1. DEFINITIONS

In this Policy (as defined below), unless the context requires otherwise, the following

capitalised terms shall have the meanings given to them —

1.1. “Active Processing” means instances where Z-Fin t/a Zero Finance has directly been

provided with the Personal Information of Data Subjects, such as when Data

Subjects submit an enquiry in respect of its Services, or when Data Subjects provide

Personal Information to Z-Fin t/a Zero Finance pursuant to concluding any commercial

agreement(s) with Z-Fin t/a Zero Finance;

1.2. “Inactive Processing” means instances where Z-Fin t/a Zero Finance has not actively been provided with the Personal Information of Data Subjects, such as when Z-Fin t/a Zero Finance

deploys Passive Processing Means to collect information from Data Subjects. These

Passive Processing Means allow Z-Fin t/a Zero Finance to Process certain kinds of Non-Personally Identifiable Information which can perhaps not be linked to Data Subjects;

1.3. “Anonymisation” means the Processing of Personal Information in such a

manner that the Personal Information can no longer be attributed to Data Subjects

without the use of additional information, provided that such additional information

is kept separately and is subject to technical and organisational measures to ensure

that the Personal Information are not attributed to Data Subjects;

1.4. “Applicable Laws” means any laws applicable to the processing of and

protection of rights associated with Personal Information and includes any statute,

regulation, notice, policy, directive, ruling or subordinate legislation; the common law;

any binding court order, judgement or ruling; any applicable industry code, policy or

standard enforceable by law; or any applicable direction, policy or order that is given

by any regulator, competent authority or organ of state or statutory industry body;

1.5. “Biometrics” means a technique of personal identification that is based on

physical, physiological or behavioural characterisation including blood typing,

fingerprinting, DNA analysis, retinal scanning and voice recognition;

1.6. “Competent Person” means anyone who is legally competent to consent to any

action or decision being taken by any matter concerning a child, for example a parent

or legal guardian;

1.7. “Consent” means any voluntary, specific and informed expression of will in

terms of which permission is given for the Processing of Personal Information;

1.8.   means small text files that store Non-personally Identifiable

Information/Data about Data Subjects, either temporarily in connection with a Data

Subjects Internet Protocol (IP) address (known as a temporary or session cookie and

deleted once a Data Subject closes their browser window) or more permanently on

the hard drive of a Data Subject’s device (known as a permanent or persistent

cookie). Z-Fin t/a Zero Finance’s Website(s) or Mobile Application(s) may from time to time use

session cookies so that Data Subject’s do not have to fill in the same information

from page to page within our Website(s) or Mobile Application(s). If Data Subject’s

elect not to receive cookies, they may be able to view some, but not all, of the

content on our Website(s) or Mobile Application(s);

1.9. “Client(s)” means any natural person(s), or juristic person(s), who have

concluded an agreement with Z-Fin t/a Zero Finance in terms of which such Client procures

the Products or Services provided by Z-Fin t/a Zero Finance ;

1.10. “Data Subject” means Z-Fin t/a Zero Finance’s Client(s) or any Third Party in respect of

whom Z-Fin t/a Zero Finance Processes Personal Information;

1.11. “Data Processing Infrastructure” means any and all systems, networks, servers,

workstations, laptops, mobile devices, web applications, mobile applications, cloud

storages, websites owned, controlled or operated by Z-Fin t/a Zero Finance;

1.12. “Embedded Scripts” means, programming code that is designed to collect

information about a Data Subject’s interactions with the relevant Website(s) or

Mobile Application(s). It is temporarily downloaded onto a Data Subject’s device from

our web server or a Third-Party Operator. This program is active only while a Data

Subject is connected to the relevant Website(s) or Mobile Application(s) and is

deleted or deactivated thereafter;

1.13. “Electronic Means” means, in relation to the Processing of any Personal

Information, the use of any Website(s), Mobile Application(s), electronic mail (email),

text, voice, sound or image messages by Z-Fin t/a Zero Finance;

