1. ABOUT THIS POLICY

1.1. This Policy describes how Zaka Money (Pty) Ltd (“Zaka Money”) Processes Personal Information that it

collects and/or receives from you.

1.2. Zaka Money is a “Responsible Party”. This means that we are responsible for deciding how we hold

and use your Personal Information. We are required under data protection legislation to notify you of the

information contained in this Privacy Policy.

1.3. This Policy applies to all Data Subjects who visit Zaka Money’s Website, make use of Zaka Money’s

services and/or any related services, and all Data Subjects whose Personal Information is Processed by

Zaka Money.

2. DEFINITIONS AND INTERPRETATIONS

2.1. In this Policy, unless the context indicates a contrary intention, the following words and expressions bear

the meanings assigned to them and similar expressions bear corresponding meanings –

2.1.1. “Data Subject" or “You” refers to any person to whom the Personal Information relates, as

contemplated in POPIA;

2.1.2. “IO” means the Information Officer of Zaka Money;

2.1.3. “Zaka Money”, “Us” or “We” refers to Zaka Money (Pty) Ltd, being the provider of the

services;

2.1.4. "Personal Information" refers to any information relating to an identified or identifiable living

natural person, and (where applicable) an identifiable, existing juristic person, including the

name, race, gender, marital status, address and identifying number of a person, symbol, e-

mail address, physical address, telephone number, location information, online identifier or

other particular assignment to the person, and shall bear the meaning as defined in POPIA,

as amended from time to time;

2.1.5. “Policy” refers to this Privacy and Data Protection Policy, as may be amended from time to

time;

2.1.6. “POPIA” means the Protection of Personal Information, 2013 and any regulations or codes of

conduct promulgated thereunder;

2.1.7. "Processing" or "Process" means any activity that involves the use of Personal Information.

It includes any operation or activity or any set of operations, whether or not by automatic

means, concerning Personal Information, including:

2.1.7.1. the collection, receipt, recording, organisation, collation, storage, updating or

modification, retrieval, alteration, consultation or use;

2.1.7.2. dissemination by means of transmission, distribution or making available in any

other form; or

2.1.7.3. merging, linking, as well as restriction, degradation, erasure or destruction of

information;

2.1.8. “Social Media Platforms” means platforms such as Facebook, LinkedIn, Twitter, Pinterest,

YouTube, Instagram, WeChat, WhatsApp, TikTok, blogs and all other similar Social Media or

communication platforms;

2.1.9. “User” refers to those users who are authorised by Zaka Money to use and/or browse the

Website; and

2.1.10. “Website” refers to Zaka Money’s website which can be accessed at www.zakamoney.com.

2.2. This Policy is subject to and to be interpreted in accordance with the laws of the Republic of South Africa.

2.3. The general rule of interpretation that, in the event of an ambiguous term or provision arising, this Policy

is to be interpreted against the party who drafted it, shall not apply in the context of this Policy.

2.4. In the interpretation of the meaning of provisions hereto, regard must be had to the context of this Policy,

the purpose for which it was drafted as well as the intentions of the parties thereto in drafting it.

2.5. Except where inconsistent with the context of this Policy, words signifying one gender will be inclusive of

the other and words signifying the singular will be inclusive of the plural and vice versa.

2.6. Words and expressions defined in any clause shall, unless the application of any such word or expression

is specifically limited to that clause, bear the meaning assigned to such word or expression throughout

this Policy.

2.7. Reference to "days" shall be construed as calendar days unless qualified by the word "business", in

which instance a "business day" will be any day other than a Saturday, Sunday or public holiday as

gazetted by the government of the Republic of South Africa from time to time.

2.8. Unless specifically otherwise provided, any number of days prescribed shall be determined by excluding

the first and including the last day or, where the last day falls on a day that is not a business day, the next

succeeding business day.

2.9. Where figures are referred to in numerals and in words, and there is any conflict between the two, the

words shall prevail, unless the context indicates a contrary intention.

2.10. The words "include" and "including" mean "include without limitation" and "including without limitation".

The use of the words "includes" and "including" followed by a specific example or examples shall not be

construed as limiting the meaning of the general wording preceding it.

