Privacy Policy

DEFINITIONS

In this document, unless the context indicates otherwise, the words and expressions set out below shall have the meanings assigned to them and cognate expressions shall have a corresponding meaning, namely:

Agreement/Credit
Agreement means any written, electronic or digital credit agreement, quotation, pre-agreement statement, DebiCheck mandate and related credit documentation entered into or accepted by a User or Consumer through the Platform or any related channel in respect of a Loan.
1. Applicant/Consumer
2. /User means any natural person who accesses or uses the Website, Platform or Services, including a prospective applicant, applicant, borrower, customer, repeat customer or account holder, as the context requires;
3. Banking Data means bank account information, bank statements, bank transaction history, open banking data, account holder information, bank code, account number, card-related payment information where applicable and related financial information processed for application, verification, affordability, payout, repayment and collection purposes;
4. Biometric Data means biometric information of a User, including selfie images, facial images, face match results, liveness detection data and related identity verification outputs processed for identity verification, onboarding and fraud prevention purposes;
5. ClickCredit means Altera Digital Services Proprietary Limited (Registration number: 2026/189260/07), trading as ClickCredit, and includes its successors, assigns and authorised service providers where the context requires;
6. Credit Bureau means TransUnion, Experian, XDS, Compuscan or any other registered credit bureau or lawful credit information provider used by ClickCredit for credit, affordability, fraud, identity, collections and risk assessment purposes and “Credit Bureaus” will have a similar meaning as the context requires;
7. DebiCheck means the authenticated debit order mandate process used to obtain and manage the User’s bank-approved repayment mandate;
8. ECTA means the Electronic Communications and Transactions Act No. 25 of 2002 as amended from time to time;
9. FICA means the Financial Intelligence Centre Act No. 38 of 2001;
10. Information Officer means the person appointed or deemed appointed by ClickCredit to perform the duties of information officer under POPIA and PAIA;
11. Loan means a short-term credit product offered by ClickCredit, subject to eligibility, verification, affordability assessment, risk assessment, the final Credit Agreement, applicable disclosures and applicable laws;
12. Manual means the PAIA manual contained in Section B of this document;
13. NCA means the National Credit Act No. 34 of 2005 and includes its regulations as amended from time to time;
14. PAIA means the Promotion of Access to Information Act No. 2 of 2000 as amended from time to time;
15. Personal Information shall have the meaning ascribed thereto in terms of section 1 of POPIA, namely: any information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person, including, but not limited to – 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; information relating to the education or the medical, financial, criminal or employment history of the person; any identifying number, symbol, e-mail address, telephone number, location information, online identifier or other particular assignment to the person; the biometric information of the person; the personal opinions, views or preferences of the person; correspondence sent by the person that would reveal the contents of the original correspondence; the views or opinions of another individual regarding the person; and 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;
16. Platform means the ClickCredit Website, application journey, customer portal, application forms, calculator, dashboards, electronic signing tools, payment tools, verification tools, integrations, databases, support channels, communications and related technology made available by ClickCredit;
17. Policy means the POPI policy contained in Section A of this document;
18. POPIA means the Protection of Personal Information Act No. 4 of 2013;
19. Processing shall have the meaning ascribed thereto in terms of section 1 of POPIA, namely: any operation or activity or any set of operations, whether or not by automatic means, concerning Personal Information, including:
  1. the collection receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use;
  2. dissemination by means of transmission, distribution or making available in any other form;
  3. merging, linking as well as restriction, degradation, erasure or destruction of information; and Process” shall have a similar meaning as the context requires.
20. Services means all services provided by ClickCredit in connection with the Platform, including online loan applications, eligibility checks, identity verification, bank account verification, affordability assessment, Credit Bureau checks, Credit Agreement signing, DebiCheck mandate facilitation, payout facilitation, repayment processing, reminders, collections support, customer support and account servicing; and
21. Website means the ClickCredit website at https://clickcredit.co.za and any related website, landing page, web application, customer portal or online interface used for the Services.
SECTION A – POPI POLICY
BACKGROUND
1. ClickCredit operates a digital short-term credit platform through which Users may apply electronically for credit products, subject to the NCA, affordability assessments, verification processes, fraud-prevention measures, Credit Bureau checks, identity verification, biometric verification, Banking Data processing, DebiCheck authentication and ClickCredit’s internal credit and risk policies.