1.14. “Z-Fin t/a Zero Finance” means Z-Fin t/a Zero Finance Pty (Ltd);

1.15. “Z-Fin t/a Zero Finance Group Company” means any company forming part of Debt

Rescue Group of Companies from time to time;

1.16. “Non-Electronic Means” means, in relation to the Processing of any Personal

Information, the use of traditional means of Processing, such as hard copy

documents, traditional filing systems deployed for the storage and retention of

Personal Information and face-to-face personal engagements with Data Subjects;

1.17. “Mobile Application(s)” means any multi-device software application, whether

in web-based format or device-native format, to which this Privacy Policy relates and

through which Client(s) and Third Parties gain access to Z-Fin t/a Zero Finance’s Products

and/or Services;

1.18. “Mobile Device Identifier” means device information if you access our

Website(s) or Mobile Application(s) through mobile devices. Certain features of the

relevant Website(s) or Mobile Application(s) may require collection of mobile phone

numbers and we may associate that phone number with the mobile device

identifiers. Additionally, some mobile phone service providers operate systems that

pinpoint the physical location of devices that use their service. Depending on the

provider, Z-Fin t/a Zero Finance and/or our Third-Party Operators may receive this

information. If Z-Fin t/a Zero Finance associates any such passively collected information with

the Personal Information of Data Subjects, we will treat the combined information as

Personal Information as contemplated in this Policy;

1.19. “Non-personally Identifiable Information/Data” means any information/data

which cannot be linked to Data Subjects, such as an internet domain name, the type

of web browser used by a Data Subject, the type of operating system relied on by a

Data Subject, the date and time of a Data Subject’s visit to our Website(s) and

Mobile Application(s), the specific pages a Data Subject may have visited, and the

address of the website which a Data Subjects may have visited prior to entering or

gaining access to Z-Fin t/a Zero Finance’s Website(s) or Mobile Application(s);

1.20. “Operator” means a person or entity who Processes Personal Information for

and on behalf of the Responsible Party, who in the context of the Website(s) and its

associated functionality is IEDM Digital Marketing;

1.21. “PAIA” means Promotion of Access to Information Act 2 of 2000;

1.22. “Passive Processing Means” means the use of technologies to facilitate the

Inactive Processing of Personal Information, namely the use of Cookies, Web

Beacons, Embedded Scripts and/or Mobile Device Identifiers;

1.23. “Person” means any natural person or juristic person;

1.24. “Personal Information” shall have the same meaning as is given in section 1 of

POPIA, which for the avoidance of doubt includes any information relating to an

identifiable, living, natural person, and where it is applicable, an identifiable, existing

juristic person, including, but not limited to:

1.24.1. 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;

1.24.2. information relating to the education or the medical, financial, criminal

or employment history of the person;

1.24.3. any identifying number, symbol, e-mail address, physical address,

telephone number, location information, online identifier or other particular

assignment to the person;

1.24.4. the biometric information of the person;

1.24.5. the personal opinions, views or preferences of the person;

1.24.6. 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;

1.24.7. the views or opinions of another individual about the person; and

1.24.8. 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; and shall, where applicable, include Special

Personal Information;

1.25. “Policy” means this Data Protection and Privacy Policy;

1.26. “POPIA” means the Protection of Personal Information Act, No 4 of 2013;

1.27. “Processing” means any operation or activity or any set of operations, whether

or not by automatic means, concerning Personal Information, including:

1.27.1. the collection, receipt, recording, organisation, collation, storage,

updating or modification, retrieval, alteration, consultation or use;

1.27.2. dissemination by means of transmission, distribution or making

available in any other form by electronic communications or other means; or

1.27.3. merging, linking, blocking, degradation, erasure or destruction. For the purposes of this definition, “Process” has a corresponding meaning.