3. THE PURPOSE UNDERPINNING DATA COLLECTION

3.1. Zaka Money and its associated partners will collect your Personal Information in order to provide,

maintain and improve the user experience and/or the performance of related services. The purpose of

collecting Personal Information from you includes collecting information to:

3.1.1. establish and verify your identity and business operations, including those processes which

may be required from Zaka Money by law or pursuant to good industry practice;

3.1.2. perform the services that you request of it in relation to its rural development mandate;

3.1.3. accomplish any further purpose that is related to providing its services;

3.1.4. communicate with you in the manner in which you prefer, including via email, post, SMS,

telephonically, through the Website or any other applicable method;

3.1.5. maintain and update our database of Users and associated partners;

3.1.6. update and inform you about our services and any changes thereto;

3.1.7. contract and for any other related activities;

3.1.8. conduct market or client satisfaction research or for statistical analysis;

3.1.9. for auditing or record keeping purposes;

3.1.10. fulfil any contractual or legal obligation that Zaka Money may have to you or a third party;

3.1.11. comply with any law or regulation or legal request from a recognised authority; and

3.1.12. any other activity which may be lawful, reasonable and necessary to its rural development

activities.

4. THIRD PARTY WEBSITES

This Policy does not extend to, and we are not responsible for, the privacy, information or other practices of any

third parties, including any third party operating any website to which our Website contains a link.  The inclusion of

a third-party link on our Website does not imply endorsement of the linked website by us or by our partner

companies.

5. HOW ZAKA MONEY COLLECTS YOUR PERSONAL INFORMATION

5.1. In most circumstances, providing your Personal Information to us is voluntary. However, it may be

mandatory to provide your Personal Information to us. If you fail to provide certain information when

requested, we may not be able to perform the services you requested from us or we may be prevented

from complying with our legal obligations. We collect Personal Information from you that you provide to us

directly in the following ways:

5.1.1. when you sign-up to utilise our services;

5.1.2. by filling in forms on our Website or those provided to you;

5.1.3. when you complete a survey;

5.1.4. by posting comments or content on our Website or any Social Media Platforms;

5.1.5. when you contact us or we contact you and you provide Personal Information directly to us;

5.1.6. through electronic communication, telephonically, during meetings, through related

documentation and in general interactions with you or your representatives;

5.1.7. from your online profiles, including from our Website and Social Media Platforms. Information

received from your online profiles may be used for informational purposes;

5.1.8. from our partners and service providers. This information may be used to supplement

information which you have already provided or agreed to provide;

5.1.9. through IT and electronic networks to determine who is visiting and using the Website and

related services; and

5.1.10. any other Personal Information that we may request from you for purposes of providing our

services to you.

5.2. Zaka Money will never disclose, share or sell your data without your consent; unless required to do so by

law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice.

Where you have consented to us providing you with promotional offers and marketing, you may at any

stage withdraw this consent.

6. COOKIES

6.1. By accessing our Website and using our services, or products, you consent to the collection, storage, and

use of your browsing data by us and our third-party partners. This data collection is primarily facilitated

through the use of cookies and similar tracking technologies (“Cookies”).

6.2. The purpose of data collection by using Cookies is to personalise content and ads, provide social media

features, analyse our Website traffic, understand where our visitors are coming from, and enhance and

tailor user experiences on our Website.

6.3. We may collaborate with third-party partners who may use Cookies to collect information about your

online activities across different websites and services. This helps us provide advertising tailored to your

interests, understand your preferences, and improve user experience.

6.4. By continuing to use our Website, and associated services, you signify your understanding and consent

to this clause on the use and collection of data via Cookies.

7. RETENTION OF DATA

We will retain your Personal Information only for as long as is necessary for the purposes set out in this Policy or

to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

8. DISCLOSING YOUR PERSONAL INFORMATION

8.1. Zaka Money will not disclose your Personal Information unless it is for the purposes set out in this Policy

or if Zaka Money has received your permission to do so. Zaka Money will disclose your Personal

Information:

8.1.1. to its employees, contractors, agents and affiliates to the extent that these parties need your

Personal Information in order for it to provide services to you;

8.1.2. to authorities or governmental agencies in order to comply with any law, regulation or legal

process; or

8.1.3. in order to protect our rights, property or safety or those of our employees, contractors,

agents, clients, affiliates or any other third party.

8.2. Zaka Money may make Personal Information available to any Users of the Website for purposes of

advancing its mandate and providing the services to you.

