Privacy Policy

We collect information: 

• when you give it to us directly; or 
• when you give it to us indirectly; or 
• when you give it to us via social media; or 
• when you use our websites or apps. 

Directly 
You may give us personal information when you: engage us as a service provider, apply to work with us, register as a user on our Site, sign up for one of our events, communicate with us, sign up or subscribe for email newsletters, complete a registration form, and/or leave a comment or message on our website or social media accounts.

When you contact us, as Site managers, the information sent in the manner provided is saved in order to complete your request or order. These direct interactions with us may stem from the following channels: face-to-face, website, and customer care and/or office-call interactions, website interactions including user registration, social networks interactions, and newsletter signups. 

Indirectly 
Churchill may also indirectly receive your personal information from your personal networks or social media platforms in the form of a referral or profile information. Similarly, indirectly supplied personal information may also be received for the purposes of recruitment or engaging us as a service provider.

Social media
We may get information about you from your social media accounts or services. Facebook, Twitter, Instagram, and LinkedIn are examples. We can do this if you have set your account settings to give us permission. Please check your settings and your social media provider’s privacy policies for more details.

In some cases, we hold publicly available information from social media channels (such as social media handles or number of followers) on our social customer relationship management system. This provides us with an overview of who drives the conversation on topics that relate to our work. Should we want to reach out to a particular social media handle, we would do so using the contact information they have provided publicly. 

Website and Apps 
We use “cookies” to help Churchill improve the performance of our websites and campaigns. 

Cookies are small text files that are transferred from the website to your computer, phone or tablet. Websites store cookies on your internet browser (Chrome, Firefox, Edge, or Internet Explorer, for example) when you visit. Every time you return to the Site, and navigate around, it picks up these bits of information. Cookies enable a faster and easier website experience. 

Data for the Newsletter 
If you wish to receive our Newsletter, you are required to provide us with your email address, and all information that enables us to verify that you are the email address holder, and that you are actually interested in receiving the Newsletter. No additional data is collected. The data provided is used exclusively to communicate the requested information, and is not forwarded to third parties.

The consent to save data, the email address, and receive the Newsletter can be withdrawn at any time by using the link “clear” in the Newsletter.

Find out more about how we use cookies on the Cookie Policy.  

Whenever you use the Site, comment, register, subscribe, download or apply online for any Churchill products or services, complete an application form, contact Churchill electronically, or use one of the products, services, facilities, tools, resources or utilities offered by Churchill on the Site, Churchill will collect your personal information.

We may have collected your information from other sources. If you share your personal information with any third parties, we will not be responsible for any loss suffered by you, your business or your employer, or employees.

You understand that when you include details of parties other than yourself on this Site or on your application or enrolment, we will process their personal information in line with the terms and conditions of this Site and/or to pursue legitimate interest. We will furthermore process their information for the purposes set out in this Privacy Policy.

If you are giving consent for a person under 18 years of age (a minor/child), you confirm that you are a Competent Person, and that you have authority to give their consent on their behalf.

We collect, and process your personal information mainly to provide you with access to our services, and products to help us improve our offerings to you, and for certain other purposes explained below. In order for us to do this, you must provide us with the information that we request, failing which, we cannot enter into a relationship with you or assist you.

If you contact Churchill directly, we will usually collect your:

• • Name; and
  • Surname; and
  • Email; and
  • Phone number; and
  • Address.

We will process personal information for the purposes set out in this Privacy Policy. You warrant that when you give us personal information about yourself or third parties, this information is accurate and correct and in the case of third parties you have received their permission to share their personal information with us for the purposes set out in this Privacy Policy or any other related purposes. If you are giving consent for a person under 18 years of age (a minor/child), you confirm that you are a Competent Person and that you have authority to give their consent on their behalf.

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, and we shall appreciate it if you would keep your personal information up to date, and accurate, by notifying us of any changes.

Website usage information is collected using “cookies” which allows us to collect standard internet visitor usage information. This includes information about how you logged on to our Site, including your IP address, information about your visit, your device information, and how you use our website. This will include the capture of your approximate location information – please see the Cookie Policy on our website for further information on this.

Our servers may also automatically collect information about your computer when you visit the Site, including without limitation the type of browser software you use, the operating system you are running, the website that referred you, and your Internet Protocol address.