1.28. “Products” means the various debt counselling services which are procured by

Clients of Z-Fin t/a Zero Finance;

1.29. “Regulator” means the Information Regulator established in terms of POPIA;

1.30. “Responsible Party” means in the context of this Policy, Z-Fin t/a Zero Finance;

1.31. “Services” means the various services provided by Z-Fin t/a Zero Finance to its Client(s),

the particulars of which services are clearly set forth on Z-Fin t/a Zero Finance’s Website from

time to time;

1.32. “Special Personal Information/Data” means Personal Information concerning,

amongst other aspects contemplated in terms of section 26 Part B of POPIA, a Data

Subject’s, religious beliefs, race or ethnic origin, trade union membership, political

persuasion, health or sex life, biometric data, or criminal behaviour;

1.33. “Third-Party” means any Z-Fin t/a Zero Finance Group Company (if applicable), Client(s),

Data Subject(s), employees, independent contractor, agent, consultant or user of

Z-Fin t/a Zero Finance’s Products, Services, Website or any other digital application interface;

1.34. “Unique Identifier” means any identifier that is assigned to a Data Subject and

is used by the Responsible Party for the purposes of the operations of that

Responsible Party and that uniquely identifies that data subject in relation to the

Responsible Party;

1.35. “Website” means the website owned and operated by Z-Fin t/a Zero Finance sourced at

Z-fin.co.za;

1.36. “Web Beacons” means small graphic images called web beacons, also known

as “Internet tags” or “clear gifs,”, which Web Beacons may be deployed on Debt

Rescue’s Website(s) pages and e-mail messages. Web beacons may be invisible to

Data Subjects, but any electronic image inserted into a web page or e-mail can act

as a Web Beacon. Z-Fin t/a Zero Finance may use web beacons or similar technologies for a

number of purposes, including, without limitation, to count the number of visitors to

our Websites, Mobile Application(s), to monitor how users navigate the Website(s)

or Mobile Application(s), to count how many e-mails that we have sent were actually

opened or to count how many particular articles or links were actually viewed by

Data Subjects in certain circumstances.

2. INTRODUCTION

2.1. This Policy regulates the Processing of Personal Information by Z-Fin t/a Zero Finance

and sets forth the requirements with which Z-Fin t/a Zero Finance undertakes to comply

when Processing Personal Information pursuant to undertaking its operations and

fulfilling its contractual obligations in respect of Data Subjects and Third Parties in

general.

2.2. Z-Fin t/a Zero Finance places a high premium on the privacy of every person or

organisation with whom it interacts or engages with and therefore acknowledges

the need to ensure that Personal Information is handled with a reasonable standard

of care as may be expected from it. Z-Fin t/a Zero Finance is therefore committed to ensuring

that it complies with the requirements of POPIA and also with the terms of

Applicable Laws.

2.3. When a Data Subject or Third Party engages with Z-Fin t/a Zero Finance, whether it be

physically or via any digital, electronic interface such as Z-Fin t/a Zero Finance Website, the

Data Subject or Third Party acknowledges that they trust Z-Fin t/a Zero Finance to Process

their Personal Information, including the Personal Information of their dependents,

beneficiaries, Clients, members, or employees as the case may be, which further

entrenches the importance of Z-Fin t/a Zero Finance’s compliance with Applicable Laws in

regards to the Processing of Personal Information.

2.4. All Data Subjects and Third Parties have the right to object to the processing of

their Personal Information. It should be voluntary to accept the Terms and Conditions

to which this Policy relates. However, Z-Fin t/a Zero Finance does require the Data Subject’s

or Third Party’s acceptance to enable the proper use of Z-Fin t/a Zero Finance Website and/or

Services.

3. PURPOSE AND APPLICATION

3.1. The purposes of this Policy are not only to inform Data Subjects of what

Personal Information of theirs Z-Fin t/a Zero Finance may Process, where Z-Fin t/a Zero Finance may

have collected such Personal Information from (if not directly from them as the Data

Subject), how Z-Fin t/a Zero Finance Processes their Personal Information, but also to

communicate the prevailing standards by which Z-Fin t/a Zero Finance and its employees,

representatives and operators shall comply in as far as the Processing of Personal

Information is concerned.

