1. Introduction
1.1 FinPoza (PTY) Ltd, registration number 2026/231021/07, a private company duly incorporated under the company laws of the Republic of South Africa (“FinPoza”, “we”, “us”, “our”), respects your privacy and is committed to protecting your personal information.
1.2 This Privacy Policy explains what personal information we collect through our website at https://finpoza.com (the “Website”), how and why we collect and use it, who we share it with, and what rights you have, in accordance with the Protection of Personal Information Act 4 of 2013 (“POPIA”).
1.3 This Privacy Policy applies only to personal information collected through the Website, for example via our contact forms, demo requests, newsletter sign-up, or job applications. It does not apply to personal information processed within the FinPoza software platform in connection with a licensed customer’s lending business, which is governed separately, as explained in clause 3 below.
1.4 By using the Website, you acknowledge that you have read and understood this Privacy Policy. Where we rely on your consent to process your personal information, you may withdraw that consent at any time as described in clause 9.
2. Who Is Responsible for Your Information
2.1 In relation to personal information collected through the Website, FinPoza (PTY) Ltd is the “Responsible Party” as defined in POPIA.
2.2 We have appointed an Information Officer who is responsible for ensuring compliance with POPIA and for handling any queries or requests you may have. The Information Officer’s contact details are set out in clause 13.
3. Scope — Website Versus Software Platform
3.1 This Privacy Policy covers only personal information collected through the public Website (for example, general visitors, prospective customers, job applicants, and newsletter subscribers).
3.2 If you are a borrower, applicant, guarantor, or other end user interacting with a FinPoza customer’s lending or purchase order finance process through the FinPoza software platform, a different arrangement applies: the relevant lending company is the Responsible Party for your personal information, and FinPoza acts only as an Operator processing that information on the lending company’s instructions. For information about how your personal information is handled in that context, please refer to the relevant lending company’s own privacy policy or contact that company directly, as further described in the FinPoza Terms and Conditions.
4. The Personal Information We Collect
We may collect and process the following categories of personal information through the Website:
- Contact and identification information you provide, such as your name, job title, company name, email address, and telephone number, when you complete a contact form, request a demo, subscribe to our newsletter, or otherwise contact us.
- Information you provide when applying for a job with us, such as your CV, qualifications, employment history, and references.
- Correspondence and content of any messages you send us, including through email or the Website’s contact or chat features.
- Technical and usage information collected automatically when you visit the Website, such as your IP address, browser type and version, device information, pages visited, time spent on pages, referring website, and general location information (derived from IP address).
- Information collected through cookies and similar technologies, as described in clause 8.
We do not knowingly collect special personal information (as defined in POPIA, such as information relating to health, race, religious beliefs, or criminal behaviour) through the Website, and you should not submit such information to us via the Website unless specifically requested and relevant, for example in a job application.
5. How We Use Your Personal Information
We collect and use your personal information for the following purposes, on the legal bases indicated:
- To respond to your enquiries, demo requests, or other communications you send us — necessary to take steps at your request prior to entering into an agreement, or based on our legitimate interest in responding to enquiries.
- To send you marketing communications about FinPoza’s products and services, where you have opted in to receive these — based on your consent, which you may withdraw at any time.
- To manage a job application you have submitted to us — necessary to take steps at your request prior to entering into an employment agreement.
- To operate, maintain, secure, and improve the Website, including monitoring usage and diagnosing technical issues — based on our legitimate interest in maintaining a functional and secure website.
- To comply with our legal obligations, including tax, accounting, and regulatory record-keeping requirements, and to respond to lawful requests from courts, regulators, or law enforcement.
- To establish, exercise, or defend legal claims.
