Privacy Policy

This Notice applies to the business activities of Lesaka Utilities (Pty) Ltd ('Lesaka', 'we', 'us' or 'our') and describes how and why we collect, store, use, and/or share ('process') your personal information.

This Notice applies to the personal information we collect about:

• Users of our Website, www.recharger.co.za, which includes users of our Lesaka Recharger Tenant App;
• Our current, former, and prospective customers and business partners;
• Users and recipients of our Services; and
• Subscribers to our email newsletter.

It does not apply to the personal information that we collect from our employees.

This Notice must be read with any other documents, agreements and privacy notices that describe how we process your personal information. If there is any conflict, the terms of the specific document will apply.

For any questions concerning this Notice, your data protection rights, access to information rights and any complaints, you may contact our Information Officer at:

• Email Address:
• Telephone No:

Our corporation registration information is as follows:

• Corporation Registration Number:
• Registered Address:
• Email Address for other inquiries: onlinestore@recharger.co.za

Further contact information and contact forms are available in our PAIA Manual.

Lesaka is a vendor of prepaid electricity sub-meters and a provider of prepaid metering services. We are not a provider of electricity or an agent for electricity providers or similar services. We do not manufacture, install or uninstall prepaid sub-meters. ("our Services").

We may collect, acquire, receive, record, organise, collate, store, update, change, retrieve, read, process, analyse, use and share your personal information in the manner as set out in this Privacy Notice. When we perform one or more of these actions, we are "processing" your personal information.

The personal information we collect may differ according to the Services you receive from us.

You do not have to provide us with your personal information to access much of the Website. If you choose not to disclose certain information, you can still visit our Website, but you will not be able to create an account with us to register your prepaid meter or make use of our services on the Lesaka Recharger Tenant App. If you do not register your prepaid meter with us, then you may be unable to access certain Services and we may be unable to fully respond to your inquiries.

Information Collected Directly from You

We may collect personal information about you directly from you or from your company or organization. For example, when you fill out a 'Registration' form to register your prepaid meter with us, or otherwise provide us information through our Website, we may collect personal information such as:

When you sign up for our e-newsletter we will only collect your email address.

Special or Sensitive Personal Information

We do not collect or process special category information from you.

When you register your Lesaka Utilities meter with us, we will collect the following sensitive information:

Automatically Collected Information

We may passively collect certain categories of your technical and usage information from the devices that you use to access and navigate our Website ("Access Devices") using your browser's cookies.

For example, when you view our Website, we can see:

• What you click;
• What you view;
• How long you spend on pages;
• Your device and internet connection details such as: type of device you are using, IP address and details about your internet connection, technical details such as your screen size and the software you are using, such as your web browser;
• Your country or region (not exactly where you are unless we ask permission); and
• Your unique advertising or other identification numbers allocated to your browser or device.

We don't often know exactly who you are from this data. But sometimes we may connect this data with other information we hold about you, for example, when you submit a form.

Information Collected from Third Parties

We may also receive your personal information indirectly from, among others, the following sources (including public parties):

• Cookies and similar technologies, these are set on your device by us and our trusted partners, such as Google Analytics. To opt out of being tracked by Google Analytics across all websites, visit: http://tools.google.com/dlpage/gaoptout.
• Third party social networks (such as Facebook and Google) if you interact with us through them;
• Advertising interactions (if you interact with one of our ads on a third party website, we may receive information about that interaction);
• From other responsible parties where we act as contracted outsourced processors ("Operators") or co-responsible parties in performing our Services, including:
  • Banks and other financial institutions;
  • Payment gateways and processors;
  • Owner(s) of your Lesaka Utilities meter;
  • Our technology providers and marketplaces such as Shopify, Takealot and other retail partners.
• Our customers may occasionally supply us with their customers' personal information to allow us to respond to any queries or complaints concerning our products and services.