3.2. Z-Fin t/a Zero Finance, in its capacity as a Responsible Party and/or Operator, as the case

may be, shall strive to observe and comply with its obligations under POPIA and

Applicable Laws (as may be applicable and to the extent necessary) when it

Processes Personal Information from or in respect of any Data Subject.

4.

COLLECTING & PROCESSING OF PERSONAL

INFORMATION

4.1. Whenever any Data Subject engages with Z-Fin t/a Zero Finance, whether it be physically

or electronically, or through the use of its Services, facilities or Website, Z-Fin t/a Zero Finance

will in effect be processing the Data Subject’s Personal Information.

4.2. It may be from time to time that Z-Fin t/a Zero Finance has collected a Data Subject’s

Personal Information from other sources and in such instances Z-Fin t/a Zero Finance will

inform the Data Subject by virtue of any privacy notices it deploys from time to time.

In the event that a Data Subject has shared their Personal Information with any third

parties, Z-Fin t/a Zero Finance will not be responsible for any loss suffered by the Data

Subject, their dependents, beneficiaries, Clients, representatives, agents or

employees (as the case may be).

4.3. When a Data Subject provides Z-Fin t/a Zero Finance with the Personal Information of

any other Third Party, Z-Fin t/a Zero Finance will process the Personal Information of such

Third Party in line with this Policy, as well as any terms and conditions or privacy

notices to which this Policy relates.

4.4. Z-Fin t/a Zero Finance will primarily Process Personal Information in order to facilitate and

enhance the delivery of Products and/or Services to its Clients, manage and

administer its business, foster a legally compliant workplace environment, as well as

safeguard the Personal Information relating to any Data Subjects which it in fact

holds. In such an instance, the Data Subject providing Z-Fin t/a Zero Finance with such

Personal Information may also be required to confirm that they are a Competent

Person and that they have authority to give the requisite consent to enable Debt

Rescue to process such Personal Information.

4.5. Z-Fin t/a Zero Finance undertakes to process any Personal Information in a manner which

promotes the constitutional right to privacy, retains accountability and Data Subject

participation.

4.6. Prior to recording the purpose(s) for which Z-Fin t/a Zero Finance may, or will, process the

Personal Information of Data Subjects, Z-Fin t/a Zero Finance hereby records the broad

categories and types of Personal Information of Data Subjects it may process from

time to time:

4.6.1. Full names;

4.6.2. Identity numbers;

4.6.3. Registration numbers;

4.6.4. Financial information, including banking account information;

4.6.5. Statutory information;

4.6.6. Physical and postal address particulars;

4.6.7. Telephone numbers;

4.6.8. Email addresses;

4.6.9. Biometrics;

4.6.10. Unique Identifiers.

4.7. In supplementation of the above and any information privacy notices provided to

any Data Subject from time to time pursuant to any engagement with them, Debt

Rescue may process Personal Information for the following purposes:

4.7.1. To provide or manage any information, Products and/or Services

requested by or delivered to Data Subjects in general;

4.7.2. To establish a Data Subject’s needs, wants and preferences in relation to

the Products and/or Services provided by Z-Fin t/a Zero Finance or any other Debt

Rescue Group Company;

4.7.3. To help Z-Fin t/a Zero Finance identify Data Subjects when they engage with Debt

Rescue;

4.7.4. To facilitate the delivery of Products and/or Services to Clients;

4.7.5. To allocate to Clients and Data Subjects Unique Identifiers for the

purpose of securely storing, retaining and recalling their Personal Information

from time to time;

4.7.6. To maintain records of Data Subjects and specifically Client records;

4.7.7. To maintain Third Party records;

4.7.8. For recruitment purposes;

4.7.9. For employment purposes;

4.7.10. For apprenticeship purposes;

4.7.11. For general administration purposes;

4.7.12. For legal and/or contractual purposes;

4.7.13. For health and safety purposes;

4.7.14. To monitor access, secure and manage any facilities owned or operated

by Z-Fin t/a Zero Finance regardless of the location;