6. How We Share Your Personal Information
6.1 We do not sell your personal information. We may share your personal information with:
- service providers who perform functions on our behalf, such as website hosting, email delivery, customer relationship management, analytics, and IT support providers, who process your information on our instructions and under appropriate confidentiality and security obligations;
- professional advisers, including lawyers, auditors, and accountants, where necessary for the purposes described in clause 5;
- regulators, law enforcement agencies, or courts, where required or permitted by law;
- a purchaser or prospective purchaser, in the event of a merger, acquisition, financing, or sale of all or part of our business, subject to appropriate confidentiality arrangements.
6.2 Where we share personal information with a third-party service provider (an “Operator” under POPIA), we take reasonable steps to ensure that provider is bound by written contractual terms requiring it to protect your personal information and to process it only for the purposes we specify.
7. Cross-Border Transfers
Some of our service providers, such as cloud hosting or email platforms, may store or process personal information outside South Africa. Where this occurs, we take reasonable steps to ensure the recipient is subject to a law, binding corporate rules, or contractual terms that provide an adequate level of protection substantially similar to POPIA, in accordance with section 72 of POPIA, before transferring your personal information outside the Republic of South Africa.
9. Direct Marketing
9.1 We will only send you direct marketing communications by electronic means, such as email, where you have opted in to receive them, or where you are an existing customer or contact and we are marketing similar products or services to you, in each case in accordance with section 69 of POPIA.
9.2 You may opt out of receiving marketing communications from us at any time, free of charge, by clicking the “unsubscribe” link included in any marketing email, or by contacting us using the details in clause 13. We will process your opt-out request promptly.
10. Data Retention
We retain personal information collected through the Website only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements. When determining the appropriate retention period, we consider the amount, nature, and sensitivity of the personal information, the purpose for which we process it, and applicable legal requirements. Once no longer required, we securely delete or anonymise your personal information.
11. Security of Your Personal Information
We implement appropriate technical and organisational security measures designed to protect your personal information against loss, unauthorised access, alteration, and disclosure, in accordance with the security safeguard requirements of POPIA. While we take reasonable steps to protect your personal information, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.
12. Your Rights Under POPIA
Subject to applicable law, you have the right to:
- be notified that we are collecting your personal information and for what purpose;
- request access to the personal information we hold about you;
- request that we correct or update any personal information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or obtained unlawfully;
- request the deletion or destruction of personal information that we are no longer authorised to retain;
- object, on reasonable grounds, to the processing of your personal information, including for direct marketing purposes;
- withdraw any consent you have given, at any time, without affecting the lawfulness of processing carried out before you withdrew consent;
- lodge a complaint with us, or with the Information Regulator, if you believe your personal information has been processed unlawfully, as described in clause 14.
To exercise any of these rights, please contact our Information Officer using the details in clause 13. We may need to verify your identity before responding to your request, and may take reasonable time, and where permitted charge a reasonable fee, to respond in accordance with POPIA.
13. Contact Us / Information Officer
If you have any questions about this Privacy Policy, or wish to exercise any of your rights under POPIA, please contact our Information Officer:
- Company: FinPoza (PTY) Ltd
- Information Officer: Willem Deyzel
- Email: Info@FinPoza.com
14. How to Lodge a Complaint with the Information Regulator
If you are not satisfied with our response to a request or complaint, you have the right to lodge a complaint with the Information Regulator of South Africa, whose contact details are:
- Physical Address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
- Postal Address: P.O. Box 31533, Braamfontein, Johannesburg, 2017
- Telephone: 010 023 5200
- General Enquiries: enquiries@inforegulator.org.za
- POPIA Complaints: POPIAComplaints@inforegulator.org.za
- Website: www.inforegulator.org.za
Complaints may also be lodged through the Information Regulator’s eServices portal, accessible via its website. We recommend confirming current complaint channels and portal details on the Information Regulator’s website, as these are updated by the Regulator from time to time.
15. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, our services, or applicable law. We will post the updated version on the Website with a revised effective date. We encourage you to review this Privacy Policy periodically. Material changes affecting how we use your personal information will, where required by law, be brought to your attention.