PRIVACY POLICY

1.1) SuccessorX Proprietary Limited (Registration Number: 2020/874722/07) t/a as GoodWill is committed to ensuring the protection and confidentiality of all personal information in our possession.

1.2) The purpose of this privacy policy (the “Policy”) is to explain how we collect, use, disclose and store personal information, in accordance with the requirements of the Protection of Personal Information Act 4 of 2013 (“POPIA”).

1.3) In adopting this Policy, we wish to establish our legitimate business interest and your reasonable expectation of privacy through trust.

By providing us with your personal information, you are deemed to have:

2.1) read, understood, accepted, and agreed to be bound by the terms of this Policy; and

2.2) authorised us to process your personal information for the purposes set out in clause 4

3.1) We will collect certain personal information that you provide to us via our website or our various opt-in platforms, such as GoodWill, our automated will creation platform.

3.2) In addition, we may collect certain personal information that you provide to us by phone or via email or WhatsApp, where necessary.

3.3) We also collect certain information from our website to compile anonymous information about our website and to store user preferences, where necessary.

4.1) We require certain personal information in order for us to provide our services to you.

4.2) We will only request and process personal information that is necessary for the purposes of:

4.2.1) creating a valid will in accordance with the Wills Act 7 of 1953;

4.2.2) informing you of changes made to our digital platforms;

4.2.3) responding to any queries or requests you may have;

4.2.4) developing an online user profile;

4.2.5) security, administrative and legal purposes;

4.2.6) understanding general user trends and patterns so that we can develop and support existing and ongoing marketing strategies; and

4.2.6) the creation and development of market data profiles which may provide insight into market norms, practices and trends to help us improve our offering to you.

 

5.1) In order for us to perform the services listed in clause 4 above, we will typically require the following personal information:

5.1.1) full name;

5.1.2) date of birth;

5.1.3) gender;

5.1.4) physical address;

5.1.5) email address;

5.1.6) cellphone number;

5.1.7) marital status;

5.1.8) information regarding your family members;

5.1.9) name(s) of your elected guardian(s), beneficiary(ies), agent(s), trustees and/or executor(s);

5.1.10) details concerning your assets, such as a description or address of real estate property;

5.1.11) preferences for end of life burial;

5.1.12) bank account and payment details (which may be collected through our third party payment processor);

5.1.13) website usage and other technical information such as details of visits to our website or information collected through cookies, your interaction with our online advertising and content and other tracking technologies; and

5.1.14) any other relevant personal information that may be reasonably necessary for the purposes of executing a valid will.

5.2) The personal information may be compiled and retained in aggregated form, but will not be used in any way which may compromise the identity of a user.

5.3) We will take reasonably practicable steps to ensure that the personal information is complete, accurate, not misleading and updated where necessary.

6.1) Special personal information is sensitive personal information concerning a person’s religious or philosophical beliefs, race or ethnic origin, trade union membership, political opinions, health, sexual life, biometric information or criminal behavior.

6.2) We will not process special personal information unless:

6.2.1) you have provided your consent;

6.2.2) the processing is necessary for the establishment, exercise or defence of a right or obligation in law; or

6.2.3) the processing is necessary for such other purpose as prescribed in section 27 of POPIA.

If you provide us with someone else’s personal information and that person is older than 18 years of age, you must ensure that the person has provided his/her consent to disclose their personal information.

We will only process the personal information of children under the age of 18 years if:

8.1) we have received the prior consent of any person who is legally competent to consent to any action or decision being taken in respect of any matter concerning the child (such as a parent or guardian);

8.2) it is necessary for the establishment, exercise or defence of a right or obligation in law; or

8.3) it is necessary for such other purpose as prescribed in section 35 of POPIA.

9.1) We will not disclose any personal information except with your specific consent or in circumstances permitted by law.

9.2) We may, however, share your personal information with certain third parties such as service providers and/or partners who provide website, application development, hosting, maintenance, payment services and other services to us that may be necessary for us to perform our services.

9.3) Certain third parties may accordingly have access to or process personal information as part of performing certain necessary services for us.

