Swiftbanker.co.za is operated by Lacuna Digital ApS, company registration number (CVR) 38985981, Århusgade 118, 2150 Nordhavn, Denmark. Under POPIA, Lacuna Digital ApS is the responsible party for the personal information processed through this website, which means we decide why and how it is processed and we answer for it.

You can contact us about your personal information at any time at info@swiftbanker.co.za. We aim to reply within 14 days, and in any event within 30 days, which is the period the Promotion of Access to Information Act allows us for a request to access your record.

Section 55 of POPIA requires every responsible party to have an Information Officer. That role is held by the head of Lacuna Digital ApS, and requests, objections and complaints about our processing reach the Information Officer through the email address above. We have not appointed a separate deputy.

We process two kinds of information: what you give us yourself, and what is collected automatically while you use the site.

Information you give us

• Contact details: your name, email address and mobile number
• What you are looking for: the loan amount, the repayment term and the purpose of the loan
• Anything you write to us yourself in an email or a contact form
• Your consent to marketing, and the date and wording of the consent you gave

We never ask for your South African ID number, your bank account details, your payslips or your bank statements on swiftbanker.co.za. If you receive a message in our name asking for any of these, it did not come from us.

Information collected automatically

• Your IP address and an approximate location at city or province level
• Technical details about your device, browser and operating system
• Which pages you open, what you click and how long you stay
• Which website or advertisement you arrived from
• Cookie identifiers and similar identifiers, to the extent that you have consented

We do not process special personal information as described in section 26 of POPIA — for example your race, health, religious or political beliefs, biometrics or criminal history — and we do not ask you for it. Our service is for adults only: you must be 18 or older to enter into a credit agreement in South Africa, and we do not knowingly process the personal information of children, which section 34 of POPIA protects separately.

Section 16 of POPIA obliges us to keep the information complete, accurate and up to date for the purpose we use it for, so please tell us if any detail you have given us changes.

Section 11 of POPIA allows processing only where one of its justifications applies. Below you can see each purpose, the justification we rely on, and how long we keep the information afterwards.

Passing your loan request on to our partner

Justification: your consent, section 11(1)(a), together with section 11(1)(b) because sending the request is the step you asked us to take. Without your consent nothing is passed on. We keep the request and the record of your consent for 6 months after we pass it on, so that we can show what was sent and on what basis.

Sending you loan offers and news by email or SMS

Justification: your consent, section 11(1)(a), read with section 69 of POPIA, which allows electronic direct marketing only to a person who has consented or who is an existing customer. We process the information until you withdraw your consent. If you have not responded to our marketing for 3 years, we ask you to renew the consent — if you do not reply, we delete you.

Answering your enquiry to customer service

Justification: our legitimate interest in being able to answer you, section 11(1)(f). We keep the correspondence for 2 years, so that we can follow up on a matter and show what was agreed.

Running and securing the website

Justification: our legitimate interest in a website that works and is not abused, section 11(1)(f). Server logs are kept for 12 months.

Measuring how the site is used and improving the content

Justification: your consent to statistics and marketing cookies, section 11(1)(a). Data in our analytics tool is kept for up to 14 months.

Meeting our legal obligations

Justification: compliance with an obligation imposed by law, section 11(1)(c). Company and accounting records that the Companies Act 71 of 2008 requires us to keep are retained for 7 years from the date they were created.

Section 15 of POPIA allows us to use your information for a further purpose only where that purpose is compatible with the one it was collected for — we do not repurpose your data beyond what is described here. When a retention period under section 14 has run out, we delete the information or de-identify it so that it can no longer be linked to you. Where one record serves several purposes, we keep it until the longest of the periods above has expired.

Swiftbanker is a free comparison and marketing service. We are not a bank, not a lender and not a registered credit provider or credit intermediary under the National Credit Act 34 of 2005. We do not grant credit, we do not assess applications and we make no decision about whether you can borrow. Our role is to pass the details you have consented to on to a partner, who handles the application and is a separate responsible party for what it does with your information from that point on.

Once you have consented, your details are shared with our South African loan marketplace partner Myloan.co.za, and through it with the credit providers that assess your request. Those credit providers must be registered with the National Credit Regulator.

This list of partners is not fixed and changes when we start or end a collaboration. If you want to know exactly which partners your information was sent to, ask us at info@swiftbanker.co.za and we will tell you. Section 18 of POPIA also requires us to tell you, when we collect your information, who it will go to — you will see this on the form before you submit anything.

Beyond our partners, we share information with the operators that keep the site running, described in the section on operators below, and with public authorities, courts or regulators where the law obliges us to or where it is necessary to establish or defend a legal claim. We do not sell or rent your personal information.

Swiftbanker carries out no affordability assessment and no credit check. We do not obtain reports from credit bureaux such as TransUnion, Experian or XDS, and we make no decision about whether credit will be granted to you.

The affordability assessment required by section 81 of the National Credit Act is carried out by the credit provider you are referred to. That provider decides which checks to run, obtains the credit bureau enquiry, and does so on its own legal basis and under its own privacy policy. We recommend reading that policy before you submit an application.

Section 71 of POPIA protects you from decisions taken solely by automated processing, including profiling, that have legal consequences for you or affect you to a substantial degree. We take no such decisions about you. If a loan application is declined, it is not a decision we made — ask the credit provider for the reasons and for how it uses automated processing.

We use external suppliers for hosting, email delivery, statistics and advertising. In POPIA terms they are operators: they process personal information on our behalf, may use it only for what we ask, and must under sections 20 and 21 process it only with our authorisation, treat it as confidential and be bound by a written contract that obliges them to apply the security measures POPIA requires.