2. This Policy explains how ClickCredit collects, uses, stores, shares, retains, safeguards and otherwise Processes Personal Information in connection with the Website, Platform, Services, credit application, Credit Agreement and customer account servicing.
3. This Policy must be read together with the ClickCredit Terms and Conditions of Use of the Platform, the applicable Credit Agreement, the pre-agreement statement and quotation, the DebiCheck mandate and any specific consent or declaration presented to the User during the application journey.
PERSONAL INFORMATION COLLECTED
1. ClickCredit may collect and Process the following categories of Personal Information, depending on the User’s interaction with the Platform and the stage of the application or account lifecycle:
  1. identity information - South African ID number, date of birth, citizenship information derived from ID number, full names as reflected on identity documentation, passport information where applicable, identity document images and identity verification results;
  2. contact information - South African mobile number in +27 format, email address, chosen electronic address, WhatsApp contact details and communication preferences;
  3. address and demographic information - residential address, postal code, province, residential status, marital status, language preference and similar application information;
  4. employment and income information - employment status, employer name, industry, salary frequency, payday, gross income, net income and income-source information;
  5. affordability and expense information - declared expenses, rent or bond expenses, utilities, transport, groceries, insurance, other credit commitments, recurring obligations, affordability outputs, disposable income and minimum expense norm calculations where applicable;
  6. Banking Data;
  7. credit information - credit scores, Credit Bureau enquiries, arrears, open limits, payment profile, judgments, administration orders, sequestration, debt review/debt counselling status, deceased status, enquiries, affordability data and other credit, identity, fraud and risk indicators from registered Credit Bureaus or lawful credit information providers;
  8. Biometric Data and special personal information - selfie images, face match outputs, liveness detection, anti-spoofing, anti-deepfake and anti-replay verification results used for identity verification and fraud prevention;
  9. Device, session and technical data - IP address, device identifiers, browser and operating-system information, geolocation information where requested and permitted, anti-bot checks, logs, cookies or similar technologies, timestamps, audit trails and security events;
  10. application and Loan information - loan amount selected, term selected, calculator inputs, application status, acceptance records, pre-agreement disclosures, Credit Agreement records, DebiCheck mandate records, payout records, repayment records, settlement records, overdue records and account servicing information;
  11. Electronic signature and authentication records - OTP records, SMS delivery records, click-wrap records, electronic acceptance logs, user identifiers, IP address information, device information, timestamps and audit logs evidencing the application, consent and agreement process;
  12. communications and support records - SMS, email, WhatsApp, customer portal messages, support requests, complaints, call or interaction records, repayment reminders, overdue notices, collection communications and service communications;
  13. collections and enforcement information - arrears information, collection notes, handover information, payment arrangements, default-related communications, legal records and information shared with debt collectors, attorneys, Credit Bureaus, regulators or courts where permitted by law; and
  14. marketing information - marketing opt-in records, consent records and promotional communication preferences.
2. ClickCredit shall endeavour to only collect and Process the Personal Information of a User which is adequate, relevant, and not excessive in terms of POPI and which is required by ClickCredit in order to render the necessary Services to the User via the Platform.
3. ClickCredit shall endeavour to inform a User of the information which is required for ClickCredit to adequately render the required Services and which information is optional, but may still be useful to ClickCredit for the provision of the Services via the Platform.
PURPOSES AND LEGAL BASIS OF PROCESSING
1. ClickCredit Processes Personal Information where Processing is necessary for one or more lawful bases under POPIA, including consent, contract, compliance with law, protection of a legitimate interest of the User and pursuit of the legitimate interests of ClickCredit or a third party to whom information is supplied, subject to applicable laws.