4.7.15. To transact with Third Parties;

4.7.16. To improve the quality of Z-Fin t/a Zero Finance’s Services;

4.7.17. To transfer Personal Information to any other Z-Fin t/a Zero Finance Group

Company so as to enable the relevant Z-Fin t/a Zero Finance Group Company to market

its products and/or services to Z-Fin t/a Zero Finance’s Client(s) or Third Party’s, as well

as to render specific services to Z-Fin t/a Zero Finance itself which would in turn enable

Z-Fin t/a Zero Finance to render its Services to its Client(s);

4.7.18. To transfer Personal Information to Third Party service providers so as

to enable Z-Fin t/a Zero Finance to deliver Services to its Client(s);

4.7.19. To analyse the Personal Information collected for research and

statistical purposes;

4.7.20. To help recover bad debts;

4.7.21. To transfer Personal Information across the borders of South Africa to

other jurisdictions if it is required;

4.7.22. To carry out analysis and Client profiling;

4.7.23. To identify other products and services which might be of interest to

our Clients and Data Subjects in general, as well as to inform them of such

products and/or services;

4.7.24. To comply with any Applicable Laws applicable to Z-Fin t/a Zero Finance and in

some instances other Z-Fin t/a Zero Finance Group Companies.

4.8. When collecting Personal Information from a Data Subject, Z-Fin t/a Zero Finance shall

comply with the notification requirements as set out in Section 18 of POPIA, and to

the extent applicable, comparable provisions on other Applicable Laws.

4.9. Z-Fin t/a Zero Finance will collect and Process Personal Information in compliance with

the conditions as set out in POPIA and/or the Processing principles in relevant

Applicable Laws (as the case may be), to ensure that it protects the Data Subject’s

privacy.

4.10. Z-Fin t/a Zero Finance will not Process the Personal Information of a Data Subject for

any purpose other than for the purposes set forth in this Policy or in any other

privacy notices which may be provided to Data Subjects from time to time, unless

Z-Fin t/a Zero Finance is permitted or required to do so in terms of Applicable Laws or

otherwise by law.

4.11. Z-Fin t/a Zero Finance may from time-to-time Process Personal Information by making

use of automated means (without deploying any human intervention in the decision making process) to make decisions about the Data Subject or their application. In

these instances, Z-Fin t/a Zero Finance will take reasonable steps to information Data

Subjects thereof and it is specifically recorded that the Data Subject may object to or

query the outcomes of such a decision.

5.

PERSONAL INFORMATION/PERSONAL DATA FOR DIRECT

MARKETING PURPOSES

5.1. Z-Fin t/a Zero Finance acknowledges that it may only use Personal Information to contact

Data Subjects for purposes of direct marketing where Z-Fin t/a Zero Finance has complied

with the provisions of POPIA and relevant Applicable Laws (where applicable) and

when it is generally permissible to do so in terms of Applicable Laws.

5.2. In the event that Z-Fin t/a Zero Finance may lawfully direct market to a Data Subject in

terms of section 69 of POPIA, Z-Fin t/a Zero Finance will ensure that a reasonable opportunity

is given to such Data Subjects to object (opt-out) to the use of their Personal

Information for Z-Fin t/a Zero Finance’s marketing purposes when collecting the Personal

Information and on the occasion of each communication to the Client for purposes of

direct marketing.

6.

STORAGE AND RETENTION OF PERSONAL

INFORMATION/PERSONAL DATA

6.1. Z-Fin t/a Zero Finance will retain Personal Information it has processed in accordance

with its prevailing retention policies from time to time, which retention policies will

reflect the justified retention of any Personal Information in terms of Section 14 of

POPIA.