9. INFORMATION SECURITY

The security of your Personal Information is important to Zaka Money. While Zaka Money strives to use

commercially acceptable means to protect your Personal Information, Zaka Money cannot guarantee its absolute

security. However, Zaka Money employs a number of safeguards intended to mitigate the risk of unauthorised

access or disclosure of your Personal Information. Zaka Money will do our best to protect your Personal

Information and will use up to date technology that will help Zaka Money to do this. Zaka Money will at all times

comply with our obligations under POPIA or applicable data protection legislation.

10. INTERNATIONAL TRANSFER OF PERSONAL INFORMATION

10.1. Zaka Money is based in and operate from South Africa. Your Personal Information may be transferred to

and maintained on servers located outside of your country of residence, where the data privacy laws,

regulations and standards, may not be equivalent to the laws in your country of residence.

10.2. Zaka Money might transfer your Personal Information to places outside of South Africa and store it there,

where Zaka Money’s suppliers might Process it. If that happens, your Personal Information will only be

transferred to and stored in country that has equivalent, or better, data protection legislation than South

Africa or with a service provider which is subject to an agreement requiring it to comply with data

protection requirements equivalent or better than those applicable in South Africa.

10.3. Your use of Zaka Money’s Website followed by your submission of information to Zaka Money, represents

your consent to such transfer.

10.4. By withholding your consent to the transfer of your Personal Information, you may have limited or

restricted access to Zaka Money’s Website or use of our services.

10.5. Zaka Money will take all steps reasonably necessary to ensure that your Personal Information is treated

securely and in accordance with this Policy.

11. CONSENT OF PROCESSING BY THIRD PARTY SERVICE PROVIDERS

11.1. We make use of third-party service providers, including (without limitation) to AddPay (PTY) LTD and

MTN South Africa in order to process payments in accordance with the services provided.

11.2. By using Zaka Money’s Website and/or services, you expressly consent to the Processing of your

Personal Information by such third-party providers for the purposes set out herein.

12. DATA SUBJECT RIGHTS

12.1. Data Subjects have the following rights as they relate to the collection and processing of your personal

information:

12.1.1. Access to information:

As a Data Subject you have the right to request a copy of your personal information that

Zaka Money holds under the Promotion of Access to Information Act, 2000 (“PAIA”). A

request for such information may be subject to an administrative fee permitted by law. Zaka

Money may also require a copy of your identity document or any applicable documentation

for verification purposes. Confirmation of whether or not we hold Personal Information about

you may be requested free of charge. If you would like to obtain a copy of your Personal

Information held by Zaka Money, please review our PAIA Manual.

12.1.2. Right to the correction of information:

As a Data Subject, you have the right to request that Zaka Money updates or corrects the

Personal Information that Zaka Money holds about you. Please ensure that the Personal

Information Zaka Money holds about you is complete, accurate and up to date. If you fail to

keep your information updated, or if your information is incorrect, Zaka Money may limit the

products and services offered to you or elect not to open the account.

12.1.3. Right to the deletion of information:

As a Data Subject, under certain circumstances, you have the right to request that the

deletion or destruction of your Personal Information.

12.1.4. Right to object:

As a Data Subject, you have the right to object on reasonable grounds to the Processing of

your Personal Information where the Processing is carried out in order to protect Zaka

Money’s legitimate interests or your legitimate interests, unless the law provides for such

Processing.

12.1.5. Right to lodge a complaint:

As a Data Subject you have the right to complain if you are concerned about the way in

which Zaka Money Processes your Personal Information that it holds. All corrections,

deletions, objections and complaints in respect of confidential information may be sent to

info@zakamoney.com .

13. CHANGES TO THIS POLICY

Zaka Money may update this Policy at any time by publishing an updated version on the Website. Zaka Money

encourages you as a Data Subject to review this Policy on a regular basis.

14. GENERAL

It is not mandatory under the law for you to provide Personal Information to Zaka Money however, we may be

required to obtain Personal Information from you to comply with applicable legal requirements, and certain

Personal Information may be needed to enable Zaka Money to fulfil its rural development mandate terms with you

(or someone else), or in preparation of entering into a contract with you (or someone else).  In these

circumstances, if you do not provide the relevant Personal Information to us, we may not be able to provide our

products or services to you.