beneficiaries or any other person, you have permission from them to share their personal information with us. We will process the personal information of your spouse, dependents, beneficiaries or any other person which you have shared with it as stated in this notice.
4. You have the following rights;
  1. Right of access to and request to rectify information
  2. Right to object to processing
  3. Right to lodge a complaint to the Information Regulator
5. In order to exercise the rights in 10.4 you must follow the process as set out in our Promotion of Access to Information Manual – available at https://www.evolution.za.com/legal-and-compliance/
6. 10.6 If, you feel that we have not resolved your complaint adequately you can contact the information regulator through its website https://inforegulator.org.za/contact-us/