Privacy Policy

C1 Wealth Management (Pty) Ltd (“C1WM”) is committed to respecting the privacy of your personal information. To demonstrate its commitment, C1WM has created this privacy supplement to communicate its intent to provide effective processes for the appropriate handling of such personal information and to comply with applicable legislation that governs the authentication, protection and disclosure of personal information.

This privacy supplement explains how C1WM processes your personal information for the C1 Wealth Wallet services offered on the C1 Wealth application or the C1 Wealth website hosted on www.C1wealth.co.za (collectively the “C1WM Platforms”) to offer you the ability to pay for goods and services without carrying cash. Importantly, it is designed to provide additional contextual information to that already provided by C1WM’s privacy notice. For more information on the C1WM privacy notice please visit www.C1wealth.co.za

This privacy supplement explains the information that is collected in C1 Wealth Wallet and how it will be used. 

By registering for the C1WM Platforms you are bound by this privacy supplement as well as the C1 Wealth Wallet Platform Terms and Conditions.

Responsible Parties

C1WM and Goods4cash (Pty) Ltd (“G4C”) are joint responsible parties in terms of the Protection of Personal Information Act 4 of 2013 (“POPIA”), in respect of C1 Wealth Wallet.

How to contact us

Your opinion matters to us – if you have any questions about this privacy supplement, you can email us at: [email protected] or you can write to our privacy team at:

The Information Officer
C1 Wealth Management (Pty) Ltd
Block C The old Tannery
Hermon Road
Wellington
7654

Personal information we collect about you

Information we collect about you

  • C1WM will collect personal information when you register on the C1WM Platforms. The personal information collected will include cell phone number, e-mail and PIN. This will enable C1WM to recognise you during subsequent visits.
  • You can load your bank details on the C1WM Platforms. Bank details such as name, account number, will be collected should you elect the option of making a withdrawal to your bank account. 
  • C1WM will collect additional personal information when you register for a Wallet on the C1WM Platforms. The personal information collected may include identification number, business registration number, nature of business, occupation address and source of funds.
  • C1WM Platforms facilitate transactions between you and the third party that is selling goods or services on the C1WM Platforms (“Third Party Merchants”). When you purchase goods and services from a Third Party Merchant additional personal information may be requested to fulfil the service.
  • C1WM Platforms will also collect personal information from third-party information sources to fulfil its obligations to comply with the Financial Intelligence Centre Act No 38 of 2001 as amended (“FICA”) should you register for a Wallet, this will be for customer identification and verification purposes required under FICA.
  • We collect personal information when you first download the C1 Wealth Wallet app and set up your profile.
  • We also collect anonymous analytics information on how customers use the C1 Wealth Wallet app in order to improve the C1 Wealth Wallet app and troubleshoot. We use a variety of analytics methods including what is commonly referred to as “Big data analytics”. Big data analytics are mathematically driven analysis techniques on large and varied data sets (that is why it is “big” data) to uncover hidden patterns and hitherto unrevealed trends. At C1WM we take governance of big data analytics seriously. Our data scientists are required to adhere to a Code of Ethics. We have a strict use case process that requires that privacy and data protection law checks are carried out before any use case commences. We also have strict rules ensuring that personal information is protected at the appropriate stage in the process.
  • We use our analytics to, for example:
  • Conduct market research and to carry out research and statistical analysis, including to monitor how customers use our networks, products and services; and
  • Frame our marketing campaigns and determine how we might personalise those.

How we use your personal information

 C1WM processes and discloses your personal information for specific and limited purposes. These include:

