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PRIVACY NOTICE

  1. GENERAL
    1. 1609 Group (Pty) Ltd and its subsidiaries and/or affiliates (“1609 Group”) (also collectively referred to as “we”, “our”, and “us” want you to be familiar with our Privacy Notice and how we collect, use, process and disclose personal information. This Notice describes our practices in connection with the information that we collect through activities that link to this Notice including websites and mobile sites.
    2. 1609 Group is a Responsible Party in terms of the POPIA with regard to your Personal Information. We process all such Personal Information in order to enable us to do business with you and to provide products and services to you as requested. In this Notice, “you” means you as an individual or entity with whom we are dealing whose Personal Information we may need to collect and process in order to provide the requested services and for any of the purposes described in the Notice.
    3. 1609 Group’s Notice clearly sets forth our position in relation to the processing of any of your Personal Information regardless of whether it is in terms of this Notice or not. Our Notice also summarises our principal obligations to you in connection with the lawful processing of your Personal Information, as well as the rights which you have in relation thereto. You will also be able to source the contact particulars of our Information Officer and how you can contact them in our Privacy Policy.
    4. This Notice has been developed to acknowledge the importance and assist in providing a framework for, the appropriate level of protection for consumer identification, collection, holding, using, disseminating, merging, collating, disclosing and protection of your Personal Information (“process” or “processing”). The Notice represents 1609 Group’s commitment to compliance with its obligations under the Protection of Personal Information Act, 2013 (“POPIA”). This Notice is prepared in accordance with the provisions of POPIA, detailing the lawful approach we take in the collection of information and in regard to the management, use and processing of all information collected from you and other legitimate sources and all subsequent dealings with your lawful representatives, credit reporting bodies and other entities listed in this policy. In the course of our business we only process Personal Information for the sole and exclusive use for which it is sought and intended.
    5. We respect your privacy and we are committed to protecting the privacy of the users of this website. We seek to use our best endeavours when it comes to the collection and processing of Personal Information. We further reserve the right to change our Notice as necessity dictates.
  2. COLLECTION OF PERSONAL INFORMATION
    1. In terms of Section 18 of POPIA you are hereby expressly informed of the fact that when you engage with the website, you are providing 1609 Group with the following Personal Information, including but not limited to:
      1. Your first and last name,
      2. Mobile number;
      3. Date of birth;
      4. Banking details;
      5. Email address; or
      6. Other contact data as the case may be.
    2. We collect and record all telephone calls, internet communications (including IP addresses), all correspondence we have with you irrespective of the medium of communication and visits to our website. You may contact our Information Officer to obtain any information in regard to your personal data that we hold about you.
  3. LINKS TO OTHER WEBSITES
      1609 Group has no control over and accepts no responsibility for the privacy practices of any third-party websites to which hyperlinks may have been provided and strongly recommend that you review the privacy policy of any website you visit before using it further.
  4. INFORMATION WE DO NOT COLLECT
      We do not collect any special Personal Information as defined in section 26 of POPIA including your religious or philosophical beliefs, race or ethnic origin, trade union membership, political persuasion (except as is required for purposes of identifying a politically exposed person (peps) under the Financial Intelligence Centre Act, 2001), health or sexual orientation or biometric information.
  5. SOURCE OF INFORMATION COLLECTED AND PROCESSED
    1. We collect Personal Information from:
      1. You on the basis of information provided;
      2. Agents;
      3. Service Providers;
      4. Advisers;
      5. Credit Reporting bodies;
      6. Government;
      7. Contractors, vendors, or suppliers; and/or
      8. Agents, distributors, or other resellers.
  6. WHY DO WE COLLECT YOUR PERSONAL INFORMATION
    1. Using, processing, sharing/transferring or engaging in analytics of your Personal Information for:
      1. routine business purposes; or
      2. the purpose of new business or product development. This may include circumstances contemplated in clauses 6.2. to 6.14.
    2. To establish your needs, requirements and preferences in relation to the products and/or services provided by 1609 Group.
    3. Recruitment purposes;
    4. To allocate unique identifiers to you for the purposes of processing your Personal Information, securely storing, retaining, and recalling your Personal Information from time to time, regardless of whether you conclude an agreement with 1609 Group.
    5. To evaluate whether or not to offer, extend or modify any offering or service requested by, or provided to you.
    6. For general administration purposes pertaining to your request(s) and to reply to you when you provide your contact information.
    7. To improve the quality of 1609 Group’s products and services.
    8. To transfer your Personal Information across the borders of South Africa to other jurisdictions should it be so required for the legitimate business requirements and interests of 1609 Group.
    9. To identify products and services which might be of interest to you, as well as to inform you of such products or services.
    10. To investigate and attempt to resolve your query, complaint or request.
    11. For business purposes such as analysing and managing our business, market research, audits, developing new products, gauging customer satisfaction and customer services.
    12. For the purpose of enhancing the scope of the products and services we can offer to you or the method of delivery of same, share or transfer all or any part of your Personal Information to a third party who is a potential business partner or actual provider/supplier of outsourced services to 1609 Group.