6.2. Personal Information will only be retained by Z-Fin t/a Zero Finance for as long as

necessary to fulfil the legitimate purposes for which that Personal Information was

collected in the first place and/or as permitted or required in terms of Applicable Law.

6.3. It is specifically recorded that any Data Subject has the right to object to the

Processing of their Personal Information and Z-Fin t/a Zero Finance shall retain and store the

Data Subject’s Personal Information for the purposes of dealing with such an

objection or enquiry as soon and as swiftly as possible.

7. FAILURE TO PROVIDE PERSONAL INFORMATION

7.1. Where Z-Fin t/a Zero Finance is required to collect Personal Information from a Data

Subject by law or in order to fulfil a legitimate business purpose of Z-Fin t/a Zero Finance and

the Data Subject fails to provide such Personal Information, Z-Fin t/a Zero Finance may, on

notice to the Data Subject, decline to render services without any liability to the Data

Subject.

8. SECURING PERSONAL INFORMATION

8.1. Z-Fin t/a Zero Finance will always implement appropriate, reasonable, physical,

organisational, contractual and technological security measures to secure the

integrity and confidentiality of Personal Information, including measures to protect

against the loss or theft, unauthorised access, disclosure, copying, use or

modification of Personal Information in compliance with Applicable Laws.

8.2. In further compliance with Applicable Laws, Z-Fin t/a Zero Finance will take steps to

notify the relevant Regulator(s) and/or any affected Data Subjects in the event of a

security breach and will provide such notification as soon as reasonably possible

after becoming aware of any such breach.

8.3. Notwithstanding any other provisions of this Policy, it should be acknowledged

that the transmission of Personal Information, whether it be physically in person, via

the internet or any other digital data transferring technology, is not completely

secure. Whilst Z-Fin t/a Zero Finance has taken all appropriate, reasonable measures

contemplated in clause 8.1 above to secure the integrity and confidentiality of the

Personal Information its Processes, in order to guard against the loss of, damage to

or unauthorised destruction of Personal Information and unlawful access to or

processing of Personal Information, Z-Fin t/a Zero Finance in no way guarantees that its

security system(s) are 100% secure or error-free. Therefore, Z-Fin t/a Zero Finance does not

guarantee the security or accuracy of the information (whether it be Personal

Information or not) which it collects from any Data Subject.

8.4. Any transmission of Personal Information will be solely at the own risk of a Data

Subject. Once Z-Fin t/a Zero Finance has received the Personal Information, it will deploy and

use strict procedures and security features to try to prevent unauthorised access to

1. As indicated above, Z-Fin t/a Zero Finance reiterates that it restricts access to Personal

Information to Third Parties who have a legitimate operational reason for having

access to such Personal Information. Z-Fin t/a Zero Finance also maintains electronic and

procedural safeguards that comply with the Applicable Laws to protect your

Personal Information from any unauthorised access.

8.5. Z-Fin t/a Zero Finance shall not be held responsible and by accepting any terms and

conditions to which this Policy relates, any Data Subject agrees to indemnify and

hold Z-Fin t/a Zero Finance harmless for any security breaches which may potentially expose

the Personal Information in Z-Fin t/a Zero Finance’s possession to unauthorised access and or

the unlawful processing of such Personal Information by any Third-Party.

9.

PROVISION OF PERSONAL INFORMATION TO THIRD

PARTIES

9.1. Z-Fin t/a Zero Finance may disclose Personal Information to Third-Party service providers

and any Z-Fin t/a Zero Finance Group Company where necessary and to achieve the

purpose(s) for which the Personal Information was originally collected and

processed. Z-Fin t/a Zero Finance will enter into written agreements with such Third-Party

service providers and Z-Fin t/a Zero Finance Group Company, to ensure that they comply with

Applicable Laws pursuant to the Processing of Personal Information provided to it by

Z-Fin t/a Zero Finance from time to time.

10.

