Privacy Policy

1. Introduction

This Privacy Policy explains how Cocofinance ("we," "us," or "our") collects, uses, discloses, and protects your personal information when you use our website, loan services, and related products. This policy complies with the Protection of Personal Information Act, 2013 (POPIA).

2. Information We Collect

2.1 Personal Information

We collect the following types of personal information:

• Identity Information: Full name, ID number, date of birth
• Contact Information: Email address, phone number, physical address
• Financial Information: Employment details, income, bank account details, credit history
• Supporting Documents: ID copies, payslips, bank statements, proof of residence
• Account Information: Username, password (encrypted), login history

2.2 Information Collected Automatically

We automatically collect:

• IP address and device information
• Browser type and version
• Pages visited and time spent
• Referring website addresses
• Cookies and similar tracking technologies

2.3 Information from Third Parties

We may receive information from:

• Credit bureaus (e.g., TransUnion, Experian, Compuscan)
• Identity verification services
• Your employer (with your consent)
• Banking institutions

3. How We Use Your Information

3.1 Primary Uses

We use your personal information to:

• Process and assess your loan applications
• Verify your identity and prevent fraud
• Conduct credit checks and affordability assessments
• Disburse approved loans to your bank account
• Manage your account and provide customer service
• Process loan repayments and manage collections
• Send important notifications about your account

3.2 Legal and Regulatory Compliance

We use your information to:

• Comply with the National Credit Act (NCA)
• Meet FICA (Financial Intelligence Centre Act) requirements
• Report to the National Credit Regulator (NCR)
• Respond to legal requests and prevent crime

3.3 Marketing and Communications

With your consent, we may:

• Send promotional offers and product updates
• Provide personalized loan recommendations
• Send newsletters and financial tips

You can opt-out of marketing communications at any time.

4. Legal Basis for Processing

Under POPIA, we process your information based on:

• Consent: You have given explicit permission
• Contract Performance: Processing is necessary to fulfill our loan agreement
• Legal Obligation: We must comply with NCA, FICA, and other regulations
• Legitimate Interest: Fraud prevention, credit assessment, business operations

5. Information Sharing and Disclosure

5.1 With Your Consent

We may share your information with:

• Credit Bureaus: To conduct credit checks and report loan performance
• Debt Collection Agencies: If you default on your loan
• Legal and Professional Advisors: Lawyers, auditors, consultants

5.2 Service Providers

We work with third-party service providers who assist us with:

• Payment processing and banking services
• Identity verification and fraud detection
• Email and SMS communications
• IT infrastructure and data storage
• Customer support services

All service providers are contractually obligated to protect your information.

5.3 Credit Brokers

If you apply through a registered credit broker, we share necessary information with that broker to facilitate your application and manage your account.

5.4 Legal Requirements

We may disclose your information when required by law:

• To comply with court orders or legal processes
• To respond to government or regulatory requests
• To protect our rights, property, or safety
• To prevent or investigate suspected fraud or illegal activity

6. Data Security

6.1 Security Measures

We implement industry-standard security measures:

• Encryption: All data transmissions use SSL/TLS encryption
• Access Controls: Strict role-based access to personal information
• Firewalls: Network security to prevent unauthorized access
• Regular Audits: Security assessments and vulnerability testing
• Employee Training: Staff are trained on data protection

6.2 Password Security

You are responsible for:

• Choosing a strong, unique password
• Keeping your password confidential
• Notifying us immediately of any unauthorized access

7. Data Retention

We retain your personal information for:

• Active Accounts: Duration of your relationship with us
• Loan Records: 5 years after loan completion (as required by NCA)
• Credit Information: As required by credit bureau regulations
• Legal Requirements: As mandated by applicable laws

After the retention period, we securely delete or anonymize your information unless legally required to retain it longer.

8. Your Rights Under POPIA

8.1 Right to Access

You have the right to request:

• Confirmation of what personal information we hold
• Access to your personal information
• Details about how we use and share your information

8.2 Right to Correction

You can request correction of:

• Inaccurate personal information
• Incomplete information
• Outdated information

8.3 Right to Deletion

You can request deletion of your information when:

• It's no longer necessary for the purpose collected
• You withdraw consent (where consent was the legal basis)
• You object to processing and there are no overriding legitimate grounds

Note: Some information must be retained to comply with legal obligations.

8.4 Right to Object

You can object to:

• Direct marketing communications
• Processing based on legitimate interests
• Automated decision-making (including profiling)

8.5 Right to Data Portability

You can request your personal information in a structured, commonly used format to transfer to another service provider.

9. Cookies and Tracking

9.1 What Are Cookies?

Cookies are small text files stored on your device when you visit our website. We use cookies to improve your experience and analyze website usage.

9.2 Types of Cookies We Use

• Essential Cookies: Required for website functionality
• Performance Cookies: Help us understand how visitors use our site
• Functional Cookies: Remember your preferences
• Marketing Cookies: Track your interests for advertising (with consent)

9.3 Managing Cookies

You can control cookies through your browser settings. Note that disabling cookies may affect website functionality.

10. Children's Privacy

Our Services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from minors. If we become aware that we have collected information from a minor, we will take steps to delete it immediately.

11. International Data Transfers

Your information is primarily stored and processed in South Africa. If we transfer data outside South Africa, we ensure adequate protection through:

• Contracts with data protection clauses
• Ensuring recipients comply with POPIA standards
• Using approved transfer mechanisms

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated "Last Updated" date. Significant changes will be communicated via email or prominent notice on our website.

Your continued use of our Services after changes constitutes acceptance of the updated Privacy Policy.

13. How to Exercise Your Rights

To exercise any of your POPIA rights, please contact us:

We will respond to your request within 30 days as required by POPIA.

14. Complaints

If you believe we have mishandled your personal information, you may file a complaint with:

15. Contact Information

For general privacy questions or concerns: