1 Introduction
iMali Loans (“we”, “us”, “our”) is committed to protecting your privacy and handling your personal information responsibly, lawfully and transparently. This policy sets out how we process the personal information you share with us when you apply for a loan, use our website, or otherwise interact with us.
“Personal information” means information relating to an identifiable, living natural person — and where applicable, an identifiable existing juristic person — as defined in POPIA. By applying for a loan or using our services, you acknowledge that you have read and understood this policy.
As a registered credit provider, we are also subject to the National Credit Act, 2005 (NCA), the Financial Intelligence Centre Act, 2001 (FICA) and related legislation, some of which requires us to collect and retain your information regardless of your consent.
2 Who we are (Responsible Party)
For the purposes of POPIA, the Responsible Party is:
- Speedy Dollar Eight no 2 (Pty) Ltd, trading as iMali Loans
- Company registration number: 2018/616235/07
- NCR credit provider registration: NCRCP 1205
- Authorised Financial Services Provider through Novitas (Pty) Ltd (FSP 14068)
- Website: imaliloans.co.za
Information Officer
Our Information Officer is responsible for ensuring we comply with POPIA. You can reach them at:
3 Information we collect
Depending on how you interact with us, we may collect the following categories of personal information:
Identity & contact details
- Full name, South African ID number, date of birth and gender
- Residential and postal address
- Contact numbers and email address
- A photograph or selfie and your signature, where required for verification
Financial & credit information Special / sensitive
- Bank account details and bank statements
- Income, expenses and employment information for affordability assessments
- Credit history, credit score and credit bureau records
- Loan application, repayment and account history
Technical & usage information
- IP address, device and browser information
- Pages visited and how you use our website
- Communications with us (calls, emails, SMS, WhatsApp and chat messages)
Children’s information: Our services are intended for adults (18 years and older). We do not knowingly collect the personal information of children. If we learn that we have done so without proper legal justification, we will delete it.
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4 How we collect your information
- Directly from you when you apply for a loan, complete forms, or contact us
- Automatically when you use our website (cookies and similar technologies)
- From third parties such as credit bureaus, banks, employers and payment providers, where you have authorised this or where the law permits
Where we collect information directly from you, we will, at the time of collection, make you aware of the purpose and of your rights, including your right to object.
5 Why we process your information
We process your personal information only for lawful, specific and explicitly defined purposes, including to:
- Verify your identity and prevent fraud
- Assess your loan application and conduct affordability assessments required by the NCA
- Perform credit checks and report to credit bureaus as required by law
- Enter into and administer your loan agreement, including collections and repayments (e.g. debit orders / DebiCheck)
- Comply with our legal and regulatory obligations under the NCA, FICA and other laws
- Communicate with you about your account and application
- Improve our services and website
- Send you marketing communications, where you have consented (see section 12)
6 Our lawful basis for processing
In line with section 11 of POPIA, we process your personal information where:
- You have given your consent;
- Processing is necessary to conclude or perform a contract with you (your loan agreement);
- Processing is required to comply with a legal obligation (such as the NCA and FICA);
- Processing protects a legitimate interest of yours; or
- Processing is necessary for our legitimate interests, balanced against your rights.
Because we are a regulated credit provider, some processing — such as identity verification, affordability checks and credit bureau reporting — is a legal requirement and does not depend solely on your consent.
7 Who we share your information with
We do not sell your personal information. We may share it, only as necessary and under appropriate safeguards, with:
- Credit bureaus, for credit checks and mandatory reporting
- Banks and payment processors, to disburse loans and collect repayments
- Identity verification and fraud-prevention providers
- SMS, email and messaging service providers used to communicate with you
- Operators (service providers) who process information on our behalf under written agreements
- Regulators, courts and law enforcement, where required or permitted by law
- Professional advisors such as auditors, attorneys and debt collectors
Where we appoint an Operator to process information on our behalf, we require them by written contract to maintain confidentiality and appropriate security measures.