2. ClickCredit may Process Personal Information for the following purposes:
  1. assessing, processing, approving, declining, pausing, blocking or manually reviewing a credit application;
  2. performing identity, FICA, biometric, liveness, anti-spoofing, anti-deepfake, anti-replay, device, geolocation, technical, fraud-prevention and risk checks;
  3. performing bank account verification through providers such as Amplifin, Altron or other authorised providers, including verifying that the account holder information corresponds with the User’s identity and application information;
  4. accessing, receiving and analysing Banking Data, bank statements and transaction data for affordability assessment, income verification, expense analysis, salary-marker checks, returned debit order checks, gambling or betting indicator checks, other micro-finance or payday-loan transaction checks, identity verification, fraud prevention, credit decisioning and collections;
  5. conducting affordability assessments under the NCA, including use of declared expenses, verified Banking Data, credit information and minimum expense norms or affordability standards where required by applicable laws or the ClickCredit policy;
  6. obtaining, verifying and analysing Credit Bureau information for creditworthiness, affordability, fraud prevention, identity verification, collections, behavioural scoring, credit risk and regulatory compliance;
  7. reporting account conduct, payment behaviour, default information, settlement information and other permitted information to registered Credit Bureaus where permitted or required by law;
  8. presenting pre-agreement statements, quotations, Credit Agreements, consents, declarations and DebiCheck mandates electronically and retaining audit records of electronic acceptance;
  9. facilitating DebiCheck or debit order mandate authentication, payout to a verified bank account, repayment processing, payment allocation, account servicing, settlement and collections;
  10. sending application, payout, repayment reminder, overdue, pre-collection, collection, security, servicing and support communications by SMS, email, WhatsApp, mobile application notification or another lawful channel;
  11. administering customer support, complaints, disputes, adverse action notices, requests to access or correct information, PAIA requests and regulatory enquiries;
  12. complying with POPIA, PAIA, NCA, ECTA, FICA, tax laws, company laws, consumer laws, debt collection laws, court orders, regulatory directions and other applicable laws;
  13. detecting, preventing, investigating and responding to fraud, impersonation, identity mismatch, bank account mismatch, technical abuse, unauthorised access, cyber incidents, policy abuse, repeated unsuccessful applications or legal stops;
  14. improving, testing, maintaining, securing and administering the Website, Platform, systems, integrations, models, workflows, reports, dashboards and back-office applications; and
  15. sending direct marketing communications only where permitted by POPIA, including where the User has given the required consent or where another lawful basis applies and subject to the User’s right to opt-out at any time.
SPECIAL PERSONAL INFORMATION AND BIOMETRICS
1. ClickCredit may Process Biometric Data and other special personal information only where permitted under POPIA, including where the User has expressly consented, where Processing is necessary for identification, verification or fraud-prevention purposes, or where another lawful ground applies.
2. Biometric Data Processing may be conducted through service providers such as FaceTec or equivalent providers and may include selfie capture, liveness checks, anti-spoofing, anti-deepfake, anti-replay checks and face matching against an identity document or other permitted identity source.
DISCLOSURE AND SHARING OF PERSONAL INFORMATION
1. ClickCredit may share Personal Information only where necessary, lawful and proportionate. Recipients may include:
  1. Credit Bureaus and lawful credit information providers, including for credit enquiries, affordability assessment, identity checks, fraud prevention, account conduct reporting, default reporting and dispute handling;
  2. banks, banking partners, DebiCheck service providers, payment processors and account verification providers, including Amplifin, Altron and other authorised providers;
  3. bank statement, open banking, transaction-data or affordability service providers, including providers used to access or analyse 90 (ninety) - day transaction data or such other period required by law or policy;
  4. biometric, identity verification, fraud-prevention, geolocation, device intelligence, anti-bot, security and risk service providers;
  5. SMS, email, WhatsApp, notification, cloud hosting, infrastructure, software, analytics, customer support, archiving and technology service providers;
  6. collection agents, debt collectors, attorneys, tracing agents, courts, dispute resolution bodies, ombuds and alternative dispute resolution agents where permitted by law;
  7. professional advisers, auditors, insurers, funders, corporate restructuring parties or assignees, subject to confidentiality and legal requirements;
  8. regulatory authorities, including the Information Regulator, National Credit Regulator, National Consumer Tribunal, Financial Intelligence Centre, law enforcement agencies, courts and other competent authorities where required or permitted by law; and
  9. any other third party where the User has consented or where disclosure is necessary for the performance of the Services, a Credit Agreement, compliance with law or protection of rights.