Cookies:
A cookie is a piece of information that is deposited on your computer’s hard drive by your web browser when you use our computer server. The cookies enable us to recognise you, and give us information about your previous visits. We learn which advertisements bring users to our Site. Most browsers accept cookies automatically, but usually, you can alter your settings to prevent automatic acceptance. If you choose not to accept cookies, this may disable some of the features of our Website. The information that we collect and may share with our advertisers is anonymous and not personally identifiable. It does not contain your name, address, telephone number or email address.

 Mobile Device Identifiers:
Certain mobile service providers uniquely identify mobile devices and we or our third-party service providers may receive such device information if you access the Website through mobile devices. Certain features of our Website may require the collection of mobile phone numbers, and we may associate that phone number to the mobile device identification information. Additionally, some mobile phone service providers operate systems that pinpoint the physical location of devices that use their service. Depending on the provider, we or our third-party service providers may receive this information.

Embedded Scripts:
A script is a piece of program code that is used to make our Site function properly and interactively. This code is executed on our server or on your device.

An embedded script is a programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your computer from our web server or a third-party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter. Information collected through passive means may be non-identifying or may be associated with you. If the latter, it will be treated as personally identifiable information.

Information You Provide About A Third Party:
If you send someone else a communication from the Site, such as sending Site content to a friend, the information you provide (names, e-mail addresses etc.) is used to facilitate the communication and is not used for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you use any send-to-a-friend functionality on our Site, your e-mail address may be included in the communication sent to your friend.

Information Provided By Third Parties About You:
From time to time, we may supplement the information we collect with outside records from third parties in order to enhance our ability to serve you, to tailor our content to you and to offer you opportunities to purchase products or services that we believe may be of interest to you. We may combine the information we receive from those other sources with the information we collect through the Site. In those cases, we will apply this Privacy Policy to any personally identifiable information received, unless otherwise specifically disclosed by us at the time you provide your personally identifiable information.

Other Links / Sites: Our Site may link to or contain links to other third-party websites that we do not control or maintain. We are not responsible for the privacy practices employed by any third party website. We encourage you to note when you leave our website to read the privacy statements of all third-party websites before submitting any personally identifiable information.

The personally identifying information you supply is used to provide you with the information, downloads, or services you have requested, to respond to your inquiries or in other ways naturally associated with the circumstances in which you provided the information. For example, we may use your e-mail address to send you a confirmation notice. We may also use the information to communicate with you about new features, products or services, and/or to improve the services that we offer by tailoring them to your needs. You may opt-out from receiving such communication from us or any of our affiliated companies.

As a general rule, your personal data will not be used for any other purpose than that for which they were voluntarily provided to us. Your personal data are shared or transferred to third parties if such sharing or transfer is authorized by you or required to achieve the purposes for which you have provided them to us. For instance, by registering to our newsletter, you consent that your personal data (name and email) be processed for the purpose of sending you emails.

We will use your personal information only for the following purposes:

. To provide our products or services to you, to carry out the transaction you requested, and to maintain our relationship
• To conduct credit reference searches or verification for new clients
• To confirm and verify your identity, address, and banking details
• To verify that you are an authorised user
• For maintaining the accuracy of your personal information
• For operational purposes, and where applicable, credit scoring and assessment and credit management
• For the detection and prevention of fraud, crime, money laundering or other malpractice
• For debt tracing or debt recovery
• To conduct market or customer satisfaction research or for statistical analysis
• For audit and record-keeping purposes
• To promote social responsibility
• In connection with legal proceedings.

We will also use your personal information to comply with legal and regulatory requirements or industry codes to which we subscribe, or which apply to us, or when it is otherwise allowed by law (for example to protect Churchill’s interests).

We may also process your information, including personal, and special personal information, to conduct sanction screening against all mandatory, and non-mandatory sanctions lists, and we may communicate such personal information to local and International Regulatory Bodies as well as to other entities in the Churchill Group, if you are matched to one of these sanctions lists.

You agree that we may obtain and share information about your creditworthiness, or the creditworthiness of any payer, or your company with any credit bureau, or credit provider’s industry association, or industry body. This includes information about credit history, financial history, judgments, default history, and sharing of information for purposes of risk analysis, tracing, and any related purposes.