TRANSFER OF PERSONAL INFORMATION OUTSIDE OF

SOUTH AFRICA

10.1. Z-Fin t/a Zero Finance may, under certain circumstances, transfer Personal Information

to a jurisdiction outside of the Republic of South Africa in order to achieve the

purpose(s) for which the Personal Information/Data was collected and Processed

including for Processing and storage by Third-Party service providers.

10.2. If it is required, Z-Fin t/a Zero Finance will obtain the Data Subject’s consent to transfer

the Personal Information to such foreign jurisdiction.

10.3. The Data Subject should also take note that, where the Personal Information is

transferred to a foreign jurisdiction, the Processing of Personal Information in the

foreign jurisdiction may be subject to the laws of that foreign jurisdiction.

11. ACCESS TO PERSONAL INFORMATION

11.1. A Data Subject has the right to a copy of the Personal Information which is

held by Z-Fin t/a Zero Finance (subject to a few limited exemptions as provided for under

Applicable Law).

11.2. The Data Subject must make a written request (which can be by email) to the

Information Officer designated by Z-Fin t/a Zero Finance from time to time and whose contact

details can be sourced in Z-Fin t/a Zero Finance’s PAIA Manual.

11.3. Z-Fin t/a Zero Finance will provide the Data Subject with any such Personal Information

to the extent required by Applicable Law and subject to and in accordance with the

provisions of Z-Fin t/a Zero Finance’s PAIA Manual (published in terms of section 51 of PAIA,

which PAIA Manual can be sourced either at Z-Fin t/a Zero Finance’s premises upon request

or on Z-Fin t/a Zero Finance’s Website.

11.4. The Data Subject can challenge the accuracy or completeness of his/her/its

Personal Information in Z-Fin t/a Zero Finance’s records at any time in accordance with the

process set out in Z-Fin t/a Zero Finance’s PAIA Manual.

12. KEEPING PERSONAL INFORMATION ACCURATE

12.1. Z-Fin t/a Zero Finance will take reasonable steps to ensure that Personal Information

that its Processes are kept updated where reasonably possible. For this purpose, Debt

Rescue shall provide Data Subjects with the opportunity to update their information

at appropriate times.

12.2. Z-Fin t/a Zero Finance may not always expressly request the Data Subject to verify and

update his/her/its Personal Information and expects that the Data Subject will notify

Z-Fin t/a Zero Finance from time to time in writing:

12.2.1. of any updates or amendments required in respect of his/her/its

Personal Information;

12.2.2. where the Data Subject requires Z-Fin t/a Zero Finance to delete his/her/its

Personal Information; or

12.2.3. where the Data Subject wishes to restrict the Processing of his/her/its

Personal Information.

13.

COSTS TO ACCESS PERSONAL

INFORMATION/PERSONAL DATA

13.1. In the event that a cost is applicable, the prescribed fees to be paid for copies

of the Data Subject’s Personal Information are listed in Z-Fin t/a Zero Finance’s PAIA Manual.

13.2. Z-Fin t/a Zero Finance reserves the right to make amendments to this Policy from time to

time.

14. COMPLAINTS TO THE INFORMATION REGULATOR

14.1. If any Data Subject or Third Party is of the view or belief that Z-Fin t/a Zero Finance has

Processed their Personal Information in a manner or for a purpose which is contrary

to the provisions of this Policy, the Data Subject is requested to first attempt to

resolve the matter directly with Z-Fin t/a Zero Finance, failing which the Data Subject or Third

Party shall have the right to lodge a complaint with the Information Regulator, under

the provisions of POPIA.

14.2. The current contact particulars of the Information Regulator are:

The Information Regulator (South Africa)

Website: https://www.justice.gov.za/inforeg/index.html

JD House 27 Stiemens Street Braamfontein Johannesburg, 2001

PO Box 31533

Braamfontein, Johannesburg, 2107

15. CONTACTING US

15.1. All comments, questions, concerns or complaints regarding Personal

Information or this Policy, should be forwarded to Z-Fin t/a Zero Finance’s Information Officer

at the following email address – info@Z-fin.co.za.