CROSS-BORDER TRANSFERS
ClickCredit may transfer Personal Information outside South Africa where its service providers, hosting providers, support teams, group companies or technical systems are located in another country. ClickCredit will take reasonable steps to ensure that such transfers comply with POPIA, including by ensuring that the recipient is subject to a law, binding corporate rules or contractual obligations that provide an adequate level of protection or by obtaining consent where required.
DIRECT MARKETING AND SERVICE COMMUNICATIONS
1. Service communications are necessary communications relating to a credit application, account, payout, repayment, overdue amount, collection, security notification, support request, complaint, legal notice or operational issue and may be sent by SMS, email, WhatsApp, customer portal message or another lawful channel.
2. Direct marketing communications will be sent only in accordance with POPIA. Users may opt out of direct marketing at any time by using the available unsubscribe or opt-out method or by contacting ClickCredit.
3. ClickCredit will maintain records of direct marketing consents, opt-outs and withdrawals where required by law.
DISCLOSURE
1. ClickCredit may disclose the Users’ Personal Information to any of its subsidiaries, affiliates or third-party service providers from which the Users require the Services via the Platform.
2. ClickCredit undertakes to ensure that any subsidiaries, affiliates or third-party service providers to which Personal Information is disclosed in terms of clause 9.1 above, comply with the necessary confidentiality, Processing and privacy standards set out by POPIA and this Policy.
3. ClickCredit may obtain information regarding a User from third parties for the reasons set out in this Policy.
4. ClickCredit may disclose a User’s Personal Information where it is required to do so in terms of law or it is necessary to protect its rights.
SECURITY SAFEGUARDS AND INCIDENT NOTIFICATION
1. ClickCredit will implement appropriate, reasonable technical and organisational measures to prevent loss of, damage to, unauthorised destruction of, unlawful access to or unlawful Processing of Personal Information.
2. These measures may include access controls, authentication, OTP controls, encryption where appropriate, logging, monitoring, backups, system segregation, vendor controls, staff training, incident response procedures, physical security, vulnerability management and regular review of safeguards.
3. ClickCredit will take reasonable measures to identify reasonably foreseeable internal and external risks to Personal Information, establish and maintain appropriate safeguards, regularly verify that safeguards are effectively implemented and update safeguards in response to new risks or deficiencies.
4. Where there are reasonable grounds to believe that Personal Information has been accessed or acquired by an unauthorised person, ClickCredit will notify the Information Regulator and affected data subjects as soon as reasonably possible, unless a public body responsible for prevention, detection or investigation of offences or the Information Regulator determines that notification will impede a criminal investigation.
RETENTION AND DESTRUCTION
ClickCredit will retain Personal Information only for as long as necessary to fulfil the purposes for which it was collected or subsequently Processed, to perform a Credit Agreement, to comply with statutory retention periods, to maintain audit trails, to defend or enforce legal rights, to resolve disputes, to comply with regulatory obligations or as otherwise permitted by law. When Personal Information is no longer required, ClickCredit will delete, destroy, de-identify or archive it in accordance with applicable retention and records-management requirements.
DATA SUBJECT RIGHTS
1. A User has the right, subject to POPIA and other Applicable Laws, to:
  1. ask whether ClickCredit holds Personal Information about the User;
  2. request access to Personal Information held by ClickCredit;
  3. request correction or deletion of Personal Information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully;
  4. object to the Processing of Personal Information where permitted by POPIA;
  5. withdraw consent where Processing is based on consent, without affecting lawful Processing carried out before withdrawal;
  6. provide consent for direct marketing and opt out of direct marketing;
  7. request reasons or information relating to certain automated or risk-based decisions where required by law;
  8. lodge a complaint with ClickCredit; and
  9. lodge a complaint with the Information Regulator.
2. Requests must be directed to the Information Officer using the details under the General section below. ClickCredit may require proof of identity and sufficient information to locate the relevant records before acting on a request.
INFORMATION OFFICER
1. ClickCredit has appointed an Information Officer responsible for overseeing ClickCredit’s compliance with POPIA and applicable data protection laws.
2. Users may contact the Information Officer regarding any questions, requests or complaints relating to the Processing of Personal Information.
3. The details of the Information Officer are set out below at clause 25 (Details of Information Officer and Head Office) of this document.