9.4) We limit the information provided to such third parties to that which is reasonably necessary for them to perform their functions.

9.5) We require all third parties to adopt the same level of security that we use to ensure the protection and confidentiality of personal information.

9.6) We will take reasonable steps to ensure that such third parties process any personal information in accordance with this Policy, all relevant policies and procedures and POPIA.

10.1) We follow generally accepted industry information security standards to protect and secure the integrity and confidentiality of the personal information that is submitted to us.

10.2) Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our platforms and any transmission is at your own risk.

10.3) Once we have received your information, we will take appropriate, reasonable technical and organisational measures to try to protect your personal information from accidental or intentional manipulation, interference, loss, misuse, destruction or unauthorised access, modification or disclosure.

10.4) We will continue to maintain and improve these security measures in line with legal and technological developments in order to prevent any unauthorised access to your personal information.

10.5) If there are reasonable grounds to believe that any personal information has been accessed or acquired by any unauthorised person, we will notify you and the Information Regulator of South Africa, in accordance with section 22 of POPIA.

11.1) All information that you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our platforms, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

11.2) We may also store your personal information on, and transfer your personal information to, a central database. If the location of the central database is located in a country that does not have substantially similar laws which provide for the protection of personal information, we will take the necessary steps to ensure that your personal information is adequately protected in that jurisdiction by means of ensuring that standard data protection clauses are enforced as envisaged by the EU General Data Protection Regulation (“GDPR”).

11.3) By submitting your personal information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.

11.4) If you want to learn more about your rights under the GDPR, you can visit the European Commission’s web page on data protection at: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en

12.1) We will only keep your personal information for as long as reasonably necessary to fulfil the relevant purposes set out in this Policy and in order to comply with our legal and regulatory obligations.

12.2) After we are no longer authorised to retain the personal information, we will ensure that it is destroyed, deleted and/or de-identified in a manner that prevents its reconstruction in an intelligible form.

13.1) We may use personal information to contact you and/or market our services directly to you if you are an existing user of our various platforms, you have requested to receive marketing material from us or you have provided us with your consent to market our services directly to you.

13.2) If you are an existing user of our various platforms, we will only use your personal information if we have obtained it through the provision of our services to you and only in relation to similar services and/or products to the ones we previously provided to you (such as marketing of our current and future inheritance planning services and other related offerings).

13.3) You will be provided with a reasonable opportunity to object to the use of your personal information for direct marketing purposes when we collect the personal information from you and whenever we contact you for the purposes of direct marketing.

13.4) We will not use your personal information to send you marketing materials if you have requested not to receive them.

13.5) If you request that we stop processing your personal information for marketing purposes, we shall do so.

14.1) We may change the terms of this Policy from time to time by updating this web page.

14.2) If we change any of the terms of this Policy, we will inform you by email or by placing a notice on our website setting out the changes that have been made and the date on which the changes shall come into effect.

14.3) If you do not agree with any of the changes made to this Policy, you may request that we stop processing your personal information and will accordingly stop providing our services to you.

14.4) If you continue to provide us with your personal information following notification of a change to the terms, the changed terms will apply to you and you will be deemed to have accepted those updated terms.

15.1) If you would like us to destroy or delete any of your personal information or you would like to opt-out of all our services to you, please email us at: deleteprofile@successorx.co.za.

15.2) If you would like us to correct any of your personal information or if you have any further requests, questions, complaints or comments about this Policy or the processing of your personal information or you would like to ask us whether we are processing any of your personal information, please feel free to contact us at:

Email:  legal@successorx.co.za

Telephone: +27711389393

Information Officer: Mr. Kabelo Makua

15.3)If you are unsatisfied with the manner in which we address any complaint regarding the processing of personal information, you may contact the Information Regulator of South Africa:

15.3.1) Website: https://www.justice.gov.za/inforeg/contact.html

15.3.2) Email: inforeg@justice.gov.za

15.3.3) Telephone: 012 406 4818

15.4) If you want to learn more about your rights under the POPIA, you can visit the Information Regulator’s page on data protection at: https://www.justice.gov.za/inforeg/portal.html

 

 

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