We're in an era of rapid digital transformation where consumers demand more access to seamless, personalised products and services online. But the currency of personal data that fuels this platform economic boom poses threats to individuals and endangers corporate security.

Now more than ever — and likely more so in the future — consumers and corporates need new levels of trust and transparency.

As a global information and insights company, TransUnion seeks to make trust possible. We do this by curating an accurate and comprehensive picture of each consumer so they're safely and reliably represented in the marketplace. This enables businesses and consumers to transact with confidence and achieve great things. We call this Information for Good.

We're a group of companies with registered offices at TransUnion, 10th Floor, 11 Alice Lane, Sandton, Johannesburg 2196. Although we're part of a larger group, this notice covers only the activities of TransUnion companies within the Republic of South Africa.

Jointly responsible parties

TransUnion companies sometimes cooperate with other TransUnion companies when sharing and making decisions about your personal information. When this happens, all employees across the group ensure each company involved complies with data protection rules.

Contact our Consumer Services Team to enquire about any of our companies or exercise your rights regarding your personal information.

Contact details

Post:TransUnion PO Box 4522 Johannesburg 2000
Telephone:TransUnion Contact Centre: 0861 482 482

2. How we use personal information

You can find more detail about the personal information we might use for these purposes in Section 3 below.

Direct marketing

If you give your consent or law permits it, we may use your personal information for direct marketing purposes. We may access, use, process and analyse personal information provided by you, your consumer credit information, Internet information and marketing data to provide personalised offers from TransUnion and our trusted partners.

Opting out

Suppose you no longer want to receive such communications. In that case, you can opt-out by responding to the newsletter and asking to be unsubscribed, or calling our customer service department and asking to be taken off the list. Alternatively, you can go to transunion.co.za, log in as a subscriber, click on your "profile" link, go to "My Settings", and de-select the Emails and Special offers opt-in box.

Digital marketing

Our digital marketing services enable our business partners to communicate with consumers about relevant products and services. These businesses use our data and technology to devise, create, deploy and measure targeted advertising programs. We also aggregate and depersonalise data for analytical purposes to provide statistical reporting and performance measurements.

Market research

If you choose to take part in market research, we may use your information to improve our products and services. If we engage third parties to assist, they can use non-personal aggregated data, but they use all personal information for our research purposes only.

Consumer engagement

With your consent, we may use your personal information to present additional products, services, and special offers from our affiliates and marketing partners. We may also share basic information — name and email address — with third parties to fulfil your request.

Our third-party email processor may use action tags (also known as single-pixel gif or web beacons) to collect anonymous information on your use of the TransUnion Site in connection with the email registration program.

If you do not register your ID Number, we will not collect any personal information while you visit TransUnion Site.

Client data enhancement

Some TransUnion clients provide data collected under their separate privacy notices and ask us to enhance it. Here, our client is responsible for ensuring the personal information is used fairly and lawfully. You can refer to their privacy notices for details on the data they collect, what they use it for, and how to exercise your rights.

Development and testing

We sometimes use personal information while improving, developing, monitoring, maintaining and testing our products, systems and security measures. Where possible, we create pseudonyms, anonymity or aggregate the data beforehand.

Consumer queries

We will sometimes use your personal information to help deal with your enquiry and for legal and regulatory purposes.

Legal compliance with laws and regulations

We only access, use and disclose personal information without consent in exceptional circumstances where necessary to:

Comply with the law or a legal process served on us
Comply with requests for information from police or government authorities
Protect and defend our rights or property (including the enforcement of agreements)
Protect the public interest
Act in urgent circumstances to protect the personal safety of our employees or members of the public
Act on implied consent

We apply the above in terms of the NCA, PoPIA and other relevant national legislation.

3. Where we get personal information

We get personal information directly from our business partners, suppliers, clients, site visitors, and customers signing up for any of our products or services.