INTERNAL PROCEDURES
ClickCredit shall put the following internal measures in place to ensure the protection of a User’s Personal Information –
1. the appointment of the Information Officer;
2. training its staff on the provisions of POPIA;
3. making ClickCredit’s internal POPIA manual binding upon its staff; and
4. conducting regular backups of data.
SECTION B – PAIA MANUAL
BACKGROUND AND PURPOSE OF THIS MANUAL
1. This Manual is prepared in terms of section 51 of PAIA for ClickCredit as a private body. It explains the categories of records held by ClickCredit and the procedure for requesting access to records.
2. PAIA gives effect to the constitutional right of access to information held by another person where that information is required for the exercise or protection of rights.
3. This Manual must be made available on the ClickCredit Website and at ClickCredit’s principal place of business for public inspection during normal business hours, to any person upon request and upon payment of the prescribed fee where applicable, and to the Information Regulator upon request.
RIGHT TO ACCESS RECORDS OF PRIVATE BODY
In terms of PAIA, a person requesting records of a private body must be granted such access if:
1. the record is required for the exercise or protection of any rights;
2. the requesting person complies with the procedural requirements of PAIA; and
3. access is not refused in terms of a ground for refusal contained in PAIA.
RECORDS HELD IN TERMS OF LEGISLATION
ClickCredit is required to hold records in terms of legislation including, without limitation:
1. Basic Conditions of Employment Act No. 75 of 1997;
2. Companies Act No. 71 of 2008;
3. Compensation for Occupational Injuries and Diseases Act No. 130 of 1993;
4. Consumer Protection Act No. 68 of 2008;
5. Debt Collectors Act No. 114 of 1998;
6. Electronic Communications and Transactions Act No. 25 of 2002;
7. Employment Equity Act No. 55 of 1998;
8. Financial Intelligence Centre Act No. 38 of 2001;
9. Income Tax Act No. 58 of 1962;
10. Labour Relations Act No. 66 of 1995;
11. National Credit Act No. 34 of 2005;
12. Promotion of Access to Information Act No. 2 of 2000;
13. Protection of Personal Information Act No. 4 of 2013;
14. Skills Development Act No. 97 of 1998;
15. Skills Development Levies Act No. 9 of 1999;
16. Unemployment Insurance Act No. 63 of 2001;
17. Unemployment Insurance Contributions Act No. 4 of 2002;
18. Value Added Tax Act No. 89 of 1991; and
19. any other legislation, directive, code, rule or regulatory requirement applicable to ClickCredit, credit providers, digital platforms, payments, data protection, employment, tax, consumer protection or financial crime compliance.
SUBJECTS AND CATEGORIES OF RECORDS HELD BY CLICKCREDIT
1. The inclusion of any category of information of records must not be taken to mean that the said records will be made available to such person requesting access without following the necessary procedure set out in this Manual.
2. The following records are held by ClickCredit –
  1. Company Records:
    1. registration certificate;
    2. memorandum of incorporation;
    3. shareholder and direct records;
    4. policies and procedures;
    5. directors’ minute book; and
    6. shareholders’ minute book,
  2. Financial Records:
    1. annual financial statements;
    2. accounting records;
    3. asset register;
    4. bank and related records;
    5. audit records
    6. inventory register; and
    7. income and expense vouchers,
  3. Trading Records:
    1. trademarks;
    2. licences;
    3. permits;
    4. insurance records;
    5. policies; and
    6. agreements,
  4. Credit provider, NCA and product Records:
    1. National Credit Regulator registration records and compliance documents, where applicable;
    2. credit policies and risk policies;
    3. affordability assessment policies and audit trails;
    4. pre-agreement statements and quotations;
    5. Credit Agreements;
    6. DebiCheck mandates;
    7. loan application records;
    8. payout, repayment, settlement and default records;
    9. NCA section 129 and enforcement records where applicable; and
    10. complaints, disputes and ombud correspondence,
  5. Consumer, Applicant and User Records:
    1. application forms and captured data;
    2. identity, contact, address and employment records;
    3. income, expense and affordability records;
    4. Banking Data and bank verification records;
    5. Credit Bureau enquiry and reporting records;
    6. Biometric Data and identity verification outputs;
    7. OTP, electronic signature and audit records;
    8. communication records;
    9. customer support and account servicing records; and
    10. decline, adverse action, block, fraud and manual-review records,
  6. Platform, technology and security Records:
    1. Website and Platform logs;
    2. device, geolocation, session and technical records;
    3. cybersecurity records;
    4. access-control records;
    5. incident records;
    6. backup and disaster recovery records; and
    7. software, cloud, vendor and infrastructure records,
  7. Taxation Records:
    1. pay-as-you-earn records;
    2. documents issued to employees for income tax purposes;
    3. records of payments made to the South African Revenue Service on behalf of employees;
    4. annual tax return records;
    5. value-added-tax records;
    6. skills development levies records; and
    7. unemployment insurance fund records,
  8. Personnel Documents and Records:
    1. curriculum vitae;
    2. disciplinary records;
    3. employment contracts;
    4. leave records;
    5. remuneration records and policies;
    6. training manuals;
    7. training records;
    8. workmen’s compensation records;
    9. medical aid records; and
    10. pension fund records,
  9. Collections and Legal Records:
    1. overdue and collection records;
    2. handover records;
    3. debt collector and attorney records;
    4. payment arrangements;
    5. court records; and
    6. legal opinions and privileged records.
