Last Update: 30 June 2021
We respect your privacy and your personal information, and for this reason we will take all reasonable measures, in accordance with this Policy, to protect your personal information to keep it confidential, even when you are no longer directly involved with Smart Money at a given time.
Who we are
Smart Money is a subdivision and brand of Adarna.
Smart Money is aimed at assisting South African residents with their financial wellness through the Smart Money website and platform together with our financial wellness programmes offer through Smart Money by Adarna.
Adarna (Pty) Ltd, trading as Adarna is a focused on providing advertising, business, financial wellness and marketing services and products. Services and products are aimed at both businesses and individuals. In addition, to provide these services we have created subdivisions and brands focused on specific services and products and are as below:
Money 101 is aimed at educating South African residents about financial related topics through a blog website.
South African Listings
Advertising and online directories
South African Listings is aimed at assisting South African residents both find suppliers and service providers as well as promoting suppliers and service providers. Businesses are eligible to “list” themselves on South African Listings website or sub-website such as www.southafricanlistings.co.za/schools. The public is then able to search for businesses that are listed on the website.
Adarna company details:
- CPIC Registration: Private Company (2020 / 184534 / 07)
- Website address: https://adarna.co.za
- Registered address: 28 Parkway, Fourways, Johannesburg, 2068
Personal information refers to any information that identifies you or specifically relates to you.
Personal information includes, but is not limited to, the following information about you:
- First name
- Middle name
- Last name
- Physical address
- Postal address
- Email address
- Telephone and/or cell number
- Online identifiers such as social media profiles
- User-generated content, documents and other content you submit to us or to our website.
Any information about what you buy, where you shop, where you bank, and all related information will also be regarded as personal information.
In short, any information that we know about you will be regarded as your personal information.
When personal information is collected, Smart Money will indicate, where possible, the purpose for the collection and whether the information required is compulsory or voluntary.
Special personal information is personal information that is not limited to demographic and contact information that could include, but is not limited to the below:
- Expressed personal interests (example: gaming products, office equipment, etc)
- Personal preferences relating to a product or service.
When special information is collected, Smart Money will indicate, where possible, the purpose for the collection and whether the information required is compulsory or voluntary.
Usage Data may include information such as your device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the website by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
We may also collect information that your browser sends whenever you visit our website or when you access the website by or through a mobile device.
How we process your information
When do we process information?
We will only process your personal information for lawful purposes related to our business if the following circumstances apply:
- You have consented thereto.
- A person legally authorised by you, the law or a court, has consented thereto.
- It is necessary to conclude or perform under a service or contract we have with you.
- The law requires or permits it.
- It is required to protect or pursue your legitimate interest, ours, or that of a third party; and
- You are a child, and a competent person (such as a parent or guardian) has consented thereto on your behalf.
We collect and process your Personal Information mainly to provide you with access to our services and products, to help us improve our offerings to you, to support our contractual relationship with you. The type of information we collect will depend on the purpose for which it is collected and used. We will only collect information that we need for that purpose.
We may process your special personal information under the following circumstances:
- If you have consented to the processing thereof.
- If the processing is needed to create, use or protect a right or obligation in law.
- If the processing is for statistical or research purposes.
- If the special personal information was made public by you.
- If the processing is required by law; and
The type of information we collect will depend on the purpose for which it is collected and used. We will only collect information that we need for that purpose.
We may process your usage data under the following circumstances:
- Access to our website: https://smartmoney.co.za through a non-mobile or mobile device.
- If you agree to our cookie notice (more information about Cookies can be found under Tracking)
Reasons for processing your information.
We will use your Personal and Non-personal Information only for the purposes for which it was collected or agreed with you. We will process your personal information for any of the following possible reasons:
- To complete transactions on our website;
- To complete transactions with our sales representatives;
- To fulfil customer support enquiries;
- To process payments with on the website or directly when instructed to do so;
- To conduct market or customer satisfaction research or for statistical analysis;
- To evaluate the use of the site, products and services;
- To assist with business development;
- To suggest products or services (including those of relevant third parties) which we think may be of interest to you;
- To collect Usage Data and link this to your Personal Information so as to ensure that the site presents the best web experience for you;
- To evaluate (anonymously and in the aggregate) statistics on website activity, such as what time you visited it, whether you have visited it before and what site referred you to it;
- To carry out our obligations arising from any orders or contracts entered into between you and us;
- To confirm and verify your identity or to verify that you are an authorised customer for security purposes;
- To contact you regarding products and services which may be of interest to you, provided you have given us consent to do so or you have previously requested a product or service from us and the communication is relevant or related to that prior request and made within any timeframes established by applicable laws;
- To notify you about changes to our service;
- To respond to your queries or comments;
- For audit and record-keeping purposes;
- In connection with legal proceedings.
- To enable you to participate in and make use of value-added products and services; or
- For any other related purposes.
Confidentiality and security
Smart Money has physical, technological, and procedural security safeguards in place and will use its best endeavours to protect your personal information.
