Privacy Policy
1. Introduction and scope
Welcome to the website owned and operated by AAA Consortium (Pty) Ltd (Registration Number: 2022/655398/07). We are committed to protecting your privacy and ensuring that your Personal Information is collected and processed lawfully, ethically, and securely in accordance with the Protection of Personal Information Act No. 4 of 2013 (POPIA). This Privacy Policy governs your use of our website, specifically regarding the online application process for funding and the submission of Financial Intelligence Centre Act (FICA) compliance documentation.
2. Information we collect
We collect highly specific financial, corporate, and personal data to meet our statutory and operational obligations. When you apply for funding online, we collect:
- Corporate and Financial Details: CIPC registration numbers, VAT numbers, tax compliance PINs, bank details, financial statements, and credit histories.
- FICA and Identity Documentation: Proofs of residence, identity numbers, Director IDs, and facial recognition selfies provided alongside ID documents for verification purposes.
- Beneficial Ownership and Risk Status: Details of shareholders or directors holding 25% or more voting rights, Central Supplier Database (CSD) reports, and declarations regarding whether any related parties are Politically Exposed Persons (PEPs) or Prominent Influential Persons (PIPs).
- Transaction Documents: Purchase orders, supplier quotes, RFQs, invoices, and related project documentation.
3. Purpose of processing personal information
We collect and process your Personal Information exclusively for legitimate commercial purposes, which include:
- To assess, originate, vet, execute, and monitor Purchase Order (PO) funding deals and Invoice Discounting facilities.
- To perform mandatory commercial vetting, credit risk assessments, fraud prevention, and FICA/Anti-Money Laundering (AML) due diligence.
- To verify the validity of contracts, purchase orders, invoices, and stock availability directly with third parties.
- To comply with our legal and tax obligations in terms of South African legislation.
4. Disclosure and third-party sharing
We limit the disclosure of your Personal Information to what is strictly necessary for our operational requirements and legal compliance. Your information may be shared with secure third parties for vetting and origination purposes, including:
- Credit bureaus, secure third-party financial platforms, and specialised vetting agencies (such as ClientScanner and CPB) to assess creditworthiness and compliance.
- External funders, SARS, and the Central Supplier Database (CSD).
- Regulatory authorities and law enforcement, such as the South African Police Services for criminal checks, where required by law.
5. Cookies and website tracking
Our website utilizes cookies and similar tracking technologies to enhance user experience, analyse website traffic, and optimize our digital application process. These cookies do not store highly sensitive personal or financial information. You may adjust your browser settings to refuse cookies, though this may limit your ability to utilize certain features of our application portals.
6. Cross-border data transfers
To provide a seamless application and client management process, AAA Consortium utilizes third-party digital infrastructure, including Monday.com, EeziFund APIs, and Google cloud services. As a result, your Personal Information may be transferred to and stored on servers located outside of the Republic of South Africa. We ensure that these international operators maintain adequate data protection standards that align with POPIA requirements.
7. Data security and retention
We maintain comprehensive physical, technical, and organisational security safeguards to protect your highly sensitive data.
- Security Measures: These include SSL encryption, secure hosting, encrypted cloud storage (via Monday.com and secure servers), firewalls, strict password protocols, 24/7 CCTV surveillance at our physical offices, and mandatory Non-Disclosure Agreements for staff.
- Retention: Records are legally retained for 5 years post-transaction as required by FICA laws and our internal retention schedules, after which they are securely destroyed.
- Data Breaches: In the event of a suspected data breach, we will activate our Data Breach Incident Response Plan and notify affected data subjects and the Information Regulator as soon as reasonably possible, in compliance with Section 22 of POPIA.
8. Your rights as a data subject
In accordance with POPIA and the Promotion of Access to Information Act (PAIA), you have the right to request access to, correction of, or deletion of your Personal Information. You may also object to the processing of your data. To exercise these rights, please complete the prescribed Form C and submit it to our Information Officer.
9. Contact information
For privacy-related queries, please contact our Information Officers:
- Information Officers: Ethan Keyter / Ruan Fourie
- Deputy Information Officers: Vaneshree Naidoo / Gershwin Gamba
- Email: [email protected] / [email protected]
- Telephone: 021 300 0224 / 012 004 1115
- Head Office Address: 9B Bridgeway Building, 6 Mascador Street, Mossel Bay, 6506