Where we must process certain personal information by law, or in terms of a contract that we have entered into with you, and you fail to provide such personal information when requested to do so, we may be unable to perform in terms of the contract in place or are trying to enter into with you. In such a case, we may be required to terminate the contract or relationship with you, upon due notice to you and according to contractual Terms and Conditions that apply to you.

We do not use your personal information to make any automated decisions or profiling about you.

We may share your personal information with third-party vendors, service providers, contractors or agents ("third parties") who perform services for us or on our behalf and require access to such information strictly to do that work. For example, sharing a delivery address and contact information with trusted couriers to facilitate the delivery of your order.

The disclosure of information will always be subject to applicable regulatory requirements on confidentiality and appropriate data protection measures.

We will also ensure we have contracts in place with our third parties which are designed to help safeguard your personal information. This means they cannot do anything with your information unless we have instructed them to do it and they will also not share your personal information with any other organisation apart from us.

The categories of third parties we may share your information with are as follows:

• Cloud computing and data storage services;
• Data analytics services such as Google Analytics;
• Electronic forms builders and processors for our Website such as Hulk Form Builder. When you fill out a form on our Website, the information that you submit will be collated into an email and sent to us;
• Security and authentication services — for example, our service providers may look at all use of our Website to help block malicious activity. One of our security providers is Google ReCAPTCHA. Google asks us to tell you that this is subject to the Google Privacy Policy and Terms of Use; and
• Regulatory authorities when required by legislation or by a Court Order.

We may also share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Affiliates. We may share your information with our Affiliates, in which case we will require those affiliates to honour this Privacy Notice. "Affiliates" include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us. For example, if we, in good faith, believe that such access, retention or disclosure to our Affiliate is reasonably necessary to:
  • Comply with legal process (e.g., a subpoena or court order);
  • Enforce our terms and conditions, this Privacy Notice, or other contracts with you, including investigating any potential violations to such terms and policies;
  • Respond to claims that any content violates the rights of third parties;
  • Respond to your requests for customer service; or
  • To mitigate any reasonable risk, or to protect the rights, property or personal safety of the Affiliate and its service providers, its customers or the public.
• As you direct us, we may also disclose your personal information in other ways you direct us to.

The information we collect about you will be processed in South Africa.

However, we reserve the right to transfer to and/or store your personal information on servers in a country other than where it was collected, and in a jurisdiction that may not have comparable data protection legislation to South Africa. If we do, we will take reasonable steps to ensure that your personal information has an appropriate level of protection and that the transfer is in line with applicable legal requirements.

We will take reasonable technical and organisational steps to protect all personal information held by us in line with industry best practices, including protection against accidental or unlawful destruction, accidental loss or alteration, and unauthorised disclosure or access. This includes to:

• Keep systems secure (such as monitoring access and usage);
• Control access to our premises, systems and records on a strict need-to-know basis;
• Safely destroy records;
• Encrypt and/or password protect sensitive data;
• Use firewalls and anti-virus software;
• Test the security of our IT systems regularly;
• Ensure our payment gateways comply with PCI-DSS;
• Require our staff and any third-parties who carry out any work on our behalf to comply with appropriate compliance standards including obligations to protect any information and applying appropriate measures for the use and transfer of information; and
• Review how we collect, store and use information, including security measures.

We will notify you and the relevant regulatory authorities of any data breaches where we are legally required to do so and within the prescribed period.

We will keep your personal information for as long as needed to meet the purposes listed in this Privacy Notice. We may need to keep your information for longer where we need the information to comply with regulatory or legal requirements, help detect or prevent fraud and financial crime, or answer requests from regulators.

If there are no other lawful grounds for us to continue processing your personal information, we will destroy such data using secure methods.

When Lesaka Utilities receives personal information from customers and acts as a data processor or service provider, we abide by the retention period set forth by our customers.

We will take reasonable steps to ensure that your personal information is accurate and complete.

Anyone about whom we maintain personal information may request to inspect and, if appropriate, correct the personal information held by us by following our Access to Information Manual. It is your responsibility to inform us should your personal information be incorrect, incomplete, misleading or out-of-date by contacting us.

