PRIVACY POLICY

1. INTRODUCTION
  1. 1. Nova Life Proprietary Limited, registration number 2015/332393/07, (“Nova Life”), is a specialist telemarketing company that provides various marketing services to our business partners and their customers.
  1. 2. These services relate to direct marketing and consulting, and include, amongst other things:
    1. 2.1. Telemarketing
    1. 2.2. Lead Generation
    1. 2.3. Client Care
    1. 2.4. Quality Control
    1. 2.5. Sales Training
    1. 2.6. Recruitment
  1. 3. We value our business partners and the personal information that is shared with us. We understand the sensitive nature of the personal information which we hold. It is for this reason that the protection of your personal information is one of our top priorities. We endeavour to maintain the confidentiality of your personal information and process your personal information in adherence to the Protection of Personal Information Act 4 of 2013 (“POPIA”).
  1. 4. This privacy policy (“privacy policy”) explains how we collect, use, transfer and protect your personal information. This notice may be revised from time to time as and when necessitated by the changes in our growing business and updated versions of this notice will be posted on our website and be made available via email on request. If you wish to receive this privacy policy by email you may do so by request to our information officer at einfo@novalifesales.co.za.
2. WHAT IS PERSONAL INFORMATION
  1. 1. In terms of POPIA, personal information is information that may be used to identify an individual or a company.
  1. 2. Examples of personal information include, but are not limited to:
    1. 2.1. Name;
    1. 2.2. Identification number;
    1. 2.3. Contact information;
    1. 2.4. Financial information;
    1. 2.5. Information relating to race, gender or sexual orientation;
    1. 2.6. Age;
    1. 2.7. Physical or mental health;
    1. 2.8. Disability; and/or
    1. 2.9. Language.
    3. PERSONAL INFORMATION THAT WE COLLECT
    1. 1. We collect and use personal information mainly to perform direct marketing for our business partners, and to perform contractual obligations.
    1. 2. We may collect personal information which includes, but is not limited to:
      1. 2.1. Identification and contact information and information that will assist us to provide products and services to you, such as:
        • Name
        • Physical and postal address
        • Email address
        • Telephone or other contact details
        • Gender
        • Marital status
        • Date of birth
        • Educational background
        • Physical attributes
        • Photos
        • Employment history
        • The relationship that you, as the policyholder, have with others including dependents
        • Identification number
      1. 2.2. Financial information and account details, such as:

        • Bank account number and account details
        • Credit history
        • Credit score
      1. 2.3. Medical condition and health information, such as:
          • Current physical, mental or medical condition
          • Past physical, mental or medical condition
          • Injury or disability information
        1. 2.4. Other sensitive information, such as:
            • Family medical history
            • Details of your children
            • Other sensitive information voluntarily provided by you
        1. 3. We may also collect feedback, comments and questions received from you in service-related communication and activities.
        1. 4. When personal information is collected, we will indicate the purpose for the collection of the personal information and whether the personal information required is compulsory or voluntary.
        4. HOW WE COLLECT PERSONAL INFORMATION
        1. 1. We collect your personal information in one of the following ways:
          1. 1.1. Directly from you through a telephone call centre;
          1. 1.2. When you use our website your information may be automatically collected (e.g. data gathered by cookies);
          1. 1.3. When you use our website for online queries or chat box functionality;
          1. 1.4. When your personal information is publicly available; and
          1. 1.5. If you gave consent to the collection of your information from another source (including our business partners) and we have provided you with the detail of the source.
        5. USE OF PERSONAL INFORMATION
        1. 1. Personal information collected by us may be used, stored, disclosed or shared for the following purposes:
          1. 1.1. To conclude your agreed purchasing of a product or service;
          1. 1.2. To communicate with you regarding product information, membership, application or delivery;
          1. 1.3. To comply with our internal policies and procedures such as:
            1. 1.3.1. Quality assurance;
            1. 1.3.2. Audit reports;
            1. 1.3.3. Finance and accounting;
            1. 1.3.4. Billing and collections;
            1. 1.3.5. IT systems;
            1. 1.3.6. Data and website management; and
            1. 1.3.7. Records management.