REQUEST FOR RECORDS
1. All requests for records in terms of this Manual must comply with the requirements as set out in PAIA and the PAIA Regulations. The request for records must be in the form prescribed by the PAIA Regulations.
2. A requester must identify the right that he, she or it is seeking to exercise or protect and provide an explanation of why the requested record is required for the exercise or protection of that right.
3. A request for records in terms of PAIA must be made formally by way of e-mail or by hand and in the prescribed format.
4. Requests for records must be directed to the Information Officer who shall consider the request and provide a decision within 30 (thirty) days of having received the request or having received the prescribed particulars in terms of section 53(2) of PAIA.
5. A request for information may be refused by ClickCredit if it does not comply with PAIA or if ClickCredit believes that there is a valid ground for objection in terms of PAIA.
6. The person requesting the information must provide ClickCredit with sufficient information for the Information Officer to identify the record and the person requesting the record.
7. The person requesting information must indicate the type of access required and his/her/its contact details including e-mail address, and postal address.
8. Should the requesting person prefer a certain means of communication, such means of communication must be included in the request for information.
9. Should a request for records be made on behalf of a third party, authority to do so must be provided to the Information Officer.
GRANTING OF REQUEST FOR INFORMATION
1. Should a request be granted, ClickCredit shall provide the requesting person with the following information:
  1. the access fee payable by the requesting person;
  2. the type of access which will be granted; and
  3. notice that the requesting person may approach a competent court to dispute the access fee or the type of access to be granted.
2. Once a request has been granted, the records shall be made available to the requesting person once the relevant fee has been paid.
DENIAL OF REQUEST FOR INFORMATION
1. A request for access to information may be refused in the following circumstances:
  1. protecting Personal Information that ClickCredit holds regarding a third party from unreasonable disclosure;
  2. protecting commercial information that ClickCredit holds regarding a third party and may harm the commercial or financial interests of such third party;
  3. if the disclosure would result in a breach of a duty of confidence owed to a third party;
  4. if the disclosure would result in a breach of legislative duties and obligations imposed on ClickCredit;
  5. if the disclosure would jeopardise the safety or life of a natural person;
  6. if disclosure would prejudice or impair the security of property or means of transport of a person;
  7. if disclosure would prejudice or impair the protection of a person who is subject to a witness protection scheme;
  8. if disclosure would prejudice or impair the protection of the safety of the public;
  9. the record is privileged from production in legal proceedings unless privilege in relation to such record has been waived;
  10. if the record is a computer programme;
  11. disclosure of the record will put ClickCredit at a disadvantage in contractual or other negotiations or prejudice ClickCredit in commercial competition;
  12. disclosure of the record would harm the commercial or financial interests of ClickCredit; and
  13. records containing information about research being carried out or about to be carried out on behalf of a third party or a company which is related to ClickCredit and which have not been made public by ClickCredit.
2. Should a request be refused, ClickCredit shall provide the requesting person with the following information –
  1. adequate reasons for the refusal including the relevant sections of PAIA; and
  2. notice that the requesting person may lodge an application with a competent court against the refusal and against the procedure including the period for lodging the application.