Personal information refers to information that identifies or relates specifically to you as outlined in the Information disclosure.
Personal Information Security
Smart Money will take all reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. The company will store all the personal information in secured environments.
We will, on an on-going basis, continue to review our security controls and related processes to ensure that your Personal Information is secure.
Our security policies and procedures cover:
- Acceptable usage of personal information, special information and usage data;
- Access to personal information, special information and usage data;
- Computer and network security;
- Governance and regulatory issues;
- Investigating and reacting to security incidents.
- Monitoring access and usage of personal information;
- Physical security;
- Retention and disposal of information;
- Secure communications;
- Security in contracting out activities or functions.
Review and correct your personal information.
You can request to review your personal information contained in Smart Money‘s records at any time to correct or update the information. If the purpose for which your personal information was requested initially does not exist anymore, for example you no longer have a contract with us, you may request information held by the company to be removed.
However, Smart Money can decline your request to delete the information from its records if other legislation requires the continued retention thereof or if it has been de-identified.
Please note that any such access request may be subject to a payment of a legally allowable fee, as laid down in our POPI Act Policy.
Retention of personal information
Smart Money will retain your personal information and data in compliance with the POPI Act and in compliance with other applicable legislation.
We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies
Sharing your information
Smart Money will only share your personal information with third parties if you have consented to such disclosure. If consent has been obtained, Smart Money may share your personal information with persons or organisations within and outside of Smart Money.
Smart Money may be obliged to disclose your personal information to the extent that it is required to do so by law, in connection with any legal proceedings or prospective legal proceedings, or for the purposes of protecting the interest of its members, for example, fraud prevention or to give effect to an agreement.
Your privacy is important to us. We will therefore not sell, rent or provide your personal information to unauthorised entities or other third parties, for their independent use, without your consent.
Third-Parties access to your personal information
Where Smart Money discloses personal information to intermediaries, other institutions, insurers, suppliers, manufacturers or any other third parties, the third parties will be obliged to use that personal information only for the reasons and purposes it was disclosed for.
When we contract with third parties, we impose appropriate security, privacy and confidentiality obligations on them to ensure that Personal Information that we remain responsible for, is kept secure.
We will ensure that anyone to whom we pass your Personal Information agrees to treat your information with the same level of protection as we are obliged to.
Our website does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us.
If Smart Money becomes aware that we have collected Personal Data from anyone under the age of 13 without verification of parental consent, we will take steps to remove that information from our servers.
If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent’s consent before we collect and use that information.
Tracking and links
The technologies we use may include:
Cookies or Browser Cookies.
Certain features of our website may use local stored objects (or Flash Cookies) to collect and store information about your preferences or your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how you can delete Flash Cookies, please visit www.allaboutcookies.org for details on how to delete or reject cookies and for further information on cookies generally.
Certain sections of our website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Smart Money, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Type of Cookies
Cookies can be Persistent or Session Cookies.
Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as you close your web browser.
We use both Session and Persistent Cookies for the purposes set out below:
Necessary / Essential Cookies
- Type: Session Cookies
- Administered by: Smart Money
- Purpose: These Cookies are essential to provide you with services available through the Website and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that you have asked for cannot be provided, and we only use these Cookies to provide you with those services.
Cookies Policy / Notice Acceptance Cookies
- Type: Persistent Cookies
- Administered by: Smart Money
- Type: Persistent Cookies
- Administered by: Smart Money
- Purpose: These Cookies allow us to remember choices you make when you use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the Website.
Third-Party Tracking and Links
Google AdSense and Ads
We have implemented the following:
- Remarketing with Google AdSense
- Demographics and Interests Reporting
We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.
Right to object and complain
Right to object
In terms of the POPI Act (POPIA) section 18. (h) (iv) you have the right to object to the processing of Personal Information as referred to in section 11(3) of the POPI Act.
Right to lodge a complaint
In terms of the POPI Act (POPIA) section 18. (h) (v) you have the right to lodge a complaint to the Information Regulator (South Africa) (IRSA).
The IRSA contact details are:
- JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
- PO Box 31533, Braamfontein, Johannesburg, 2017
- Email: [email protected]
CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
- Send information, respond to inquiries, and/or other requests or questions
- Process orders and to send information and updates pertaining to orders.
- Send you additional information related to your product and/or service
- Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.
To be in accordance with CANSPAM, we agree to the following:
- Not use false or misleading subjects or email addresses.
- Identify the message as an advertisement in some reasonable way.
- Include the physical address of our business or site headquarters.
- Monitor third-party email marketing services for compliance, if one is used.
- Honour opt-out/unsubscribe requests quickly.
- Allow users to unsubscribe by using the link at the bottom of each email.
If at any time you would like to unsubscribe from receiving future emails:
- Email us at [email protected]
- Follow the instructions at the bottom of each email and we will promptly remove you from ALL correspondence.
At our discretion we will inform you via email and/or a prominent notice on our website, prior to any significant changes becoming effective.
If you have any questions about this policy or Smart Money’s treatment of your personal information, send an email to: [email protected]