We also allow access to our database by third parties that provide us with services, such as technical maintenance, vendors that process credit card orders, administer our outbound marketing, and promotions, provide us with marketing or promotional assistance, analyse our data, assist us with customer service, etc. Our vendors agree to use this information, and we share information with them, only to carry out our requests. In addition, we may share your information with participating sponsors to a programme, course, promotion, or competition you may enter via our Site, our co-promotional partners, and others with whom we have marketing or other relationships. Other than as provided in this Privacy Policy, and our Terms of Use, or as set forth when you submit the information to the Site, we will not share or sell your personally identifiable information to third parties without your consent.

We reserve the right to use the information we collect about your computer, which may at times be able to identify you, for any lawful business purpose, including without limitation, to help diagnose problems with our servers, to gather broad demographic information, and to otherwise administer our Site.

While your personally identifiable information is protected as outlined above, we reserve the right to use, transfer, sell, and share aggregated, anonymous data about our users as a group for any business purpose, such as analysing usage trends and seeking compatible advertisers and partners.

In addition, as our business changes, we may buy or sell various assets, services, products, or business units. In the event all, or a portion of the aforementioned items owned or controlled by Churchill, its parent or any subsidiary or affiliated entity are sold, assigned, transferred or acquired by another company, the information from and/or about our Site users may be among the transferred assets.

You agree that we may process your personal information, and information supplied by you in regard to third-parties for all purposes that relate to the Site, and the products, services, facilities, tools, resources or utilities offered on the Site as informative and successful as possible, it is necessary for Churchill to find out exactly what you need and want.

Where applicable and to the extent appropriate, you confirm that we may share such information within the Churchill Group of companies:

• for administration;
• for fraud prevention;
• for the provision of Churchill services, benefits and infrastructure to help you in your personal or professional capacity.

You also confirm that we may share and combine all your personal information for any one or more of the following purposes:

– market, statistical and academic research; and
– to customise our benefits and services to meet your needs

By accepting this Privacy Policy, as a customer, you authorise us to obtain, and share information about your creditworthiness with any credit bureau or credit provider’s industry association or industry body. This includes information about credit history, financial history, judgments, default history and sharing of information for purposes of risk analysis, tracing, and any related purposes.

Your privacy is important to us and we will therefore not sell, rent, or provide your personal information to unauthorised third parties for their independent use, without your consent.

You agree that we may transfer your personal information outside South Africa:

• if you give us an email address that is hosted outside South Africa; or
• to administer certain services, for example, cloud services.

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.

You agree that we may communicate with you electronically about any changes to your information or newsletters, blog posts, articles, and subscriptions you have subscribed to or opted into.

We have a duty to keep you updated about any offers and new products or services that we make available from time to time. Any entity within the Churchill Group, and contracted third-party service providers, may communicate with you about these.

We may process your information using automated means (without human intervention in the decision-making process) to make a decision about you or your application for any product or service. You may query the decision made about you. We have the right to communicate with you electronically about any changes on your product, services or changes to fees and retainer fees in regard to the aforementioned.

Please also let us know if you do not wish to receive any direct electronic marketing from us. We will store your personal information for the purpose to action this request and action it as soon as reasonably possible.

Because Churchill is not responsible for any representations or information or warranties or content on any third party website (including third party websites linked to this Site, websites facilitated by us or websites that serve as social networks like Facebook or Twitter), Churchill does not exercise control over the privacy policies of these third parties, and you should refer to the privacy policy of these third parties to see how they protect your privacy.

Churchill may enter into arrangements with its partners and other third-party suppliers in order for them to provide services to you. Those arrangements may require us to disclose your personal information to them, whether in person or by means of an application or the Churchill App.

If a third party asks us for any of your personal information, we will share it with them only if:
– you have already given your consent for the disclosure of this information to that third party; or
– we have a legal or contractual duty to give the information to that third party.

You agree that your personal information may be shared with third parties such as academics, and researchers, including those outside South Africa. We ensure that the academics, and researchers will keep your personal information confidential and all data will be made anonymous to the extent possible and where appropriate. No personal information will be made available to a third party unless that third party has agreed to abide by strict confidentiality protocols that we require. If we publish the results of this research, you will not be identified by name.