          1. 1.4. To respond to queries or resolve complaints;
          1. 1.5. To handle requests for the correction, updating, access or deletion of your personal information; and
          1. 1.6. To comply with applicable laws and regulatory obligations.
        6. SHARING OF PERSONAL INFORMATION
        1. 1. Access to your personal information within Nova Life is restricted to those individuals who require access to your personal information for business purposes.
        1. 2. Nova Life may be obliged to disclose your personal information to the extent that it is required to do so by law.
        7. SECURING YOUR PERSONAL INFORMATION
        1. 1. Nova Life will:
          1. 1.1. Take reasonable and appropriate technical and organisational measures to ensure that your personal information is kept secure and is protected against unauthorised or unlawful processing, accidental loss, destruction or damage, alteration, disclosure or access;
          1. 1.2. Provide you with access to your personal information to view and/or update your personal details;
          1. 1.3. Promptly notify you if we become aware of any unauthorised use, disclosure or processing of your personal information; and
          1. 1.4. Provide you with reasonable evidence of our compliance with our obligations under this policy on reasonable notice and request.
        1. 2. Whilst we will do all things reasonably necessary to protect your rights of privacy, we cannot guarantee or accept any liability whatsoever for unauthorised or unlawful disclosures of your personal information, whilst in our possession, by a third party who is not subject to our control, unless such disclosure is as a result of our gross negligence.
        1. 3. If you disclose your personal information to a third party, such as an entity which operates a website linked to this Website or anyone other than Nova Life, NOVA LIFE SHALL NOT BE LIABLE FOR ANY LOSS OR DAMAGE, HOWSOEVER ARISING, SUFFERED BY YOU AS A RESULT OF THE DISCLOSURE OF SUCH INFORMATION TO THE THIRD PARTY. This is because we do not regulate or control how that third party uses your personal information. You should always ensure that you read the privacy policy of any third party.
        1. 4. All information obtained by Nova Life is stored on dedicated servers within the borders of South Africa. The servers are secured behind a firewall and access to the servers are password protected and strictly limited. Notwithstanding this, no security measures or systems are impenetrable. We cannot make any guarantees against data breaches.
        8. HOW YOU CAN REVIEW AND CORRECT YOUR PERSONAL INFORMATION
        1. 1. We undertake to provide you with access to your personal information and provide mechanisms so that any personal information found to be inaccurate or incomplete can be corrected or amended as feasible, subject to any requirement or rule for such personal information to be retained by law.
        1. 2. Prior to the amendment, correction or removal of your personal information, we will require you to identify yourself and to identify the portion of information requested to be amended, correct or removed. A request for the amendment, correction or removal of personal information may be declined if the process of the request is unreasonably repetitive, require disproportionate technical effort, or jeopardizes the privacy of others.
        1. 3. The services of access and correction of personal information is done free of charge, except to the extent that it would require disproportionate effort by Nova Life. Once personal information is deleted, residual copies of the information may take a period of time before they are deleted from our servers and may remain in our backup systems.
        1. 4. It is important that any information you provide directly to us is accurate and correct. Please let us know as soon as you can if any information that we hold about you is no longer correct.
        1. 5. Providing false or inaccurate information in order to obtain a product or service may also result in said product or service being restricted or cancelled.
        9. DATA RETENTION
        1. 1. We will only retain your personal information to the extent and duration that we have a legitimate interest to process your personal information as defined in point 5 above (“Use of Personal Information”).
        1. 2. We will upon your request, promptly return or destroy any and all of your personal information in our possession or control, save for that which we are legally obliged to retain.
        10. YOUR RIGHTS AS A DATA SUBJECT
        1. 1. As a data subject, you have a number of data privacy rights. These rights include the right to request from Nova Life access to, correction or deletion of your personal data or restriction of processing concerning your data or to object to the processing of your personal information.
        1. 2. All the rights of a data subject are contained in POPIA. The information on these rights can be found at the Information Regulator’s website at https://www.justice.gov.za/inforeg/, to whom you have the right to make a complaint, if we do not resolve your concern.
        11. CONTACT US
        1. 1. If you have any questions about this notice our treatment of your personal information or wish to exercise any of your rights, please address an email to einfo@novalifesales.co.za.