There are various types and categories of personal information we gather for marketing, including:

Marketing — consumer, household, business, non-personal aggregated information, and advertising program performance data.
Demographic — age, gender, income, occupation, education and marital status.
Life events — a recent move or home purchase.
Public records — census data, geographic data, property data from local tax assessor and recorded deed information.
Firmographic — type of business, years in business, size of business, and job titles.

4. How long we keep personal information

We keep personal information for as long as we handle your request and for an additional period after completion — as determined by:

Demonstrating appropriate processes are in place to deal with enquiries, requests and complaints, and that we’re doing so fairly and under our regulatory requirements
Responding to requests from you or a regulator to explain how we dealt with a request and to show we dealt with it properly
Defending potential legal claims or regulatory action resulting from the request

5. Our legal basis for handling personal information

This section explains the basis on which we process your personal marketing information.

Legitimate interests

The Protection of Personal Information Act allows the use of personal information where necessary for legitimate purposes, provided this isn't outweighed by the impact it has on you. We base most of our processing activities on the legitimate interests condition.

The legitimate interests we’re pursuing are:

Interest	Explanation
Commercial interests	Earning revenue through the products and services we provide to our customers and clients.
Improving the accuracy of marketing materials	Removing out-of-date contact details and providing up-to-date contact details where possible.

For more details, refer to the relevant privacy notices in the links above.

6. Who we share personal information with

Our group of companies

As stated, we share personal information among TransUnion companies as appropriate. We've set out a list of current such companies below.

Group Company	Physical Address
TransUnion Africa Holdings (Pty) Ltd	TransUnion 10th Floor, 11 Alice Lane Sandton Johannesburg 2196
TransUnion Credit Bureau (Pty) Ltd
TransUnion Africa (Pty) Ltd
TransUnion Analytic and Decision Services (Pty) Ltd
TransUnion Auto Information Solutions (Pty) Ltd

Clients and resale partners

Our clients have privacy notices that provide more information about how they use the data we supply. These clients typically operate in the following sectors:

Auto dealers
Commercial
Insurance
Retail
Telecommunications
Collections
Financial services
Public sector
Startup

If our clients appoint an intermediary to act on their behalf, they too will receive the data. We also appoint data resale partners to distribute our data to third parties.

Service providers

Our clients and we may provide your information to third parties who help us achieve the purposes described in section 2. For example:

Third parties may host our databases of personal information
Printing companies produce and send direct mail or other correspondence.
Market research companies help us better understand our customers.
Cloud-based technologies, such as Microsoft Office 365, support our ordinary business operations.

These service providers can't use your information for their purposes or on behalf of other organisations unless you agree otherwise.

7. Where we store and send personal information

We access and use your information from our base in South Africa. We will not transfer personal information to a country lacking laws that provide an adequate level of information protection — unless we have an agreement with the recipient requiring measures that offer a similar level of protection as POPIA in South Africa.

8. Your rights concerning personal information

We outline your rights regarding the personal information we hold about you below.

Access: Refer to the PAIA Manual on how to access what personal information we hold about you.

Correction/Destruction/Deletion: If the information we hold about you is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained lawfully, you have the right to ask us to correct or delete it.

Objection to processing: You may object (on reasonable grounds) to processing your personal information unless legislation provides for such processing.

Objection to direct marketing: You may object to us using your personal information for direct marketing, and if you do, we will stop.

To find out about exercising these rights, please contact us on TransUnion Contact Centre: 0861 482 482.

9. Where to lodge a complaint

We strive to deliver the highest levels of customer service. However, if you’re ever unhappy with us, please contact us so we can investigate.

Location: 10th Floor, 11 Alice Lane, Sandton, 2196
Postal Address: PO Box 4522, Johannesburg, 2000
Telephone: +250 7889 33094

You can also contact our Information Officer or Deputy Information Officer at TUAPrivacy@transunion.com

You may complain to the Information Regulator:

Physical Address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
Postal Address: P.O. Box 31533, Braamfontein, Johannesburg, 2017
Email: POPIAComplaints@inforegulator.org.za.
Site: www.inforegulator.org.za