If we want to share your personal information for any other reason, we will do so only with your permission.

If we become involved in a proposed or actual merger, acquisition or any form of sale of any assets, we have the right to share your personal information with the third parties in connection with the transaction. In the case of a merger, acquisition or sale, the new entity will have access to your personal information. The terms of the Privacy Policy will continue to apply.

We are legally obliged to provide adequate protection for the personal information we hold, and to stop unauthorised access, and use of personal information. We will, on an ongoing basis, continue to review our security controls, and related processes to ensure that your personal information is secure.

We may wish to transfer your personal information to another country for processing or storage. We will ensure that anyone to whom we pass your personal information agrees to treat your information with the same level of protection as we are obliged to.

Because no data transmission over the internet is completely secure, and no system of physical or electronic security is impenetrable, Churchill cannot guarantee the security of the information you send to us, or the security of your web browser or the security of your network or computing devices used in such communication or the security of our servers, hosted servers, or databases, and by using the Site you agree to assume all risk in connection with the information sent to us or collected by us when you use the Site. In the unlikely event that we believe that the security of your information in our possession or control may have been compromised, we may seek to notify you. If notification is appropriate, we may notify you by e-mail, provided that we have your e-mail address.

Notwithstanding anything to the contrary in this Privacy Policy, we reserve the right to disclose any personally identifiable or non-personal information about you if we are required to do so by law, and if we believe that such action is necessary to: (i) fulfil a government request; (ii) conform with the requirements of the law or legal process; (iii) protect or defend our legal rights or property, our Website, or other users; or (iv) in an emergency to protect the health and safety of our Site’s users or the general public.

You have an obligation to notify us, if any of your personal information held by Churchill changed or is no longer valid to ensure our records are up to date.

Churchill is committed to protecting the personal information of its clients, members, employees, and related stakeholders. A data subject is any individual whose data Churchill holds or processes. When a data subject needs access to such information to exercise or protect their rights, Churchill will facilitate the process.

You have the right to know what personal information we hold about you. As a data subject, you’ll be required to fill in the requisite form in order for us to assist you.

Access to information
We will take all reasonable steps to confirm your identity before providing details of your personal information. Please note that any such access request may be subject to a payment of a legally allowable fee.

Update, Correction or Deletion of your information
You agree that we may keep your personal information until we destroy your information based on Churchill’s destruction standards. You have the right to ask for an update, a correct or a deletion or destruction of your personal information – we will do that unless the law requires us to keep it or if we need it for legitimate business purposes. You may do this by using the appropriate form as detailed below.

Automated decision making
You agree that we may process your personal information by using automated means (without human intervention) to assess or make a decision about you or your application for any product or service.

Please take note of the requirements outlined in the manual. Incomplete submissions may delay our response to your submission.

Download and submit the form
Download the form, fill in it manually, and submit to us at contact@churchill.co.za, as per the instructions contained in the Churchill Access to Information Manual, and in the form stipulated below in line with the Protection Of Personal Information Act, 2013. Act No. 4 of 2013 (POPI/POPIA).

• Request access to information 

• Correction or deletion of personal data     or

• Object to the processing of personal data   or

• Lodge a data privacy complaint 

Churchill may amend this Privacy Policy at any time. We will give you notice of any material changes within a reasonable time, however, we recommend that you familiarise yourself with this Privacy Policy regularly.

The most updated version of this Privacy Policy will govern the respective rights and obligations between you, and Churchill each time that you access and use the Site.

Please check this Site periodically to inform yourself of any changes.

This Privacy Policy is governed by the laws of the Republic of South Africa, and you consent to the jurisdiction of the Cape Town, South African courts in respect of any dispute which may arise out of or in connection with the formation, interpretation, substance or application of this Privacy Policy.

If you believe that we have used your personal information contrary to this Privacy Policy, you must first attempt to resolve any concerns with us. If you are not satisfied after this process, you have the right to lodge a complaint with the Information Regulator, under the Protection of Personal Information Act.

The contact details are:

This Privacy Policy is complementary to and should be read and understood with, the general terms and conditions of the use of this Site.

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