We will only collect information that is relevant and necessary for us to perform the relevant activity.

We have procedures in place to destroy information given to us by you or a third party that is surplus to our requirements.

Data protection laws grant you the following rights:

• Request access to your personal information – You may ask us free of charge to confirm that we hold your personal information, or ask us to provide you with details, at a fee, how we have processed your data, which can be done by submitting PAIA Form 2 to us;
• Request the correction of your personal information – to ensure any incomplete or inaccurate personal information is corrected by submitting POPI Form 2 to us;
• Request erasure of your personal information – where there is no lawful basis for the retention or continued processing of your personal information by submitting POPI Form 2 to us;
• Object to the processing of your personal information for a legitimate interest (or those of a third party) – under certain conditions where you feel it impacts your fundamental rights and freedoms by submitting POPI Form 1 to us;
• Request restriction of processing of your personal information – to restrict or suspend the processing of your personal information to limited circumstances by submitting POPI Form 1 to us;
• Withdraw consent given in respect of the processing of your personal information at any time – withdrawal of consent will not affect the lawfulness of any processing conducted before your withdrawal notice. It may also not affect the continued processing of your personal information in instances where your consent is not required. To withdraw your consent – email our Information Officer stating that you "withdraw your consent for Lesaka Utilities to process your personal information."

You can exercise your rights by contacting us using the details set out in the 'Contact Us' section above. We will respond within 30 calendar days. The relevant forms to be completed in exercising your rights are also available on the website of the Information Regulator of South Africa, or in our PAIA Manual.

You also have a right to complain to the Information Regulator of South Africa by visiting inforegulator.org.za.

We will not knowingly solicit or collect personal information in respect of children (persons below the age of 18). Any person who provides their information to Lesaka Utilities represents to us that they are 18 years of age or older.

We use external processors ("Operators") for certain activities to assist with our operations. We reserve the right to change our Operators at any time without further notice to you, but we will ensure our Operators are bound by this Privacy Notice and our relevant policies, or similar terms providing the same or higher level of protection. Such external processing activities include, but are not limited to:

• IT systems and infrastructure;
• Debt collection services;
• Payment processors;
• Posting and email infrastructure;
• Record keeping infrastructure;
• Credit reference agencies; and
• Server hosts and data centres.

Before entering business relationships with our Operators, we go through due diligence checks with them.

We may place small text files called "cookies" on your device when you visit our website. Cookies do not hold personal information, but they do contain a personal identifier allowing us to affiliate your personal information with a certain device. Cookies serve useful purposes for you, including:

• Remembering who you are as a user of our website to remember any preferences you may have selected on our website, such as saving your username and password, or settings ("functional cookies");
• Allowing our website to perform their essential functions. Without these cookies, some parts of our website would stop working ("essential cookies"). For example, data on error messages displayed to Users will be collected and the developer team will assess and solve it; and
• Monitoring how our website is performing, and how you interact with it to understand how to improve our website or Services ("site analytics").

See our Cookie Statement below for more information on our use of cookies.

Your internet browser may accept cookies automatically and you can delete cookies manually. However, no longer accepting cookies or deleting them may prevent you from accessing certain aspects of our website where cookies are necessary.

As cookies are stored in the web browser used to access our website, to disable cookies you need to change the settings on that browser. Many websites use cookies and more information is available at: www.allaboutcookies.org.

While we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content, or the security or privacy practices employed by other sites. We recommend that you always read the privacy and security statements on such sites.

This Privacy Notice is governed by South African law.

If any provision of this Privacy Notice is determined to be illegal, void or unenforceable due to applicable law or by order of court, it shall be deemed to be deleted and the continuation in full force and effect of the remaining provisions shall not be prejudiced.

We may amend this Privacy Notice from time-to-time, and we will take reasonably practicable steps to inform you when changes are made. Without limiting the way we may inform you, we may notify you by email, or by posting an updated notice on our Website.