    13. To receive confirmation that you have provided us with authority to act as the Responsible Party if information is held by a third party.
    14. To, unless you expressly “opt-out”, process your Personal Information as defined above for the purpose of marketing and advertising to you products and services provided by 1609 Group.
  7. OTHER REASONS FOR COLLECTING PERSONAL INFORMATIION
    1. We are legally required to collect and process certain information, including:
      1. in terms of the Financial Intelligence Centre Act (to meet our know-your-client obligations), including monitoring accounts to combat money laundering, financing of terrorist activities and conducting sanctions screening; or
      2. to report suspicious, unusual and fraudulent activities on your account to the relevant authorities; or
      3. to report to any other governmental agency or statutory body (including, but not limited to, the South African Police Service, the South African Revenue Service, the Mpumalanga Economic Regulator (or any other provincial gambling board) and the National Gambling Board); or
    2. We also reserve the right to disclose your Personal Information in the interests of enforcing our terms and conditions.
  8. SHARING OF PERSONAL INFORMATION WITH THIRD PARTY SERVICE PROVIDERS
    1. Your personal information may be shared with third party vendors (such as software developers or providers) to help us maintain our service.
    2. Your personal information is only shared with service providers that we trust and who have agreed to keep your personal information safe and confidential.
    3. We will take all reasonable steps to ensure that your information is kept secure and protected.
  9. CROSS BORDER INFORMATION SHARING
    1. The information you provide maybe transferred across foreign borders. This information transfer is authorised under Chapter 9 of POPIA which allows a Responsible Party (“access seeker”) access to transfer the information across foreign borders in the following circumstances:
      1. For the implementation of pre-contractual measures taken in response to your request;
      2. The conclusion or performance of a contract concluded in your interest between the Responsible Party and a third party; or
      3. The transfer is for your benefit and it is not reasonably practicable to obtain your consent for that transfer and if it were reasonably practicable to obtain such consent, you would provide it.
  10. PROTECTION AND STORAGE OF PERSONAL INFORMATION
    1. In all circumstances the information is held by 1609 Group on our secure systems or database.
    2. We undertake to take all reasonable and necessary steps to secure the integrity and confidentiality of your Personal Information and protect your information from misuse, loss, interference, unauthorised access, modification or unauthorised disclosure.
    3. Electronic copies are held in a secure environment, with the application of appropriate passwords and other computer and software security protocols.
    4. All your Personal Information is stored securely by 1609 Group through the use of Cloud based storage facilities.
    5. We may transmit or transfer Personal Information outside South Africa to a foreign country, as such, Personal Information may be stored on servers located outside of South Africa in a foreign country.
  11. HOW LONG WILL 1609 GROUP KEEP PERSONAL INFORMATION OF A DATA SUBJECT
    1. 1609 Group will always keep the Personal information of a Data subject for the period required by law and where it needs to do so in connection with legal action or an investigation in which it is involved.
    2. Otherwise, 1609 Group will keep Personal information of a Data subject:
      1. for as long as needed to provide the Data subject with access to services he has requested;
      2. where the Data subject has contacted 1609 Group with a question or request, for as long as necessary to allow 1609 Group to respond to the question or request and as required by law.
  12. YOURS RIGHTS AS A DATA SUBJECT
    1. You have the right to withdraw all or part of any consent you may be required to provide in relation to our processing of your Personal Information.
    2. In the event that you withdraw all or part of your consent, there may be a certain period of time during which 1609 Group is legally or contractually obliged to, or for which there may be a legitimate business need, to continue processing such Personal Information until a full and final termination of our business relationship with you can be affected.
    3. If your consent is withdrawn partially or fully in any particular set of circumstances, this may influence our ability to provide services to you, for which 1609 Group cannot be held liable or responsible.
    4. You have a right to be notified that your Personal Information is being collected.
    5. You have a right to be notified of any security breaches and/or compromises where there are reasonable grounds to believe that your personal information may have been accessed by an unauthorised person.
    6. You have a right to ask 1609 Group what Personal Information we have on record and gain access to such information.
    7. You have the right to correct and/or erase wrong and/or inappropriate personal information provided that specific statutory and/or gaming regulations do not require us to retain certain Personal Information about you.
    8. You have a right to unsubscribe (“opt-out”) from any direct marketing material that 1609 Group may send you from time to time.
  13. APPLICATION OF NOTICE
      This notice applies to all data (including all Personal Information) past, present or future submitted by you to 1609 Group or which we otherwise obtain pursuant to undertaking our normal business activities.
  14. HOW TO COMPLAIN ABOUT OUR FAILURE TO COMPLY WITH POPIA
  15. INFORMATION OFFICER
      In terms of section 1 of the Promotion of Access to Information Act, 2000 and section 55 of POPIA, Ms Niveshani Grogor (info@1609group.com) is the Information Officer for 1609 Group. In terms of section 58 of POPIA, Ms Alexandra Stylianou (info@1609group.com) is the Deputy Information Officer.
  16. ACCESS TO INFORMATION AND PRIVACY NOTICE
      To have access to information or records held by 1609 Group you may lodge an application for access to those records by sending an email to info@1609group.com.