The operators we use include Google, Meta (Facebook), Microsoft and Marketingplatform ApS.

Some of these suppliers store or access data outside South Africa, in the European Union and in the United States. Section 72 of POPIA allows such a transfer only on one of its listed grounds, and these are the grounds we rely on:

• Section 72(1)(a): the recipient is bound by an agreement with us that upholds principles for lawful processing substantially similar to POPIA and imposes the same restriction on any onward transfer
• Section 72(1)(b): your consent, where you have given it for a specific transfer
• Section 72(1)(d): the transfer is necessary for a contract we conclude with a supplier in your interest, so that the service you asked for can be delivered

Separately from section 72, these suppliers operate under the European framework that applies to them: the European Commission's adequacy decision of 10 July 2023 on the EU-US Data Privacy Framework where the recipient is certified, and the European Commission's standard contractual clauses of 4 June 2021. That framework is the protection the suppliers themselves work under; the legal ground for our transfer out of South Africa remains section 72.

You can ask us for a copy of the transfer arrangement we rely on for a specific supplier by writing to info@swiftbanker.co.za.

A cookie is a small text file stored on your device so that the website can recognise it, remember your choices, produce statistics and target advertising. Cookies cannot carry viruses or other harmful code. Because a cookie identifier can be linked back to you, POPIA treats it as personal information.

We use three kinds:

• Necessary cookies, which make the website work. They do not require your consent.
• Statistics cookies, which show us how the site is used so that we can improve it. They require your consent.
• Marketing cookies, which are used to show you relevant advertising and measure how it performs. They require your consent.

You give or refuse consent in the cookie banner the first time you visit, and you can change or withdraw your choice at any time. You can also delete or block cookies in your browser settings.

If you block cookies, parts of the website may stop working and the advertising you see becomes less relevant — but it does not disappear.

We send marketing only if you have said yes. Section 69 of POPIA prohibits unsolicited electronic direct marketing unless you have consented or are an existing customer being offered a similar product. Your consent is voluntary, and withdrawing it must be as easy as giving it was.

You can opt out by clicking the unsubscribe link at the bottom of any email from us, replying STOP to an SMS, or writing to info@swiftbanker.co.za. Opting out is free, and section 11 of the Consumer Protection Act 68 of 2008 also gives you the right to block direct marketing pre-emptively.

If you withdraw your consent under section 11(2)(b) of POPIA, we stop the marketing. It does not make the processing we carried out while the consent was valid unlawful. We keep a record that you opted out, so that we can show your choice was respected.

If you have not been active for 3 years, we ask you to renew your consent. If we do not hear from you, we delete your information.

Section 19 of POPIA requires us to secure the integrity and confidentiality of your information by taking reasonable technical and organisational measures against loss, damage, unauthorised destruction and unlawful access or processing. We identify the risks to the information we hold and keep our safeguards under review as those risks change.

In practice this includes encryption of the traffic to and from the website, access control so that only the people who need your information can see it, and written agreements with our operators about how they must protect it.

If a security compromise does occur, section 22 of POPIA requires us to notify the Information Regulator and every affected person as soon as reasonably possible after we discover it. POPIA sets no fixed deadline in hours, but it does not allow us to wait: the only reason we may delay is if the police or the Regulator ask us to, so that an investigation is not harmed. Our notification will describe what happened, what information was involved and what you can do to protect yourself.

POPIA gives you a set of rights over the information we hold about you. To use one of them, write to info@swiftbanker.co.za. If a request has to be made on a prescribed form, we will send you the form and help you complete it.

• Access, section 23: you can ask us to confirm, free of charge, whether we hold information about you, and to give you the record or a description of it. Confirmation costs nothing; POPIA allows a prescribed fee for the copy itself, and we will tell you the amount before we start.
• Correction, section 24: you can ask us to correct information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or unlawfully obtained.
• Deletion or destruction, section 24: you can ask us to destroy or delete a record we are no longer authorised to keep.
• Objection, section 11(3): you can object at any time, on reasonable grounds relating to your situation, to processing we base on our legitimate interests — and you can object to direct marketing at any time, without giving a reason.
• Withdrawal of consent, section 11(2)(b): you can withdraw a consent whenever you like.
• Notification, sections 18 and 22: you have the right to be told what we collect and why, and to be told if your information is accessed by an unauthorised person.
• Automated decisions, section 71: you have the right not to be subject to a decision based solely on automated processing that significantly affects you.
• Complaint and civil action, sections 74 and 99: you can complain to the Information Regulator, and you can go to court for damages.

The rights have limits. We cannot delete records we are obliged to keep under the Companies Act 71 of 2008, and access may be refused on the grounds set out in the Promotion of Access to Information Act — for instance where it would reveal another person's information. If we turn a request down, we tell you in writing why, and you may take that refusal to the Information Regulator.

If you are unhappy with the way we handle your personal information, we would like to hear it first at info@swiftbanker.co.za, so that we have a chance to put it right.

You may complain to the Information Regulator at any time under section 74 of POPIA, whether or not you have contacted us. The complaint must be submitted in writing on the prescribed form, Form 5:

• Information Regulator (South Africa)
• Complaints email: POPIAComplaints@inforegulator.org.za
• Website: inforegulator.org.za

Complaining is free. The Regulator can investigate the matter, attempt to settle it, and issue an enforcement notice if it finds that POPIA has been breached. Form 5 and the guidance on how to complete it are published on the Regulator's website.

We update this policy when our processing changes or when the law requires it. The date of the latest update is shown at the top of the page.

If we change something significant — for example if we start using your information for a new purpose — we tell you directly before the change takes effect, provided we have your email address.

The version in force at any time is the one published here. We recommend looking in from time to time.