1. Introduction

Liquidfin (Pty) Ltd ("Liquidfin", "we", "us" or "our") respects your right to privacy and is committed to protecting the personal information of data subjects in accordance with the Protection of Personal Information Act, 4 of 2013 ("POPIA").

This Privacy Notice explains how we collect, use, store, disclose and protect personal information when you visit our website or engage with us in the ordinary course of business, including our external debt collection services.

2. Who is the Responsible Party?

Liquidfin (Pty) Ltd is the responsible party as contemplated in POPIA.

3. Information Officer

For any privacy related queries, access requests, objections or complaints, please contact our Information Officer using the details above, marked for the attention of the Information Officer.

4. What Personal Information We Collect

Depending on your interaction with us, we may collect and process the following categories of personal information:

4.1 Website related information

• IP address
• Browser type and version
• Device type and operating system
• Date and time of access
• Pages visited and referring URLs

4.2 Contact and enquiry information

• Name and surname
• Email address
• Telephone or WhatsApp number
• Information you provide when completing a contact form, calling, or messaging us

4.3 Creditor, consumer and account-related information

Where applicable and lawful, in the course of placing or collecting on an account:

• Identity numbers
• Contact details
• Financial and banking information necessary for direct debit order collection into your trust account
• Account, payment, and transaction details, including AOD, RPC and Conversion records

5. How We Collect Personal Information

We collect personal information:

• Directly from you (e.g. via contact forms, WhatsApp, emails, or phone calls);
• Automatically when you use our website (via cookies and server logs); or
• From creditor clients who place a book with us for collection, where lawful and required for the administration of accounts.

6. Purpose of Processing Personal Information

We process personal information for purposes including but not limited to:

• Operating and maintaining our website;
• Responding to enquiries and correspondence;
• Managing early delinquency and debt collection books placed with us by creditor clients;
• Facilitating direct-to-trust-account settlement, with no holding of funds;
• Compiling AOD, RPC and Conversion reporting for our creditor clients;
• Complying with legal and regulatory obligations; and
• Ensuring the security and integrity of our systems.

7. Lawful Basis for Processing

We process personal information in accordance with POPIA only where processing is lawful, including where:

• Processing is necessary to perform or conclude a contract;
• Processing is required by law;
• Processing is necessary for a legitimate interest of Liquidfin or a third party; or
• Consent has been obtained where required.

8. Direct-to-Account Settlement and Third-Party Processors

Liquidfin facilitates the collection of debit order payments directly into a creditor client's own trust account. Liquidfin does not itself receive, hold, or transfer these funds.

Any financial information necessary to facilitate this direct settlement is shared only with the relevant payment infrastructure providers and is subject to appropriate security and confidentiality safeguards.

9. Cookies and Website Analytics

9.1 Cookies

• Our website may use cookies to enhance functionality, security and performance.
• Cookies are small text files stored on your device.
• You may control or disable cookies through your browser settings. Disabling cookies may affect website functionality.

9.2 Analytics

We may use website analytics tools to understand website usage trends. Information collected is used in aggregated form and, where reasonably practicable, anonymised.

10. Disclosure of Personal Information

We may disclose personal information to:

• Authorised operators, service providers or contractors acting on our instructions, including payment infrastructure providers;
• Registered credit bureaux, where required or permitted by the National Credit Act;
• Regulatory or governmental bodies, where required by law; or
• Any party where disclosure is legally mandated or permitted.

11. Retention of Personal Information

We retain personal information only for as long as necessary for the purpose for which it was collected, unless retention is required or permitted by law, or is necessary for lawful business purposes.

12. Security Safeguards

Liquidfin implements appropriate technical and organisational measures to protect personal information against unauthorised access, loss or damage, and misuse or unlawful processing. These measures include access controls, secure systems, policies, training and contractual safeguards.

13. Data Subject Rights

As a data subject, you have the right to:

• Request confirmation whether we hold personal information about you;
• Request access to your personal information;
• Request correction or deletion of inaccurate or excessive information;
• Object to the processing of your personal information on reasonable grounds;
• Lodge a complaint with the Information Regulator.

Requests may be directed to us using the contact details above.

14. Complaints to the Information Regulator

If you believe that we have not complied with POPIA, you may lodge a complaint with:

15. Changes to this Privacy Notice

We reserve the right to update this Privacy Notice from time to time. The latest version will always be available on our website.