Privacy Policy

Threerae processes personal information in the course of providing financial services, commodity facilitation and environmental rehabilitation services. This policy explains what we collect, why we collect it, who we share it with and what rights you have. It applies to our website, our application processes and our ongoing client relationships.

Information We Collect

What we collect depends on why you are dealing with us.

• Identity information — full name, South African ID number, date of birth and contact details
• Contact and address information — physical and postal address, email address, telephone numbers
• Financial information — bank account details, bank statements, income and salary information, existing credit obligations and expenses
• Employment information — employer, employment status, salary advice or payslip details, and (for employer-partnered advances) employment verification supplied by your employer
• Credit information — credit bureau records, payment history and affordability assessment outcomes
• Business information (for SMME clients) — company registration and compliance documents, purchase orders, supplier quotations and buyer details
• Website information — enquiry form submissions and basic technical information sent by your browser

Why We Process It

• To verify your identity, as required by the Financial Intelligence Centre Act (FIC Act)
• To conduct the affordability assessment required by the National Credit Act before granting credit
• To assess, approve, decline, administer and collect on credit agreements
• To process payroll deductions where an employer partnership is in place and you have authorised it
• To communicate with you about your application, your account and your repayments
• To meet our reporting obligations to the National Credit Regulator, credit bureaux, the Financial Intelligence Centre, SARS and other regulators
• To prevent fraud, money laundering and the financing of terrorism
• To respond to enquiries submitted through our website or other channels

Lawful Basis

We process personal information where it is necessary to conclude or perform a contract with you, where processing is required to comply with an obligation imposed on us by law, where it is necessary for our legitimate interests or yours, and — where none of those apply — on the basis of your consent. Where we rely on consent you may withdraw it, subject to any legal obligation we have to continue holding or reporting the information.

Who We Share It With

We share personal information only where there is a lawful reason to do so.

• Credit bureaux — for affordability assessment and for the credit reporting we are required to perform as a registered credit provider
• Banks and payment providers — to disburse funds and to process authorised repayments, including via DebiCheck
• Your employer — where you have applied through an employer partnership, limited to what is needed to verify employment and process an authorised payroll deduction
• Regulators and authorities — the National Credit Regulator, Financial Intelligence Centre, SARS and other bodies where we are legally obliged to report
• Service providers — technology, verification, communication and collections providers who process information on our behalf under contractual confidentiality and security obligations
• Debt collectors and legal representatives — where an account has defaulted and recovery steps are taken

We do not sell your personal information, and we do not share it for third-party marketing purposes.

How Long We Keep It

We retain personal information for as long as we have a relationship with you and thereafter for the periods required by law — including retention obligations under the National Credit Act, the FIC Act, tax legislation and the Companies Act. Where no legal retention period applies, we keep information only for as long as it is needed for the purpose it was collected for.

Security

We apply reasonable technical and organisational measures to protect personal information against loss, unauthorised access and unlawful processing, including access controls, system-level protections and confidentiality obligations on staff and service providers. No system is absolutely secure, and we will notify you and the Information Regulator of a compromise where the law requires it.

Your Rights

• To ask what personal information we hold about you and to request access to it
• To ask us to correct or delete information that is inaccurate, irrelevant, excessive, out of date or obtained unlawfully
• To object to processing in the circumstances allowed by POPIA
• To withdraw consent where processing is based on consent, subject to our legal obligations
• To lodge a complaint with the Information Regulator of South Africa

Requests relating to credit information held by a credit bureau should also be directed to the bureau concerned, which has its own dispute process under the National Credit Act.

Changes To This Policy

We may update this policy from time to time to reflect changes in our operations or in the law. The version published on this page is the current one.