Privacy & Policy
THETA HOLDINGS GROUP WEBSITE PRIVACY POLICY
1 INTRODUCTION
1.1 The Theta Holdings Group is committed to ensuring and protecting your privacy whenever you access
or use the websites. The Theta Holdings Group Website Privacy Policy ("this policy") is set out below
and provides a detailed explanation as to how the Theta Holdings Group may use your personal
information, either provided by you or collected through other legal means.
1.2 The “Theta Holdings Group” refers to Theta Holdings (Pty) Limited. ("THG") and any or all of its
subsidiaries or affiliates as the context requires.
1.3 The “websites” includes the website situated at www.Thetaholdings.co.za ,
www.Thetaprop.com , www.Realtrust.co.za , www.Thetaam.com
and any applicable social media platforms and this expressly
excludes any third party websites linked to the Theta Holdings Group websites, and “website” shall
mean any one of these as the context may indicate.
1.4 Personal information includes information relating to an identifiable, living, natural person,
and where it is applicable, an identifiable, existing juristic person, including, but not limited
to:
a) information relating to the race, gender, sex, pregnancy, marital status, national,
ethnic or social origin, colour, sexual orientation, age, physical or mental health, wellbeing,
disability, religion, conscience, belief, culture, language and birth of the person;
b) information relating to the education or the medical, financial, criminal or
employment history of the person;
c) any identifying number, symbol, e-mail address, physical address, telephone number,
location information, online identifier or other particular assignment to the person;
d) the biometric information of the person;
e) the personal opinions, views or preferences of the person;
f) correspondence sent by the person that is implicitly or explicitly of a private or
confidential nature or further correspondence that would reveal the contents of the
original correspondence;
g) the views or opinions of another individual about the person; and
h) the name of the person if it appears with other personal information relating to the
person or if the disclosure of the name itself would reveal information about the
person.
1.5 We will only collect your personal information by lawful and fair means and, where
appropriate, with your knowledge and consent. We will retain your personal information as
long as necessary for the fulfilment of those purposes as have been identified by us. Your
personal information will be deleted or destroyed where required in terms of applicable laws
once the purpose for which it was collected is completed unless the Theta Holdings Group is required
to keep a record of such information in accordance with applicable laws.
1.6 By accessing this website, you agree to be bound by this policy with effect from the first time
you access the website and each time thereafter.
1.7 The Theta Holdings Group reserves the right, in its sole discretion, to amend this policy. Please refer
back to this policy in the future because by accessing this website you are bound to the version
of the terms and conditions published on this website at the time of your visit to this website.
2 COLLECTION OF DATA FROM YOU
2.1 When accessing or using this website, this website may request you to provide certain
personal information pertaining to you. If you provide your information, you warrant that
the information which you provide relates to you and is true and complete.
2.2 Should you know or become aware of personal information, that has been provided to the
Theta Holdings Group, which is inaccurate, out of date, incomplete or incorrect, you may request
in writing that the Theta Holdings Group correct or delete such personal information that is in the
Theta Holdings Group’s possession and control.
2.3 In addition to any other methods used by the Theta Holdings Group to collect data and/or
personal information through this website, the following are approved methods of
collection of personal information from you:
a) if you register on this website, complete an application form or provide your personal
information in response to any request to do so;
b) depending on your settings or the privacy policies for other online services, you may
give us permission to obtain information from your account with those other services.
For example, this can be via social media, traffic data, weblogs, location data, and any
other communication. These details are obtained from your visit to the website and
from any resource tools that you may use while accessing or using the website;
c) any communication by you (i) using this website or (ii) to employees, officers, directors,
agents and subcontractors of the Theta Holdings Group.
2.4 The Theta Holdings Group may gather information (including personal information) from you as
you access and navigate through this website by using tracking technology, navigational
data collection tools and cookies, amongst other technologies.
I. Cookies are files which are automatically transferred (without prompting)
onto the hard drive of your computer whilst you use the website and enable
the Theta Holdings Group’s systems to identify your computer every time you access
the website using the computer on which the cookie was saved.
II. Cookie and tracking technology are useful for gathering information such as
browser type and operating system, tracking the number of visitors to the
website, and understanding how visitors use the website. Cookies can also
help customise this website for visitors.
III. Personal information cannot be collected via cookies and other tracking
technology; however, if you previously provided personally identifiable
information, cookies may be tied to such information. Aggregate cookie and
tracking information may be shared with third parties.
IV. Cookies only store information from your browser, they cannot access data
on your hard drive. Cookies are text files that cannot transfer viruses to your
computer or mobile device.
V. You can set your browser to notify you if “cookies” are to be transferred or to
reject “cookies”. You may also choose to not consent to us making use of
“cookies” when the consent pop-up is presented to you.
2.5 The information (including personal information) collected by the Theta Holdings Group using
tracking technology, navigational data collection tools and cookies –
a) assists the Theta Holdings Group to, amongst other things, (i) detect problems with this
website and its systems, (ii) improve this website and offerings on this website, and
(iii) compile information for analytical purposes; and
b) will be used by the Theta Holdings Group for those purposes contemplated in 2.4. and no
identifying information will be shared about you specifically and how you specifically
accessed and/or used the website.