  • Processing bank card details to facilitate payments of goods and services purchased on the C1WM Platforms.
  • Processing of Wallet details to facilitate purchases of goods and services on the C1WM Platforms, deposit and withdrawals into and out the Wallet and domestic remittances from the Wallet.
  • Processing of personal information to assess and handle any customer queries, to develop and improve our products, services, communication methods and the functionality of C1WM Platforms.
  • As our customer, we will contact you to keep you informed about new and existing products and services, competitions, prize draws and other promotions and we may use your personal information to run those competitions, prize draw, events and promotions, only to the extent that you have not, at any stage, objected to receiving such marketing communications. 
  • We may send you marketing of all products or services provided within the C1 Wealth Wallet app unless you have opted out. 
  • If you have given your permission, we will also contact you to let you know about products and services of C1 Wealth Management (PTY) Ltd and Goods4cash (PTY) Ltd products and services and those of other companies which we think may interest you.
  • You can control your marketing permissions at any time within the C1 Wealth Wallet app. 
  • Processing of personal information to create unique personalised in-app offers based on your C1 Wealth Wallet app activity. 
  • Disclosure of personal information to Nedbank for the purposes of registering a Wallet and facilitating transactions in and out of the Wallet.
  • Disclosure of your C1 Wealth Wallet profile personal information to Third Party Merchants to facilitate the purchase of goods and service on the C1WM Platforms when you consent to the disclosure.
  • Disclosure of personal information to C1 Wealth Management (PTY) Ltd and Goods4cash (PTY) Ltd goods and services on the C1WM Platforms.
  • Disclosure of personal information to C1 Wealth Management (PTY) Ltd for purposes of offering you Tokens, Coins or personalized discounts at no cost to you for your activity on C1WM Platforms.
  • C1WM may share your personal information within the C1 Group Holdings Pty Ltd, which includes, C1 Wealth Management (PTY) Ltd, C1 FS (PTY) Ltd, C1 Digital Asset Group, C1 Venture Capital Group, C1 Fund Management, C1 Foundation, C1 Capital and C1 Operation Group. For the purposes of providing you with customized products, and unique experiences.

Where applicable, C1WM will share information about you with:

C1WM may also transfer and disclose your personal information to third parties who may process information on our behalf:

  • To comply with a legal obligation;
  • When we believe in good faith that applicable law requires it;
  • At the request of governmental authorities conducting an investigation;
  • To verify or enforce our “Terms of Use” or other applicable policies;
  • To detect and protect against fraud, or any technical or security vulnerabilities;
  • To respond to an emergency; or otherwise; and
  • To protect the rights, property, safety, or security of third parties and C1WM.

What about the security of your personal information?

  • C1WM takes the security of your personal information very seriously. C1WM takes every effort to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure.
  • Our measures include implementing technology, policies and processes aimed at protecting the confidentiality, integrity and availability of your personal information. We will update and refine these measures on an ongoing basis. 
  • C1WM will maintain Wallet compliance and as such C1WM is responsible for securely storing, processing and transmitting bank data to the Wallet compliance standards. C1WM will at no point share or transmit your bank details in clear text between systems. The bank data will always be encrypted.
  • You agree not to give or make available your means to access C1WM to any unauthorised individuals. You are responsible for all transactions you authorise using the Wallet. If you permit other persons to use the Wallet you are responsible for any transactions, they authorise. C1WM will not be liable for any claims where payments were made by unauthorised persons using your cellphone or credentials online. 
  • Access to your personal information is only permitted among our employees and agents on a need-to-know basis and subject to strict contractual confidentiality obligations when processed by third parties.

How long we keep your personal information for?

We may not retain your personal information any longer than is necessary for achieving the purpose for which your personal information was collected or subsequently processed. For example, where you make a purchase on the C1 Wealth Wallet app with us we will keep the data related to your purchase, so we can perform the specific contract you have entered and after that, we will keep the personal information for a period which enables us to handle or respond to any complaints, queries or concerns relating to the purchase, unless:

  • The retention of your personal information is required or authorised by law.
  • We reasonably require your personal information for lawful purpose related to our function or activities.
  • The retention of your personal information is required by a contract that we enter into with you.
  • You or competent person consent to the retention of personal information relating to a child. 

C1WM will retain your payment records for a period of 5 years as required by law. After the 5-year period, your transaction data will be deleted from the live system.

C1WM may also retain your personal information for the following reasons:

  • Your personal information may also be retained so that we can continue to improve your experience with us and to ensure that you receive any loyalty rewards which are due to you.
  • We retain the personal information we collect directly for targeting purposes for as little time as possible, after which we employ measures to permanently delete it.
  • We will actively review the personal information we hold and delete it securely, or in some cases anonymise it when there is no longer a legal, business or consumer need for it to be retained.

Keeping your personal information secure

We have specialised security teams who constantly review, improve, and ensure the implementation of appropriate, reasonable technical and organisational measures to protect your personal information from unauthorised access, accidental loss, disclosure, or destruction.  We are required in terms of POPIA to notify you and the Information Regulator, if any of your personal information has been compromised.

Communications over the internet (such as emails) aren’t secure unless they’ve been encrypted. Your communications may go through a number of countries before being delivered, as this is the nature of the internet.

We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.

We’ll never ask for your secure personal or account information by an unsolicited means of communication. You’re responsible for keeping your personal and account information secure and not sharing it with others.

