Housing Investment Partners Proprietary Limited
Housing Investment Partners Proprietary Limited (“HiP”) is a home loans provider jointly owned by the Old Mutual Limited Group and the National Housing Finance Corporation (SOC) Limited.
At HiP, we are committed to protecting your privacy and to ensure that your Personal Information is collected and used properly, lawfully and transparently in compliance with the Protection of Personal Information (POPI) Act, 2013.
Purpose of this Privacy Notification
This Privacy Notification explains how we obtain, use and disclose your personal information and aims to inform you of your rights and how to exercise them.
This Privacy Notification supplements other notices and privacy policies and is not intended to override them.
What is Personal Information?
Personal Information is information that relates to an identifiable, living natural person or existing, identifiable juristic person e.g. name, address, identity number, gender, marital status and so on.
Purposes for which Personal Information is being collected
- We will only process your Personal Information lawfully and in a reasonable manner that does not infringe on your privacy. Most commonly, we will use your Personal Information:
- To enter into a home loans credit agreement with you, maintain the relationship and to ensure fulfilment by all parties, of terms and conditions of the agreement;
- To enter into any other contracts with you, maintain the relationship and to ensure fulfilment by all parties, of terms and conditions of such contracts;
- To comply with relevant legal obligations;
- To protect our legitimate interests.
- We may also use your Personal Information in the following situations:
- Where we need to protect your legitimate interests (or someone else’s interests);
- Where it is needed in the public interest or for official purposes.
- We only collect Personal Information for the specific, explicitly defined and lawful purpose of conducting our business.
- Lawful bases for processing Personal Information are:
- Data subject or competent person acting for a child, consents to the processing;
- To carry out actions for the conclusion or performance of a contract to which the Data Subject is party;
- To comply with a legal obligation;
- To protect the Data Subject’s legitimate interests;
- To protect the Responsible Party’s (or third party) legitimate interests;
- When necessary for the proper performance of a public law duty by a public body.
We may process Personal Information for more than one lawful basis depending on the specific purpose for which we are using the data. Please contact us if you need details about the specific legal basis, we are relying on to process your Personal Information.
- Direct Marketing
- We may use your Personal Information to periodically send you direct marketing communications about our products or related services that we think may be of interest to you. This will be in the form of email, post, [SMS or targeted online advertisements]. We will limit direct marketing to a reasonable and proportionate level, based on the information we have about you;
- Where opt-in consent is required, we will ask for your consent.
- You have the right to stop receiving direct marketing at any time. You can stop receiving direct marketing by following the opt-out links located in the electronic communications (such as emails) you receive from us or by contacting us, or by emailing us.
Is the supply of the information voluntary or mandatory?
Supplying of certain types of information is mandatory in terms of legislation and regulations. For example, in terms of the National Credit Act, certain information must be reported to the credit bureaus or the National Credit Regulator.
Failure to provide the requested information
Your Personal Information is required achieve our purpose for collecting Personal Information as spelt out above. Failure to provide any requested information may limit our ability achieve that purpose.
Transfer of the information to another Country
If your Personal Information is transferred outside the Republic of South Africa to third party service providers, we will take steps to ensure that your Personal Information receives the same level of protection as if it remained within the Republic.
Recipients or Category of Recipients of the Information
Your Personal Information will be treated as prescribed by the eight (8) Conditions for the Lawful Processing of Personal Information in the POPI Act. HiP may have to share your Personal Information:
- Related Companies, Business Partners and Affiliates – subject to your consent, where appropriate, when we believe it will enhance our business/professional relationship with you. HiP will take practicable and reasonable steps to ensure that these entities will also accord the same of level of protection to your Personal Information as HiP.
- Service Providers – We may disclose the information we collect from you to third party vendors, technology and other service providers, auditors, professional advisors, contractors or agents who perform functions on our behalf, or are engaged by us. These service providers are allowed to access and use the information we make available to them only as needed to perform their functions and for no other purposes, subject to appropriate contractual restrictions and security measures. HiP will take practicable and reasonable steps to ensure that Service Providers will also accord the same of level of protection your Personal Information as HiP.
- In Response to Legal Process and/or Regulatory Requirements – We may disclose the information we collect from you in order to comply with the law, a legal proceeding, court order, or other legal process, such as in response to a court order or a subpoena. We may also disclose your Personal Information to satisfy government and/or regulatory requirements.
- To Third Parties – these are third party whose services facilitate, enhance or are necessary for the achievement of our purpose for collecting your Personal Information e.g.:
- third parties that are involved in the home loans application assessment process e.g. credit bureaus, property valuators, employers or other creditors;
- third parties used to facilitate payment transactions, e.g. clearing houses, clearing systems, financial institutions, and transaction beneficiaries;
- third parties where you have a relationship with that third party, and you have consented to us sharing information e.g. your bankers, social media sites or other third-party application providers;
- third parties for marketing purposes (e.g. our business partners and other third parties with whom we work and whose products or services we think will interest you or will enhance your business relationship with us. Examples include financial services organisations (such as banks, insurers, finance providers), payment solutions providers, software and services providers that provide business solutions);
- To Protect Ours, Yours or Others’ Legitimate Interests – We also may disclose the information we collect from you to protect our, your or other persons’ legitimate interests e.g. where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of this Privacy Notification, or as evidence in litigation in which we, you or others are involved.
Your Rights as a Data Subject.
As a Data Subject in terms of the POPI Act, you have the following rights:
- Right to be Notified: The right to be notified that:
- Personal Information about you is being collected; and
- your Personal Information has been accessed or acquired by an unauthorised person;
- Right of Access:
- The right to establish whether we hold your Personal Information and to request access to your Personal Information;
- Right to Correction, Destruction or Deletion:
- The right to request, where necessary, the correction, destruction or deletion of your Personal Information;
- Right to Objection: The right to object:
- on reasonable grounds relating to your particular situation to the processing of your Personal Information;
- to the processing of your Personal Information:
- at any time for purposes of direct marketing; or
- o for purposes of direct marketing by means of unsolicited electronic communications;
- Right with regards to Automated Processing:
- The right not to be subject, under certain circumstances, to a decision which is based solely on the basis of the automated processing of your Personal Information, intended to provide a profile of you;
- Right to Complain: The right to:
- submit a complaint to the Information Regulator regarding the alleged interference with the protection of the Personal Information of any Data Subject or to submit a complaint to the Regulator in respect of a determination of an adjudicator as; and
- to institute civil proceedings regarding the alleged interference with the protection of your Personal Information.
If you believe that HiP has not replied to your access request, has not handled your Personal Information in a reasonable manner or have any questions regarding this Privacy Notification, please contact our Information Officer:
Changes to this Privacy Notification
Please note that HiP may amend this Privacy Notification from time to time. Please check with us or our website to inform yourself of any changes.