Privacy Policy


At Kouga Development Company ta Circa, we respect our clients/customers, suppliers, service provider and staff’s right to privacy and we are committed to protecting your privacy. Of course, in the performance of our work and the fulfilment of our mandate to you, there is a need for us to access some of your personal information.

This policy is intended to explain how we obtain, use, and disclose your personal information as is required by the Protection of Personal Information Act (POPI Act). We assure you all information collected is used specifically for the intended purposes, in a proper and lawful manner.

If you use our services and service channels you agree that we may process your personal information as explained under this policy.

What constitutes personal information

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:

  • your marital status
  • your national origin
  • your age
  • your language; birth; education
  • your financial history
  • your identifying number
  • your e-mail addresses
  • your physical address
  • your telephone numbers
  • your race; gender; sex; pregnancy; ethnic origin; social origin; colour; sexual orientation
  • your physical health; mental health; well-being; disability; religion; belief; conscience; culture
  • your medical history
  • your criminal history
  • your employment history
  • your personal views, preferences, and opinions
  • your confidential correspondence
  • another’s views or opinions about you and your name also constitute your personal information

Special personal information is personal information about the following:

  • your race
  • your ethnic origin
  • your trade union membership
  • your health
  • your biometric information

We may process your personal information in the following circumstances:

  • if you have consented to the processing
  • if the information is being used for any human resource or payroll requirement
  • 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 and all legal conditions are met
  • if the special personal information was made public by you
  • if the processing is required by law
  • if racial information is processed, and the processing is required to identify you; and/or if health information is processed, and the processing is to determine your insurance risk, or to comply with an insurance policy or to enforce an insurance right or obligation

The information we collect

We collect and process your personal information essentially for the management, administration, and processing of our clients’ pension funds. For legislative, regulatory, contractual and compliance purposes we might need to share your information with third parties. This is always done in a controlled and circumspect manner.

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 collect information either from our clients’ or directly from our clients’ members. Where possible, we will inform you of what information is required and what information is optional.

We will only process your personal information for lawful purposes relating to our business if the following applies:

  • if you have consented to the use/sharing of your information
  • if a person legally authorised by you, the law, or a court, has consented thereto
  • if it is necessary to conclude or perform under our mandate in relations to you
  • if the law requires or permits it
  • if it is required to protect or pursue your, our, or a third party’s legitimate interest

Access to our website allows us to collect standard internet visitor usage information, using “cookies”.

Our cookie policy

A cookie is a small piece of data sent from our websites or applications to your computer or device hard drive or internet browser, where it is saved. The cookie contains information to personalise your experience on our websites or applications and may improve your experience on the websites or applications. The cookie will also identify your device, like the computer or smart phone. By using our websites or applications you agree that cookies may be forwarded from the relevant website or application to your computer or device. The cookie will enable us to know that you have visited the website or application before and will identify you. We may also use the cookie to prevent fraud and for analytics.

How we use your information

We will use your personal information only for the purposes for which it was collected or agreed with you, for example:

  • To provide our services to you
  • To act according to your instructions
  • To conduct checks and verification
  • To verify your identity, and that of others linked to you such as your spouse, partner, next-of-kin, and children – for HR and processing purposes
  • For operational purposes
  • For legislative, regulatory and compliance purposes
  • For the detection and prevention of fraud, crime, money laundering and other malpractice
  • For debt tracing and debt recovery
  • To conduct market or customer satisfaction research or for statistical analysis
  • For audit and record keeping purposes
  • For legal proceedings

Disclosure of your information

To the extent that we are obliged or required to share your personal information with another party, the other party’s privacy policy shall apply to you as well. Where and when we use service providers who are involved in the delivery of services to you, we have agreements in place with such service providers to ensure that they comply with these privacy terms.

We may also share your personal information with:

  • Third parties for the purpose of fraud prevention
  • law enforcement agencies, such as the South Africa Police Services
  • other parties where we have a duty or right to disclose in terms of law or industry codes, and when we believe it is necessary to protect our rights

How we use your personal information for marketing

  • We will use your personal information to market our services to you
  • We will do this in person, by post, telephone, or electronic channels such as SMS, WhatsApp and email
  • In all cases you can request us to stop sending marketing communications to you at any time

How we keep your information secured

We make every effort to ensure that your information remains secure and private. We will not share your information to others outside the scope of our mandate and responsibilities. Some of the measures we have in place includes:

  • physical security
  • computer and network security
  • secure communications
  • retention and disposal of information/documents
  • governance and regulatory issues
  • monitoring access and usage of private information
  • investigating and reacting to security incidents
  • when contracting with third parties we impose appropriate security, privacy, and confidentiality obligations on them
  • we insist on staff to maintain a clean desk policy – in this way personal information is not kept out in the open when not being referred to/used

Retention of your personal information

We will keep your personal information for as long as:

  • the law requires us to keep it
  • you have consented for us keeping it
  • we are required to retain the information to achieve the purposes listed in this policy
  • we require it for statistical or research purposes
  • we are required to retain the information due to legislative, regulatory, and contractual reasons
  • we require it for our lawful business purposes

Otherwise, once we not longer have a need to retain your information, we will proceed to destroy same.

Your right to access your own information

You have the right to request a copy of the personal information we hold in respect of you. We will take all reasonable steps to first verify your identity and right to access before we share your personal information to you. Please note that any such access request may be subject to a payment of a legally allowed fee.

Third parties right of access to information

Please refer to our Promotion of Access to Information Act 2 of 2000 Manual (PAIA Manual) which explains   how/what information you may access from us.

Please note that right to access information may be limited by law.

Correction of your information

Information that you share with us is what we have on record. Whenever your information changes, it is your responsibility to notify us of same and to furnish us with the necessary supporting documents for record purposes.

In certain instances, you have the right to object to the processing of your personal information. You have the right to update, correct or delete your personal information. Please notify us as soon as there are changes to your personal information.

Changes to this policy

We reserve the right to amend this policy from time to time, when and if required.

How to contact us

If you have any questions relating to the policy, or believe that we have not adhered to it, or you may require further information about our privacy practices or wish to give or withdraw your consent, exercise preferences or access or correct your personal information, please do not hesitate to contact our Information Officer:

Name: Andre Homan
Telephone: 011 579-2900

We have also appointed Singhs Attorneys as our legal advisors to advise us on our rights and obligations in terms of this policy and POPI.

Information regulator

If you still believe, after first notifying us, that we are not adhering to this policy or that your right to privacy is being infringed, you have the right to complain to the Information Regulator, whose contact details are:

The Information Regulator

Telephone: 012 406 4818
Fax: 086 500 3351