Our website may provide links to third-party websites. We cannot be responsible for the security and content of such third-party websites. You are therefore required to make sure you read that company’s privacy and cookies policies before using or putting your personal information on their site.

The same applies to any third-party websites or content you connect to using our products and services.

You may choose to disclose your information in certain ways such as social plug-ins (including those offered by Google, Facebook, Twitter and Pinterest) or using third-party services that allow you to post reviews or other information publicly, and a third party could use that information.

Social plug-ins and social applications are operated by the social network themselves and are subject to their own terms of use and privacy and cookies policies. You should make sure you’re familiar with these.

Your rights

At C1WM, we are committed to processing personal information honestly, ethically, with integrity, and always consistent with applicable laws and our values. Below we set out details on how you can exercise your rights. Please note, under certain circumstances these rights may be limited if we still have lawful grounds to process your personal information. If you have a question or cannot find the answer, please email [email protected] visible on the C1 Wealth Wallet app homepage. 

Rights related to automated decision-making

C1WM may process your personal information using automated means. An automated decision is a decision that is made solely by automatic means, where no humans are involved in the decision-making process related to your personal information. Automated processing in the C1 Wealth Wallet app is conducted to comply with FICA, conduct fraud and risk control checks.

Right to correct personal information

If you become aware that any of the information we keep about you is incorrect or outdated, you can log into the C1 Wealth Wallet app to edit your personal details. 

C1WM will allow you access to update your stored personal information in the C1 Wealth Wallet app. You may add, delete and/or edit stored bank details data. You may also be able to change your email address and PIN. You may amend personal information such as address, occupation and source of funds if you have elected to register for a Wallet. 

Right to access personal information

You have the right to request a record or description of personal information that we hold about you. This includes the right to request C1WM to confirm, free of charge, whether or not it holds any personal information about you; as well as information about the categories of third parties who have, or have had, access to your personal information. To make this request please contact our Customer Services team at [email protected].

Right to object to use of personal information

You have the right, in certain circumstances, to object to C1WM processing your personal information. In order for C1WM to provide you with products and services, C1WM is required to process your personal information which is necessary for the conclusion or performance of a contract and to give effect to you signing up to the C1 Wealth Wallet app and as such the provision of your personal information is mandatory and you may not object to same in order to continue using the C1 Wealth Wallet app. 

Under certain circumstances, you have the right to object to certain types of processing, including processing for direct marketing (i.e. receiving emails or SMS from us notifying you or being contacted with varying potential opportunities). If you no longer want to receive marketing messages from us, you can choose to opt out at any time within the C1 Wealth Wallet app.

 

How to lodge a complaint?

If you want to contact us about any of your rights or should you believe that C1WM has used your personal information contrary to applicable law, you undertake to first attempt to resolve any concerns with our Customer Services team at [email protected]. Kindly lodge your complaint by accessing the C1 Wealth Wallet app homepage. We will do our best to help but if you are still unhappy, you can contact the Privacy Office at [email protected].  If you are not satisfied with such process, you have the right to lodge a complaint with the Information Regulator at: The Information Regulator (South Africa)

JD House
27 Stiemens Street
Braamfontein
Johannesburg
2001

Email: [email protected]

Complaints email:[email protected] 

Right to restrict use of your personal information

If you feel that the personal information we hold on you is inaccurate, please update your personal information in the C1 Wealth Wallet app, or you believe we shouldn’t be processing your personal information, please contact our Customer Services team at [email protected]. In certain circumstances, for example where you contest the accuracy of your information, or where C1WM no longer requires your information for achieving its purpose but must maintain it for purposes of proof, you have the right to ask us to restrict processing. 

Right to deletion

C1WM strives to only process and retain your personal information for as long as we need to. In certain circumstances, for example, where you indicate that your personal information is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or obtained unlawfully, you have the right to request that we erase your personal information that we hold. If you feel that we are retaining your personal information longer than we need, it is worth first checking that your contract with us has been terminated, which you can do with Customer Services. If your contract with us has been terminated, we may still have lawful grounds to process your personal information.

How does C1WM keep this privacy supplement up to date?

  • C1WM will update this privacy supplement when necessary to reflect customer feedback and changes in our products and services.
  • C1WM will update this privacy supplement when necessary to reflect customer feedback and changes in our products and services. If the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy supplement changes). We will also keep prior versions of this privacy supplement in an archive for your review. 
  • C1WM will not reduce your rights under this privacy supplement.