3 USE OF YOUR INFORMATION
3.1 You agree that the Theta Holdings Group may collect, store, analyse and use any information
(including your personal information) and may transfer such information to its employees,
officers, directors, agents and sub-contracts (who are bound by obligations of
confidentiality) for the following purposes –
3.1.1 to establish and verify your identity and contact details;
3.1.2 the assessment of any applications for loans, goods or services provided by the
Theta Holdings Group now or in the future, including the pre-assessment of any potential
loans, services or product offerings which may be made to you by the Theta Holdings Group;
3.1.3 the implementation or enforcement of any commitment made or obligation
assumed by and any right of the Theta Holdings Group in terms of a contract;
3.1.4 developing, maintaining and improving the websites and/or the Theta Holdings Group’s
services and/or the Theta Holdings Group’s product offerings (including credit products);
3.1.5 to communicate with you regarding existing or potential transactions or claims, new
or existing services and/or product offerings (including credit products),
competitions or promotions;
3.1.6 notifications regarding changes or improvements in services and/or product
offerings may be sent to you;
3.1.7 to provide you with value-added service offerings (if any) and may include
customised offerings to suit your requirements;
3.1.8 to analyse and compile reports and databases for purposes of research (including,
without limitation, product research, market research), developing credit scoring
and other business models, statistical analyses and reporting, determining browsing
habits and usage.
3.2 Furthermore, you agree that the Theta Holdings Group may transfer your personal information to
the Theta Holdings Group’s employees, agents or contractors which may be situated in other
jurisdictions. To the extent that the Theta Holdings Group transfers your personal information to
alternative jurisdictions, it will ensure that your personal information is subjected to a
similar level of protection.
4 STORING YOUR PERSONAL DATA
4.1 The Theta Holdings Group will take appropriate, reasonable technical and organisational
measures to prevent (i) loss of, damage to or unauthorised destruction of personal
information; and ii) unlawful access to or processing of personal information.
4.2 In order to comply with the obligation mentioned above, the Theta Holdings Group will use
secured servers and/or data warehousing facilities to ensure proper data storage,
however, transmission of data on the Internet can never be ultimately secure. The Theta Holdings
Group accordingly does not guarantee and provides no warranties or undertakings with
regards to the security of information collected electronically or transmitted, whether
through this website or by other means. As a result of the Theta Holdings Group’s inability to
guarantee safety, you are submitting information to us at your own risk.
4.3 You may be required to use a password, provide certain of your personal information or
use other access features on the website to access certain areas of the website. You are
responsible to safeguard any password or personal information.
5 DISCLOSURE OF YOUR INFORMATION IN CERTAIN CIRCUMSTANCES
5.1 The Theta Holdings Group may share any information which it collects from you through the
website or other electronic means with third parties in the following instances –
5.1.1 if the equity in the Theta Holdings Group is sold to a third party or if the Theta Holdings Group sells
or outsources all or a portion of its business or assets to a third party;
5.1.2 to any affiliate of the Theta Holdings Group, such as subsidiaries, associates, holding
companies and their subsidiaries;
5.1.3 to third parties engaged by the Theta Holdings Group to render services to it or on its behalf;
5.1.4 where it is compelled to do so by law, regulation or by-laws or in terms of a court
order or at the direction of any regulatory or governmental authority;
5.1.5 where the Theta Holdings Group needs to protect or enforce its rights or is required to do
so to protect the rights, property or safety of the public;
5.1.6 disclosure to credit bureaux in the countries where the Theta Holdings Group operates;
5.1.7 disclosure for audit purposes; and
5.1.8 for fraud detection and prevention purposes.
6 THIRD PARTY LINKS
The Theta Holdings Group does not accept liability or responsibility for the privacy policies of third
parties and therefore does not accept responsibility for any disclosure of your personal
information due to the use by you of links to access the website or links on the website to access
third parties’ websites. You should accordingly acquaint yourself with the terms and conditions
of privacy policies pertaining to such third parties’ websites.
7 QUERIES AND COMPLAINTS
7.1 If you have any queries, comments or requests regarding this policy, please contact us at
the relevant address, based on the website accessed:
Website: Contact details:
7.2 Should you no longer wish to receive communications from the Theta Holdings Group, please
contact us at the relevant address, based on the website accessed:
Website: Contact details:
7.3 You have the right to lodge a complaint with the appropriate regulator should you believe
that the Theta Holdings Group has failed to comply with its obligations in terms of any applicable
legislation.
8 DISPUTES
8.1 If any dispute arises in connection with this website and/or this policy, the parties shall
attempt to settle such dispute or difference, and, failing such settlement within a period of
20 (twenty) business days, the said dispute or difference shall on written demand by any
party be submitted to arbitration in accordance with relevant arbitration rules and in the
relevant country which has jurisdiction to adjudicate the matter.
8.2 The provisions of this 8 shall not be construed as prohibiting or restricting a party from
applying for any urgent or mandatory relief from any court of competent jurisdiction.
9 GENERAL PROVISIONS
9.1 Subject to 9.4, this policy, as amended from time to time by the Theta Holdings Group in its sole
discretion, constitutes the entire agreement between you and the Theta Holdings Group in
relation to the subject matter hereof.
9.2 No failure or delay to exercise any of the Theta Holdings Group’s rights will be construed as a
waiver of any such right, whether express or implied, nor will it affect the validity of any
part of this policy or prejudice the Theta Holdings Group’s rights to take subsequent action against
you.
9.3 If any of the provisions of this policy are held to be invalid, unlawful or unenforceable, such
provision will be deleted from the remaining provisions, which will continue to be valid to
the full extent permitted by the law.
9.4 The provisions of this policy must be read in conjunction with the terms and conditions
pertaining to this website and shall be deemed to be incorporated in those terms and
conditions.
9.5 The Theta Holdings Group shall be entitled to cede, assign and transfer any of its rights and
obligations under this policy without obtaining your consent and without notice to you.
Any of the Theta Holdings Group’s rights under this policy are expressed for the benefit of the
affiliates of the Theta Holdings Group and shall be capable of acceptance by them, whether
expressly or tacitly.