8 Credit bureaus
As a credit provider, we are required to share and check information with registered credit bureaus. This means:
- We may check your credit record when you apply and during the life of your loan;
- We report your account conduct, including both positive and negative payment behaviour, to credit bureaus as required by the NCA;
- Credit bureaus keep a record of this information and may share it with other credit providers.
You have the right to contact the credit bureaus to obtain a copy of your credit record and to challenge information you believe is inaccurate.
9 Cross-border transfers
We aim to store and process your personal information within South Africa. Where a service provider (for example, cloud hosting or messaging) processes information outside South Africa, we will only transfer it where the recipient is subject to laws, binding rules or agreements that provide an adequate level of protection substantially similar to POPIA, or where another lawful ground under section 72 of POPIA applies.
10 How we protect your information
We take the security of your personal information seriously and maintain appropriate, reasonable technical and organisational measures to safeguard it against loss, unauthorised access, disclosure or destruction. These include:
- Encryption of data in transit (HTTPS/TLS)
- Access controls, authentication and role-based permissions
- Supporting documents stored outside the public website, readable only by authorised staff
- An audit trail recording which staff member accessed which records, and when
- Staff confidentiality obligations and awareness
- Regular review of our security safeguards
Data breaches: If a security compromise affects your personal information, we will notify the Information Regulator and you as soon as reasonably possible after becoming aware of it, as required by section 22 of POPIA.
11 How long we keep your information
We keep your personal information only for as long as necessary to fulfil the purposes described in this policy, and to meet our legal, regulatory and contractual obligations. As a credit provider, we are generally required to retain certain records for a minimum period after the end of our relationship with you — for example, records under FICA and the NCA are typically kept for at least five years.
Once retention is no longer required, we will delete, destroy or de-identify your personal information in a secure manner.
12 Direct marketing
In line with section 69 of POPIA, we will only send you electronic direct marketing (SMS, email or automated messages) where:
- You have given your consent; or
- You are an existing customer, the marketing relates to our similar products, and you have not opted out.
You may withdraw your consent or opt out of marketing at any time, free of charge, by using the unsubscribe option in any message or by contacting our Information Officer. Opting out of marketing will not affect messages we are required to send about your account or loan.
13 Cookies
Our website uses cookies and similar technologies to make it work, remember your preferences, and understand how the site is used. You can control or delete cookies through your browser settings, although some parts of the site may not function properly without them.
14 Your rights as a data subject
Under POPIA, you have the right to:
- Be notified that we are collecting your personal information;
- Request access to the personal information we hold about you;
- Request that we correct, update or delete inaccurate, irrelevant, excessive or outdated information;
- Object, on reasonable grounds, to the processing of your personal information;
- Object to direct marketing;
- Not be subject to a decision based solely on automated processing that significantly affects you, except as permitted by law;
- Withdraw your consent, where processing is based on consent (subject to legal or contractual restrictions);
- Lodge a complaint with the Information Regulator.
The exercise of these rights may be limited where the law requires us to keep or process your information.
15 How to exercise your rights
To access, correct or delete your personal information, or to object to processing, please contact our Information Officer using the details in section 2. We may need to verify your identity before acting on your request.
Formal requests for access to information are handled in terms of the Promotion of Access to Information Act, 2000 (PAIA). Our PAIA manual is available here: https://imaliloans.co.za/paia-manual. Certain access requests may attract a prescribed fee.
16 Lodging a complaint
If you are not satisfied with how we have handled your personal information, please first contact our Information Officer so we can try to resolve the matter. You also have the right to lodge a complaint directly with the Information Regulator:
Complaints must be submitted in writing, usually via the Regulator’s eServices Portal using the prescribed POPIA complaint form.
17 Changes to this policy
We may update this policy from time to time to reflect changes in our practices or the law. The latest version will always be available on our website, with the “last updated” date shown at the top. We encourage you to review it periodically.