FEES
1. A non-refundable request fee is payable to ClickCredit upon the submission of the request.
2. A requesting party who has made a request for access to records and such request has been granted must pay an access fee to ClickCredit for the search and preparation of the records and any time reasonably required which exceeds the prescribed hours for searching and preparation arrangements.
3. The prescribed forms and fees are available on the website of the Department of Justice and Constitutional Development.
REQUEST FOR RECORDS CONTAINING THIRD PARTY INFORMATION
1. Should records be requested that contain information pertaining to a third party, ClickCredit is obliged to attempt to contact the third party to inform it of the request and to provide it with the opportunity to respond to the request by consenting or providing reasons why the access should be refused.
2. Should the third party provide reasons for the support of or against providing access, the Information Officer will consider such reasons in determining whether access should be granted.
3. The requesting party may appeal the decision of the Information Officer to a competent court in the Republic of South Africa in accordance with PAIA.
RECORDS THAT CANNOT BE FOUND OR DO NOT EXIST
1. Should all reasonable steps be taken by ClickCredit to find a requested record and there are reasonable grounds to believe that the record:
  1. is in ClickCredit’s possession but cannot be found; or
  2. does not exist, then the Information Officer shall notify the requesting party that it is not possible to provide the requesting party access to such record.
2. The communication contemplated in clause 24.1 shall set out the steps taken and correspondence exchanged relating thereto by ClickCredit to find the requested record or to determine whether the record exists.
3. A notice in terms of clause 24.1 shall constitute a refusal by ClickCredit.
4. Should the record be found after a notice in terms of clause 24.1 is sent to the requesting party, ClickCredit shall provide the requesting party access to the record, unless refused in terms of a ground for refusal by the Information Officer.
GENERAL
DETAILS OF INFORMATION OFFICER AND HEAD OFFICE
1. Information Officer:
  - Name: Rosina Nana Mude
  - Telephone Number: +27 79 617 7481
  - E-mail: [email protected]
2. ClickCredit Head Office:
  - Attention: ClickCredit Support
  - Physical Address: 28 The Kennedy, 21 Mercurius Road Solheim, Gauteng, 1401 South Africa
  - E-mail: [email protected]
  - Website: https://clickcredit.co.za/
AVAILABILITY OF THIS DOCUMENT
This document is available for inspection by the general public at the physical address of ClickCredit, should ClickCredit have received 7 (seven) days prior written notice of the intended inspection.
DOCUMENT AMENDMENTS
1. This document shall be reviewed annually by ClickCredit.
2. Notwithstanding clause 27.1, ClickCredit may amend this document as and when required.
GUIDE TO PAIA COMPILED BY THE HUMAN RIGHTS COMMISSION
1. In terms of PAIA, the Human Rights Commission is required to compile a guide to assist persons who wish to exercise any rights in terms of PAIA (“Guide”).
2. The Guide is available on the following website address: https://www.sahrc.org.za/home/21/files/Section%2010%20guide%202014.pdf.
3. Alternatively, the Human Rights Commission may be contacted for provision of the Guide at:
  - Physical address: Sentinel House, Sunnyside Office Park 32 Princess of Wales Terrace Parktown Johannesburg South Africa 2001;
  - Postal address: Private Bag 2700, Houghton, 2041;
  - Telephone: 011 877 3600
  - Website: https://www.sahrc.org.za/
  - E-mail: [email protected]
INTERPRETATION
1. In this document, unless the context requires otherwise:
  1. words importing any one gender shall include the other gender;
  2. the singular shall include the plural and vice versa; and
  3. a reference to natural persons shall include created entities (corporate or unincorporated) and vice versa.
2. In this document, the headings have been inserted for convenience only and shall not be used to assist or affect its interpretation.
3. Any reference in this document to an enactment is to that enactment as amended or re-enacted from time to time.
4. Where a clause reference is referred to in this document and followed by the heading of the clause so referred, if there is any conflict between the two, the word reference to the heading shall prevail.
5. Words and/or expressions defined in any clause in the body of this document shall, unless the application of such words and/or expressions is specifically limited to that clause, bear the meaning so assigned to it throughout this document.
6. The eiusdem generis rule shall not apply and accordingly, whenever a provision is followed by the word “including” followed by specific examples, such examples shall not be construed to limit the ambit of the provision concerned.