Personal Information means information relating to an identifiable, living, natural person, and where it is applicable to, an identifiable, existing juristic person, including but not limited to:
a) information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth of the person;
b) information relating to the education or the medical, financial, criminal or employment history of the person;
c) any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier or other particular assignment to the person;
d) the biometric information of the person;
e) the personal opinions, views or preferences of the person;
f) correspondence sent by the person that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence;
g) the views or opinions of another individual about the person; and
h) the name of the person if it appears with other personal information relating to the person or if the disclosure of the name itself would reveal information about the person.

Special personal information and personal information concerning children Special personal information is:
a) unique identifiers. Examples of unique identifiers are, amongst others – Bank Account Numbers or any account number, Policy Number, Identity Number, Employee Number, Student Number, Telephone or cellphone number, or Reference Number;
b) religious or philosophical beliefs;
c) race or ethnic origin;
d) trade union membership or political persuasion;
e) health, or sex life or sexual orientation;
f) genetic or biometric information for the purpose of uniquely identifying a natural person;
g) process information for the purposes of credit reporting; and
h) criminal behaviour or unlawful or objectionable conduct of individuals.

Our main source of Personal Information are the Data subjects i.e. the individuals to whom the Personal Information relates, in exceptional cases, where information about children is processed, we collect it from the parent or legal guardian of the children to whom the Personal Information relates.

It is not mandatory that you provide us with your personal information but should you do so, you must accept all the terms of this policy when you register for an account or request the use of our services. If you do not agree with anything in this policy, then you should not register for an account or make use of the Dytabank website or its services.

The following table explains the types of data we collect and the legal basis, under current data protection legislation, on which this data is processed.

Purpose	Data (Key Elements)	Basis
Enquiring about our organisation and its services	Name, email, message.	Consent: it is necessary that you provide us with your consent before we collect this information about you, when you enquire about us or our services, in order for us to read and store your message so that we can provide you with a quality service.
Subscribing as seller	Identity Information Contact Information Education Information Employment Information Banking Information Income Information Expense Information Liability Information Asset Information Insurance Claims History Dependents Information Health History Information Social Media Information Pricing Information Sales Information	Consent: Since our contract incorporates selling your personal information to subscribed buyers if you are subscribed as a seller, it is necessary that you consent to our processing of your information, prior to entering into a contractual relationship with us as a seller, as set out in our user terms and conditions. This information is necessary as it enables us to manage our relationship and effectively meet our obligations to you. We may be unable to enter into an agreement and/or perform accordingly if you fail to provide the information needed.
Communicating with you	Contact details	Consent: it is necessary that you consent to us collecting and storing your contact details, prior to us initiating any communication with you.
Subscribing as a buyer (Supervisor)	Contact details Website Access details Company details Company revenue Bank Card details Purchase Information	Consent: it is necessary that you consent to our processing of your information, prior to entering into a contractual relationship with us as a Buyers’ supervisor, as set out in our membership terms and conditions. It is necessary that you provide this information, in order for us to manage our relationship and effectively meet our obligations to you. We may be unable to enter into an agreement and/or perform accordingly if you fail to provide the information needed.
Subscribing as a buyer (Representative)	Contact details Identification details Professional details Purchase Information	Consent: it is necessary that you consent to our processing of your information, prior to entering into a contractual relationship with us as a Buyer representative, as set out in our membership terms and conditions. It is necessary that you provide this information, in order for us to manage our relationship and effectively meet our obligations to you. We may be unable to enter into an agreement and/or perform accordingly if you fail to provide the information needed.
Subscribing to email updates about our work	Name and email	Consent: it is necessary that you give your consent prior to subscribing to receive email updates about our work.
Storage	All subscriber information	Legitimate interests of all users: we work with third party storage service providers to protect all users’ personal information from unauthorised access and maintain the integrity of all users’ information.
Data sharing	Name, email, address, bank card and payment information	Consent: it is necessary that you consent to us collecting and sharing your bank card details with our payment processing service provider, prior to us processing any payment. To facilitate payment for our product(s) and services, where the services you request carry a cost.
Buyer transactions and product quotes	Identification details, including unique identifiers such as identity numbers	Contract: we may collect personal information about you from third parties in order for us to perform third party buyer transactions and to provide you with third party product quotes. assist in making product quote decisions about consumers.
Website functionality	Website usage information collected automatically through cookies when using the Service	Legitimate interests: it is necessary for us to store a small amount of information, usually through cookies, to deliver functionality that you would expect, such as remembering the contents of your order before you have fully completed the process.
Security	IP address, location, device used, browser type, browser version, the pages of our service that you visit, the time and date of your visit	Security safeguards: We collect this information in order to ensure the security of our information and prevent data breaches.
Legal obligations	Any information necessary for legal processes	Where we are under a lawful obligation to disclose information, for example, if we receive a valid legal request for certain information such as a search warrant, we will access, preserve and/or share your information with regulators, law enforcement and the like.

By accessing and using our Website, you consent to us collecting and processing your Personal Information.

We will only use your data in a manner that is appropriate considering the basis on which that data was collected, as set out in the table at the top of this notice.

We will also use your personal information to:
*let you know about our policies and terms of service;
*create and maintain your account and profile;
*connect your account to third parties to share your information;
*promote the information products we sell on your behalf to third parties on our site. This information will be shared with that third party, but only with your consent and for the purpose of that promotion;
*compare and analyse product quotes from third parties, but only where you have provided your consent and for the purpose of providing you with only those product quotes that are competitive;
*have your information shared with, stored and/or processed by third parties, including across the borders of South Africa, but only with your consent and for the purpose of storage or processing;
*operate and provide the services described in the terms that apply to our services which you are using and product quotes from third parties;
*allow you to share information and connect with sellers, buyers and services provided by our partners;
*use less information that is connected to individual users, in some cases we de-identify or aggregate information or anonymize it so that it no longer identifies you;
*verify accounts and activity;
*detect and stop threats to our personnel and property;
*promote safety, security and integrity;
*handle transactions that you initiate;
*reply to enquiries when you contact us with questions;
*access and review your information;
*provide a personalized experience to you;
*fix, analyse and improve our services;
*to rate the quality of the information you provide to our partners;
*provide measurement, analytics and business services;
*conduct and support research for innovative for service improvement purposes;
*where you have specifically agreed to this, send you marketing communications by email relating to our work which we think may be of interest to you;
*We send messages about the services we know you use, using the email you register to your account. Depending on your settings, we send marketing communications about services you might like. We ask you to participate in research based on things like how you use our services;
*We facilitate customer support communications with you when you've told us;
*find and address violations of our terms or policies;
*investigate suspicious activity;
*detect, prevent and combat harmful or unlawful behaviour against vulnerable individuals and/or communities;
*detect and prevent spam and other bad experiences and provide support; and
*maintain the integrity of our services.

We will only pass your data to third parties in the following circumstances:

*We make available to you services and products provided by third parties for use on or through our Dytabank website. For example, you can sell your personal information to third-party businesses, such as accredited financial service providers and in turn they may provide you with competitive insurance quotes. You can tell when a third party is involved in the transaction, because your personal information will be shared with that third party only, and only with your consent and for the purpose of that transaction only;
*We employ other companies and individuals to perform functions on our behalf. Examples include processing payments and transmitting content, and providing cloud storage service. These third-party service providers have access to your personal information needed to perform their functions, but may not use it for other purposes;
*you are required to provide your consent for us to pass data to named third parties and you receive notice when personal information about you might be shared with third parties, and you will have an opportunity to choose not to share the information;
*we are using third parties purely for the purposes of processing data on our behalf and we have in place data processing agreements with those third parties that fulfil our legal obligations in relation to the use of third parties; and
*we may also be required by law to share your data.
*We will never share your information with any entity without your consent.

We use AWS to store and protect personal information collected from our website subscribers. The AWS privacy policy is available here: https://aws.amazon.com/compliance/data-privacy-faq/#:~:text=We%20do%20not%20access%20or,more%20than%20one%20AWS%20Region.

We use PayFast to enable online payments by bank card. The PayFast privacy policy is available here: https://www.payfast.co.za/wp-content/uploads/2021/10/PayFast-Privacy-Policy.pdf.

In addition, we will not pass data to third parties outside of the Republic of South Africa without your consent and should we do so in future, we will only do so where appropriate safeguards are in place as defined by the Protection of Personal Information Act 4 of 2013.

We take the principles of data minimisation and removal seriously and have internal policies in place to ensure that we only ever ask for the minimum amount of data for the associated purpose and delete that data promptly once it is no longer required. Where data is collected on the basis of consent, we will seek renewal of consent at least every three years. By accessing and using the Website, you consent to us retaining records of your Personal Information for no longer than may be necessary to achieve the purpose for which the information was initially collected or subsequently processed.

You have a range of rights over your data, which include the following:
*Where data processing is based on consent, you may revoke this consent at any time and we will make it as easy as possible for you to do this (for example by putting ‘unsubscribe’ links at the bottom of all our marketing emails).
*You have the right to ask for rectification and/or deletion of your information.
*You have the right of access to your information.
*You have the right to lodge a complaint with the Information Regulator if you hold the perception that your rights have been infringed.

A full summary of your legal rights over your data can be found on the Information Regulator’s website here: https://inforegulator.org.za

If you would like to access the rights listed above, or any other legal rights you have over your data under current legislation, please get in touch with us at [email protected].

Please note that relying on some of these rights, such as the right to deleting your data, will make it impossible for us to continue to deliver some services to you. However, where possible we will always try to allow the maximum access to your rights while continuing to deliver as many services to you as possible.

A cookie is a small file of letters and numbers that is downloaded on to your computer when you visit a website. Cookies are used by many websites and can do a number of things, for example, remembering your preferences, protecting the security of your account, recording what you have put in your shopping basket, your incomplete transaction, and counting the number of people looking at a website. Where cookies are used to collect personal data, we list these purposes in section 1 above, along with other personal data that we collect. However, we also use some cookies that do not collect personal information but that do help us collect anonymous information about how people use our website. By accessing and using the Website, you consent to our use of cookies.

We may modify this Privacy Notice from time to time and will publish the most current version on our website. If a modification meaningfully reduces your rights, we'll notify people whose personal data we hold and is affected.